{"arw":[{"Case ID":"ARW-255","Case Title (Name of Public Official or Entity Allegedly Involved)":"Diezani Alison-Madueke","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Minister of Petroleum (2010-2015)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"(1) Jurisdiction initiated legal action to recover assets \r\n(2) Jurisdiction of Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2017","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdictions","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"$114,000,000 (not confirmed)","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"In a 2017 civil forfeiture complaint, the U.S. DOJ alleges that from 2011 to 2015, Nigerian businessmen Kolawole Akanni Aluko and Olajide Omokore conspired with others to pay bribes to Nigeria\u2019s former Minister for Petroleum Resources, Diezani Alison-Madueke, who oversaw Nigeria\u2019s state-owned oil company. Diezani Alison-Madueke, a former President of OPEC, allegedly used her influence to steer lucrative oil contracts to two Nigerian shell companies set up and controlled by Aluko and Omokore.\nThe U.S. Department of Justice seeks recovery of $144 million in assets connected to Diezani Alison-Madueke, Kolawole Aluko, and Olajide Omokore, which it says are the proceeds of corruption in Nigeria. The assets subject to forfeiture include a $50 million condominium in One57 - 157 W. 57th Street - one of Manhattan\u2019s most expensive buildings, and an $80 million yacht, known as Galactica Star.\nThe U.S. government further alleges that Aluko, Omokore and others funded a lavish lifestyle for Alison-Madueke, conspiring to purchase millions of dollars in real estate in and around London for Alison-Madueke and her family members, then renovated and furnished these homes with millions of dollars in furniture, artwork and other luxury items purchased at two Houston-area furniture stores at Alison-Madueke\u2019s direction. Aluko and Omokore also laundered proceeds into and through the U.S, and used it to purchase U.S. real estate. During the period from March 2012 through January 2015, Aluko purchased more than $87 million dollars\u2019 worth of real property in the United States and an $82 million luxury yacht, according to the DOJ complaint.","Disposition of Criminal Case(s)":"According to the U.S. DOJ\u2019s civil forfeiture complaint, in return for the bribes, Alison-Madueke allegedly used her influence as Petroleum Minister to direct a subsidiary of the Nigerian National Petroleum Corporation to award contracts to two shell companies created by Aluko and Omokore: Atlantic Energy Drilling Concepts Nigeria Ltd. and Atlantic Energy Brass Development Ltd, in 2011 and 2012. The companies were incorporated in Nigeria in 2010 and 2013 respectively, and were both owned by holding companies incorporated in the British Virgin Islands, beneficially owned by Aluko and Omokore. Omokore acted as a registered director of both Nigerian companies.\nUnder the contracts, the two companies were required to finance the exploration and production operations of eight on-shore oil and gas blocks. However, according to the DOJ complaint, the companies provided only a fraction of the agreed upon financing or, in some instances, failed entirely to provide it. The companies also failed to meet other contractual obligations, including the payment of a $120 million entry fee. Nevertheless, the companies were allegedly permitted to lift and sell more than $1.5 billion worth of Nigerian crude oil.\nA February 2014 report prepared by the then-governor of the Central Bank of Nigeria determined that Atlantic Energy Drilling Concepts Nigeria Ltd \u201chad neither the technical expertise nor the capital to develop the joint venture, but [was] none-the-less able to lift crude and retain the proceeds . . . up to 70% of the profit of the Joint Venture.\u201d The report concluded that the arrangement was set up \u201cfor the purpose of acquiring assets belonging to the [Federal Republic of Nigeria] and transferring the income to private hands.\u201d\nAtlantic Energy Brass Development Ltd allegedly sold $811 million worth of crude oil over the course of one year to a UK subsidiary of Glencore, \u201cdespite failing to meet any obligations\u201d under its contract with the Nigerian state-owned oil company, according to the DOJ.\nIn addition to the Nigerian companies and its BVI holding companies, the conspirators also set up a number of other BVI-registered companies and at least three companies incorporated in the Seychelles that were used by Aluko and Omokore to purchase real estate in the United Kingdom, allegedly for the benefit of Alison-Madueke. The $82 million yacht was bought by a company incorporated in the British Virgin Islands that was controlled and beneficially owned by Kolawore Aluko; the sale was brokered by a financial and corporate services company based in Guernsey. At least three companies incorporated in U.S. states \u2013 Nevada, Delaware, and California \u2013 were used by conspirators to spend corrupt funds at a furniture store in Houston, pay for transportation services, and purchase a property in Santa Barbara, California.\nAlison-Madueke is also under investigation by the National Crime Agency in the U.K., where she currently resides, for corruption and money laundering. In Nigeria, the former Petroleum minister is under investigation by the Economic and Financial Crimes Commission (EFCC) for diverting money from the Nigerian National Petroleum Corporation, (NNPC), but as of September 2017, no charges had been filed against her related to this case. She has been charged for money laundering in connection to a separate election-bribery case. Local Nigerian media reports say that EFCC recently blocked her application to travel to Nigeria and join the trial against her associate Omokore as a defendant, arguing that it was a ploy to escape prosecution in the U.K.","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission (EFCC). \r\nAccording to media reports, the Central Bank of Nigeria announced in May 2016 that it was participating in the investigation into corruption targeting the former oil minister.","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"FBI\u2019s International Corruption Squads in Washington, D.C. and Los Angeles and the IRS-CI","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. DOJ Criminal Division\u2019s Money Laundering and Asset Recovery Section","Jurisdiction of Asset Recovery: Courts Involved":"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/DOJ-Galactica-Complaint.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/DOJ%20Press%20Release%20-%20Alison-Madueke%20-%2014%20July%202017.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/U.S.%20Seeks%20%24144%20Million%20in%20Laundered%20Nigerian%20Oil%20Funds%20-%20Risk%20%26%20Compliance%20Journal.pdf","Sources ":"U.S.\u00a0DOJ Press Release, 14 July 2017\u00a0 https:\/\/www.justice.gov\/opa\/pr\/department-justice-seeks-recover-over-100...\n"},{"Case ID":"ARW-254","Case Title (Name of Public Official or Entity Allegedly Involved)":"1Malaysia Development Berhad (1MDB) (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Malaysia, Saudi Arabia, United Arab Emirates","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"(1) Jurisdiction that initiated legal action to recover assets; \r\n(2) Jurisdiction of asset location","Asset Recovery Start":"2016","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdictions","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"over $1.6 billion","Assets Adjudicated, Not Yet Returned (USD)":"$30 million","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"","Case Summary":"Members of an international conspiracy allegedly diverted \u201cmore than $4.5 billion\u201d in state funds from 1Malaysia Development Berhad (1MDB), a state investment fund wholly owned by the government of Malaysia, according to a series of civil forfeiture complaints filed in 2016 and 2017 under the U.S. DOJ Kleptocracy Asset Recovery Initiative. The United States is seeking to recover \u201calmost $1.7 billion\u201d of 1MDB funds that were allegedly laundered through the United States and are traceable to the conspiracy in \u201cthe largest single action ever brought under the [U.S. DOJ\u2019s] Kleptocracy Asset Recovery Initiative.\u201d In August 2017, the U.S. DOJ asked for a stay of the civil forfeiture cases pending the conclusion of a related federal criminal investigation.\nThe DOJ complaints allege that \u201cusing fraudulent documents and representations, the co-conspirators allegedly laundered the funds through a series of complex transactions and fraudulent shell companies with bank accounts located in the Singapore, Switzerland, Luxembourg and the United States. These transactions were allegedly intended to conceal the origin, source and ownership of the funds, and were ultimately processed through U.S. financial institutions and were used to acquire and invest in assets located in the United States.\u201d\nU.S. assets that were allegedly purchased with diverted 1MDB funds and are subject to forfeiture actions include high end real estate and hotel properties in New York, Los Angeles, and London; a $35 million jet airplane; a 300-foot luxury yacht; works of art by Vincent Van Gogh, Pablo Picasso, and Claude Monet; a substantial interest in the music publishing rights of EMI Music; the production of the 2013 film The Wolf of Wall Street; shares in Tech company Palantir and fitness company Flywheel; gambling expenses at Las Vegas casinos; and over $27.3m worth of diamond jewelry.\nAs of June 2018, U.S. authorities have frozen or restrained over $1.6 billion in assets related to this case. These assets are subject to ongoing, active litigation. Around $30 million in assets forfeited by U.S. authorities have been fully adjudicated. The restrained assets are located in the United States, Switzerland, Indonesia, Singapore, and London.\nProsecutors portray a Malaysian national called Jho Low as the mastermind of the complex embezzlement scheme. Although he held no official position with 1MDB, he de facto conducted extensive business for the state fund and set up a myriad of opaque shell companies around the world through which 1MDB funds were diverted and ultimately channeled into the United States, for the personal benefit of members of the conspiracy. Other conspirators allegedly implicated include a group of high-ranking Malaysian officials at 1MDB, two high-ranking UAE officials at an investment fund owned by Abu Dhabi government (Khadem Abdulla Al-Qubaisi and Mohamed Ahmed Badawy Al-Husseiny), and two Saudi nationals affiliated with a little-known Saudi oil company (PetroSaudi International). Malaysia\u2019s former prime minister Najib Razak and his stepson Riza Aziz are allegedly\u00a0implicated in the scheme and benefitted from diverted 1MDB funds, with Razak receiving funds totaling approximately $681 million directly into a bank account in his name, according to the U.S. DOJ\u2019s forfeiture complaints. One of the conspirators, Al-Husseiny, served as chairman of Falcon Bank, a private bank in Singapore and Switzerland, that was allegedly extensively used for moving and laundering funds in the scheme.\nTo divert funds from the 1MDB fund, disguise their origin, disguise the identity of the conspirators, and launder funds into the United States, prosecutors claim that the members of the conspiracy set up a vast network of corporate vehicles in offshore secrecy jurisdictions around the world. Corporate vehicles employed in this scheme were incorporated in jurisdictions including Seychelles, British Virgin Islands, Hong Kong, United Arab Emirates, Cura\u00e7ao, Malaysia, Cayman Islands, Luxembourg, and the United States (New York, Delaware). The diverted funds were allegedly transferred through bank accounts belonging to these companies in, among others, Singapore, Switzerland, USA, Netherlands, Luxembourg, Germany, and Barbados, with a majority of the money at some point passing through Singapore accounts, according to the forfeiture complaints.\nProsecutors further claim that several corporate vehicles were deceptively named to mimic an affiliation with a genuine, operational entity that 1MDB was doing business with or to mimic an affiliation with well-known global financial service companies, when in fact no such affiliation existed. Two shell companies, both called \u201cAabar Investments PJS Ltd\u201d, one registered in BVI and the other in the Seychelles, were named to give the impression that the CV was associated with Aabar Investments PJS, a legitimate subsidiary of Abu Dhabi investment company IPIC, which entered into a joint venture agreement with 1MDB. \u201cBlackstone Asia Real Estate Partners Ltd\u201d, \u201cAffinity Equity International Partners Limited\u201d, \u201cVista Equity International Partners Ltd\u201d were all named to mimic well-known global financial service companies. Also of note is the alleged use of an Interest on Lawyer Account (IOLA) and another attorney trust account held by U.S. law firms to launder diverted funds into the U.S. by purchasing real estate assets. Transfers totaling $368 million were made directly from an account of a Seychelles shell company to an IOLA account of a U.S. law firm.\nThe U.S. DOJ forfeiture complaints outline four distinct phases of the complex corruption scheme, named after key corporate vehicles that were employed: (1) the \u201cGood Star\u201d Phase, 2009-2011; (2) the \u201cAabar-BVI\u201d Phase, 2012; (3) the \u201cTanore\u201d Phase, 2013; and (4) the \u201cOptions Buyback\u201d Phase, 2014.\nDuring the \u201cGood Star\u201d Phase, 1MDB officials entered a joint venture agreement with PetroSaudi International, a little-known Saudi oil company founded in 2005 by a son of the late King Abdullah, for the stated purpose of exploiting certain energy concessions in Turkmenistan and Argentina. Under the terms of the agreement, 1MDB agreed to invest $1 billion in the newly created joint venture in exchange for a forty percent equity interest. 1MDB only transferred US$300 million into the account of the \u201clegitimate\u201d joint venture company and allegedly diverted US$700 million into a bank account at RBS Coutts, Switzerland, that was held by Good Star Limited, a Seychelles-registered corporate vehicle\u00a0beneficially owned by Jho Low. Conspirators made false representations to banks that Good Star was a wholly-owned subsidiary of PetroSaudi.\nDuring the \u201cAabar-BVI\u201d Phase, 1MDB raised additional funds through two separate bond offerings arranged and underwritten by Goldman Sachs. The bonds were guaranteed by both 1MDB and International Petroleum Investment Company (IPIC), an investment fund wholly-owned by the government of Abu Dhabi in the United Arab Emirates. 1MDB officials allegedly caused approximately $1.367 billion (40% of the bond proceeds) to be wire transferred to a Swiss bank account belonging to a British Virgin Islands entity that was deceptively named to mimic a legitimate subsidiary of IPIC.\nDuring the \u201cTanore\u201d Phase, several individuals, including 1MDB officials, allegedly diverted more than $1.26 billion out of a total of $3 billion in principal that 1MDB raised through a third bond offering arranged by Goldman Sachs in March 2013, via two bank accounts in Singapore held by a BVI-registered company.\nDuring the \u201cOptions Buyback\u201d phase, an additional $850 million in 1MDB funds was allegedly misappropriated under the guise of paying an IPIC subsidiary to relinquish certain options 1MDB had given in return for IPIC\u2019s guarantee of the 2012 bonds. To fund this options buyback, 1MDB borrowed a total of $1.225 billion from a syndicate of banks led by Deutsche Bank in Singapore, of which more than $850 million was allegedly diverted via two companies\u00a0incorporated in BVI and in the Seychelles.","Disposition of Criminal Case(s)":"In August 2017, the U.S. DOJ asked for a temporary stay of the civil forfeiture cases related to the 1MDB case, pending conclusion of related federal criminal investigations. In an affidavit supporting the government\u0027s motion to stay the forfeiture cases, a\u00a0FBI special agent wrote: \u0022The related criminal investigation is global in scope because the underlying crimes were committed over several years in numerous jurisdictions. Perpetrators, which includes both entities and individuals acting in individual and representative capacities, are believed to have committed violations of both U.S. and foreign laws. A significant amount of the evidence and\u00a0witnesses with knowledge of these violations are located in foreign jurisdictions, and will take time to pursue.\u0022 The FBI agent warned\u00a0that any further disclosure of information in the civil cases would risk revealing \u0022potential targets and subjects of the investigation and the investigative techniques that have been and will be used in the investigation.\u0022 No further information about the criminal cases is\u00a0publicly available, as of June 2018.\u00a0","Jurisdiction of Origin: Investigative Agency":"Malaysian Anti-Corruption Commission (referenced in the FBI\u0027s press release, 20 July 2016)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"FBI\u2019s International Corruption Units in New York and Los Angeles\r\nInternal Revenue Service\u2019s Criminal Investigative Division","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"This case is part of the U.S. DOJ\u0027s Kleptocracy Asset Recovery Initiative, led by a team of prosecutors in the Criminal Division\u2019s Asset Forfeiture and Money Laundering Section. Deputy Chief Woo S. Lee and Trial Attorney Kyle R. Freeny of the U.S. DOJ\u0027s Criminal Division\u2019s Asset Forfeiture and Money Laundering Section and Assistant U.S. Attorneys John Kucera and Christen Sproule of the Central District of California prosecuted the case. The Criminal Division\u2019s Office of International Affairs provided additional assistance.","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Central District of California","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/DOJ%20Press%20Release%20-%20July%202016.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/DOJ%20Press%20Release%20-%20June%202017.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/FBI%20Press%20Release%20-%2020%20July%202016.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Viceroy_complaint.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/wolf_of_wall_street_complaint.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/van_gogh_drawing_complaint.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/park_laurel_complaint.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/oriole_drive_complaint.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/park_lane_complaint.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/lermitage_complaint.pdf","Sources ":"U.S. DOJ Kleptocracy Asset Recovery Initiative - Documents\nhttps:\/\/www.justice.gov\/archives\/kleptocracy-enforcement-action\n"},{"Case ID":"ARW-253","Case Title (Name of Public Official or Entity Allegedly Involved)":"Teodoro Nguema Obiang Mangue (11 luxury cars seized in Geneva)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Equatorial Guinea","Position of Public Official(s) (yrs in office)":"Vice President of Equatorial Guinea (2012-2018) and son of President Teodoro Obiang Nguema Mbasogo (1979 - current)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"(1) Jurisdiction initiated legal action to recover assets \r\n(2) Jurisdiction of Asset Location","Asset Recovery Start":"2016","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdictions","Intl.Cooperation: MLAT\/Letter of Request?":"NA","Basis for Intl Cooperation":"N\/A - The related criminal investigation was initiated by the Swiss Public Prosecutor. ","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"\u0022more than $8 million\u0022 (estimate) ","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"In November 2016, Swiss authorities seized 11 luxury cars as part of criminal proceedings opened against Teodoro Nguema Obiang Mangue, the son of Equatorial Guinea\u2019s longtime leader, on suspicions of money laundering. The prosecutor\u2019s office said in an e-mailed statement to Reuters: \u201cThe Geneva public prosecutor confirms the opening of criminal proceedings against Teodorin Obiang. The latter is accused of money laundering.\u201d \u201cAs part of the procedure, 11 vehicles were effectively sequestered in the cargo area of \u200b\u200bGeneva airport on behalf of the prosecution.\u0022\nThe cars seized by the Geneva police were a Bugatti Veyron, four Ferraris including an Enzo and 599GTB, a Porsche 918 Spyder, a Lamborghini Veneno, a Maybach, a Koenigesegg, an Aston Martin and a McLaren P1, the Geneva prosecutor\u2019s office said. According to media reports, the Bugatti Veyron is worth $2 million and the Swedish-made Koenigegg One is one of only seven ever produced for $2.8 million.\u00a0The total value of the 11 cars has not been reported - but the value of only two of the 11 cars (Bugatti Veyron \u0026 Koenigegg One) totals $4.8 million. Media reports estimate the total value to be \u0022more than $8 million\u0022.\nEquatorial Guinea filed a legal challenge to the seizure, arguing that the cars do not belong to Obiang but to a state company and were only in Geneva for repairs. In July 2017, the Swiss Federal Court rejected the request from the government of Equatorial Guinea to release the luxury cars.\u00a0","Disposition of Criminal Case(s)":"","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Public Prosecutor\u0027s Office in Geneva, Switzerland","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Public Prosecutor\u0027s Office in Geneva, Switzerland","Jurisdiction of Asset Recovery: Courts Involved":"Swiss Federal Court, Switzerland","Documents":"","Sources ":"Swiss seize 11 cars in probe of Equatorial Guinea\u0027s VP, Reuters, 03 November 2016:https:\/\/www.reuters.com\/article\/us-equatorial-swiss-idUSKBN12Y28B\nCorruption trial against \u0027playboy\u0027 son of Equatorial Guinea\u0027s president opens in France, Deutsche Welle, 02 January 2017:http:\/\/www.dw.com\/en\/corruption-trial-against-playboy-son-of-equatorial-...\nEquatorial Guinea\u0027s VP Obiang\u0027s cars seized in Switzerland, BBC, 03 November 2016:http:\/\/www.bbc.com\/news\/world-africa-37861795\nSwiss refuse to release Obiang luxury cars, SWI Swissinfo, 25 July 2017:https:\/\/www.swissinfo.ch\/eng\/politics\/corruption-case_swiss-refuse-to-re...\n"},{"Case ID":"ARW-252","Case Title (Name of Public Official or Entity Allegedly Involved)":"Teodoro Nguema Obiang Mangue (\u0022Ebony Shine\u0022 yacht)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Equatorial Guinea","Position of Public Official(s) (yrs in office)":"Vice President of Equatorial Guinea (2012-2018) and son of President Teodoro Obiang Nguema Mbasogo (1979 - current)","Jurisdiction of Asset Recovery":"Netherlands, Switzerland","Jurisdiction of Asset Description":"(1) Jurisdiction initiated legal action to recover assets (Switzerland)\r\n(2) Jurisdiction of Asset Location\/Alleged Asset Location (Netherlands)","Asset Recovery Start":"2016","Asset Recovery End":"","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdictions","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"$120,000,000","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to a Dutch court order (ECLI: NL: RBOVE: 2017: 1630), on 2 December 2016, the Public Prosecutor\u0027s Office in Geneva, Switzerland, submitted a request for legal assistance to the Dutch Public Prosecution Service, Zwolle location. The reason for this request was the start of an investigation by the Public Prosecution Service in Geneva on 31 October 2016 against Obiang, Vice President of Equatorial Guinea and son of the President, in connection with money laundering. According to the Public Prosecutor\u0027s Office in Geneva, the defendant bought a yacht, Ebony Shine, that was docked in (near) Makkum at the time of the start of the investigation. The Swiss prosecution had a strong suspicion that the yacht was bought through acts of misconduct in a public office and bribery, with funds from Equatorial Guinea, that the defendant uses the yacht exclusively for private purposes and that jure imperii activities of the state of Equatorial Guinea are not involved. The Geneva Public Prosecutor requested that the yacht be seized.\nOn December 2, 2016, at the request of the Swiss authorities, the Dutch authorities seized Mr. Obiang\u2019s 250-foot, $120 million yacht, \u201cEbony Shine,\u201d as it was about to sail to Equatorial Guinea. Mr. Obiang has denied ownership of the yacht, and the government of Equatorial Guinea started legal proceedings in Zwolle, Netherlands to release and return the yacht to the government of Equatorial Guinea. Government lawyers argued in a Dutch court that the yacht belonged to his country\u2019s government and was used for defense purposes. In April 2017, the yacht was placed in sequestration in Den Helder port after a judge in Zwolle ruled that the vessel be held by the Dutch Public Prosecution Service (openbaar ministerie) while its owner is investigated under charges of corruption in Switzerland and France.\nBy a letter of 5 December 2016, the Public Prosecution Service in Geneva additionally requested to seize all available private and public documents relating to the Ebony Shine.\u00a0 On the basis of a decision of 6 December 2016 of the examining magistrate, the Ebony Shine was searched on 8 December 2016, in which a number of goods were seized.\nDuring the proceedings, it was revealed that the yacht is formally owned by a company Named Dara Ltd, registered in the Marshall Islands. Lawyers representing Equatorial Guinea in the Dutcg court stated that Dara Ltd is owned 100% by the Ministry of Defense of Equatorial Guinea. The vessel, built by Feadship in Makkum, has two jaccuzis, a spa, a pool and gym, a helipad, several jetskis and a cinema seating 12.\nSwiss prosecutors had opened their investigation into Obiang in 2016. in July 2017, a Swiss Federal Court turned down a demand by the government of Equatorial Guinea to release the impounded yacht, which is moored in the Netherlands.\u00a0\nEleven luxury cars were seized at Geneva airport in October\/November 2016 as part of the same investigation - see ARW-253","Disposition of Criminal Case(s)":"","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Public Prosecutor\u0027s Office in Geneva, Switzerland","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Public Prosecutor\u0027s Office in Geneva, Switzerland","Jurisdiction of Asset Recovery: Courts Involved":"RECHTBANK OVERIJSSEL (Overijssel District Court), Netherlands","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_Yacht_Dutch%20court%20order%20%231_ECLI_NL_RBOVE_2017_1630.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_Yacht_Dutch%20court%20order%20%232_ECLI_NL_RBOVE_2017_1631.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_Yacht_Equatorial%20Guinea%27s%20Teodorin%20Obiang%20has%20had%20his%20luxury%20yacht%20seized%20in%20the%20Netherlands%20%E2%80%94%20Quartz.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_Yacht_Het%20superjacht%20blijft%20aan%20de%20ketting%20-%20NRC.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_yacht_Superyacht%20seized%20in%20Den%20Helder%20port%20as%20part%20of%20corruption%20probe%20-%20DutchNews.pdf","Sources ":""},{"Case ID":"ARW-250","Case Title (Name of Public Official or Entity Allegedly Involved)":"Family of former President Sani Abacha","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Sani Abacha: President (1993-1998)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"(1) Jurisdiction that initiated legal action to recover assets; (2) Jurisdiction of asset location","Asset Recovery Start":"2014","Asset Recovery End":"2017","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdictions","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"The MOU references: the letter of intent signed by Nigeria and Switzerland in March 2016; Article 25 of the Addis Ababa Action Agenda which encourage the international community to develop good practices on asset return; goal 16 of the 2030 UN agenda for sustainable development that highlights corruption as one of the main factors preventing a supportive and sustainable socioeconomic development; and chapter V of UNCAC, the international legal framework for asset recovery.  ","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$321,000,000","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"The Nigerian authorities requested the funds be used to support a program of targeted cash transfers to poor and vulnerable Nigerians under the National Social Safety Net Project financed by a credit extended by the World Bank. The responsibility for the use of the funds is with the Federal Government of Nigeria. The World Bank\u2019s role is to provide institutional support and monitoring of the use of these funds. The parties have agreed to establish monitoring framework for the use of the repatriated funds that will enhance transparency and accountability. To that end, the Federal Government of Nigeria will engage civil society organizations to help monitor the use of the funds. See MOU attached to this entry for details.","Case Summary":"The Federal Government of Nigeria, the Swiss Federal Council and the World Bank signed a Memorandum of Understanding (MOU) on the repatriation and monitoring of $321 million of funds illicitly acquired by the family of the late former President of Nigeria, General Sani Abacha on 04 December 2017. The MOU was signed during the Global Forum on Asset Recovery, a three-day forum hosted by the United Kingdom and the United States with support from the Stolen Asset Recovery (StAR) Initiative. It was signed by Nigeria\u2019s Attorney-General and Minister of Justice, Mr. Abubakar Malami; Switzerland\u2019s Secretary of State and Head of the Directorate of International Law at the Federal Department of Foreign Affairs, Ambassador Roberto Balzaretti; and the World Bank\u2019s country director for Nigeria, Rachid Benmessaoud.\nThe MOU captures the tripartite agreement on the World Bank\u2019s monitoring role and the proposed modalities of the funds repatriation and disbursement. The signing of the MOU followed a December 2014 Swiss court order that the funds be repatriated, on the condition that the World Bank would monitor their use.\nThis MOU followed through on a Letter of Intent that was signed by Nigeria and Switzerland in March 2016 in Abuja, aimed at regulating the return to Nigeria of assets totaling USD 321 million stolen by Nigeria\u0027s former dictator Sani Abacha. The letter of intent was signed by the Swiss Foreign Minister Didier Burkhalter and Nigeria\u2019s Attorney-General and Minister of Justice, Mr. Abubakar Malami.\nThis return of stolen assets was made possible after the Attorney General of the Canton of Geneva confiscated these assets, which had originally been deposited in bank accounts in Luxembourg, pursuant to a forfeiture order dated 11 December 2014.\u00a0\nThe Nigerian authorities requested the funds be used to support a program of targeted cash transfers to poor and vulnerable Nigerians under the\u00a0National Social Safety Net Project\u00a0financed by a credit extended by the World Bank. The responsibility for the use of the funds is with the Federal Government of Nigeria. The World Bank\u2019s role is to provide institutional support and monitoring of the use of these funds. According to the World Bank\u2019s press release, the parties have agreed to establish monitoring framework for the use of the repatriated funds that will enhance transparency and accountability. To that end, the Federal Government of Nigeria will engage civil society organizations to help monitor the use of the funds.\nAccording to media reports, Nigeria\u2019s minister of finance Kemi Adeosun through her special advisor Oluyinka Akintunde confirmed the receipt of money from Switzerland in December 2017, with $1.5 million in interest. Akintunde said: \u0022We state that $322,515,931.83 (N116,105,735,458.80) was received into a Special Account in the Central Bank of Nigeria (CBN) on Dec. 18, 2017, from the Swiss government\u0022.\nIn 2006, the World Bank was involved in a similar framework, providing institutional support for the return and use of approx. $723 million in public funds that had been corruptly diverted by General Abacha. See case entry ARW-167 and the attached World Bank Fact Sheet.\u00a0","Disposition of Criminal Case(s)":"","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General of the Canton of Geneva","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/MOU_Dec%202017.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Swiss%20Federal%20Council%20press%20release%20-%20Restitution%20of%20USD%20321%20million%20by%20Switzerland%20to%20Nigeria%20under%20World%20Bank%20oversight.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Swiss%20Federal%20Council%20press%20release%20-%20Letter%20of%20Intent.%20March2016.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Nigeria_%20World%20Bank%20to%20Help%20Monitor%20Repatriated%20Abacha%20Funds.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/World%20Bank%20Monitoring%20of%20Repatriated%20Abacha%20Funds.pdf","Sources ":"Information about the National Social Safety Net Project for Nigeria: http:\/\/projects.worldbank.org\/P151488?lang=en\nWorld Bank press release about the National Social Safety Net Project for Nigeria:\u00a0http:\/\/www.worldbank.org\/en\/news\/press-release\/2016\/06\/07\/world-bank-com...\nBBC News.\u00a0\u0027Abacha loot\u0027: Switzerland to return $320m to Nigeria:\u00a0https:\/\/www.bbc.com\/news\/world-africa-42237752\nDaily Trust.\u00a0We returned $322.5m Abacha loot with $1.5m interest in 2017:\u00a0https:\/\/www.dailytrust.com.ng\/we-returned-322-5m-abacha-loot-with--1-5m-...\n"},{"Case ID":"ARW-238","Case Title (Name of Public Official or Entity Allegedly Involved)":"Unnamed Uzbek \u0022Government Official A\u0022\/ Mobile Telesystems and Vimpelcom Telecom Case (Luxembourg)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Uzbekistan","Position of Public Official(s) (yrs in office)":"\u0022Several Positions\u0022 in Uzbek Government, including during 2005-2011; a \u0022relative of the President of Uzbekistan\u0022","Jurisdiction of Asset Recovery":"Luxembourg","Jurisdiction of Asset Description":"","Asset Recovery Start":"2015","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Forfeiture (in US)","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"See related entry, civil asset forfeiture actions by the United States. \u00a0In one of the two civil asse forfeiture actions filed against assets related to unnamed Uzbek official and VimpelCom bribery case, including assets held in accounts in Luxembourg, at Clearstream Banking SA. \u00a0(Source: \u00a0US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015 and Partial Default Judgment and Order of Forfeiture filed January 11, 2016; Court Docket Report as of June 27, 2016.)","Disposition of Criminal Case(s)":"According to the US Department of Justice complaint filed in the case, Gayane Avakyan and Rustan Madumarov, close associates of \u0022Government Official A\u0022 were arrested in 2014 and subsequently convicted and of multiple criminal offenses in relation to the case and sentenced to prison terms. \u00a0(Source: \u00a0US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015, paragraphs 18-19; See also, US v. All Assets Held in Accounts [by First Global Accounts, Case No. 15-cv-05063 (SDNY), January 26, 2016.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"Tashkent Regional Criminal Court in the Republic of Uzbekistan","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/VimpelCom%20Limited%20and%20Unitel%20LLC_DOJ_PR_Resolution_Feb2016_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/NCB_First%20Global%20Accts_Partial%20Default%20Judgment_01112016_1.pdf","Sources ":"US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015 and Partial Default Judgment and Order of Forfeiture filed January 11, 2016; Court Docket Report as of June 27, 2016; See also US Department of Justice Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million\u037e United States Seeks $850 Million\n\tForfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016.\n"},{"Case ID":"ARW-237","Case Title (Name of Public Official or Entity Allegedly Involved)":"Unnamed Uzbek \u0022Government Official A\u0022\/ Mobile Telesystems and Vimpelcom Telecom Case (Ireland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Uzbekistan","Position of Public Official(s) (yrs in office)":"\u0022Several Positions\u0022 in Uzbek Government, including during 2005-2011; a \u0022relative of the President of Uzbekistan\u0022","Jurisdiction of Asset Recovery":"Ireland","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2015","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Asset Forfeiture (in US)","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"See related entry, civil asset forfeiture actions by the United States. \u00a0In one of the two civil asset forfeiture actions filed against assets related to unnamed Uzbek official and VimpelCom bribery case, including assets held in Ireland at Bank of New York Mellon Investment Servicing (International) Limited held by or benefit of SWISDORN Limited, Takilant Limite and Expoline Limited and other portfolio funds. (Source: US v. Any and all assets held on Behalf of Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015 and Partial Default Judgment and Order of Forfeiture filed January 11, 2016; Court Docket Report as of June 27, 2016.)","Disposition of Criminal Case(s)":"According to the US Department of Justice complaint filed in the case, Gayane Avakyan and Rustan Madumarov, close associates of \u0022Government Official A\u0022 were arrested in 2014 and subsequently convicted and of multiple criminal offenses in relation to the case and sentenced to prison terms. \u00a0(Source: \u00a0US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015, paragraphs 18-19; See also, US v. All Assets Held in Accounts [by First Global Accounts, Case No. 15-cv-05063 (SDNY), January 26, 2016.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"Tashkent Regional Criminal Court in the Republic of Uzbekistan","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015 and Partial Default Judgment and Order of Forfeiture filed January 11, 2016; Court Docket Report as of June 27, 2016; See also US Department of Justice Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million\u037e United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016.\n"},{"Case ID":"ARW-235","Case Title (Name of Public Official or Entity Allegedly Involved)":"Unnamed Uzbek \u0022Government Official A\u0022\/ Mobile Telesystems and Vimpelcom Telecom Case (Belgium)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Uzbekistan","Position of Public Official(s) (yrs in office)":"\u0022Several Positions\u0022 in Uzbek Government, including during 2005-2011; a \u0022relative of the President of Uzbekistan\u0022","Jurisdiction of Asset Recovery":"","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2015","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Forfeiture (in US)","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"See related entry, civil asset forfeiture actions by the United States. \u00a0In one of the two civil asset forfeiture actions filed against assets related to unnamed Uzbek official and VimpelCom bribery case, including assets held in accounts at Bank of New York Mellon SA\/NV in Brussels, Belgium on behalf of First Global Investments SPC Limited Funds. (Source: \u00a0US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015 and Partial Default Judgment and Order of Forfeiture filed January 11, 2016; Court Docket Report as of June 27, 2016.)","Disposition of Criminal Case(s)":"According to the US Department of Justice complaint filed in the case, Gayane Avakyan and Rustan Madumarov, close associates of \u0022Government Official A\u0022 were arrested in 2014 and subsequently convicted and of multiple criminal offenses in relation to the case and sentenced to prison terms. \u00a0(Source: \u00a0US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015, paragraphs 18-19; See also, US v. All Assets Held in Accounts [by First Global Accounts, Case No. 15-cv-05063 (SDNY), January 26, 2016.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"Tashkent Regional Criminal Court in the Republic of Uzbekistan","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/VimpelCom%20Limited%20and%20Unitel%20LLC_DOJ_PR_Resolution_Feb2016.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/NCB_First%20Global%20Accts_Partial%20Default%20Judgment_01112016.pdf","Sources ":"US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015 and Partial Default Judgment and Order of Forfeiture filed January 11, 2016; Court Docket Report as of June 27, 2016; See also US Department of Justice Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million\u037e United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016.\n\u00a0\n"},{"Case ID":"ARW-247","Case Title (Name of Public Official or Entity Allegedly Involved)":"Jose Luis Ramos Castillo \/ Petroleos de Venezuela S.A. (PDVSA)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Venezuela","Position of Public Official(s) (yrs in office)":"Superintendent of Purchasing and other purchasing related positions (Ramos, about 2002-Sept 2013)","Jurisdiction of Asset Recovery":"","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2015","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Forfeiture (by the United States)","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the Information filed in his case, Mr. Ramos, a resident of Venezuela and then Texas, was employed by the Venezulan state-owned oil company Petroleos de Venezuela S.A. or its affiliates from 2002 to 2013. \u00a0During that time he held various positions related to purchasing including as Superintendent of Purchasing and Purchasing Manager with responsibility for selecting companies for bidding panels. \u00a0(US v. Jorge Luis Ramos Castillo, Case No. 15-cr-636 (SD Tex), Information filed November 24, 2015.) \u00a0 As of June 2016, three US based businessmen and three former employees of PDVSA have pleaded guilty to various charges relating to a scheme in which the businessmen paid bribes in order to win contracts at the state-owned oil company. \u00a0(Source: US Department of Justice, \u0022Businessman Pleads Guilty to Foreign Bribery and Tax Charges in Connection with Venezuela Bribery Scheme,\u0022 June 16, 2016.) \u00a0In April 2016, a \u00a0supplement to notice of forfeiture was filed against four real properties in Miami-Dade County, Florida and funds (unspecified amount) held in deposit in an account at Royal Skandia Life Assurance Limited, held at Isle of Man. \u00a0(Source: \u00a0US v. Ramos Castillo, Case No. 15-cr-636 (SD Tex), United States Supplement to Notice of Forfeiture in the Information, filed April 29, 2016.)","Disposition of Criminal Case(s)":"According to the Court Docket Report in his case, Mr. Ramos pleaded guilty to 2 counts of conspiracy and awaits sentencing scheduled for September 30, 2016. (Source: US v. Jose Luis Ramos-Castillo, Case No. 15-cr-636 (SDTEX), Court Docket Report as of June 23, 2016.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ramos-Castillo_SDTEX_Information_Nov24_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ramos-Castillo_SDTEX_Supplement_Forfeiture%20Notice_04292016.pdf","Sources ":"US v. Ramos Castillo, Case No. 15-cr-636 (SD Tex), Information filed November 24, 2015; United States Supplement to Notice of Forfeiture in the Information, filed April 29, 2016; Court Docket Report as of June 23, 2016; US Department of Justice Press Release, \u0022Businessman Pleads Guilty to Foreign Bribery and Tax Charges in Connection with Venezuela Bribery Scheme,\u0022 June 16, 2016.\n"},{"Case ID":"ARW-246","Case Title (Name of Public Official or Entity Allegedly Involved)":"Janet Lim Napoles \/ Arthur Pingoy, and many others \/ Philippines Development Assistance Fund (PDAF) Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"Napoles (Businesswoman); Congressman (Pingoy)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2015","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation ","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the US Department of Justice, from 2004-2012 Philippines businesswoman Janet Lim-Napoles paid tens of million dollars in bribes and kickbacks to Philippines politicians and other government officials, in exchange for over $200 million in purported development and disaster relief. In July 2015, the DOJ Kleptocracy Asset Recovery Initiative filed a civil asset forfeiture complaint to recover approximately $12.5 million in assets (mainly real properties in Los Angeles and Orange counties) allegedly derived from the kickback scheme which were funnelled through her non-governmental organizations. \u00a0Accordind to the DOJ Press Release, \u0022The complaint alleges that Napoles transferred over $12 million in Philippine government awarded funds to bank accounts in the United States in the names of, or controlled by, her family members. According the complaint, Napoles used the money to purchase numerous assets, including a condominium at the Ritz-Carlton in Los Angeles for her 21 year-old daughter. The complaint seeks to forfeit the proceeds from the sale of the Los Angeles condominium, along with several other assets, including a motel near Disneyland in Anaheim, California\u037e properties in Covina and Irvine, California\u037e a 19 percent stake in a California-based consulting company\u037e and a Porsche Boxster that was purchased for another daughter.\u0022 (Source: US DOJ Press Release, \u0022U.S. Seeks to Recover $12.5 Million Obtained from High Level Corruption in the Philippines,\u0022 July 14, 2015; See also US v. Proceeds from the sale of a condominium located at Ritz-Carlton in Los Angeles, et al, Case No. 8:15-cv-1110 (CDCA), First Amended Verified Complaint of Forfeiture filed March 21, 2016). \u00a0As of June 21, 2016, a settlement conference was scheduled for December 14, 2016. \u00a0","Disposition of Criminal Case(s)":"According to the US Department of Justice, Janet Lim Napoles is serving a sentence of life imprisonment in the Philippines for her role in the kidnapping and detention of her cousin, Benhur Luy, \u0022who served as Napoles\u2019s finance officer and tracked her schemes.\u0022 \u00a0(Source: DOJ Press Release, \u0022U.S. Seeks to Recover $12.5 Million Obtained from High Level Corruption in the Philippines,\u0022 July 14, 2015.) \u00a0 According to the Philippines Office of the Ombudsman, on May 6, 2016, \u0022Ombudsman Conchita Carpio Morales has affirmed the indictment of ex-Representative Arthur Pingoy of the second district of South Cotabato for Malversation of Public Funds, violation of Section 3(e) of the Anti-Graft and Corrupt Practices Act (RA 3019) and Direct Bribery for the misappropriation of his 2007-2008 Priority Development Assistance Fund (PDAF) totaling P20.91M. \u00a0In a 36-page Order, Ombudsman Morales directed the filing of Informations against Pingoy with the Sandiganbayan for 2 counts of Direct Bribery and 4 counts each of Malversation and violation of the anti-graft law. \u00a0Charged alongside Pingoy are Technology Resource Center (TRC) officials Antonio Ortiz, Dennis Cunanan, Francisco Figura and Marivic Jover, Department of Budget and Management officials Mario Relampagos, Rosario Nu\u00f1ez, Marilou Bare and Lalaine Paule, National Agribusiness Corporation (NABCOR) officials Alan Javellana, Rhodora Mendoza, Maria Ninez Guanizo and Victor Cacal, Philippine Social Development Foundation, Inc. (PSDFI) employees Evelyn de Leon, Noel Macha, John Raymund De Asis and John Bernardo, together with Janet Lim Napoles and former Energy Regulatory Commission Chairperson Zenaida Ducut.\u0022 \u00a0(Source: Office of the Ombudsman Press Release, \u0022Ombudsman charges ex-Rep. Pingoy, Napoles for PDAF scam,\u0022 May 6, 2016.)","Jurisdiction of Origin: Investigative Agency":"Office of the Ombudsman","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Ombudsman","Jurisdiction of Origin: Courts Involved":"Sandiganbayan","Jurisdiction of Asset Recovery: Investigative Agency":"FBI, Los Angeles Field Office; US Marshalls Service; Department of Justice Office of International Affairs","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Kleptocracy Asset Recovery Initiative; US Attorney\u0027s Office - Central District of Los Angeles","Jurisdiction of Asset Recovery: Courts Involved":"District Court for the Central District of California","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Napoles_CDCA_First%20Amended%20Complaint_Mar2016.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Napoles_Philippines_Ombudsman_Charges%20against%20five%20Lawmakers_Jul2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Napoles_Philippines_Ombudsman_Charges%20Filed%20PEPs_May2016.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/NapolesCDCA_DOJ%20PR_Complaint_Jul2015.pdf","Sources ":"Office of the Ombudsman (Philippines) Press Release, \u0022Ombudsman charges ex.Rep Pingoy, Napoles for PDAF scam,\u0022 May 6, 2016, at http:\/\/www.ombudsman.gov.ph\/index.php?home=1\u0026pressId=ODQ3; \u00225 more Congressman et.al. indicted for PDAF Scam,\u0022 July 1, 2015, at http:\/\/www.ombudsman.gov.ph\/index.php?home=1\u0026pressId=Njc4;\n\t\u00a0\n\tUS v. Proceeds from the sale of a condominium located at the Ritz-Carlton in Los Angeles, Case No. 15-cv-1110 (CDCA), First Amended Verified Complaint for Forfeiture In Rem, filed March 21, 2016 and Court Docket Report as of June 21, 2016; \u00a0US Department of Justice Press Release, \u0022U.S. Seeks to Recover $12.5 Million Obtained from HighLevel Corruption in the Philippines,\u0022 July 14, 2015.\n"},{"Case ID":"ARW-245","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pavel Lazarenko (United States Civil Asset Forfeiture Case) \/ Lithuania","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Member of Parliament (1998); Prime Minister (1996-1997); First Vice Prime Minister (1995-1996); various government and political positions, Dnepropetrovsk region (1992-1995)","Jurisdiction of Asset Recovery":"Lithuania","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.18, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"As of June 2016, the civil asset forfeiture case in the United States was ongoing against accounts held in a number of financial institutions around the world, including Vilnius Bankas in Lithuania. \u00a0The amounts held are not specified. \u00a0(Source: U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Court Docket Report as of June 20, 2016.)\n\t\u00a0\n\tOn May 14, 2004, the U.S. filed a civil asset forfeiture suit, seeking to forfeit more than $250 million which the government alleged were illegal proceeds of criminal activities by Mr. Lazarenko and his associates. \u00a0The U.S. government also alleged that the assets were obtained through the abuse of public office and illegally transported and\/or laundered through the abuse of financial institutions in the United States, and were located in in foreign bank accounts in Guernsey, Antigua \u0026 Barbuda, Switzerland, Lithuania and Liechtenstein.(Source: U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Verified Claim for Forfeiture In Rem filed on May 14, 2004 and First Amended Verified Claim for Forfeiture In Rem filed on June 30, 2005.) \u00a0 On May 20, 2004, a Restraining Order was issued against the defendant accounts. \u00a0(Source: U.S. v. All Assets Held in Julis Baer, et al, Case No. 1:04-cv-00798-PLF (D.D.C.), which stipulated that \u0022terms of Order shall remain in full force and effect until the judgment rendered in the case or further Order of the court.\u0022) \u00a0Actions against some of the assets were terminated in June 2005.","Disposition of Criminal Case(s)":"According to the U.S. Department of Justice Press Release dated November 19, 2009, Mr. Lazarenko was sentenced to 97 months in prison, subsequent to his conviction on eight counts of money laundering. \u00a0(Source: U.S. Department of Justice, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison,\u0022 November 19, 2009.) According to \u00a0BBC News, Mr. Lazarenko was convicted in Switzerland, in June 2000, on money laundering charges. (Sources: \u00a0BBC News, \u0022The case against Lazarenko,\u0022 \u00a0August 25, 2006. \u00a0See also, Swiss court decisions: BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court).\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Lazarenko_Amended%20Complaint_June%202005_0.pdf","Sources ":"U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Verified Claim for Forfeiture In Rem filed on May 14, 2004; First Amended Verified Claim for Forfeiture In Rem filed on June 30, 2005 and Notice of Errata for First Amended Verified Claim for Forfeiture In Rem filed on January 21, 2011; Restraining Order filed on May 20, 2004; and Court Docket Report as of June 20, 2016.\n"},{"Case ID":"ARW-242","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pavel Lazarenko (United States Civil Asset Forfeiture Case) \/ Liechtenstein","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Member of Parliament (1998); Prime Minister (1996-1997); First Vice Prime Minister (1995-1996); various government and political positions, Dnepropetrovsk region (1992-1995)","Jurisdiction of Asset Recovery":"Liechtenstein","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.18, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"\u00a0As of June 2016, the civil asset forfeiture case in the United States was ongoing against accounts held in a number of financial institutions around the world, including Verwaltungs-und Privatbank and LGT banks in Liechtenstein. \u00a0The amounts held are not specified. \u00a0(Source: U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Court Docket Report as of June 20, 2016.)\n\t\u00a0\n\tOn May 14, 2004, the U.S. filed a civil asset forfeiture suit, seeking to forfeit more than $250 million which the government alleged were illegal proceeds of criminal activities by Mr. Lazarenko and his associates. \u00a0The U.S. government also alleged that the assets were obtained through the abuse of public office and illegally transported and\/or laundered through the abuse of financial institutions in the United States, and were located in in foreign bank accounts in Guernsey, Antigua \u0026 Barbuda, Switzerland, Lithuania and Liechtenstein.(Source: U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Verified Claim for Forfeiture In Rem filed on May 14, 2004 and First Amended Verified Claim for Forfeiture In Rem filed on June 30, 2005.) \u00a0 On May 20, 2004, a Restraining Order was issued against the defendant accounts. \u00a0(Source: U.S. v. All Assets Held in Julis Baer, et al, Case No. 1:04-cv-00798-PLF (D.D.C.), which stipulated that \u0022terms of Order shall remain in full force and effect until the judgment rendered in the case or further Order of the court.\u0022)\u00a0","Disposition of Criminal Case(s)":"According to the U.S. Department of Justice Press Release dated November 19, 2009, Mr. Lazarenko was sentenced to 97 months in prison, subsequent to his conviction on eight counts of money laundering. \u00a0(Source: U.S. Department of Justice, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison,\u0022 November 19, 2009.) According to \u00a0BBC News, Mr. Lazarenko was convicted in Switzerland, in June 2000, on money laundering charges. (Sources: \u00a0BBC News, \u0022The case against Lazarenko,\u0022 \u00a0August 25, 2006. \u00a0See also, Swiss court decisions: BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court).\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Lazarenko_Amended%20Complaint_June%202005.pdf","Sources ":"\u00a0U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Verified Claim for Forfeiture In Rem filed on May 14, 2004; First Amended Verified Claim for Forfeiture In Rem filed on June 30, 2005 and Notice of Errata for First Amended Verified Claim for Forfeiture In Rem filed on January 21, 2011; Restraining Order filed on May 20, 2004; and Court Docket Report as of June 20, 2016.\n"},{"Case ID":"ARW-244","Case Title (Name of Public Official or Entity Allegedly Involved)":"Standard Bank\/ Enterprise Growth Market Advisors \/ Tanzania Sovereign Note Private Placement","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Tanzania","Position of Public Official(s) (yrs in office)":"Harry Kitilya, Commissioner of the Tanzanian Revenue Authority (resigned December 2013); Fratern Mboya, CEO of Tanzania Capital Markets and Securities Authority (1995-2011)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort","Asset Recovery Start":"2013","Asset Recovery End":"2016","UNCAC Offenses Implicated":"Art.16, Art.18, Art.19","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Deferrred Prosecution Agreement\/Settlement","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"The case was triggered by a self disclosure by Standard Bank.  The UK SFO also acknowledged working with the US Department of Justice and Securities and Exchange Commission, the UK Foreign and Commonwealth Office and the Financial Conduct Authority. (Source: UK SFO Press Release, \u0022 SFO agrees first UK DPA with Standard Bank,\u0022 November 30, 2015)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"According to the UK Serious Fraud Office, \u0022The money due to the Government of Tanzania will be returned in line with advice being received from the Department for International Development.\u0022 (Source:  SFO Press Release, \u0022SFO agrees first UK DPA with Standard Bank,\u0022 November 30, 2015)","Case Summary":"According to a news article by the British High Commission Dar es Salaam, \u0022The UK has recently transferred to the Tanzanian Government the $7m fine that Standard Bank paid as a result of its failure to prevent bribery.\u0022 (Source: British High Commission Dar es Salaam, \u0022UK, Tanzania close partners in fighting corruption scourge,\u0022 May 17, 2016.)\n\t\t\t\u00a0\n\t\t\tAccording to the UK Serious Fraud Office and the Statement of Facts in the case, in 2012-2013, Standard Bank and its Tanzanian subsidiary Stanbic Bank were involved in a US$600 million soveeign note private placement for the Government of Tanzania, which was seeking to raise funds in support of its \u0022Five Year Development Plan\u0022 to finance various infrastructure projects. \u00a0As part of the deal, the fees to be paid to the bank was increased to 2.4%, with the \u0022local partner\u0022 Enterprise Growth Market Advisors receiving a consulting fee of 1% although according to the Statement of Facts, there was \u0022no evidence of payment represented reasonable consideration for services rendered on this transaction.\u0022 \u00a0(Source: Statement of Facts, para 28; See also Final Judgment, paras 6 and 7). \u00a0The chairman of Enterprise Growth Market Advisors (EGMA) was Mr. Harry Kitilya, who was also one of its three directors and shareholders, and at the same time serving as the Commission of the Tanzanian Revenue Authority. \u00a0EGMA\u0027s Managing Director was Dr. Fratern Mboya, who had been the Chief Executive Officer of the Tanzanian Capital Markets and Securities Authority (a government agency), 1995-2011. \u00a0The Statement of Facts in the case also lists (in paras 56-57) the involvement of other Tanzanian government officials in the deal, including two successive Ministers of Finance. \u00a0\u00a0\n\t\t\t\u00a0\n\t\t\tThe case was triggered by a disclosure to the SFO by Standard Bank\u0027s legal counsel. \u00a0The SFO noted that despite \u0022obvious red flags for bribery\u0022 Standard Bank and Stanbic Bank \u0022team not appears to have recognized possibility of the arrangement being corrupt.\u0022 \u00a0(Source: Statement of Facts, paras 153-154). The Statement of Facts notes that within days and weeks of being paid $6 million into an account opened specifically to receive the fees, Dr. Mboya of EGMA made four withdrawals in cash of nearly all of the amounts paid, with the assistance of bank personnel. \u00a0The Statement of Facts noted that \u0022The cash withdrawals prevents any further tracing of the US$6 million.\u0022 (Statement of Facts, paras 178-185, 30). \u00a0\n\t\t\t\u00a0\n\t\t\tAs part of the Deferred Prosecution Agreement, Standard Bank will pay $25.2 million in total financial penalty, consisting of $16.8 million financial penalty, $8.4 million disgorgement of profits.\u00a0\n\t\t\t\u00a0\n\u00a0","Disposition of Criminal Case(s)":"According to the UK Serious Fraud Office, in November 2015, the Southwark Crown Court approved the SFO\u0027s first Deferred Prosecution Agreement with the Standard Bank, which was the subject of an indictment alleging failure to prevent bribery contrary to section 7 of the Bribery Act 2010. \u00a0As a result of the Deferred Prosecution Agreement, the charge against Standard Bank has been suspended for three years. \u00a0(Sources: \u00a0UK SFO Press Release, \u0022SFO agrees first UK DPA with Standard Bank,\u0022 November 30, 2015; Deferred Prosecution Agreement, November 2015; Between Serious Fraud Office and Standard Bank, Case U20150854, Approved Judgment, November 30, 2015)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Serious Fraud Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Serious Fraud Office","Jurisdiction of Asset Recovery: Courts Involved":"Southwark Crown Court","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/UK%20SFO%20agrees%20first%20UK%20DPA%20with%20Standard%20Bank%20_%20Nov302015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/deferred%20prosecution%20agreement%20-%20standard%20bank_Nov2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/sfo%20v%20icbc%20sb%20plc%20-%20statement%20of%20facts_Nov2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/sfo-v-standard-bank_Preliminary_judgment_Nov2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/sfo-v-standard-bank_Final%20judgment_Nov2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Standard%20Bank_UK%2C%20Tanzania%20close%20partners%20in%20fighting%20corruption%20scourge_May2016.pdf","Sources ":"UK Serious Fraud Office Press Release, \u0022 SFO agrees first UK DPA with Standard Bank,\u0022 November 30, 2015, at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-20... (which also provides links to the Deferred Prosecution Agreement, Statement of Facts, Preliminary Judgment and Final Judgment); \u00a0 British High Commission Dar es Salaam, \u0022UK, Tanzania close partners in fighting corruption scourge,\u0022 May 17, 2016, at https:\/\/www.gov.uk\/government\/world-location-news\/uk-tanzania-close-part....\n"},{"Case ID":"ARW-241","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pavel Lazarenko (United States Civil Asset Forfeiture Case) \/ Guernsey","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Member of Parliament (1998); Prime Minister (1996-1997); First Vice Prime Minister (1995-1996); various government and political positions, Dnepropetrovsk region (1992-1995)","Jurisdiction of Asset Recovery":"Guernsey","Jurisdiction of Asset Description":"Location of Assets \/ Alleged Assets","Asset Recovery Start":"2004","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.18, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"Approximately US$150 million","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"As of June 2016, the civil asse forfeiture case in the United States was ongoing against three accounts totalling approximately US$150 million: \u00a0(1) Credit Suisse (Guernsey) Limited - Balford Trust account of US$147.9 million, (2) Credit Suisse (Guernsey) - Credit Suisse Trust Limited - Escrow Account Re BT of approximately GBP14,308 and (3) Bank Julius Baer Company Guernsey Branch, about $2 million in account of P. Lazarenko. \u00a0(Source: U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Court Docket Report as of June 20, 2016.)\n\u00a0\nOn May 14, 2004, the U.S. filed a civil asset forfeiture suit, seeking to forfeit more than $250 million which the government alleged were illegal proceeds of criminal activities by Mr. Lazarenko and his associates. \u00a0The U.S. government also alleged that the assets were obtained through the abuse of public office and illegally transported and\/or laundered through the abuse of financial institutions in the United States, and were located in in foreign bank accounts in Guernsey, Antigua \u0026 Barbuda, Switzerland, Lithuania and Liechtenstein.(Source: U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Verified Claim for Forfeiture In Rem filed on May 14, 2004 and First Amended Verified Claim for Forfeiture In Rem filed on June 30, 2005.) \u00a0 On May 20, 2004, a Restraining Order was issued against the defendant accounts. \u00a0(Source: U.S. v. All Assets Held in Julis Baer, et al, Case No. 1:04-cv-00798-PLF (D.D.C.), which stipulated that \u0022terms of Order shall remain in full force and effect until the judgment rendered in the case or further Order of the court.\u0022) \u00a0Actions against some of the assets were terminated in June 2005.","Disposition of Criminal Case(s)":"According to the U.S. Department of Justice Press Release dated November 19, 2009, Mr. Lazarenko was sentenced to 97 months in prison, subsequent to his conviction on eight counts of money laundering. \u00a0(Source: U.S. Department of Justice, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison,\u0022 November 19, 2009.) According to \u00a0BBC News, Mr. Lazarenko was convicted in Switzerland, in June 2000, on money laundering charges. (Sources: \u00a0BBC News, \u0022The case against Lazarenko,\u0022 \u00a0August 25, 2006. \u00a0See also, Swiss court decisions: BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court).\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Verified Claim for Forfeiture In Rem filed on May 14, 2004; First Amended Verified Claim for Forfeiture In Rem filed on June 30, 2005 and Notice of Errata for First Amended Verified Claim for Forfeiture In Rem filed on January 21, 2011; Restraining Order filed on May 20, 2004; and Court Docket Report as of June 20, 2016.\n"},{"Case ID":"ARW-243","Case Title (Name of Public Official or Entity Allegedly Involved)":"Mahamoud Adam Bechir and Nouracham Niam; Ikram Mahamt Saleh \/ United Kingdom (Caracal Energy [formerly Griffiths Energy] shares case)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Chad","Position of Public Official(s) (yrs in office)":"Ambassador to South Africa (current); former Ambassador to Canada and the United States (Bechir); Wife of Ambassador (Niam); Wife of Chad\u0027s Deputy Chief of Mission Youssouf Hamid Takane. 2007-2015 (Saleh)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort; Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.18, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation; Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the US Department of Justice press release, \u0022As alleged in the complaint, in 2009, Bechir and Takane agreed to use their official positions to influence the award of oil development rights in Chad to Griffiths Energy International Inc., a Canadian oil company, in exchange for shares in the company. \u00a0Thereafter, in or about October 2009, Griffiths Energy issued four million shares to the wives of Bechir and Takane and to another associate.\n\t\u00a0\n\tThe complaint further alleges that Griffiths Energy agreed with Bechir and his wife that the company would pay a $2 million \u201cconsulting fee\u201d to Bechir\u2019s wife to influence the award of oil development rights in Chad. \u00a0After securing the desired oil development rights in February 2011, Griffiths Energy allegedly transferred $2 million to an account held by a shell company created by Bechir\u2019s wife. \u00a0This bribe payment was commingled and laundered through U.S. bank accounts and real property, and eventually was transferred to Bechir\u2019s bank account in South Africa, where he is now serving as Chad\u2019s Ambassador. \u00a0In 2013, Griffiths Energy pleaded guilty in Canadian court to bribing Bechir.\n\t\u00a0\n\tThe $34 million that the United States seeks in forfeiture represents the cash value of the four million shares in Griffiths Energy that were provided to the wives of Bechir and Takane and to their associate. \u00a0In a separate action filed in 2014, the United States also is seeking the civil forfeiture of over $100,000 in allegedly laundered funds traceable to the $2 million bribe payment. \u00a0Takane resides in the United States.\u0022 (Source: US Department of Justice Press Release, \u0022Department of Justice Seeks Forfeiture of $34 Million in Bribe Payments to the Republic of Chad\u2019s Former Ambassador to the U.S. and Canada,\u0022 June 30, 2015.)\n\t\u00a0\n\tAccording to the civil asset forfeiture complaint in the case, the alleged bribery proceeds are held in accounts in the UK\u0027s Royal bank of Scotland in the name of Mrs. Niam and Mrs. Saleh, who have both filed claims, along with Ms. Niam\u0027s former attorney in Canada for unpaid fees arising out of canadian court proceedings, to the assets in the US District Court for the District of Columbia. \u00a0(Source: \u00a0US v. Approximately \u00a322 million in British Pounds representing the value of 4,000,000 shares of common stock in Caracal Energy Inc., formerly Griffiths Energy International, Inc., Case No. 1:15-cv-01018 (D.D.C.), Verfied Complaint filed June 30, 2015; Verfied Claim filed by Ms. NIma on August 14; Verified Claim filed by Mrs. Saleh on August 17; Verified Claim filed by CESPC.) \u00a0The Government of Chad also filed a claim on October 16, stating that the \u0022funds [were] paid wrongfully to representatives of Chad in an effort to obtain rights belonging to Chad.\u0022 \u00a0The Claim was signed by the Deputy General Secretary of the Republic of Chad. (Source: \u00a0US v. Approximately \u00a322 million in British Pounds representing the value of 4,000,000 shares of common stock in Caracal Energy Inc., formerly Griffiths Energy International, Inc., Case No. 1:15-cv-01018 (D.D.C.), Verified Claim filed by Government of Chad, at para 6, October 16, 2015; Answer by Government of Chad to Verified Claim, filed October 26, 2015). As of June 23, 2016, the case was ongoing.\u00a0\n\t\u00a0\n\tAccording to the UK High Court Judgment issued in July 2015, Mrs. Saleh\u0027s application to discharge the Property Freezing Order pursuant to the Proceeds of Crime Act (POCA) issued against the GBP 4.4 million and interest held at Royal Bank of Scotland in proceeds of sale of 800,000 shares in Caracal Energy (formerly known as Griffiths Energy Inc. [GEI]) was denied. \u00a0The Court stated in part that \u0022Although GEI made no admission in the Agreed Statement of Facts that the shares allotted to Mrs Saleh and Mr Hassan were a part of the corrupt incentives provided by GEI, there is easily sufficient circumstantial evidence to raise a good arguable case that they were, and that the GEI shares are \u0027recoverable property\u0027 as defined in POCA. \u00a0It is unnecessary for the purposes of POCA to show that the person who is the lawful owner of the \u201crecoverable property\u201d was himself or herself guilty of any criminal offence.\u0022 \u00a0(Source: \u00a0Between Serious Fraud Office and Ikram Mahamed Saleh, [2015] EWHC 2119 QB (July 21, 2015), para 61.)","Disposition of Criminal Case(s)":"NA (civil asset forfeiture case in the US); Civil Recovery Order Property Freezing Order (Mrs. Saleh\u0027s shares)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Serious Fraud Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Serious Fraud Office","Jurisdiction of Asset Recovery: Courts Involved":"England and Wales High Court - Queens Bench","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths%20Energy%20Stock%20Forfeiture%20Case_PR_Jun30%202015_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths_Energy_Complaint_Jun30%202015_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths%20Energy%20Certif_Arrests%20in%20Rem%20Order_June30%202015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths%20Energy%20Stock_Niam%20Claim_Aug%2014%202015_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths%20Energy%20Stock_Saleh%20Claim_Aug2015_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths%20Energy%20Stock_Rep%20of%20Chad%20Claim_Oct%202015_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_UK_SALEH_PFO_2015%20EWHC2119QB.pdf","Sources ":"US Department of Justice Press Release, \u0022Department of Justice Seeks Forfeiture of $34 Million in Bribe Payments to the Republic of Chad\u2019s Former Ambassador to the U.S. and Canada,\u0022 June 30, 2015, at http:\/\/www.justice.gov\/opa\/pr\/department-justice-seeks-forfeiture-34-mil... Source: \u00a0US v. Approximately \u00a322 million in British Pounds representing the value of 4,000,000 shares of common stock in Caracal Energy Inc., formerly Griffiths Energy International, Inc., Case No. 1:15-cv-01018 (D.D.C.), Verified Complaint filed June 30, 2015, and accessed at http:\/\/www.justice.gov\/opa\/file\/624266\/download; Verfied Claim filed by Ms. NIma on August 14; Verified Claim filed by Mrs. Saleh on August 17; Verified Claim filed by CESPC; Verified Claim filed by Government of Chad, October 16, 2015 and Answer by Government of Chad to Verified Complaint; Court Docket Report as of June 23, 2016; Between Serious Fraud Office and Ikram Mahamed Saleh, [2015] EWHC 2119 QB (July 21, 2015).\n"},{"Case ID":"ARW-240","Case Title (Name of Public Official or Entity Allegedly Involved)":"Mahamoud Adam Bechir and Nouracham Niam; Ikram Mahamat Saleh \/ United States (Caracal Energy [formerly Griffths Energy] shares case)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Chad","Position of Public Official(s) (yrs in office)":"Ambassador to South Africa (current); former Ambassador to Canada and the United States (Bechir); Wife of Ambassador (Niam); Wife of Chad\u0027s Deputy Chief of Mission Youssouf Hamid Takane. 2007-2015 (Saleh)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Asset Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty (between US and UK - for freeze of assets)","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the US Department of Justice press release, \u0022As alleged in the complaint, in 2009, Bechir and Takane agreed to use their official positions to influence the award of oil development rights in Chad to Griffiths Energy International Inc., a Canadian oil company, in exchange for shares in the company. \u00a0Thereafter, in or about October 2009, Griffiths Energy issued four million shares to the wives of Bechir and Takane and to another associate.\n\t\u00a0\n\tThe complaint further alleges that Griffiths Energy agreed with Bechir and his wife that the company would pay a $2 million \u201cconsulting fee\u201d to Bechir\u2019s wife to influence the award of oil development rights in Chad. \u00a0After securing the desired oil development rights in February 2011, Griffiths Energy allegedly transferred $2 million to an account held by a shell company created by Bechir\u2019s wife. \u00a0This bribe payment was commingled and laundered through U.S. bank accounts and real property, and eventually was transferred to Bechir\u2019s bank account in South Africa, where he is now serving as Chad\u2019s Ambassador. \u00a0In 2013, Griffiths Energy pleaded guilty in Canadian court to bribing Bechir.\n\t\u00a0\n\tThe $34 million that the United States seeks in forfeiture represents the cash value of the four million shares in Griffiths Energy that were provided to the wives of Bechir and Takane and to their associate. \u00a0In a separate action filed in 2014, the United States also is seeking the civil forfeiture of over $100,000 in allegedly laundered funds traceable to the $2 million bribe payment. \u00a0Takane resides in the United States.\u0022 (Source: US Department of Justice Press Release, \u0022Department of Justice Seeks Forfeiture of $34 Million in Bribe Payments to the Republic of Chad\u2019s Former Ambassador to the U.S. and Canada,\u0022 June 30, 2015.)\n\t\u00a0\n\tAccording to the civil asset forfeiture complaint in the case, the alleged bribery proceeds are held in accounts in the UK\u0027s Royal bank of Scotland in the name of Mrs. Niam and Mrs. Saleh, who have both filed claims, along with Ms. Niam\u0027s former attorney in Canada for unpaid fees arising out of canadian court proceedings, to the assets in the US District Court for the District of Columbia. \u00a0(Source: \u00a0US v. Approximately \u00a322 million in British Pounds representing the value of 4,000,000 shares of common stock in Caracal Energy Inc., formerly Griffiths Energy International, Inc., Case No. 1:15-cv-01018 (D.D.C.), Verfied Complaint filed June 30, 2015; Verfied Claim filed by Ms. NIam on August 14; Verified Claim filed by Mrs. Saleh on August 17; Verified Claim filed by CESPC.) \u00a0The Government of Chad also filed a claim on October 16, stating that the \u0022funds [were] paid wrongfully to representatives of Chad in an effort to obtain rights belonging to Chad.\u0022 \u00a0The Claim was signed by the Deputy General Secretary of the Republic of Chad. (Source: \u00a0US v. Approximately \u00a322 million in British Pounds representing the value of 4,000,000 shares of common stock in Caracal Energy Inc., formerly Griffiths Energy International, Inc., Case No. 1:15-cv-01018 (D.D.C.), Verified Claim filed by Government of Chad, at para 6, October 16, 2015; Answer by Government of Chad to Verified Claim, filed October 26, 2015). As of June 23, 2016, the case was ongoing.\u00a0","Disposition of Criminal Case(s)":"N\/A; Civil asset forfeiture case in US","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"US law firms representing Office of the President of the republic of Chad:  Stein Mitchell Cipollone Beato \u0026 Missner LLP; Hellring Lindeman Goldstein \u0026 Siegal LLP","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Kleptocracy Asset Recovery Initiative, Department Justice, Criminal Division\u2019s Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the District of Columbia","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths%20Energy%20Stock%20Forfeiture%20Case_PR_Jun30%202015_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths_Energy_Complaint_Jun30%202015_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths%20Energy%20Stock_Niam%20Claim_Aug%2014%202015_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths%20Energy%20Stock_Saleh%20Claim_Aug2015_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths%20Energy%20Stock_Rep%20of%20Chad%20Claim_Oct%202015_0.pdf","Sources ":"US Department of Justice Press Release, \u0022Department of Justice Seeks Forfeiture of $34 Million in Bribe Payments to the Republic of Chad\u2019s Former Ambassador to the U.S. and Canada,\u0022 June 30, 2015, at http:\/\/www.justice.gov\/opa\/pr\/department-justice-seeks-forfeiture-34-mil... Source: \u00a0US v. Approximately \u00a322 million in British Pounds representing the value of 4,000,000 shares of common stock in Caracal Energy Inc., formerly Griffiths Energy International, Inc., Case No. 1:15-cv-01018 (D.D.C.), Verified Complaint filed June 30, 2015, and accessed at http:\/\/www.justice.gov\/opa\/file\/624266\/download; Verfied Claim filed by Ms. NIam on August 14; Verified Claim filed by Mrs. Saleh on August 17; Verified Claim filed by CESPC; Verified Claim filed by Government of Chad, October 16, 2015; Aswer by Governmen of Chad fiiled October 26, 2015; Court Docket Report as of June 23, 2016.)\n"},{"Case ID":"ARW-30","Case Title (Name of Public Official or Entity Allegedly Involved)":"Carlos F. Garcia \/ Ian Carl and Juan Paulo Depakakibo Garcia (Northern California Case)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"Former Comptroller of the Philippine Armed Forces (Carlos Garcia, 1990-2004), Sons (Ian Carl and Juan Paulo Depakakibo)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location\/ Alleged Asset Location","Asset Recovery Start":"2003","Asset Recovery End":"2012","UNCAC Offenses Implicated":"Art.15, Art.17, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$100,000","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"One-hundred thousand dollars in U.S. currency had been seized from Ian Carl and Juan Paulo Depakakibo when they tried to enter the U.S. with the cash.  In January 2011, the U.S. District Court for the District of Northern California forfeited the confiscated funds to the U.S. Government. The brothers had agreed, as part of their plea, to forfeit the $100,000 seized from them at the time of their arrest on December 19, 2003.  (Source:  U.S. v. Ian Carl Depakakibo and Juan Paulo Depakakibo, Case No. 08-cr-00888-MHP (N.D. Cal.), Final Order of Forfeiture, filed January 7, 2011); U.S. Immigration and Customs Service Press Release, \u0022Sons of former Philippine military comptroller charged with bulk cash smuggling,\u0022 February 25, 2009.)   \nAccording to a June 3, 2015 statement by the Philippines Office of the Ombudsman, \u0022In January 2012, the United States government through then US Ambassador to the Philippines Harry Thomas, Jr. initially turned over to the Office of the Ombudsman $100,000, representing cash seized by U.S. Customs authorities from the two sons of  General Garcia upon their entry in California in December 2003, which seizure triggered the investigations into the transactions entered into by General Garcia.\u0022  (Source:  Office of the Ombudsman, \u0022US turns over $1.38M proceeds of Garcia\u2019s forfeited assets,\u0022 June 3, 2015.)","Disposition of Criminal Case(s)":"According to a June 3, 2015 statement by the Ombudsman of the Philippines, \u0022the Office of the Ombudsman filed criminal cases of perjury, money laundering and plunder against [Carlos] Garcia who eventually was convicted of perjury by the Sandiganbayan.\u00a0 In the last two criminal cases, Garcia pleaded to the lesser offenses of Indirect Bribery and Facilitating Money Laundering, which plea bargaining is the subject of review by the Supreme Court.\u00a0 Meanwhile, forfeiture proceedings are pending with the Sandiganbayan.\u0022\u00a0 (Source:\u00a0 Office of the Ombudsman, \u0022US turns over $1.38M proceeds of Garcia\u2019s forfeited assets,\u0022 June 3, 2015.)\nAccording to the April 5, 2005 Information against former Mr. Garcia, his wife Clarita Garcia and their sons Ian Carl, Juan Paulo and Timothy Mark D. Garcia, the Philippines Ombudsman\u0027s Office had charged them with committing the crime of Plunder.\u00a0 (Source:\u00a0 In the Matter of Extradition of Clarita Depakakibo Garcia, Case No. 2:09-mc-50231 (E.D. Mich.), Annex A to Extradition compaint filed on March 4, 2009).\u00a0 In November 2010, Ian Carl and Juan Paulo Depakakibo were sentenced to time served by U.S. District Court for the Northern District of California, subsequent to their guilty plea on bulk cash smuggling charge.\u00a0\u00a0 (Source: U.S. v. Ian Carl Depakakibo and Juan Paulo Depakakibo, Case No. 08-cr-00888-MHP (N.D. Cal.), Judgment in a Criminal Case, filed on December 1, 2010.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Ombudsman, Office of the Special Prosecutor","Jurisdiction of Origin: Courts Involved":"Sandiganbayan, Supreme Court (Third Division)","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Customs and Border Protection, San Francisco International Airport","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Northern District of California","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the Northern District of California","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Gacria_US_SDNY_Asset%20Return_USEmbassy%20Manila%20Press_Jun3_2015_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Garcia_US%20Asset%20Return_Phil%20Ombudsman_statement_Jun3_2015_1.pdf","Sources ":"U.S. v. Ian Carl Depakakibo and Juan Paulo Depakakibo, Case No. 08-cr-00888-MHP (N.D. Cal.), Indictment filed on December 9, 2008; Order Granting Motion for Preliminary Order of Forfeiture, filed on November 2, 2010; Judgment in a Criminal Case, filed on December 1, 2010; and Final Order of Forfeiture filed January 7, 2011.  See also, U.S. Immigration and Customs Service Press Release, \u0022Sons of former Philippine military comptroller charged with bulk cash smuggling,\u0022 February 25, 2009, accessed at http:\/\/www.ice.gov\/news\/releases\/0902\/090225sanfrancisco.htm; U.S. Department of Justice Press Release, \u0022Sons of Former Philippine General Plead Guilty to Bulk Cash Smuggling,\u0022 September 9, 2010, accessed at http:\/\/www.justice.gov\/usao\/can\/press\/2010\/2010_09_09_garcias.guiltyplea....  Philippines Complaint and Arrest Warrant in the Plunder case, included as Annex A in extradition complaint filed on March 4, 2009, In the Matter of Extradition of Clarita Depakakibo Garcia, Case No. 2:09-mc-50231 (E.D. Mich.)\nUS Embassy Manila, \u0022U.S. Helps Philippines Recover \u0027Ill-Gotten Gains\u0027\u201d, June 3, 2015, athttp:\/\/manila.usembassy.gov\/press-photo-releases-2015\/us-helps-philippin... Office of the Ombudsman, \u0022US turns over $1.38M proceeds of Garcia\u2019s forfeited assets,\u0022 June 3,2015, at http:\/\/www.ombudsman.gov.ph\/index.php?home=1\u0026pressId=NjU3\n"},{"Case ID":"ARW-239","Case Title (Name of Public Official or Entity Allegedly Involved)":"Gulnara Karimova \/ Swiss asset recovery case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Uzbekistan","Position of Public Official(s) (yrs in office)":"Permanent Representative of Uzbekistan to UN Mission in Geneva; daughter of President of Uzbekistan","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort; Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2012","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal prosecution and forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to a press statement by the Public Ministry of the Swiss Confederation, a criminal investigation had been launched against Ms. Gulnara Karimova, the daughter of the Uzbek president, on suspicion of money laundering. \u00a0The Ministry stated that it had commenced its criminal investigation in July 2012 following a communication from the Reporting Office for Money Laundering (MROS), initially against four Uzbek nationals alleged to be involved in corrupt activities in the Uzbek telecom sector. \u00a0 Over 800 million Swiss francs were frozen in Switzerland. \u00a0As part of its investigation, the Public Ministry has sent legal requests for assistance to several countries and is the source of several searches in France which took place during the summer of 2013 and triggered on-site investigations. Furthermore, based on a mutual legal assistance request by Switzerland, the Swedish prosecution authorities have also taken action by opening a corruption investigation in connection with various acquisitions of a Swedish company on the Uzbek telecommunications market. \u00a0In late August 2013, the Ministry searched, with the help of the Federal Judicial Police and the Geneva police, Ms. Karimova\u0027s villa in Geneva to gather new evidence. \u00a0The statement also noted that in her capacity as Permanent Representative of Uzbekistan to the United Nations and other international organizations in Geneva, Ms. Karimova had benefited from diplomatic immunity until last summer.\u0022 \u00a0 (Source: \u00a0Minist\u00e8re public de la Conf\u00e9d\u00e9ration, \u0022La fille du pr\u00e9sident ouzbek dans la ligne de mire de la justice suisse,\u0022 March 14, 2014; See also, Swiss Office of Federal Police Annual Report 2014, at 29.)","Disposition of Criminal Case(s)":"According to a press statement by the Swiss Public Ministry, the money laundering investigation against Ms. Karimova was initiated in 2013. (Source: \u00a0Minist\u00e8re public de la Conf\u00e9d\u00e9ration, \u0022La fille du pr\u00e9sident ouzbek dans la ligne de mire de la justice suisse,\u0022 March 14, 2014)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Minist\u00e8re public de la Conf\u00e9d\u00e9ration; Office of Federal Police; Geneva authorities; Money Laundering Reporting Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Karimova_Swiss%20News%20Admin_Freeze%20Assets_Mar12%202014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Swiss%20Federal%20Police%20Annual%20Report%202014_Pub%20May%202015_0.pdf","Sources ":"Minist\u00e8re public de la Conf\u00e9d\u00e9ration, \u0022La fille du pr\u00e9sident ouzbek dans la ligne de mire de la justice suisse,\u0022 March 14, 2014, at https:\/\/www.news.admin.ch\/message\/index.html?lang=fr\u0026msg-id=52278\n\t\u00a0\n\t\u00a0\n\tSwiss Office of Federal Police Annual Report 2014, at 29, at http:\/\/www.ejpd.admin.ch\/dam\/data\/fedpol\/publiservice\/publikationen\/beri...\n"},{"Case ID":"ARW-234","Case Title (Name of Public Official or Entity Allegedly Involved)":"Petrobras \/ Swiss asset return","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Brazil","Position of Public Official(s) (yrs in office)":"Unnamed senior executives of Petrobras","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort; Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"2015, In part","UNCAC Offenses Implicated":"Art.15, Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal forfeiture; Settlement agreement with account holders","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"MLAT","Contributing Factors in Asset Recovery":"Ongoing, but the Swiss Office of the Attorney General stated that, \u0022The Brazilian bribery scandal affects Switzerland\u0027s financial centre and its anti-money-laundering strategy, with result that the OAG has a close interest in contributing fully to the resolution of the scandal through its own investigations. Attorney General Lauber therefore discussed opportunities for mutual support in the ongoing criminal proceedings with his counterpart, Mr Janot.\u0022 (Source:  Office of the Attorney General of Switzerland, \u0022Petrobras scandal: USD 120 million released to Brazil, March 18, 2015.)","Status of Asset Recovery ":"Completed (in part) and Ongoing (in part)","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction (in part), Investigation\/Asset Tracing\/Asset Restraint (in part)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"Petrobras is majority owned by the Federal Government of Brazil. (Source: \u00a0Petrobras, Corporate Governance, \u0022Capital Ownership Composition,\u0022 at http:\/\/www.investidorpetrobras.com.br\/en\/ corporate-governance\/capital-ownership, last accessed September 14, 2015.) \u00a0\n\t\u00a0\n\tIn March 2016, the Office of the Attorney General (OAG) of Switzerland announced plans to unblock additional US$70 million and return the Petrobras related assets to Brazil: \u00a0\u0022So far the OAG has received reports of around 340 suspicious banking relations from the Money Laundering Reporting Office (MROS) in relation to the international corruption affair involving the semi-state-owned Brazilian company Petrobras. In response, the OAG has since April 2014 opened some 60 investigations on suspicion of aggravated money laundering (Art. 305bis Sec. 2 Swiss Criminal Code (SCC)) and in numerous cases on suspicion of bribery of foreign public officials (Art. 322septies SCC). The OAG has requested the handover of documents relating to over 1,000 banking accounts from over 40 banking institutions. In view of the complexity of the investigations, a task force made up of various specialists from the OAG and supported by fedpol is conducting the proceedings. Two of the investigations opened by the OAG have been taken over by the Brazilian authorities and have already led to charges in Brazil. The OAG plans to request the Brazilian authorities to take over other investigations that have been opened in Switzerland.\n\t\u00a0\n\tIn the course of these 60 investigations, around USD 800 million of assets held in Switzerland have been frozen. In spring 2015, USD 120 million of these assets were unblocked with the consent of the account holders concerned and arrangements made for the assets to be returned to the parties who have incurred related losses.\n\t\u00a0\n\tThe beneficial owners of the Swiss accounts, for the most part ostensibly held by domiciliary companies, are senior executives of Petrobras and of its suppliers, financial intermediaries, Brazilian politicians and directly or indirectly Brazilian or other foreign companies.\u0022 \u00a0(Source: \u00a0 Office of the Attorney General of Switzerland media release, \u0022Petrobras affair: Further USD 70 million of frozen assets to be unblocked and returned to Brazil,\u0022 March 17, 2016.)","Disposition of Criminal Case(s)":"In March 2016, the Office of the Attorney General (OAG) of Switzerland announced that \u0022So far the OAG has received reports of around 340 suspicious banking relations from the Money Laundering Reporting Office (MROS) in relation to the international corruption affair involving the semi-state-owned Brazilian company Petrobras. In response, the OAG has since April 2014 opened some 60 investigations on suspicion of aggravated money laundering (Art. 305bis Sec. 2 Swiss Criminal Code (SCC)) and in numerous cases on suspicion of bribery of foreign public officials (Art. 322septies SCC). (Source: \u00a0Office of the Attorney General of Switzerland media release, \u0022Petrobras affair: Further USD 70 million of frozen assets to be unblocked and returned to Brazil,\u0022 March 17, 2016.)","Jurisdiction of Origin: Investigative Agency":"Attorney General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General\u0027s Office","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Office of the Attorney General (OAG) of Switzerland; Money Laundering Reporting Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Office of the Attorney General (OAG) of Switzerland","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Petrobras_Swiss_OAG_Asset%20Return_Mar2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Petrobras_Swiss_discussion_unblock%20additional%2070m_Mar2016.pdf","Sources ":"Petrobras website, \u0022Capital Ownership Composition,\u0022 at http:\/\/www.investidorpetrobras.com.br\/en\/corporate-governance\/capital-ow..., last accessed September 14, 2015);\n\t\u00a0\n\tOffice of the Attorney General of Switzerland media releases, \u0022Petrobras affair: Further USD 70 million of frozen assets to be unblocked and returned to Brazil,\u0022 March 17, 2016, at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=61034; \u00a0\u0022Petrobras scandal: USD 120 million released to Brazil, March 18, 2015; at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=56605.\n"},{"Case ID":"ARW-232","Case Title (Name of Public Official or Entity Allegedly Involved)":"Unnamed Uzbek \u0022Government Official A\u0022\/ Mobile Telesystems and Vimpelcom Telecom Case (US)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Uzbekistan","Position of Public Official(s) (yrs in office)":"\u0022Several Positions\u0022 in Uzbek Government, including during 2005-2011; a \u0022relative of the President of Uzbekistan\u0022","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location","Asset Recovery Start":"2015","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty (by United States with Uzbekistan and Switzerland)","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the US Department of Justice Press Release in the FCPA case against VimpelCom, \u0022The department has also filed two civil complaints seeking a total of $850 million in forfeiture. A complaint filed today seeks forfeiture of approximately $550 million in proceeds of illegal bribes paid, or property involved in the laundering of those payments, to the Uzbek official by VimpelCom and two other telecommunications companies operating in Uzbekistan. The $550 million is currently located in Swiss bank accounts. The department also filed a prior complaint seeking forfeiture of an additional $300 million in proceeds of illegal bribes paid, or property involved in the laundering of those payments, to the same Uzbek official. The assets sought to be forfeited in that complaint are restrained in Belgium, Luxembourg and Ireland. In that case, on Jan. 11, 2016, the U.S. District Court for the Southern District of New York entered a partial default judgment against all potential claimants other than the Republic of Uzbekistan.\n\t\tAs alleged in the complaints and as is part of the criminal resolutions announced today, the telecom companies paid a total of more than $800 million in bribes so that the Uzbek official would assist VimpelCom and other telecommunications companies in obtaining and retaining business in Uzbekistan. Thereafter, the official\u2019s associates laundered the corruption proceeds through accounts held in Latvia, the United Kingdom, Hong Kong, Ireland, Belgium, Luxembourg and Switzerland. The illicit funds were transmitted through financial institutions in the United States before they were deposited into accounts in these countries, thereby subjecting them to U.S. jurisdiction.\u0022 \u00a0(Source: US Department of Justice Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million\u037e United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016.) \u00a0As of June 27, 2016, the case against assets held in accounts belonging to First Global is stayed, pending settlement discussions by the Department of Justice and involved parties. (US v. All Assets Held in Accounts [belonging to First Global], Case No. 15-cv-05063 (SDNY), Stipulation filed April 27, 2016 and Court Docket Report as of June 26, 2016.) while a partial default judgment motion was filed in late June 2016 in case against assets held on behalf of Takilant Limited and Tozian Limited. (Source: \u00a0US v. All Funds Held in accounts at Lombard Odier Darier Hentsch and Cie Bank et al, Case No. 16-cv-01256 (SDNY), Partial Default Judgment motion filed June 23, 2016.)\n\u00a0","Disposition of Criminal Case(s)":"According to the US Department of Justice complaint filed in the case, Gayane Avakyan and Rustan Madumarov, close associates of \u0022Government Official A\u0022 were arrested in 2014 and subsequently convicted and of multiple criminal offenses in relation to the case and sentenced to prison terms. \u00a0(Source: \u00a0US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015, paragraphs 18-19; See also, US v. All Assets Held in Accounts [by First Global Accounts, Case No. 15-cv-05063 (SDNY), January 26, 2016.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"Tashkent Regional Criminal Court in the Republic of Uzbekistan","Jurisdiction of Asset Recovery: Investigative Agency":"Internal Revenue Service (Criminal Investigations and Global Illicit Financial team); Immigration and Customs Enforcement, DHS","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"DOJ Criminal Division\u0027s Asset Forfeiture and Money Laundering Section, Kleptocracy Asset Recovery Initiative","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the Southern District of New York","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Uzbek_Telecom_Verified_Complaint_Jun2015_4-1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Uzbek_Telecom_SDNY_DOJ_Letter_Request_Arrest%20in%20Rem_Jul1_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Uzbek_Telecom_SDNY_Order_Arrest%20in%20rem_Doc5.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Uzbek_Telecom_SDNY_Order_Arrest%20in%20rem_Doc6.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Uzbek_Telecom_SDNY_Order_Arrest%20in%20rem_Doc7.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Uzbek_Ltr_Uzbek%20Govt%20Counsel_Doc16-main.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Uzbek_Min%20Justice%20Ltr_Doc%2016-1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Uzbek_Partial%20Default%20Judgment_Jan2016.pdf","Sources ":"US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015; \u00a0Letter dated July 1, 2015 by Department of Justice to the Court; Orders issued for Arrest Warrant in rem, filed July 9, 2015; Letter by Uzbek Minister of Justice filed January 4, 2016 and Partial Default Judgment filed January 11, 2016; Stipulation filed April 27, 2016 and Court Docket Report as of June 27, 2016; Related case: US v. All Funds Held at accounts [held at Lombard Odier Darier Hentsch and Cie Bank and Union Bancaire Privee of Switzerland on behalf of Takilant Limited and Tozian Limited, Case No. 16-cv-01257 (SDNY), Verified Complaint filed on February 18, 2016, at https:\/\/www.justice.gov\/opa\/file\/826636\/download; Court Docket Report as of June 27, 2016.\n"},{"Case ID":"ARW-231","Case Title (Name of Public Official or Entity Allegedly Involved)":"Lansana Conte \/ Mamadie Toure","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"","Position of Public Official(s) (yrs in office)":"President (Conte: 1984-2008, deceased), First Lady (Toure: 2000-2008)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location\/Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.18, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"Unknown amount","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"In February 2016, Ms. Toure and the US authorities entered into a settlement agreement whereby Ms. Toure acknowledged that the defendant properties were proceeds of criminal conduct, namely bribery, as alleged in the forfeiture complaint. \u00a0Ms. Toure agreed to forfeit the Pierce Arrow and Fern Hammock properties and the restaurant equipment while the US dismissed without prejudice its claim against the Yacht Basin Property. \u00a0A Consent Order of Forfeiture was filed in April 2016. \u00a0(Source: US v. Real Property located at 4866 Yacht Basin Drive, et al, Case No. 3:14-cv-01428 (M.D. Fla), Settlement Agreement filed February 1, 2016 and Consent Order for Judgment of Forfeiture filed April 4, 2016.)\n\u00a0\nIn May 2015, an order for interlocutory sale of substitute property and judgment of forfeiture was granted for the restaurant \u00a0located at 132 Everest Lane, Suite 1, St. Johns, St. Johns County, Florida, 32259, and an adjacent restaurant, located at 164 Everest Lane, Suite 5, St. Johns, St. Johns County, Florida, 32259 and related equipment. \u00a0The government requested the sale, in part because the restaurant\u0027s \u0022value is fast depreciating. \u00a0The Verified Complaint alleges that the Defendant Restaurant and Market Equipment was purchased for approximately $278,000 in 2013. \u00a0The United States\u2019 appraisal valued the property at less than one-third that amount \u2013 approximately $87,000 \u2013 in January, 2015. \u00a0Waiting to sell the property will only result in further deterioration of its value.\u0022 (Sources: Order for Interlocutory Sale and Judgment of Forfeiture filed May 7, 2015 and Consent Motion filed May 4, 2015, in US v. Real Property located at 4866 Yacht Basin Drive, et al, Case No. 3:14-cv-01428 (M.D. Fla).\u00a0\n\u00a0\nAccording to the Complaint in US v. Real Property located at 4866 Yacht Basin Drive, et al, the US is seeking to forfeit three real properties and restaurant and market equipment located in Jacksonville, Florida. \u00a0The US Department of Justice Complaint states that Ms. Toure admitted to receiving at least $5.3 million in bribery payments from a foreign mining corporation to influence her husband\u0027s decision as to the granting of Simandou project mining rights. \u00a0The complaint alleges that the properties that are being sought to be forfeited were paid with the bribery proceeds and are being held by or for the benefit of Ms. Toure, including through Florida incorporated entities. (Source: US v. Real Property located at 4866 Yacht Basin Drive, et al, Case No. 3:14-cv-01428 (M.D. Fla), Verified Complaint filed November 21, 2014; Amended Verified Complaint filed March 18, 2015.)","Disposition of Criminal Case(s)":"Mr. Conte passed away in 2008. \u00a0There appears to be no criminal proceedings against Ms. Toure.\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the Middle District of Florida","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Toure_US_Asset_Forfeit_Complaint_Nov_21_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Toure_MDFLA_Amended%20Complaint_Mar2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Toure_Consent%20Motion_May4%202015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Toure_MDFLA_Order%20Interlocutory%20Sale%20and%20Judgment_May2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Toure_US_MDFLA_Status%20Report_Jul30_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Toure_MDFLA_Settlement%20Agreement_02012016.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Toure_MDFLA_Consent%20Order%20Forfeiture_April2016.pdf","Sources ":"US v. Real Property located at 4866 Yacht Basin Drive, et al, Case No. 3:14-cv-01428 (M.D. Fla), Verified Complaint filed November 21, 2014; Amended Verified Complaint filed March 18, 2015;Order for Interlocutory Sale and Judgment of Forfeiture filed May 7, 2015; Settlement Agreement filed February 1, 2016 and Consent Order for Judgment of Forfeiture filed April 4, 2016; Court Docket Report as of June 27, 2016.\n"},{"Case ID":"ARW-233","Case Title (Name of Public Official or Entity Allegedly Involved)":"Tomas Yarrington \/ Pablo Zarate Juarez","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mexico","Position of Public Official(s) (yrs in office)":"Yarrington: Former Mayor of Matamoros, Mexico (1992- 1995); Governor of Tamaulipas state (1999-2004); Presidential candidate (2005); Zarate: former political appointee Director of Instituto Tamaulipeco De Vivienda Y Urbanismo (ITAVU)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort; Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Forfeiture; Non-Conviction Based Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"The indictment filed in March 2015, in the US District Court for the Southern District of Texas, against Mr. Zarate contains forfeiture allegations: 1) 2005 Pilatus aircraft (Tail #N679PE) and a personal monetary judgment of US $2 million which the US Government alleges are the proceeds of his corruption while he was the director of the Instituto Tamaulipeco De Vivienda Y Urbanismo (ITAVU) in the State of Tamaulipas, Mexico. \u00a0ITAVU is the Tamaulipas Institute for Housing and Urban Development. Zarate Juarez was appointed to the position of director of ITAVU by former Tamaulipas Governor Tomas Yarrington Ruvalcaba. ITAVU is the department in Tamaulipas responsible for supporting lower income residents with housing programs and financing programs. The plane is also subject of civil forfeiture action filed in the case of former governor Tomas Yarrington. \u00a0(Sources: United States Attorney\u0027s Office for the Southern District of Texas, \u0022Former Mexican Governor\u2019s Political Appointee Indicted,\u0022 March 12, 2015, at http:\/\/www.fbi.gov\/houston\/press-releases\/2015\/former-mexican-governors-... US v. Zarate, Case No. 2:15-cr-216 (S.D. Tex), Indictment filed March 11, 2015).","Disposition of Criminal Case(s)":"Mr. Pablo Zarate Juarez is under indictment in the US on charges of money laundering, bank fraud and attempt and conspiracy to commit mail fraud. (Source: US v. Zarate, Case No. 2:15-cr-216 (S.D. Tex), Indictment filed March 11, 2015).","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Organized Crime Drug Enforcement Task Force investigation conducted in San Antonio, Brownsville, Houston and Corpus Christi by the Drug Enforcement Administration, Homeland Security Investigations, Internal Revenue Service - Criminal Investigation and the Texas Attorney General\u2019s Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney\u0027s Office for the Southern District of Texas","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the Southern District of Texas","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_Arrest_West_Palm_Beach_Post_Jun_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_Extradition_Approved_Hotnews.com_Mar_2_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_Extradition_US_Embassy_Press_Release_Apr_20_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_ICE_Senate_Testimony_Feb_4_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_Interpol_Arrest_Press_Release_Jun_19_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Nicolaiciuc_MDFLA_Extradition_Certification_Mar_1_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Zarate_US_Indictment_FBI_PR_Mar_12_2015.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_Arrest_West_Palm_Beach_Post_Jun_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_Extradition_Approved_Hotnews.com_Mar_2_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_Extradition_US_Embassy_Press_Release_Apr_20_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_ICE_Senate_Testimony_Feb_4_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_Interpol_Arrest_Press_Release_Jun_19_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Nicolaiciuc_MDFLA_Extradition_Certification_Mar_1_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Zarate_SDTex_Indictment_Mar_11_2015.pdf","Sources ":"United States Attorney\u0027s Office for the Southern District of Texas, \u0022Former Mexican Governor\u2019s Political Appointee Indicted,\u0022 March 12, 2015, at http:\/\/www.fbi.gov\/houston\/press-releases\/2015\/former-mexican-governors-...\n\t\u00a0\n\tUS v. Zarate, Case No. 2:15-cr-216 (S.D. Tex), Indictment filed March 11, 2015;\n\t\u00a0\n\tSee related case, Tomas Yarrington.\n\t\u00a0\n"},{"Case ID":"ARW-236","Case Title (Name of Public Official or Entity Allegedly Involved)":"Qiao Jian Jun \/ Zhao Shilan","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"China","Position of Public Official(s) (yrs in office)":"Qiao: Director of government grain storage facility in Central China; Zhao: Ex-wife of Qiao","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort; Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2015","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"US \u0022Investigators also acknowledge the assistance provided by the Supreme People\u0027s Procuratorate and Ministry of Public Security of the People\u0027s Republic of China.\u0022  (Source: US Attorney\u0027s Office for the Central District of California, \u0022Fugitive Chinese Official And Former Wife Named In Grand Jury Indictment Charging Immigration Fraud And Money Laundering,\u0022 March 17, 2015)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to a press release by the United States Attorney\u0027s Office for the Central District of California, \u0022the indictment also alleges that Qiao engaged in fraudulent grain transactions while serving as the grain storehouse director, and Qiao and Zhao had money transferred out of China, with approximately $500,000 being used to purchase the [Seattle suburb] Newcastle property.\u0022 \u00a0 Ms. Zhao was arrested in March 2015 in the U.S. \u00a0Mr. Qiao is a fugitive. (Source: US Department of Justice, \u0022Fugitive Chinese Official And Former Wife Named In Grand Jury Indictment Charging Immigration Fraud And Money Laundering,\u0022 March 17, 2015)","Disposition of Criminal Case(s)":"According to a press release by the United States Attorney\u0027s Office for the Central District of California, Mr. Qiao and Ms. Zhao are \u0022charged in a federal grand jury indictment unsealed today with conspiracy to commit immigration fraud and international transport of stolen funds, as well as conspiracy to commit money laundering. Zhao is additionally charged with one count of immigration fraud.\u0022 (Source: \u00a0US Department of Justice, \u0022Fugitive Chinese Official And Former Wife Named In Grand Jury Indictment Charging Immigration Fraud And Money Laundering,\u0022 March 17, 2015)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Immigration and Customs Enforcement\u2019s (ICE) Homeland Security Investigations (HSI) and Internal Revenue Service - Criminal Investigation, which received assistance from U.S. Citizenship and Immigration Services","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney\u0027s Office for the Central District of California","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Central District of California","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aleman_Nicaragua_SCt_Overturn_Conviction_Jurist_Jan_19_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aleman_Nuevo_Diario_July_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aleman_Panama_SCt_Canal15_Dec_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aleman_Panama_World-check_Jul_23_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Qiao_Zhao_US_Indictment_DOJ_PR_Mar_17_2015.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aleman_Nicaragua_SCt_Overturn_Conviction_Jurist_Jan_19_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aleman_Nuevo_Diario_July_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aleman_Panama_SCt_Canal15_Dec_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aleman_Panama_World-check_Jul_23_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Qiao_Zhao_US_Indictment_The%20Seattle%20Times_Mar_17_2015.pdf","Sources ":"US Department of Justice, \u0022Fugitive Chinese Official And Former Wife Named In Grand Jury Indictment Charging Immigration Fraud And Money Laundering,\u0022 March 17, 2015, at http:\/\/www.justice.gov\/usao\/cac\/Pressroom\/2015\/028.html;\n\t\u00a0\n\tSanjay Bhatt, \u0022Newcastle woman charged with fraud in immigrant-investor visas,\u0022 The Seattle Times, March 17, 2015, at http:\/\/www.seattletimes.com\/business\/real-estate\/newcastle-woman-charged....\n"},{"Case ID":"ARW-229","Case Title (Name of Public Official or Entity Allegedly Involved)":"Viktor Yanukovych \/ Austria","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"President (2010-2014)","Jurisdiction of Asset Recovery":"Austria","Jurisdiction of Asset Description":"Location of Recovery Effort","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to a February 2014 press statement by the Austrian Federal Ministry, Austria imposed a freeze on accounts of eighteen individuals: Mr. Yanukovych, his son and top members of his government. \u00a0The statement noted that Austria had taken the step at the request of the Ukrainian government as the EU was considering sanctions against these individuals, so as to prevent the assets from being withdrawn from the country. \u00a0(Source: \u00a0Austrian Federal Ministry, \u0022APA: \u00d6sterreich friert heimische Konten von 18 Ukrainern ein \/ Auf Ersuchen der neuen Regierung in Kiew - Hintergrund sind m\u00f6gliche Menschenrechtsverletzungen und Korruptionsverdacht,\u0022 February 28, 2014; See also \u00a0\u0022Statement on Ukraine by Federal Minister Sebastian Kurz at the plenary session of the Austrian Parliament, 24.2.2014,\u0022 and Austrian Financial Market Authority Press Release, \u0022FMA draws attention to enhanced customer due diligence in the context of business relationships with politically exposed persons from Ukraine,\u0022 February 21, 2014.). \u00a0 The National Bank of Austria Regulation DevG 1\/2014 lists the individuals. (Source: \u00a0Stolen Asset Recovery Initiative, Asset Recovery Actions for Ukraine, at http:\/\/star.worldbank.org\/star\/sites\/star\/files\/verordnung_devg_1-2014fi...)","Disposition of Criminal Case(s)":"According to the INTEROL wanted list, Mr. Yanukovych is \u0022Wanted by the Judicial Authorities of Ukraine for Prosecution \/ to serve a sentence\u0022 with the following charges listed: \u0022Misappropriation, embezzlement or conversion of property by malversation, if committed in respect of an especially gross amount, or by an organized group.\u0022 \u00a0(Source: INTERPOL, \u0022Viktor Yanukovych,\u0022 at http:\/\/www.interpol.int\/notice\/search\/wanted\/2014-13031 (last accessed January 21, 2015).\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_Interpol_Wanted_List_Jan_21_2015_2.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_Austria_Asset_Freeze_Fed_Min_Speech_Feb_24_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_Austria_Natl_Bank_Sanctions_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_Austria_FMA_EDD_Notice_Feb_21_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_Austria_Asset_Freeze_Fed_Min_PR_Feb_28_2014.pdf","Sources ":"\n\tAustrian Federal Ministry, \u0022APA: \u00d6sterreich friert heimische Konten von 18 Ukrainern ein \/ Auf Ersuchen der neuen Regierung in Kiew - Hintergrund sind m\u00f6gliche Menschenrechtsverletzungen und Korruptionsverdacht,\u0022 February 28, 2014, at http:\/\/www.bmeia.gv.at\/das-ministerium\/presse\/aussendungen\/2014\/apa-oest... and \u0022Statement on Ukraine by Federal Minister Sebastian Kurz at the plenary session of the Austrian Parliament, 24.2.2014,\u0022 at http:\/\/www.bmeia.gv.at\/en\/the-ministry\/press\/speeches-and-interviews\/201...\n\n\t\u00a0\n\n\tNational Bank of Austria Regulation DevG 1\/2014, at http:\/\/star.worldbank.org\/star\/sites\/star\/files\/verordnung_devg_1-2014fi...\n\n\t\u00a0\n\n\tAustrian Financial Market Authority Press Release, \u0022FMA draws attention to enhanced customer due diligence in the context of business relationships with politically exposed persons from Ukraine,\u0022 February 21, 2014, at https:\/\/www.fma.gv.at\/fileadmin\/media_data\/1_Ueber_die_FMA\/3_Presse\/1_Pr...\n\n\t\u00a0\n"},{"Case ID":"ARW-230","Case Title (Name of Public Official or Entity Allegedly Involved)":"Viktor Yanukovych \/ European Union","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"President (2010-2014)","Jurisdiction of Asset Recovery":"European Union","Jurisdiction of Asset Description":"Location of Recovery Effort","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"","Money laundering Implicated":"","Legal Basis for Asset Recovery":"","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the European Council Council Regulation (EU) No 208\/2014 of 5 March 2014 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Ukraine, the EU has imposed an asset freeze against a total of 18 individuals including the former President Yanjukovych, senior members of his government, associates and family members. \u00a0(Source: \u00a0European Council Council Regulation (EU) No 208\/2014 of 5 March 2014 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Ukraine; See also, The Guardian, \u0022Ukraine: EU freezes assets of Yanukovych\u0027s former hierarchy,\u0022 March 5, 2014.)","Disposition of Criminal Case(s)":"According to the INTEROL wanted list, Mr. Yanukovych is \u0022Wanted by the Judicial Authorities of Ukraine for Prosecution \/ to serve a sentence\u0022 with the following charges listed: \u0022Misappropriation, embezzlement or conversion of property by malversation, if committed in respect of an especially gross amount, or by an organized group.\u0022 \u00a0(Source: INTERPOL, \u0022Viktor Yanukovych,\u0022 at http:\/\/www.interpol.int\/notice\/search\/wanted\/2014-13031 (last accessed January 21, 2015).\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_Interpol_Wanted_List_Jan_21_2015_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_EU_Council_Reg_208_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_EU_Asset_Freeze_The%20Guardian_Mar_2014.pdf","Sources ":"Council Regulation (EU) No 208\/2014 of 5 March 2014 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Ukraine, at http:\/\/eur-lex.europa.eu\/legal-content\/EN\/TXT\/?uri=CELEX:32014R0208; \u00a0he Guardian, \u0022Ukraine: EU freezes assets of Yanukovych\u0027s former hierarchy,\u0022 March 5, 2014, at http:\/\/www.theguardian.com\/world\/2014\/mar\/06\/ukraine-eu-freezes-assets-y...\n"},{"Case ID":"ARW-225","Case Title (Name of Public Official or Entity Allegedly Involved)":"Carlos Fragoso","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mozambique","Position of Public Official(s) (yrs in office)":"National Director, National Directorate of Roads and Bridges (1997-1999); President of the Board of Directors, National Roads Administration (1999-2003)","Jurisdiction of Asset Recovery":"Jersey","Jurisdiction of Asset Description":"Location of Recovery Effort; Asset Location\/Alleged Asset Location","Asset Recovery Start":"2010","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Asset Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Judgment held that the trustee of a Trust Fund held the funds deemed to be illicit proceeds as constructive trustee for the Government of Mozambique, stating in part that \u0022there are important reasons of policy for this Court to follow [the UK Privy Court decision in Attorney General for Hong Kong v.] Reid, namely the need to deter fraud and corruption and to have the ability to strip fiduciaries who have channelled their illicit funds through this jurisdiction of all benefits.\u0022  (Source: Lloyds Trust Co. (CI) Ltd. v. Fragoso and others, [2013] JRC 211, para 28.)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"$645,182 (Value of trust as of October 31, 2013 Judgment)","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"","Case Summary":"According to the October 31, 2013 Judgment by the Isle of Jersey Royal Court in Lloyds Trust Co (Channel Islands) Ltd. v. Fragoso, Hoy, Government of Mozambique and HM Attorney General {[2013] JRC 211), the funds held in The Rex Trust formed by Mr. Fragoso was ordered to be paid to the Government of Mozambique. \u00a0 In so doing, the Court held that Lloyds Trust Co as the trustee of the Rex Trust held the funds as constructive trustee for the Government of Mozambique. \u00a0As described in the Judgment, the Trust was established in 1999 by Mr. Fragoso who had described himself as a civil engineer and he informed the Lloyds TSB Offshore Trust Limited that the funds settled into the Trust were the proceeds of civil engineering consultancy contracts. \u00a0\u0022He did not disclose that he held public office in Mozambique.\u0022 (para 3) \u00a0In 2010, Lloyds Trust became aware of the conviction of the UK engineering firm Mabey \u0026 Johnson on charges of foreign bribery and that the Prosecution\u0027s Opening Statement included mention of bribes paid by the company to Mr. Fragoso in 1997 and 2000. \u00a0In 2010, Lloyds filed a Suspicious Activity Report to the Jersey Financial Crimes Unit and informed Mr. Fragoso of its concerns and \u0022required him to provide evidence as to the source of the funds, and specifically, that the funds were not the proceeds of crime.\u0022 (para 6). \u00a0Lloyds, joined by the Government of Mozambique, sought an order from the Jersey Royal Court that the trust fund, net of costs, be paid to the Government of Mozambique. \u00a0The Court held that \u0022It is true that it is not possible to trace all of the funds within the Trust back to Mabey \u0026 Johnson, but we find that, on the balance of probabilities, all of the funds within the Trust represent bribes received by Mr. Fragoso in his role as a public officer for Mozambique\u0022 including for the reasons that he lied to Lloyds as to his occupation and source of funds when the Trust was established and his inability to produce any evidence as to the source of the remaining funds within the Trust which cannot be traced back to Mabey \u0026 Johnson and that his legitimate source of income during the material period was his salary [which according to the information provided by the Government of Mozambique was equivalent to 1,500 Euros per month] (paras 12 and 18). \u00a0","Disposition of Criminal Case(s)":"Unknown","Jurisdiction of Origin: Investigative Agency":"National Roads Administration","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Jersey Financial Crimes Unit","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"Royal Court (Samedi Division)","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Fragoso_Jersey_Lloyds_Constructive_Trust_2013_JRC_211.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Fragoso_Jersey-Court-Endorses-Proprietary-Claim-to-Proceeds-of-Corruption_Baker_Partners.pdf","Sources ":"Bet. Lloyds Trust Company (Channel Islands) Limited and Carlos Fragoso and others, [2013] JRC 211, at http:\/\/www.jerseylaw.je\/judgments\/unreportedjudgments\/documents\/display....(CI)_Ltd_211.htm;\n\t\u00a0\n\tBaker \u0026 Partners, \u0022Jersey Court Endorses Proprietary Claim to Proceeds of Corruption in re: the Representation of Lloyds TSB Offshore Trust Company Limited,\u0022 (undated), at http:\/\/www.bakerandpartners.com\/media\/18948\/Jersey-Court-Endorses-Propri...\n"},{"Case ID":"ARW-226","Case Title (Name of Public Official or Entity Allegedly Involved)":"Mario Roberto Zelaya Rojas","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Honduras","Position of Public Official(s) (yrs in office)":"Executive Director, Honduran Institute of Social Security (2010-2014)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Alleged Asset Location\/Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.19, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"","Case Summary":"According to the US Department of Justice (DOJ) Press Release, \u0022From 2010 to 2014, Dr. Mario Roberto Zelaya Rojas, 46, of Tegucigalpa, Honduras, served as the Executive Director of the Honduran Institute of Social Security (HISS), a Honduran Government agency that provides social security services, including workers\u2019 compensation, retirement, maternity, and death benefits. \u00a0According to allegations in the forfeiture complaint, Zelaya solicited and accepted $2.08 million in bribes from Compania De Servicios Multiples, S. de R. L. (COSEM) in exchange for prioritizing and expediting payments owed to COSEM under a $19 million contract with HISS. \u00a0Zelaya also allegedly instructed COSEM to make bribe payments to two members of the Board of Directors of HISS charged with overseeing the COSEM contract. \u00a0To conceal the illicit payments, COSEM allegedly sent the bribes through its affiliate company, CA Technologies.\u00a0\n\t\u00a0\n\tAs further alleged in the complaint, the bribe proceeds were then laundered into the United States and used by Zelaya and his brother, Carlos Alberto Zelaya Rojas, to acquire real estate in the New Orleans area. \u00a0Certain properties were titled in the name of companies nominally controlled by Zelaya\u2019s brother in an effort to conceal the illicit source of the funds as well as the beneficial owner. \u00a0The current action seeks forfeiture of nine properties acquired with the proceeds of Zelaya\u2019s alleged bribery scheme.\u0022 \u00a0(Source: US Department of Justice Press Release, \u0022Department of Justice Seeks Recovery of Approximately $1,528,000 in Bribes Paid to a Honduran Official,\u0022 January 13, 2015.)\n\t\u00a0\n\tIn late January 2015, the defendant properties filed an Answer in the case, requesting the case be dropped for lack of sufficient evidence. \u00a0As of May 22, 2016, the case was ongoing. \u00a0(Sources: \u00a0Answer filed January 27, 2015 and Court Docket report as of May 22, 2016.)\u00a0","Disposition of Criminal Case(s)":"NA","Jurisdiction of Origin: Investigative Agency":"Assistance by Public Ministry of the Republic of Honduras","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Homeland Security Investigations\u0027 New Orleans and Miami Field Offices and Attache Tegucigalpa; Assistance by DOJ Criminal Division\u0027s Office of Overseas Prosecutorial Development, Assistance and Training Resident Legal Advisor (Tegucigalpa)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"DOJ Criminal Division\u0027s Asset Forfeiture and Money Laundering Section, Kleptocracy Asset Recovery Initiative; United States Attorney\u0027s Office, Eastern District of Louisiana","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the Eastern District of Louisiana","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Zelaya_US_Forfeiture_DOJ_PR_Jan_13_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Zelaya_US_Forfeiture_Complaint_Jan_13_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Zalaya_Answer_Jan27_2015.pdf","Sources ":"US Department of Justice Press Release, \u0022Department of Justice Seeks Recovery of Approximately $1,528,000 in Bribes Paid to a Honduran Official,\u0022 January 13, 2015, at http:\/\/www.justice.gov\/opa\/pr\/department-justice-seeks-recovery-approxim... (includes link to Complaint filed January 13, 2015 in US v. Real Property Located at 1404 North Highway 190, Covington, Louisiana 70433, et al, Case No. 2:15-cv-74 (EDLA); Answer filed January 27, 2015 and Court Docket Report as of May 22, 2016.)\n"},{"Case ID":"ARW-224","Case Title (Name of Public Official or Entity Allegedly Involved)":"Mahamoud Adam Bechir and Nouracham Niam \/ South Africa","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Chad","Position of Public Official(s) (yrs in office)":"Ambassador to South Africa (current); former Ambassador to Canada and the United States (Bechir); Wife of Ambassador (Niam)","Jurisdiction of Asset Recovery":"South Africa","Jurisdiction of Asset Description":"Alleged Asset Location \/ Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.18, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Action Initiated by Foreign Jurisdiction ","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the US Department of Justice Press Release, in November 2014, a civil asset forfeiture case was brought under the Kleptocracy Asset Recovery Initiative against alleged bribery proceeds belonging to Mr. Bechir. \u00a0The US government alleges that Mr. Bechir \u0022agreed to use his position to influence the award of oil development rights in Chad in exchange for $2 million and other valuable interests from Griffiths Energy International Inc., a Canadian company. \u00a0In order to conceal the bribe, Bechir and his wife, Nouracham Niam, 44, allegedly entered into a series of agreements with Griffiths Energy that provided for the payment of a $2 million \u201cconsulting fee\u201d if the company secured the oil rights in Chad. \u00a0After securing these oil rights in February 2011, Griffiths Energy allegedly transferred $2 million to an account located in Washington, D.C. held by a shell company created by Niam. \u00a0In 2013, Griffiths Energy pleaded guilty in Canadian court to bribing Bechir.\n\t\u00a0\n\tThe complaint further alleges that, after commingling the bribe payment with other funds and laundering these funds through U.S. bank accounts and real property, Bechir transferred $1,474,517 of the criminal proceeds traceable to the bribe payment to his account in South Africa, where he is now serving Chad\u2019s Ambassador to South Africa. \u00a0The current action seeks forfeiture of $106,488.31, which is the current balance of Bechir\u2019s accounts in South Africa. \u00a0Those funds have been seized pursuant to the complaint unsealed today. \u00a0The Department of Justice is also seeking additional assets from Bechir and Niam.\u0022 \u00a0(Source: US Department of Justice Press Release, \u0022Department of Justice Seeks Recovery of Approximately $100,000 in Bribes Paid to Former Chad Ambassador,\u0022 November 7, 2014, at http:\/\/www.justice.gov\/opa\/pr\/department-justice-seeks-recovery-approxim....) \u00a0\n\t\u00a0\n\tIn May 2015, Mr. Bechir filed an Amended Answer to the complaint, admitting that Griffiths Energy paid $2 million to Niam\u0027s company but that he had no sufficient knowledge to form a belief as to the truth of the bribery allegations. \u00a0As of May 9, 2016, the case was ongoing. (Source: US v. All Funds up to and including $1,474,517 in Interbank accounts held by or for the benefit of Nedbank, Ltd, Case No. 1:14-cv-1178 (D.D.C.), Amended Answer filed May 20, 2015 Court Docket Report as of June 23, 2016.)\u00a0","Disposition of Criminal Case(s)":"NA","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_US_DOJ_PR_Nov_7_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_US_Complaint_Jul_8_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_US_DDC_Verified_CLaim_Dec_11_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_US_Amended%20Answer_May%2020%202015_0.pdf","Sources ":"US Department of Justice Press Release, \u0022Department of Justice Seeks Recovery of Approximately $100,000 in Bribes Paid to Former Chad Ambassador,\u0022 November 7, 2014, at http:\/\/www.justice.gov\/opa\/pr\/department-justice-seeks-recovery-approxim....) \u00a0\n\t\u00a0\n\tUS v. All Funds up to and including $1,474,517 in Interbank accounts held by or for the benefit of Nedbank, Ltd, Case No. 1:14-cv-1178 (D.D.C.), Verified Complaint for Forfeiture in rem filed July 8, 2014, Amended Answer (Bechir) filed May 20, 2015 and Court Docket Report as of June 23, 2016.\n\t\u00a0\n\tSee also, Wall Street Journal Blog, \u0022U.S. Seeks Bribes Paid by Griffiths Energy,\u0022 November 7, 2014, at http:\/\/blogs.wsj.com\/riskandcompliance\/2014\/11\/07\/u-s-seeks-bribes-paid-... The Globe and Mail, \u0022Read the letter from Mahamoud Adam Bechir,\u0022 Published Wednesday, Jan. 30 2013, at http:\/\/www.theglobeandmail.com\/report-on-business\/international-business...\n"},{"Case ID":"ARW-223","Case Title (Name of Public Official or Entity Allegedly Involved)":"Mahamoud Adam Bechir and Nouracham Niam \/ United States (South Africa account)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Chad","Position of Public Official(s) (yrs in office)":"Ambassador to South Africa (current); former Ambassador to Canada and the United States (Bechir); Wife of Ambassador (Niam)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Alleged Asset Location\/Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.18, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Asset Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case ","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the US Department of Justice Press Release, in November 2014, a civil asset forfeiture case was brought under the Kleptocracy Asset Recovery Initiative against alleged bribery proceeds belonging to Mr. Bechir. \u00a0The US government alleges that Mr. Bechir \u0022agreed to use his position to influence the award of oil development rights in Chad in exchange for $2 million and other valuable interests from Griffiths Energy International Inc., a Canadian company. \u00a0In order to conceal the bribe, Bechir and his wife, Nouracham Niam, 44, allegedly entered into a series of agreements with Griffiths Energy that provided for the payment of a $2 million \u201cconsulting fee\u201d if the company secured the oil rights in Chad. \u00a0After securing these oil rights in February 2011, Griffiths Energy allegedly transferred $2 million to an account located in Washington, D.C. held by a shell company created by Niam. \u00a0In 2013, Griffiths Energy pleaded guilty in Canadian court to bribing Bechir.\n\t\u00a0\n\tThe complaint further alleges that, after commingling the bribe payment with other funds and laundering these funds through U.S. bank accounts and real property, Bechir transferred $1,474,517 of the criminal proceeds traceable to the bribe payment to his account in South Africa, where he is now serving Chad\u2019s Ambassador to South Africa. \u00a0The current action seeks forfeiture of $106,488.31, which is the current balance of Bechir\u2019s accounts in South Africa. \u00a0Those funds have been seized pursuant to the complaint unsealed today. \u00a0The Department of Justice is also seeking additional assets from Bechir and Niam.\u0022 \u00a0(Source: US Department of Justice Press Release, \u0022Department of Justice Seeks Recovery of Approximately $100,000 in Bribes Paid to Former Chad Ambassador,\u0022 November 7, 2014, at http:\/\/www.justice.gov\/opa\/pr\/department-justice-seeks-recovery-approxim....) \u00a0\n\t\u00a0\n\tIn May 2015, Mr. Bechir filed an Amended Answer to the complaint, admitting that Griffiths Energy paid $2 million to Niam\u0027s company but that he had no sufficient knowledge to form a belief as to the truth of the bribery allegations. \u00a0As of October 28, 2015, the case was ongoing. (Source: US v. All Funds up to and including $1,474,517 in Interbank accounts held by or for the benefit of Nedbank, Ltd, Case No. 1:14-cv-1178 (D.D.C.), Amended Answer filed May 20, 2015 Court Docket Report as of June 23, 2016.)","Disposition of Criminal Case(s)":"NA","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Kleptocracy Asset Recovery Initiative, Department Justice, Criminal Division\u2019s Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the District of Columbia","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_US_DOJ_PR_Nov_7_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_US_Complaint_Jul_8_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_US_DDC_Verified_CLaim_Dec_11_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_US_Amended%20Answer_May%2020%202015.pdf","Sources ":"US Department of Justice Press Release, \u0022Department of Justice Seeks Recovery of Approximately $100,000 in Bribes Paid to Former Chad Ambassador,\u0022 November 7, 2014, at http:\/\/www.justice.gov\/opa\/pr\/department-justice-seeks-recovery-approxim....) \u00a0\n\t\u00a0\n\tUS v. All Funds up to and including $1,474,517 in Interbank accounts held by or for the benefit of Nedbank, Ltd, Case No. 1:14-cv-1178 (D.D.C.), Verified Complaint for Forfeiture in rem filed July 8, 2014, Amended Answer (Bechir) filed May 20, 2015 and Court Docket Report as of June 23, 2016.\n\t\u00a0\n\tSee also, Wall Street Journal Blog, \u0022U.S. Seeks Bribes Paid by Griffiths Energy,\u0022 November 7, 2014, at http:\/\/blogs.wsj.com\/riskandcompliance\/2014\/11\/07\/u-s-seeks-bribes-paid-... The Globe and Mail, \u0022Read the letter from Mahamoud Adam Bechir,\u0022 Published Wednesday, Jan. 30 2013, at http:\/\/www.theglobeandmail.com\/report-on-business\/international-business...\n"},{"Case ID":"ARW-228","Case Title (Name of Public Official or Entity Allegedly Involved)":"Viktor Yanukovych \/ Switzerland","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"President (2010-2014)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.19, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Swiss Federal Council Ordinance","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"","Case Summary":"According to the 2014 Annual Report (published May 2015) by the Swiss Office of the Federal Police, US$175 million in Yanukovych related assets have been frozen in Switzerland. \u00a0The report indicated that the funds had passed through accounts in numerous jurisdictions, including Cyprus, British Virgin Islands, Austria, Liechtenstein, Great Britain, the Netherlands and Switzerland. \u00a0(Original text, at pages 28-29: \u0022Les renseignements disponibles indiquent un flux de fonds pass ant par de nombreux comptes off-shore, notamment \u00e0 Chypre et dans les Iles Vierges britanniques ainsi qu\u2019en Autriche, au Liechtenstein, en Grande-Bretagne, aux Pays-Bas et en Suisse. Se concertant avec l\u2019UE, la Suisse a bloqu\u00e9 \u00a0pr\u00e9ventivement des valeurs patrimoniales \u00e0 hau- teur de 75 millions de dollars environ appartenant \u00e0 M. Ianoukovytch et \u00e0 son entourage, afin de laisser suffisamment de temps aux autorit\u00e9s ukrainiennes de poursuite p\u00e9nale pour pr\u00e9senter des demandes \u00e9ventuelles d\u2019entraide judiciaire. Dans le m\u00eame temps, le MPC et les autorit\u00e9s cantonales genevoises ont ou vert des enqu\u00eates pour abus de confiance, corruption, abus d\u2019autorit\u00e9 et blanchiment d\u2019argent, bloquant \u00e0 cet \u00e9gard 100 autres millions de dollars.\u0022)\n\t\t\u00a0\n\t\tAn earlier media release by the Swiss Foreign Ministry on February 28, 2014 had stated, \u0022[t]he Federal Council has decided to block all assets Viktor Yanukovych and his entourage might have in Switzerland. The corresponding ordinance enters into force today, Friday 28 February. In taking this measure, the Federal Council wishes to avoid any risk of misappropriation of Ukrainian state assets. [ ]\u00a0\n\t\t\u00a0\n\t\tIn view of the most recent developments, the Federal Council wishes to take all measures necessary to avoid the risk of any misappropriation of financial assets of the Ukrainian state. It has therefore decided, in conjunction with other financial centres, to block all assets Viktor Yanukovych and his entourage might have in Switzerland. The Federal Council has also prohibited the sale and any disposal of assets, namely property, of these persons. The aim of this measure is to prevent these assets being taken out of Switzerland before they can be blocked through the ordinary channels of mutual legal assistance in cooperation with the Ukrainian authorities.\n\t\t\u00a0\n\t\tShould such assets subsequently be proved through criminal proceedings to have been obtained illegally, they can thus be returned to Ukraine following criminal conviction of the former leaders and their entourage. The Swiss authorities are prepared to cooperate closely with the Ukrainian authorities.\u0022 \u00a0(Source: Switzerland Ministry of Foreign Affairs media release, \u0022Federal Council blocks all assets Viktor Yanukovych and his entourage might have in Switzerland,\u0022 February 28, 2014.)\n\u00a0","Disposition of Criminal Case(s)":"According to the INTEROL wanted list, Mr. Yanukovych is \u0022Wanted by the Judicial Authorities of Ukraine for Prosecution \/ to serve a sentence\u0022 with the following charges listed: \u0022Misappropriation, embezzlement or conversion of property by malversation, if committed in respect of an especially gross amount, or by an organized group.\u0022 \u00a0(Source: INTERPOL, \u0022Viktor Yanukovych,\u0022 at http:\/\/www.interpol.int\/notice\/search\/wanted\/2014-13031 (last accessed January 21, 2015).\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General\u0027s Office","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Office of Federal Police\u0027 Ministere Public de la Confederation; Geneva cantonal authorities","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_Interpol_Wanted_List_Jan_21_2015_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_Switzerland_Fed_Council_Freeze_Feb_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Swiss%20Federal%20Police%20Annual%20Report%202014_Pub%20May%202015.pdf","Sources ":"Switzerland Office of Federal Police Annual Report for 2014 (Published May 2015), at http:\/\/www.ejpd.admin.ch\/dam\/data\/fedpol\/publiservice\/publikationen\/beri...\n\t\u00a0\n\tSwitzerland Ministry of Foreign Affairs media release, \u0022Federal Council blocks all assets Viktor Yanukovych and his entourage might have in Switzerland,\u0022 February 28, 2014, at https:\/\/www.news.admin.ch\/dokumentation\/00002\/00015\/index.html?lang=en\u0026m...\n\t\u00a0\n\tSwiss Federal Department of Foreign Affairs, \u0022FAQ on frozen assets of Politically Exposed Persons (PEPs) originating from Ukraine \u2013 ordinance of the Federal Council,\u0022 April 2014, at https:\/\/www.eda.admin.ch\/content\/dam\/eda\/en\/documents\/topics\/FAQ-frozen-...\n\t\u00a0\n\tSwiss Federal Council Ordinances Instituting measures against certain persons from Ukraine (Ordonnance\u00a0\n\tinstituant des mesures \u00e0 l\u2019encontre de certaines personnes originaires de l\u2019Ukraine), February 26, 2014 and modified March 7, 2014, accessed at http:\/\/www.admin.ch\/bundesrecht\/aop\/00724\/index.html?lang=fr;\n\t\u00a0\n\tSwissinfo.ch, \u0022Swiss investigate Yanukovych for money laundering,\u0022 February 28, 2014, at http:\/\/www.swissinfo.ch\/eng\/swiss-investigate-yanukovych-for-money-laund...\n\t\u00a0\n\tThe Economist, \u0022\u0022A Long, Hard Slog: Ukraine\u0027s stolen assets,\u0022 March 5, 2014, at http:\/\/www.economist.com\/blogs\/easternapproaches\/2014\/03\/ukraine-s-stole...\n"},{"Case ID":"ARW-227","Case Title (Name of Public Official or Entity Allegedly Involved)":"Viktor Yanukovych \/ Liechtenstein","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"President (2010-2014)","Jurisdiction of Asset Recovery":"Liechtenstein","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.19, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"","Case Summary":"According to the June 2014 statement by Liechtenstein\u0027s Prosecutor General and Director of the Financial Intelligence Unit, the jurisdiction froze assets of \u0022approximately 27 million Swiss francs that can be attributed to former Ukrainian politicians. The Liechtenstein Office of the Public Prosecutor has instituted criminal proceedings for money laundering in this connection. Shortly after the appointment of a new Ukrainian government in February 2014, criminal investigations were instituted in Ukraine against the former president, members of the former government, and family members of those persons on grounds of corruption. Consequently, Liechtenstein ordered on 28 February 2014 that potential assets of those persons be frozen and that any such assets be notified to the authorities.\u00a0\n\tThe goal of these measures is to ensure that assets of those persons can be identified. Reports to this effect were then submitted to the Financial Intelligence Unit (FIU) for evaluation. In one group of cases, there is an initial suspicion that a criminal offence was committed, so the FIU notified the Office of the Public Prosecutor. The Office of the Public Prosecutor has applied to the investigating judge to carry out preliminary investigations against four suspects on suspicion of the crime of money laundering as referred to in \u00a7 165 paragraphs 1, 2, and 3 of the Liechtenstein Criminal Code (StGB).\u0022 \u00a0(Source: \u00a0\u0022Ukraine: Liechtenstein freezes CHF 27 million and institutes criminal proceedings for money laundering,\u0022 at http:\/\/star.worldbank.org\/star\/sites\/star\/files\/liechtenstein_-_ukraine_....)\n\t\u00a0","Disposition of Criminal Case(s)":"According to the INTEROL wanted list, Mr. Yanukovych is \u0022Wanted by the Judicial Authorities of Ukraine for Prosecution \/ to serve a sentence\u0022 with the following charges listed: \u0022Misappropriation, embezzlement or conversion of property by malversation, if committed in respect of an especially gross amount, or by an organized group.\u0022 \u00a0(Source: INTERPOL, \u0022Viktor Yanukovych,\u0022 at http:\/\/www.interpol.int\/notice\/search\/wanted\/2014-13031 (last accessed January 21, 2015)).","Jurisdiction of Origin: Investigative Agency":"Prosecutor General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor-General\u0027s Office","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Financial Intelligence Unit","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General\u0027s Office","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_Interpol_Wanted_List_Jan_21_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovich_Liechtenstein_Asset_Freeze_PR_June_2014.pdf","Sources ":"\u0022Ukraine: Liechtenstein freezes CHF 27 million and institutes criminal proceedings for money laundering,\u0022 at http:\/\/star.worldbank.org\/star\/sites\/star\/files\/liechtenstein_-_ukraine_... INTERPOL, \u0022Viktor Yanukovych,\u0022 at http:\/\/www.interpol.int\/notice\/search\/wanted\/2014-13031 (last accessed January 21, 2015).\n"},{"Case ID":"ARW-93","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha \/ Ireland (Freezing Injunction on US Claim)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"Ireland","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"","Case Summary":"In August 2014, the US Department of Justice announced that more than US$480 million in Abacha corruption proceeds had been forfeited to the US: approximately US$303 million in two bank accounts in Bailiwick of Jersey, $144 million in 2 bank accounts in France [note: arrest in rem notes amount as US$159,374,531.89], and at least US$27 million in accounts in the UK and Ireland. \u00a0Please note that the amount held in Ireland was not specified in the press release. The Department of Justice also noted that claims against US$148 million in four investment portfolios in the UK are pending. (Sources: \u00a0US Department of Justice, \u0022U.S. Forfeits Over $480 Million Stolen by Former Nigerian Dictator in Largest Forfeiture Ever Obtained Through a Kleptocracy Action,\u0022 August 7, 2014; warrants for arrest in rem filed July 11, 2014 in US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, et al, Case No. l:13-cv-01832-JDB (D.D.C.).) \u00a0According to a Status Report filed by the US on August 18, 2014, the Government has until September 26, 2014 to respond to the claimants\u0027 (members of the Abacha family and others\u0027) Motion to Dismiss. \u00a0(US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Status Report filed August 18, 2014.) \u00a0According to the Department of Justice, the restraint of funds includes approximately $313 million in the name of Mohammed Sani and Doraville Properties Corporation in two bank accounts in the Bailiwick of Jersey and $145 million in the name of Rayville International SA and Standard Alliance Financial Services Limited in two bank accounts in France. In addition, four investment portfolios (all assets held in name of Blue Holding traceable to Ridley Group limited) and three bank accounts in the name of Mecosta Securities and Mohammed Sani in the United Kingdom with an expected value of at least $100 million have also been restrained [ ] [and] also seeks to forfeit five corporate entities registered in the British Virgin Islands (Doraville Properties Corporation, Mecosta Securities Inc., Rayville International SA, Ridley group Limited, Standard Alliance Financial Services Limited). (Source: US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, Limited in Jersey, Channel Islands, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Verified Complaint for Civil Asset Forfeiture).The complaint alleged that General Abacha, his son Mohammed Sani Abacha, their associate Abubakar Atiku Bagudu and others embezzled, misappropriated and extorted billions from the government of Nigeria and the Central Bank of Nigeria on the false pretense that the funds were necessary for national security, then laundered their criminal proceeds through the purchase of bonds backed by the United States using U.S. financial institutions. (Source: Department of Justice, Press release, \u0022U.S. Freezes More Than $458 Million Stolen by Former Nigerian Dictator in Largest Kleptocracy Forfeiture Action Ever Brought in the U.S..\u0022 March 5, 2014.) \u00a0","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate. \u00a0(Source: \u00a0Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_Forfeit_480_mil_DOJ_PR_Aug_7_2014_2.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_DDC_Order_Default_Aug_6_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_Mtn_Default_Judgment_Aug_4_2014.pdf","Sources ":"US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, Limited in Jersey, Channel Islands, Case No. l:13-cv-01832-JDB (D.D.C.), Verified Complaint for Civil Asset Forfeiture, unsealed on March 5, 2014 and available at:http:\/\/www.justice.gov\/iso\/opa\/resources\/765201435135920471922.pdf; US \u00a0Department of Justice, Press releases, \u0022U.S. Freezes More Than $458 Million Stolen by Former Nigerian Dictator in Largest Kleptocracy Forfeiture Action Ever Brought in the U.S.,\u0022 March 5, 2014, available at: http:\/\/www.justice.gov\/opa\/pr\/2014\/March\/14-crm-230.html and \u0022U.S. Forfeits Over $480 Million Stolen by Former Nigerian Dictator in Largest Forfeiture Ever Obtained Through a Kleptocracy Action,\u0022 August 7, 2014, at http:\/\/www.justice.gov\/opa\/pr\/2014\/August\/14-crm-835.html.\n"},{"Case ID":"ARW-13","Case Title (Name of Public Official or Entity Allegedly Involved)":"Aluminum Bahrain B.S.C. \/ Bruce Alan Hall UK SFO Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Bahrain","Position of Public Official(s) (yrs in office)":"Chief Executive Officer of State-Owned Entity, 2001-2005","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2009","Asset Recovery End":"2014","UNCAC Offenses Implicated":"Art.16, Art.18, Art.21","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Compensation","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"Extradition from Australia and \u0022liaison with foreign authorities.\u0022   (Source: UK Serious Fraud Office press release, \u0022Bruce Hall sentenced to 16 months in prison,\u0022 22 July 2014.) ","Contributing Factors in Asset Recovery":"Compensation to Alba ordered as part of Mr. Hall\u0027s sentence.","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$853,987","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the July 22, 2014 press release by the UK\u0027s Serious Fraud Office, Mr. Hall was sentenced to imprisonment for \u0022conspiracy to corrupt, in relation to contracts for the supply of goods and services to a Bahrain company, Aluminum Bahrain B.S.C. (Alba). \u00a0[ \u00a0] \u00a0[The Court] heard how Mr. Hall received [GBP] 2.9 million in corrupt payments between 2002 and 2005, including 10,000 Bahraini dinars in cash from Sheikh Isa bin Ali Al Khalifa, a member of the Bahraini royal family and at the time Bahrain\u0027s minister of finance and Alba\u0027s chairman. \u00a0The payments were made in exchange for Mr. Hall agreeing to and allowing corrupt arrangements that Sheikh Isa had been involved in before Mr. Hall\u0027s appointment as CEO to continue.\u0022 \u00a0(Source: UK Serious Fraud Office Press Release, \u0022Bruce Hall sentenced to 16 months in prison,\u0022 22 July 2014.) \u00a0 As part of his sentence, Mr. Hall was ordered to pay a confiscation order of GBP3,070,106.03; (US$5,243,560) and in addition, pay Alba compensation in the amount of GBP500,010 (US$853,987) and pay GBP 100,000 (US$170,794) as a contribution to prosecution costs.\u00a0\n\t\u00a0\n\tThe SFO also stated that, \u0022As part of Mr. Hall\u0027s mitigation he also agreed to divest himself of other corrupt payments he received during his time as the CEO of Alba. \u00a0These payments were not part of the indictment as the SFO did not have the jurisdiction to prosecute for the conduct acknowledged by Mr. Hall. \u00a0In order to recover these payments received by Mr. Hall, which amount to US$900,000, the Director of the SFO electd to launch proceedings under Part 5 of the Proceeds of Crime Act 2002 in the High Court. \u00a0These proceedings were finalised at the High Court on 17 July 2014.\u0022 \u00a0(Source: UK Serious Fraud Office Press Release, \u0022Bruce Hall sentenced to 16 months in prison,\u0022 22 July 2014.) \u00a0 On July 31, 2014, the SFO announced that the confiscation and compensation orders had been paid in full. (Source: \u00a0UK SFO Press Release, \u0022Bruce Hall confiscation order paid in full: 31 July 2014.\u0022)\n\t\u00a0\n\tSee related entry, Aluminum Bahrain B.S.C. \/ Alcoa Case (Private Civil Action)","Disposition of Criminal Case(s)":"According to the July 22, 2014 press release by the UK\u0027s Serious Fraud Office, Mr. Hall was sentenced to 16 months\u0027 inprisonment; he had entered a guilty plea to charge of Conspiracy to corrupt contrary to Section 1, Criminal Law Act 1977 and Section 1, Prevention of Corruption Act 1906. \u00a0(Source: UK Serious Fraud Office Press Release, \u0022Bruce Hall sentenced to 16 months in prison,\u0022 22 July 2014.) \u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Serious Fraud Office; City of London Police Overseas Anti-Corruption Unit","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Serious Fraud Office","Jurisdiction of Asset Recovery: Courts Involved":"City of Westminster Magistrates\u0027 Court; High Court Queens Bench","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/ALBA_UK_SFO_Hall_Sentence_Jul_22_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/ALBA_UK_SFO_Hall_Consent_Order_Jul_17_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/ALBA_UK_SFO_Hall_Civil_Recovery_Consent_Form.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/ALBA_UK__Hall_Paid_SFO_PR_Jul_31_2014.pdf","Sources ":"\n\tUK Serious Fraud Office Press Release, \u0022Bruce Hall sentenced to 16 months in prison,\u0022 22 July 2014, at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-20...\n\n\t\u00a0\n\n\tBruce Hall Civil Recovery Consent Order Claim Form, at http:\/\/www.sfo.gov.uk\/media\/269993\/140717%20sealed%20claim%20form%20and%... (last accessed and downloaded on July 27, 2014);\u00a0\n\n\t\u00a0\n\n\tUK SFO Press Release, \u0022Bruce Hall confiscation order paid in full: 31 July 2014, at http:\/\/www.sfo.gov.uk\/our-work\/our-cases\/case-progress\/bruce-hall-and-vi...\n\n\t\u00a0\n\n\tHigh Court Queens Bench Consent Order of 17 July 2014, at http:\/\/www.sfo.gov.uk\/media\/270013\/140717%20sealed%20consent%20order.pdf\n"},{"Case ID":"ARW-221","Case Title (Name of Public Official or Entity Allegedly Involved)":"Tomas Yarrington","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mexico","Position of Public Official(s) (yrs in office)":"Former Mayor of Matamoros, Mexico (1992- 1995); Governor of Tamaulipas state (1999-2004); Presidential candidate (2005)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort; Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2012","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.19, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Asset Forfeiture; Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty (US-Mexico)","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance (in part), Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"$640,000","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"In December 2012, the US District Court for the Southern District of Texas issued a final agreed judgment in a civil asset forfeiture case filed by the US Government, forfeiting a condominium at 334 South Padre Boulevard, South Padre Island. \u00a0The condominium, valued at $640,000, had been alleged to be proceeds of corrupt payments received by Mr. Yarrington from the Gulf Cartel, headquartered in Tamaulipas state, Mexico where he had been governor, in exchange for no interference in their criminal enterprise by public officials and law enforcement. \u00a0(Source: US v. Real Property Known as 334 South Padre Boulevard, South Padre Island, Case No. 12-cv-167 (S.D. Tex), Final Agreed Judgment filed December 10, 2012) \u00a0In May 2012, the US Government had also filed a criminal indictment and a superseding indictment on May 22, 2013 against Mr. Yarrington which included extensive criminal asset forfeiture allegations, including: (1) 2005 Pilatus aircraft; (2) 46.175 acre tract of land in Bexar County, Texas; (3) residence on Windward Drive, Port Isabel, Texas; and (4) over $183 million in joint and several liability with his co-defendant. \u00a0Mr. Yarrington is alleged to have funnelled bribery and embezzlement funds through use of shell companies and nominees to real properties and other assets in Mexico and the U.S. \u00a0As of June 2016 an arrest warrant had been issued and his case is pending. (Source: US v. Yarrington Ruvalcaba, et al, Case No. 1:12-cr-435 (S.D. Tex.), Superseding Indictment filed May 22, 2013; Court Docket Report as of June 27, 2016).","Disposition of Criminal Case(s)":"As of June 27, 2016, Mr. Yarrington remained under indictment on Racketeering and Money Laundering conspiracy, bank fraud and other charges. \u00a0(Source: \u00a0US v. Yarrington Ruvalcaba, Case No. 1:12-cr-435 (S.D. Tex), Court Docket Report as of June 27, 2016.)\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General of the Republic of Mexico","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Organized Crime Drug Enforcement Task Force investigation conducted in San Antonio, Brownsville, Houston and Corpus Christi by the Drug Enforcement Administration, Homeland Security Investigations, Internal Revenue Service - Criminal Investigation and the Texas Attorney General\u2019s Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney\u0027s Office for the Southern District of Texas","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the Southern District of Texas","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yarrington_SDTEX_Civil_Asset_Forfeit_Complaint_May_22_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yarrington_SDTEX_Civil_Asset_Final_Judgment_Dec_10_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yarrington_SDTEX_Supersed_Indictment_May_22_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yarrington_SDTEX_Civil_Asset_Forfeit_DOJ_PR_Dec_11_2012.pdf","Sources ":"US v. Real Property Known as 334 South Padre Boulevard, South Padre Island, Case No. 12-cv-167 (S.D. Tex), Final Agreed Judgment filed December 10, 2012 and Verified Complaint for Forfeiture in rem filed May 22, 2012; US v. Yarrington Ruvalcaba, et al, Case No. 1:12-cr-435 (S.D. Tex.), Superseding Indictment filed May 22, 2013 and Court Docket Report as of June 27, 2016.\n"},{"Case ID":"ARW-222","Case Title (Name of Public Official or Entity Allegedly Involved)":"Chun Doo Hwan \/ US Asset Forfeiture cases","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"South Korea","Position of Public Official(s) (yrs in office)":"President (1980-1988)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort; Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"2015","UNCAC Offenses Implicated":"Art.15, Art.18, Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Asset Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"The Department of Justice credited the significant assistance provided by the Seoul Central District Public Prosecutor\u0027s Office, Korea\u0027s Supreme Prosecutor\u0027s Office - Anti-Corruption Supervisory Division and the Ministry of Justice\u0027s International Criminal Affairs Division in investigating and forfeiting the corruption proceeds.  (Source: US Department of Justice Press Release, \u0022Justice Department Returns Forfeited Assets Derived from Public Corruption Scheme to Korean Minister of Justice,\u0022 November 10, 2015.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"According to a knowledgeable source, half of the funds were recovered as fine in relation to Mr. Chun\u0027s prosecution and first remitted to a fund by the Public Prosecutor\u0027s Office and eventually to a general fund managed by the Ministry of Strategy and Finance; the other half of the recovered assets went towards payment of owed taxes.","Case Summary":"According to the US Department of Justice Press Release, $1,126,951.45 in forfeited corruption proceeds related to the former Korean president Chun Doo Hwan\u0027s case was returned to the Korean Ministry of Justice. \u00a0The funds were forfeited pursuant to a settlement agreement with family members of Mr. Chun, against whom the US Department of Justice Kleptocracy Initiative had filed two asset forfeiture proceedings, in the US District Courts for the Central District of California and the Eastern District of Pennsylvania. \u00a0The Settlement Agreement provided for $100,000 for the claimants and the US DOJ agreed that should Mr. Chun\u0027s daughter in law Sang Ah Park file with the US Department of State an Application to Determine Returning Resident Status, it would not oppose or seek denial of such if filed within 2 years of the Settlement Agreement. (Sources: US Department of Justice Press Release, \u0022Justice Department Returns Forfeited Assets Derived from Public Corruption Scheme to Korean Minister of Justice,\u0022 November 10, 2015; the March 2015 Settlement Agreement is included as a link in US Department of Justice Press Release of March 4, 2015.) \u00a0\u00a0\n\t\t\t\u00a0\n\t\t\tAccording to the US in 2014, \u0022The Department of Justice filed a civil forfeiture complaint in the U.S. District Court for the Central District of California seeking to recover more than $700,000 in alleged corruption proceeds of Chun Doo-hwan, the former president of the Republic of Korea. [ \u00a0] \u00a0As alleged in the forfeiture complaint, President Chun was convicted in Korea in 1997 of receiving more than $200 million in bribes from Korean businesses and companies. \u00a0 President Chun and his relatives laundered some of these corruption proceeds through a web of nominees and shell companies in both Korea and the United States.\n\t\t\t\u00a0\n\t\t\tThrough close cooperation between U.S. and Korean law enforcement and prosecution authorities, the $721,951 sought for forfeiture was identified and seized when President Chun\u2019s relatives sold a home in Newport Beach that previously had been purchased with the laundered proceeds of President Chun\u2019s corruption.\u0022 \u00a0(Source: \u00a0US Department of Justice Press Release, \u0022U.S. Seeks to Recover Over $700,000 in Kleptocracy Proceeds of Former South Korean President Chun Doo-hwan,\u0022 April 24, 2014.)\n\t\t\t\u00a0\n\t\t\tThe complaint details the bribe payments that then-President Chun received from Korean companies, the use of nominees which included family members and close associates, shell companies and trust to conceal the origin and destination of the corruption proceeds including purchase and sale of a Georgia property which was held in a trust with his daughter-in-law\u0027s mother as sole trustee and the Newport Beach property which sold for more than US$2 million. \u00a0(Source: \u00a0US v. $726,951.45 in Uniti Bank Funds, Case No. cv-14-03140 (C.D. Cal), Verified Complaint for Forfeiture In Rem filed April 24, 2014.)\n\t\t\t\u00a0\n\t\t\tOn July 14, 2014, the claimants in the case (members of the Chun family and Port Manleigh Trust) filed an Answer to the complaint, stating that Jae Yong Chun had received bearer bonds from his grandfather and that he and his wife Sang Ah Park subsequently acquired a house in Georgia using funds earned and acquired through legal and legitimate means; they later sold that house and used to the proceeds to purchase the California house that is the subject of the present action. \u00a0(Source: US v. $726,951.45 in Uniti Bank Funds, Case No. cv-14-03140 (C.D. Cal), Answer of Claimants Jae Yong Chun, Sang Ah Park, Yang Ja Yoon, and Port Manleigh Trust to Verified Complaint for Forfeiture In Rem, para 11 and throughout, filed July 14, 2014.) \u00a0\n\t\t\t\u00a0\n\t\t\tIn a second case in the Eastern District of Pennsylvania, in September 2014, the Department of Justice announced that approximately $500,000 had been seized from an investment allegedly made by the former President\u0027s daughter-in-law in a Pennsylvania limited partnership. \u00a0(Source: US Department of Justice, \u0022Justice Department Seizes an Additional $500,000 in Corrupt Assets Tied to Former President of Republic of Korea,\u0022 September 3, 2014; US v. A Limited Partnership Interest held in the Name of or for the Benefit of Sang Ah Park in the Philadelphia U.S. Immigration Investment Fund, Case No. 2:14-mj-833 (E.D. Pa.)).\u00a0\n\u00a0","Disposition of Criminal Case(s)":"According to the April 2014 civil asset forfeiture complaint filed by the US, Mr. Chun was convicted in 1996 by Seoul District Court of accepting domestic bribes and murder and insurrection and was sentenced to death (later commuted) and ordered to pay $229 million. (Source: US v. $726,951.45 in Uniti Bank Funds, Case No. 14-cv-03140, Verified Complaint filed April 24, 2014, paras 16-18)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Supreme Prosecutor\u0027s Office, Ministry of Justice, Seoul Central District Prosecutor\u0027s Office","Jurisdiction of Origin: Courts Involved":"Seoul District Court","Jurisdiction of Asset Recovery: Investigative Agency":"FBI\u2019s Kleptocracy Program of the International Corruption Unit within the Criminal Investigation Division and the West Covina Resident Agency of the Los Angeles Division and HSI Attach\u00e9 Seoul, with assistance from HSI Miami; HSI Philadelphia","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Kleptocracy Asset Recovery Initiative, Department Justice, Criminal Division\u2019s Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"US District Courts for the Central District of California and Eastern District of Pennsylvania","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chun_US_CDCA_Complaint_Apr_24_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chun_US_CDCA_Claimants_Answer_Jul_14_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chun_US_EDPA_Seizure_DOJ_PR_Sep_3_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chun_US_Settlement_DOJ_PR_Mar_4_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chun_US_DOJ_executed_agreement_Mar_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chun_US_CDCA_Notice_of_settlement_Mar_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chun_USDOJ_Settlement%20Agreement_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chun_USDOJ_Asset%20Return_PR_Nov10%202015.pdf","Sources ":"US Department of Justice Press Release, \u0022Justice Department Returns Forfeited Assets Derived from Public Corruption Scheme to Korean Minister of Justice,\u0022 November 10, 2015, at http:\/\/www.justice.gov\/usao-cdca\/pr\/justice-department-returns-forfeited... US Department of Justice Press Release, \u0022United States Assists Korean Authorities in Recovering Over $28.7 million in Corruption Proceeds of Former President of the Republic of Korea,\u0022 March 4, 2015, including links to the Settlement Agreeement, at http:\/\/www.justice.gov\/sites\/default\/files\/opa\/press-releases\/attachment...\n\tUS v. $726,951.45 in Uniti Bank Funds, Case No. 14-cv-03140 (C.D. Cal), Verified Complaint for Forfeiture In Rem filed April 24, 2014 and Answer of Claimants Jae Yong Chun, Sang Ah Park, Yang Ja Yoon, and Port Manleigh Trust to Verified Complaint for Forfeiture In Rem, filed July 14, 2014 and Court Docket Report as of January 26, 2015; US Department of Justice Press Release, \u0022U.S. Seeks to Recover Over $700,000 in Kleptocracy Proceeds of Former South Korean President Chun Doo-hwan,\u0022 April 24, 2014, accessed at http:\/\/www.justice.gov\/opa\/pr\/2014\/April\/14-crm-430.html; Victoria Kim, \u0022Search for S. Korean official\u0027s secret funds leads to O.C.,\u0022 Los Angeles Times, April 24, 2014. \u00a0\n\t\u00a0\n\tUS Department of Justice, \u0022Justice Department Seizes an Additional $500,000 in Corrupt Assets Tied to Former President of Republic of Korea,\u0022 September 3, 2014, at http:\/\/www.justice.gov\/opa\/pr\/justice-department-seizes-additional-50000... US v. A Limited Partnership Interest held in the Name of or for the Benefit of Sang Ah Park in the Philadelphia U.S. Immigration Investment Fund, Case No. 2:14-mj-833 (E.D. Pa.), Court Docket Report;\u00a0\n\t\u00a0\n\tSee also, Korea Times, \u0022Ex-president\u0027s forfeited US assets returned,\u0022 November 10, 2015, at http:\/\/koreatimes.co.kr\/www\/news\/nation\/2015\/11\/113_190621.html\n"},{"Case ID":"ARW-220","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha \/ Jersey (Freezing on US Claim)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"Jersey","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Action Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"Civil Asset Recovery (International Co-operation) (Jersey) Law 2007","Contributing Factors in Asset Recovery":"Ongoing case but the Department of Justice press release on March 5, 2014 noted, \u0022The department appreciates the extensive assistance provided by the Governments of Jersey, France and the United Kingdom in this investigation.\u0022 ","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"See related entry, Sani Abacha \/ United States Civil Asset Forfeiture case. \u00a0According to the US Department of Justice, the civil asset forfeiture complaint filed in November 2013 and unsealed in March 2014, \u0022seeks to forfeit bank accounts and investment portfolios with funds located in Bailiwick of Jersey, France and the United Kingdom. On Feb. 25 and 26, 2014, U.S. arrest warrants for the assets were enforced in Jersey and France though mutual legal assistance requests and in the United Kingdom through litigation brought pursuant to the U.K. Civil Jurisdiction and Judgments Act.\u0022 \u00a0(Sources: US \u00a0Department of Justice, Press release, \u0022U.S. Freezes More Than $458 Million Stolen by Former Nigerian Dictator in Largest Kleptocracy Forfeiture Action Ever Brought in the U.S.,\u0022 March 5, 2014; Royal Court of Jersey, Viscount\u0027s Department, Affidavit of Service, March 12, 2014, filed as exhibit in US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Warrant of Arrest in Rem filed July 11, 2014.)","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate. \u00a0(Source: \u00a0Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Attorney General\u0027s Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"Royal Court of Jersey, Viscount\u0027s Department","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_DDC_Forfeiture_Complaint_Unsealed_Mar_2014_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_DOJ_Asset_Forfeiture_PR_Mar_5_2014_2.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_Forfeit_480_mil_DOJ_PR_Aug_7_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Jersey_Affidavit_Arrest_in_Rem_Mar_2014_0.pdf","Sources ":"US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Verified Complaint for Civil Asset Forfeiture, unsealed on March 5, 2014 and available at:http:\/\/www.justice.gov\/iso\/opa\/resources\/765201435135920471922.pdf and Warrants of Arrest in Rem filed July 11, 2014; US \u00a0Department of Justice, Press release, \u0022U.S. Freezes More Than $458 Million Stolen by Former Nigerian Dictator in Largest Kleptocracy Forfeiture Action Ever Brought in the U.S.,\u0022 March 5, 2014, available at: http:\/\/www.justice.gov\/opa\/pr\/2014\/March\/14-crm-230.html\n"},{"Case ID":"ARW-219","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha \/ France (Seizing on US Claim)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"France","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Action Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Treaty on Mutual Legal Assistance in Criminal Matters Between United States of America and France signed December 10, 1998, U.S.-Fr., Sept. 30, 2004, S. TREATY DOC. NO. 109-13 (2006)","Contributing Factors in Asset Recovery":"Ongoing case but the Department of Justice press release on March 5, 2014 noted, \u0022The department appreciates the extensive assistance provided by the Governments of Jersey, France and the United Kingdom in this investigation.\u0022 ","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"See related entry, Sani Abacha \/ United States Civil Asset Forfeiture case. \u00a0According to the US Department of Justice, the civil asset forfeiture complaint filed in November 2013 and unsealed in March 2014, \u0022seeks to forfeit bank accounts and investment portfolios with funds located in Bailiwick of Jersey, France and the United Kingdom. On Feb. 25 and 26, 2014, U.S. arrest warrants for the assets were enforced in Jersey and France though mutual legal assistance requests and in the United Kingdom through litigation brought pursuant to the U.K. Civil Jurisdiction and Judgments Act.\u0022 \u00a0(Sources: US \u00a0Department of Justice, Press release, \u0022U.S. Freezes More Than $458 Million Stolen by Former Nigerian Dictator in Largest Kleptocracy Forfeiture Action Ever Brought in the U.S.,\u0022 March 5, 2014; see also Order on request of Banque SBA issued by High Court of Paris on April 24, 2014, authorizing the bank to transfer more than $159 million, per criminal seizure order dated February 25, 2014, filed as exhibit in US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Warrants of arrest in rem filed July 11, 2014.)","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate. \u00a0(Source: \u00a0Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"High Court (Paris)","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_DOJ_Asset_Forfeiture_PR_Mar_5_2014_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_DDC_Forfeiture_Complaint_Unsealed_Mar_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_France_Seizure_Order_Apr_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_Forfeit_480_mil_DOJ_PR_Aug_7_2014_3.pdf","Sources ":"US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Verified Complaint for Civil Asset Forfeiture, unsealed on March 5, 2014 and available at:http:\/\/www.justice.gov\/iso\/opa\/resources\/765201435135920471922.pdf and Warrants in rem filed July 11, 2014, Order of High Court of Paris of April 24, 2014; US \u00a0Department of Justice, Press release, \u0022U.S. Freezes More Than $458 Million Stolen by Former Nigerian Dictator in Largest Kleptocracy Forfeiture Action Ever Brought in the U.S.,\u0022 March 5, 2014, available at: http:\/\/www.justice.gov\/opa\/pr\/2014\/March\/14-crm-230.html\n"},{"Case ID":"ARW-216","Case Title (Name of Public Official or Entity Allegedly Involved)":"Paulo Maluf \/ Brazil-Deutsche Bank settlement","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Brazil","Position of Public Official(s) (yrs in office)":"Governor and Mayor of Sao Paulo (Governor,1979-1983; Mayor, 1993-1996); Legislator (as of 2007)","Jurisdiction of Asset Recovery":"Germany","Jurisdiction of Asset Description":"","Asset Recovery Start":"2014","Asset Recovery End":"2014","UNCAC Offenses Implicated":"","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Settlement agreement","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Negotiated settlement","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to press releases by the city of Sao Paulo, the Deutsche Bank AG agreed on February 24, 2014 to pay $20 million to settle allegations that the bank helped manage funds embezzled by former city of S\u00e3o Paulo officials while Paulo Maluf was mayor of the city. On the total sum of the settlement, US $18 million will be paid to the city of Sao Paulo (towards construction of kindergartens), the rest will go to the State of Sao Paulo (US $1.5 million), a government fund dedicated to various interests (US$ 300,000), \u00a0and \u00a0for the payment of the legal fees related to the investigation (US$ 200,000). \u00a0According to public prosecution, settlements for similar allegations with UBS AG of Zurich, Safra National Bank of New York and Citigroup Inc of Geneva could be expected for an amount of US$ 60 million. (Source: \u00a0City of Sao Paulo Press Release, \u0022Prefeitura receber\u00e1 US$ 18 milh\u00f5es de banco envolvido em desvios\u0022, February 24, 2014 and \u0022Justi\u00e7a homologa acordo para banco alem\u00e3o indenizar Prefeitura em R$ 44 milh\u00f5es,\u0022 October 20, 2014, at http:\/\/www.capital.sp.gov.br\/portal\/noticia\/4870.) \u00a0According to a Reuters article, Mr. Silvio Marques, a prosecutor in the case, reported that Deutsche Bank was expected to deposit the proceeds from the settlement within the next 60 days following the settlement. \u00a0(Source: Reuters, \u0022Deutsche Bank to pay $20 mln to settle Brazil charges\u0022, February 24, 2014, available at: http:\/\/www.reuters.com\/article\/2014\/02\/24\/deutschebank-brazil-settlement...).\u00a0","Disposition of Criminal Case(s)":"\u00a0According to the March 8, 2007 press release by the New York County District Attorney\u0027s Office, Mr. Maluf was indicted in New York for his alleged conspiracy in embezzlement of public funds and concealment of such funds, and that charges were also pending against him in Brazil. \u00a0(Source: The People of the State of New York v. Paulo Maluf, Flavio Maluf, Simeao Damasceno de Oliveira, Joel Guedes Fernandes and Vivaldo Alves, Indictment filed on March 8, 2007 in New York state Supreme Court, County of New York and New York County District Attorney\u0027s Office, News Release on the Paulo Maluf case, March 8, 2007.) \u00a0According to Agence France Presse, on November 4, 2013, Mr. Maluf\u0027s conviction on \u0022administrative corruption\u0022 was upheld by a Brazilian court. (Source: Agence France Presse, \u0022Graft sentence upheld for ex-Sao Paulo ex-mayor,\u0022 November 4, 2013.)","Jurisdiction of Origin: Investigative Agency":"Brazilian Financial Intelligence Unit; Ministry of Justice; Federal Police","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General of the State of Sao Paulo, Prosecutor General of the Republic of Brazil","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_Deutschebank_Settlement_Sao_Paolo_State_PR_Feb_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_Brazil_Deutschebank_Settlement_Reuters_Feb_24_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_Brazil_Sao_Paulo_City_PR_Oct_20_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_Interpol_wanted_Feb_6_2015.pdf","Sources ":"City of Sao Paulo Press Releases, \u0022Prefeitura receber\u00e1 US$ 18 milh\u00f5es de banco envolvido em desvios\u0022, February 24, 2014, available at: http:\/\/www.capital.sp.gov.br\/portal\/noticia\/1862#.UyneGNLXbWM and \u0022Justi\u00e7a homologa acordo para banco alem\u00e3o indenizar Prefeitura em R$ 44 milh\u00f5es,\u0022 October 20, 2014, at http:\/\/www.capital.sp.gov.br\/portal\/noticia\/4870\n\tReuters,\u0022Deutsche Bank to pay $20 mln to settle Brazil charges\u0022, February 24, 2014, available at: http:\/\/www.reuters.com\/article\/2014\/02\/24\/deutschebank-brazil-settlement... Interpol Wanted list, at http:\/\/www.interpol.int\/notice\/search\/wanted\/2009-13608 (last accessed February 6, 2015.)\n"},{"Case ID":"ARW-218","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha \/ United Kingdom (Prohibition Order related to US Claim)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Asset Location\/Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Actions Initiated by a Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Instrument between the United States and the United Kingdom, signed December 2004, implementing the Agreement on Mutual Legal Assistance between the United States and the European Union","Contributing Factors in Asset Recovery":"Ongoing case; the High Court stated:  \u0022Corruption, like other types of fraud, is a global problem and it and its consequences are only going to be dealt with effectively if there is co-operation and assistance not only between the governments of states but also between the courts of different national jurisdictions. Orders enforcing US arrest warrants issued in the US Claim against property in Jersey and France have been made in those jurisdictions and I have no doubt that this court should follow suit and continue the Freezing Injunction ordered by Teare J on 25 February 2014.\u0022 (Source: para 48, United States of America (USA) v Abacha \u0026 Ors [2014] EWHC 993 (Comm) (08 April 2014)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"Ongoing Case","Case Summary":"In October 2014, the UK Court of Appeals overturned an earlier High Court decision and lifted the freezing injunction on Abacha related assets that are subject of a civil asset forfeiture proceedings in the U.S. (Source: \u00a0Blue Holding (1) Pte Ltd \u0026 Ors v United States of America [2014] EWCA Civ 1291 (09 October 2014)). \u00a0Thereafter a Prohibition Order took into effect against the properties. \u00a0(Source: National Crime Agency v. Abacha, 2015 EWHC 357 Admin, paras 4-10).\n\t\u00a0\n\tIn April 2014, the UK High Court issued a judgment in a case involving an application to continue a Freezing Injunction granted under s.25 of the Civil Jurisdiction and Judgments Act 1982 (\u0022the 1982 Act\u0022) ex parte by Teare J on 25 February 2014 and continued by Walker J on 25 March 2014. \u00a0The claimant was the United States of America, which had filed a civil asset forfeiture complaint against assets alleged to be proceeds of corruption of former Nigerian President Sani Abacha and family and associates. \u00a0The defendants were: (1) Mohammed Sani Abacha; (2) Abubakar Atiku Bagudu; (3) Mecosta Securities, Inc; (4) Ridley Group Limited; (5) Blue Holding (1) Pte Limted; (6) Blue Holding (2) Pte Limited; (7) Standard Bank plc; (8) HSBC Bank plc; (9) HSBC Life (Europe) Limited; (10) Waverton Investment Management Ltd; and (11) James Hambro \u0026 Partners LLP. \u00a0According to the decision, Mr. Abacha and Mr. Bagudu (D1 and D2) are alleged to control the assets which are the subject of a civil asset forfeiture claim in the US; respondents 3-6 are companies owned and\/or controlled by Mr. Abacha and Mr. Bagudu (D1 and D2) and used by them to hold the assets. \u00a0The court noted that D3 and D4 are \u0022BVI companies that have been struck off the BVI Companies Register for non-payment of statutory fees.\u0022 \u00a0(para 8) \u00a0D5 and D6 \u0022(together \u0027Blue Holdings\u0022) are Singaporean companies owned by a trust for the benefit of D2\u0027s family.\u0022 (para 11). \u00a0D7-D11 are \u0022banks and other financial institutions which are believed (as at dates in the last few years) to hold assets which are subject to the [US] forfeiture claim. No allegation of wrongdoing is made against these defendants.\u0022 (para 12) \u00a0According to the judgment, the following accounts and amounts are implicated: \u00a0\u0022(1) Standard Bank, which holds assets totalling US$21.7 million in two accounts in London in the name of D3; (2) the 8th and 9th Defendants (\u0022HSBC\u0022) which hold assets totalling US$1.6 million and [GBP] 940,000 in accounts i the name of the D1; and the 10th and 11th Defendants which it is alleged to hold assets totalling [EUR] 95 million in four accounts in the names of companies owned by a trust for the benefit of D2 and certain members of his family.\u0022 (para 14). \u00a0The Court also notes the 2003 Settlement agreement between the Federal Republic of Nigeria and D2 on behalf of himself and his \u0022affiliates\u0022 which in exchange for transfer of sums by D2 to the Nigerian government in exchange for \u0022renouncement by FRN of any interest whatsoever in certain scheduled assets that would be held by D2 free from any claims by FRN. \u00a0Included in those scheduled assets are assets the foreiture of which the Claimant seeks in the US claim.\u0022 (para 26). \u00a0The Court continues, \u0022It is pertinent to note that (1) although the Nigerian Request for Mutual Assistance addressed to the US Department of Justice under the UN Convention against Corruption [ ] made no mention of the fact that under the settlement with D2 he and his affiliates were permitted to retain free from any claim by the FRN the scheduled assets, and (2) the Claimant was unaware that the FRN had agreed that D2 and his affiliates could retain the scheduled assets until after these proceedings for relief under s. 25 of the 1982 Act were begun.\u0022 (para 27) \u00a0The Court upheld the freeze, stating: \u0022The application under s. 25 is not an application to enforce a foreign judgment but to continue an order designed to hold the ring until a judgment in the US claim can be lawfully enforced under the 2005 Order.\u0022 \u00a0(para 48) (Sources: United States of America (USA) v Abacha \u0026 Ors [2014] EWHC 993 (Comm) (08 April 2014); See also Between National Crime Agency and Mohammed Sani Abacha and others, Claim No. C0\/2986\/14 (High Court, Queen\u0027s Bench Division, Administrative Court), Prohibition Order of July 2, 2014, filed in US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Warrants of Arrest in Rem filed Jul 11, 2014.)","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate. \u00a0(Source: \u00a0Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"National Crime Agency","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"England and Wales Court of Appeals (Civil Division) and High Court (Commercial Court and Queen\u0027s Bench Division)","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/United%20States%20of%20America%20%28USA%29%20v%20Abacha%20%26%20Ors%20%5B2014%5D%20EWHC%20993%20%28Comm%29%20%2808%20April%202014%29.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_DOJ_Asset_Forfeiture_PR_Mar_5_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_Forfeit_480_mil_DOJ_PR_Aug_7_2014_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_UK_Prohibition_Order_Jul_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_UK_Prohibition_Order_Lift_EWCA_Civ_Oct_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_UK_NCA_v_Abacha_2015%20EWHC%20357%20Admin_21Jan2015.docx","Sources ":"\n\tNational Crime Agency v. Abacha, 2015 EWHC 357 Admin; Blue Holding (1) Pte Ltd \u0026 Ors v United States of America [2014] EWCA Civ 1291 (09 October 2014), at http:\/\/www.bailii.org\/cgi-bin\/markup.cgi?doc=\/ew\/cases\/EWCA\/Civ\/2014\/129...\n\n\t\u00a0\n\n\tUnited States of America (USA) v Abacha \u0026 Ors [2014] EWHC 993 (Comm) (08 April 2014), URL: http:\/\/www.bailii.org\/ew\/cases\/EWHC\/Comm\/2014\/993.html; Between National Crime Agency and Mohammed Sani Abacha and others, Claim No. C0\/2986\/14 (High Court, Queen\u0027s Bench Division, Administrative Court), Prohibition Order of July 2, 2014, filed in US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Warrants of Arrest in Rem filed Jul 11, 2014.\n\n\t\u00a0\n\n\tSee also related entry Sani Abacha \/ US Civil Assset Forfeiture case\n"},{"Case ID":"ARW-217","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha \/ United States civil asset forfeiture","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2013","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Asset Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"MLAT (France, UK); International Cooperation Act (Jersey); United Nations Convention against Corruption (Articles 54 and 55, Request by Nigeria to US)","Contributing Factors in Asset Recovery":"Ongoing case but the Department of Justice press release on March 4, 2014 noted, \u0022The department appreciates the extensive assistance provided by the Governments of Jersey, France and the United Kingdom in this investigation.\u0022 ","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance (in part), Investigation\/Asset Tracing\/Asset Restraint (in part)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"In August 2014, the US Department of Justice announced that more than US$480 million in Abacha corruption proceeds had been forfeited to the US: approximately US$303 million in two bank accounts in Bailiwick of Jersey, $144 million in 2 bank accounts in France [note: arrest in rem notes amount as US$159,374,531.89], and at least US$27 million in accounts in the UK and Ireland. \u00a0The Department of Justice also noted that claims against US$148 million in four investment portfolios in the UK are pending. (Sources: \u00a0US Department of Justice, \u0022U.S. Forfeits Over $480 Million Stolen by Former Nigerian Dictator in Largest Forfeiture Ever Obtained Through a Kleptocracy Action,\u0022 August 7, 2014; warrants for arrest in rem filed July 11, 2014 in US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, et al, Case No. l:13-cv-01832-JDB (D.D.C.).) \u00a0According to the Department of Justice, the restraint of funds includes approximately $313 million in the name of Mohammed Sani and Doraville Properties Corporation in two bank accounts in the Bailiwick of Jersey and $145 million in the name of Rayville International SA and Standard Alliance Financial Services Limited in two bank accounts in France. In addition, four investment portfolios (all assets held in name of Blue Holding traceable to Ridley Group limited) and three bank accounts in the name of Mecosta Securities and Mohammed Sani in the United Kingdom with an expected value of at least $100 million have also been restrained [ ] [and] also seeks to forfeit five corporate entities registered in the British Virgin Islands (Doraville Properties Corporation, Mecosta Securities Inc., Rayville International SA, Ridley group Limited, Standard Alliance Financial Services Limited). (Source: US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, Limited in Jersey, Channel Islands, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Verified Complaint for Civil Asset Forfeiture).The complaint alleged that General Abacha, his son Mohammed Sani Abacha, their associate Abubakar Atiku Bagudu and others embezzled, misappropriated and extorted billions from the government of Nigeria and the Central Bank of Nigeria on the false pretense that the funds were necessary for national security, then laundered their criminal proceeds through the purchase of bonds backed by the United States using U.S. financial institutions. (Source: Department of Justice, Press release, \u0022U.S. Freezes More Than $458 Million Stolen by Former Nigerian Dictator in Largest Kleptocracy Forfeiture Action Ever Brought in the U.S..\u0022 March 5, 2014.) \u00a0 Associates and family members of Mr. Abacha have filed Verified Claim and Statement of Interest in the property and filed a motion to dismiss the Government\u0027s Verified Claim and Government of Nigeria is also represented by counsel. As of June 2016, the case was ongoing (Source: US v. US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, Limited in Jersey, Channel Islands, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Court Docket Report as of June 27, 2016; Appearance of Counsel filed May 12, 2016)\n\t\t\t\u00a0\n\t\t\t\u00a0\n\u00a0","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate. \u00a0(Source: \u00a0Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Criminal Division, Anti-Kleptocracy Intiative, Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"United States District Court for the District of Columbia","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_DDC_Forfeiture_Complaint_Unsealed_Mar_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_DOJ_Asset_Forfeiture_PR_Mar_5_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_DDC_Order_Default_Aug_6_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_Forfeit_480_mil_DOJ_PR_Aug_7_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_Warrant_Main_Jul_11_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_France_Seizure_Order_Apr_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Jersey_Affidavit_Arrest_in_Rem_Mar_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_UK_Prohibition_Order_Jul_2014.pdf","Sources ":"\n\tUS v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, Limited in Jersey, Channel Islands, Case No. l:13-cv-01832-JDB (D.D.C.), Verified Complaint for Civil Asset Forfeiture, unsealed on March 5, 2014 and available at:http:\/\/www.justice.gov\/iso\/opa\/resources\/765201435135920471922.pdf; Warrants of arrest in rem filed July 11, 2014), and Court Docket Report as of June 27, 2016.\n\n\t\u00a0\n\n\tUS \u00a0Department of Justice, Press releases, \u0022U.S. Freezes More Than $458 Million Stolen by Former Nigerian Dictator in Largest Kleptocracy Forfeiture Action Ever Brought in the U.S.,\u0022 March 5, 2014, available at: http:\/\/www.justice.gov\/opa\/pr\/2014\/March\/14-crm-230.html and \u0022U.S. Forfeits Over $480 Million Stolen by Former Nigerian Dictator in Largest Forfeiture Ever Obtained Through a Kleptocracy Action,\u0022 August 7, 2014, at http:\/\/www.justice.gov\/opa\/pr\/2014\/August\/14-crm-835.html.\n"},{"Case ID":"ARW-212","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hector Javier Villarreal Hernandez \/ US Asset Forfeiture - Western District of Texas (Real Estate and Bank Account)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mexico","Position of Public Official(s) (yrs in office)":"Former Secretary of Finance, State of Coahuila (2005-2011)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort; Asset Location\/Alleged Asset Location","Asset Recovery Start":"2012","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Asset Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty (US-Mexico)","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"\u00a0See related cases involving assets in Bermuda. \u00a0According to the February 18, 2014 Amended Notice of Related Cases filed in US v. Villarreal Hernandez, et al, the following civil asset forfeiture cases have been filed in the US federal court for the Western District of Texas against real properties and bank account with value totalling nearly $23 million: \u00a0 US v. Real Property Known as an Exxon Service Station\/Convenience Store at 4425 E. 14th Street, Brownsville, Texas, Case No. 5:12-cv-377 (value $1,132,128); US v. Real Property Known as Peninsula Island Resort and Spa at 340 South Padre Island Blvd., Unit 602, Building B, South Padre Island, Texas, Case No. 12-cv-379 (value: $280,797); US v. Real Property Known as an Apartment Complex Located at 3454 Boca Chica Blvd., Brownsville, Texas (value: $799,958.00); \u00a0US v. Real Property Known as Javi\u0027s Carwash Located at 1317 W. Tyler, Harlington, Texas, Case No. 12-cv-374 (value: $307,503); US v. Real Property Known as Javi\u0027s Carwash Located at 5215 South Padre Highway, Brownsville, Texas, Case No. 12-cv-375 (value: $309,801); US v. Real Property Known as a Single-family Residence Located at 740 S. Central Ave., Brownsville, Texas, Case No. 12-cv-372 (value: $62,495.90); US v. Real Property Known as Strip\/Shopping Center Located at 3454 Boca Chica Blvd., Brownsville, Texas, Case No. 12-cv-382 (value: $361,147); US v. Real Property Known as White Orchid Apartment Complex Located at 3480 Boca Chica Blvd., Brownsville, Texas, Case No. 12-cv-378 \u00a0(value: $434,734); US v. Real Property Known as a Single-family Residence and Adjacent Lor Located and Situated at 3911 Luz Del Faro, San Antonio, Bexar County, Texas, Case No. 12-cv-383 (value: $1,355,970); US v. Real Property Known as the North Pointe Strip\/Shopping Center, More Fully Described as Lots 42, 43, 44 and 45, Block 6, New City Block 17586, San Antonio, Bexar County, Texas, Case No. 12-cv-381 (value: $6,324,570); US v. Real Property Known as CVS Store No. 8978 and Adjacent Vacant Lots Located and Situated at 20203 Stone Oak Parkway, San Antonio, Bexar County, Texas, Case No. 12-cv-376 (value: $3,943,810); US v. Real Property Known as Centurion Storage, a High Rise Mini-storage Facility Located and Situated at 2310 North Loop 1604 West, San Antonio, Bexar County, Texas, Case No. 12-cv-380 (value: $6,560,000); and US v. $1,214,232.59 seized from JP Morgan Chase Acct. (value: $1,214,232.59) (Sources: \u00a0US v. Villarreal Hernandez and Torres, Case No. 13-cr-01075 (S.D. Tex), Amended Notice of Related Cases filed February 18, 2014).\n\t\u00a0\n\tOn March 1, 2013, the Court granted the US Government\u0027s Motion and Ordered the civil asset forfeiture cases to be stayed pending resolution of all related criminal matters. The cases were reinstated on the Court\u0027s Docket in January 26, 2016 and was ongoing as of May 22, 2016. (Sources: \u00a0Court Docket reports as of May 22, 2016 in the above listed cases.) \u00a0\u00a0","Disposition of Criminal Case(s)":"As of May 22, 2016, Mr. Villareal Hernandez\u0027s sentencing in US Federal Court for the Western District of Texas on money laundering conspiracy charge, to which he had plead guilty, was continued to October 5, 2016. \u00a0(Source: US v. Villarreal Hernandez, Case No. 5:14-cr-00100 (W.D. Tex), Agreed and Unopposed, Sealed Motion for Continuance of Sentencing filed February 8, 2016 and Court Docket Report as of May 22, 2016.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Internal Revenue Service - Criminal Investigations","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney\u0027s Office for the Western District of Texas","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the Western District of Texas","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_Villarreal_SDTEX_Amended_Notice_Related_Cases_Feb_18_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_WDTEX_Apt_Complex_12-cv-373_Dkt_Rept_Jul_30_2014.pdf","Sources ":"US v. Villarreal Hernandez, Case No. 13-cr-01075 (S.D. Tex), Amended Notice of Related Cases filed February 18, 2014 and Court Docket Reports in the civil asset forfeiture cases listed in the summary.\n"},{"Case ID":"ARW-213","Case Title (Name of Public Official or Entity Allegedly Involved)":"Jorge Juan Torres \/ United States","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mexico","Position of Public Official(s) (yrs in office)":"General Director of the Promotion and Development, the Secretary of Finance of Coahuila state, Municipal President of Saltillo state and interim Governor of Coahuila state (1994-2011)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2013","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Asset Forfeiture; Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty (US-Mexico)","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"See also related case, Hector Javier Villarreal Hernandez (United States and Bermuda). \u00a0 In September 2013, the US Government filed a civil asset forfeiture complaint against Old Mutual of Bermuda, Ltd. Contract Number CX4011696 in Bermuda which it alleged constituted proceeds of corruption while Mr. Torres was serving in various government posts including as interm Governor of Coahuila state, Mexico. \u00a0In October 2013, the warrant for arrest in rem was executed by the Bermuda Police Service. \u00a0In March 2014, Mr. Torres and his wife filed an Answer to the complaint, not denying his government employment but denying allegations including that his government positions as sole source of income. \u00a0On August 3, an Order of Default Judgment was granted in the case in favor of the United States. \u00a0(Sources: \u00a0US v. All Funds on Deposit at Old Mutual of Bermuda, Ltd. Contract Number CX4011696 in Bermuda, Case No. 13-cv-00294 (S.D. Tex), Verified Complaint for Civil Forfeiture in Rem filed September 24, 2013; Executed Warrant of Arrest in Rem filed October 29, 2013; Answer (by Torres) filed March 28, 2014 and Court Docket Report as of October 28, 2015.)\n\t\u00a0\n\tIn the criminal case against Mr. Torres, in November 2014, the US Government filed a Supplemental Notice of Forfeiture of two properties located in Montgomery, Texas at 160 Hermitage Drive and 53 Southwind Drive, as having allegedly been acquired with proceeds of crime. \u00a0As of October 28, 2015, the criminal case against Mr. Torres is ongoing. \u00a0(Source: \u00a0US v. Torres, Case No. 2:13-cr-1075-2 (S.D. Tex), Indictment filed November 20, 2013 and Supplemental Notice of Forfeiture filed November 17, 2014.)","Disposition of Criminal Case(s)":"Mr. Torres is under indictment in the US Federal Court for the District of Southern Texas on a charge of money laundering conspiracy. \u00a0(Source: \u00a0US v. Hernandez Villarreal and Torres, Case No. 2:13-cr-1075 (SD Tex), Indictment filed November 20, 2013 and Court Docket Report as of May 22, 2016.\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Origin: Courts Involved":"Unknown","Jurisdiction of Asset Recovery: Investigative Agency":"Internal Revenue Service - Criminal Investigations","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney\u0027s Office for the Southern District of Texas","Jurisdiction of Asset Recovery: Courts Involved":"United States District Court - Southern District of Texas","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_Nigeria_EFCC_High_Profile_Cases.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Charges_Saharareporters_Apr_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Remanded_Custody_BBC_Apr_16_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTEX_Old_Mutual_Bermuda_Acct_Forfeiture_Complaint_Sep_24_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_Nigeria_EFCC_High_Profile_Cases.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Charges_Saharareporters_Apr_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Remanded_Custody_BBC_Apr_16_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTEX_Old_Mutual_Bermuda_Account_Exec_Arrest_in_Rem_Oct_29_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_Nigeria_EFCC_High_Profile_Cases.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Charges_Saharareporters_Apr_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Remanded_Custody_BBC_Apr_16_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTEX_Old_Mutual_Bermuda_Acct_Answer_Mar_28_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_Nigeria_EFCC_High_Profile_Cases.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Charges_Saharareporters_Apr_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Remanded_Custody_BBC_Apr_16_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTex_Suppl_Forfeit_Notice_Nov_17_2014_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_Nigeria_EFCC_High_Profile_Cases.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Charges_Saharareporters_Apr_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Remanded_Custody_BBC_Apr_16_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTEX_Bermuda_Acct_Default%20Judgment_Aug3%202015_0.pdf","Sources ":"Civil Asset Forfeiture Case: US v. All Funds on Deposit at Old Mutual of Bermuda, Ltd. Contract Number CX4011696 in Bermuda, Case No. 13-cv-00294 (S.D. Tex), Verified Complaint for Civil Forfeiture in Rem filed September 24, 2013; Executed Warrant of Arrest in Rem filed October 29, 2013; Answer (by Torres) filed March 28, 2014; Order of Default Judgment, August 3, 2015. \u00a0 Criminal Case: US v. Hernandez Villarreal and Torres, Case No. 2:13-cr-1075 (SD Tex), Supplemental Notice of Forfeiture filed November 17, 2014 and Court Docket Report as of May 22, 2016.\n"},{"Case ID":"ARW-215","Case Title (Name of Public Official or Entity Allegedly Involved)":"Jorge Juan Torres \/ Bermuda Account","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mexico","Position of Public Official(s) (yrs in office)":"General Director of the Promotion and Development, the Secretary of Finance of Coahuila state, Municipal President of Saltillo state and interim Governor of Coahuila state (1994-2011)","Jurisdiction of Asset Recovery":"Bermuda","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2013","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Execution of Foreign Warrant of Arrest in Rem (Bermuda); Non-Conviction Based Asset Forfeiture (United States)","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"See also related case, Hector Javier Villarreal Hernandez (United States and Bermuda). \u00a0 In September 2013, the US Government filed a civil asset forfeiture complaint against Old Mutual of Bermuda, Ltd. Contract Number CX4011696 in Bermuda which it alleged constituted proceeds of corruption while Mr. Torres was serving in various government posts including as interm Governor of Coahuila state, Mexico. \u00a0In October 2013, the warrant for arrest in rem was executed by the Bermuda Police Service. \u00a0In March 2014, Mr. Torres and his wife filed an Answer to the complaint, not denying his government employment but denying allegations including that his government positions as sole source of income. \u00a0On August 3, 2015, a Default Judgment was entered against the assets in favor of the United States. \u00a0(Sources: \u00a0US v. All Funds on Deposit at Old Mutual of Bermuda, Ltd. Contract Number CX4011696 in Bermuda, Case No. 13-cv-00294 (S.D. Tex), Verified Complaint for Civil Forfeiture in Rem filed September 24, 2013; Executed Warrant of Arrest in Rem filed October 29, 2013; Answer (by Torres) filed March 28, 2014 and Order of Default Judgment of August 3, 2015.","Disposition of Criminal Case(s)":"Mr. Torres is under indictment in the US Federal Court for the District of Southern Texas on a charge of money laundering conspiracy. \u00a0 (Source: \u00a0US v. Hernandez Villarreal and Torres, Case No. 2:13-cr-1075 (SD Tex), Indictment filed November 20, 2013 and Court Docket Report as of May 22, 2016.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Bermuda Police Service (execution of warrant of arrest in rem)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Dahdaleh_UK_SFO_Press_Release_Oct_24_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTEX_Old_Mutual_Bermuda_Account_Exec_Arrest_in_Rem_Oct_29_2013_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Dahdaleh_UK_SFO_Press_Release_Oct_24_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTEX_Old_Mutual_Bermuda_Acct_Forfeiture_Complaint_Sep_24_2013_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Dahdaleh_UK_SFO_Press_Release_Oct_24_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTEX_Old_Mutual_Bermuda_Acct_Answer_Mar_28_2014_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Dahdaleh_UK_SFO_Press_Release_Oct_24_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTEX_Indictment_Nov_20_2013_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Dahdaleh_UK_SFO_Press_Release_Oct_24_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTEX_Bermuda_Acct_Default%20Judgment_Aug3%202015.pdf","Sources ":"Civil Asset Forfeiture Case: US v. All Funds on Deposit at Old Mutual of Bermuda, Ltd. Contract Number CX4011696 in Bermuda, Case No. 13-cv-00294 (S.D. Tex), Verified Complaint for Civil Forfeiture in Rem filed September 24, 2013; Executed Warrant of Arrest in Rem filed October 29, 2013; Answer (by Torres) filed March 28, 2014; Order of Default Judgment, August 3, 2015. \u00a0Criminal Case: US v. Hernandez Villarreal and Torres, Case No. 2:13-cr-1075 (SD Tex), Indictment filed November 20, 2013 and Court Docket Report as of May 22, 2016.)\n"},{"Case ID":"ARW-211","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha (Liechtenstein)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"Liechtenstein","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"2014","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction; Criminal Prosecution","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"\u0022Liechtenstein and Nigeria are States Parties to the United Nations Convention against Corruption (UNCAC). Liechtenstein fully recognizes its obligation to prosecute all forms of corruption together with the other States Parties and to repatriate confiscated assets associated with corruption to the injured States.\u0022  (Source:  Principality of Liechtenstein Press Release, \u0022Return of \u0027Abacha Assets,\u0022 June 18, 2014.);  Investigatory assistance and cooperation by a number of countries, involvement of Stolen Asset Recovery Initiative and World Bank agreement to monitor use of funds (Sources: Ibid., and Emile van der Does de Willebois, \u0022No Statute of Limitations for Corruption:  Liechtenstein returns $225 million in stolen assets to Nigeria,\u0022 Stolen Asset Recovery Initiative Blog, June 19, 2014.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$233,795,000","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"World Bank monitoring of use of returned assets","Case Summary":"In June 2014, the Principality of Liechtenstein announced that it was returning approximately $225 milion in Abacha-related assets to Nigeria: \u00a0\u0022In its meeting on 17 June 2014, the Government approved repatriation to the Federal Republic of Nigeria of the last tranche of the assets associated with the family of the former president of Nigeria, General Abacha, in the amount of EUR 167 million. These assets had been declared forfeited to the Principality of Liechtenstein in a final judgment. At the same time, at the request of Nigeria and in accordance with Liechtenstein the World Bank declared its willingness to monitor the use of the repatriated assets.\n\t\u00a0\n\tOn the basis of suspicious activity reports submitted to the Financial Intelligence Unit of Liechtenstein, the Liechtenstein Office of the Public Prosecutor launched corruption investigations in 2000. In 2008, the Criminal Court sentenced several companies attributed to the Abacha family to the payment of a sum of money proven to have been taken from the national budget of Nigeria. With the judgment of the Constitutional Court in 2012, the recovery of the assets became final. Since several companies did not surrender the assets subject to the recovery order, enforcement proceedings had to be carried out.\n\t\u00a0\n\tUpon conclusion of these proceedings, the assets held by one of the companies in the amount of EUR 7.5 million were repatriated to Nigeria at the end of 2013.\n\t\u00a0\n\tHowever, four of the companies affected by the Abacha case filed a complaint against the Principality of Liechtenstein at the European Court of Human Rights (ECtHR) in Strasbourg in August 2012, leading to a further delay in the repatriation of the remaining assets on liability grounds. In January 2014, talks were held at the governmental level in this regard between Nigeria and Liechtenstein. In May 2014, the complaint pending in Strasbourg was withdrawn by the four Abacha companies, clearing the path for repatriation of the assets once and for all.\u0022 \u00a0(Source: \u00a0Principality of Liechtenstein Press Release, \u0022Return of \u0027Abacha Assets,\u0022 June 18, 2014.) \u00a0 \u00a0","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate. \u00a0(Source: \u00a0Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"Special Panel established to investigate Abacha looting","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Financial Intelligence Unit; Office of the Public Prosecutor","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Office of the Public Prosecutor","Jurisdiction of Asset Recovery: Courts Involved":"Criminal Court; Constitutional Court","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/StGH2012187_3753_140110033700_Liechtenstein_Abacha_Mar_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Liechtenstein_StGH2010_125.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Liechtenstein_StGH2011_078.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Liechtenstein_StGH2011_098.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Liechtenstein_Nigeria%20fights%20to%20recover%20Abacha%20funds_%20FT_Oct_10_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Liechtenstein_Okonjo-Iweala_%E2%82%AC185m%20Abacha%20loot_Vanguard%20News_Oct_14_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Liechtenstein_Repatriation_Assets_PR_Jun_18_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Liechtenstein_AR_Return_Vanderdoes_StAR_blog_Jun_19_2014_0.pdf","Sources ":"Principality of Liechtenstein Press Release, \u0022Return of \u0027Abacha Assets,\u0022 June 18, 2014, at http:\/\/www.regierung.li\/en\/press-releases\/press-releases\/english-press-r...\n\t\u00a0\n\tEmile van der Does de Willebois, \u0022No Statute of Limitations for Corruption: \u00a0Liechtenstein returns $225 million in stolen assets to Nigeria,\u0022 Stolen Asset Recovery Initiative Blog, June 19, 2014, at https:\/\/star.worldbank.org\/star\/content\/no-statute-limitations-corruption;\n\t\u00a0\n\tFinancial Times, \u0022Nigeria fights to recover Abacha funds from Liechtenstein\u0022, October 10, 2013, accessed at:http:\/\/www.ft.com\/intl\/cms\/s\/0\/2dac07c8-31bd-11e3-a16d-00144feab7de.html... Reuters, \u0022Nigeria says Liechtenstein making excuses to keep Abacha loot\u0022, October 14, 2013, accessed at: http:\/\/www.reuters.com\/article\/2013\/10\/14\/us-nigeria-liechtenstein-abach... \u0022Okonjo-Iweala laments Liechtenstein\u2019s attitude on \u20ac185m Abacha loot\u0022, accessed at: http:\/\/www.vanguardngr.com\/2013\/10\/okonjo-iweala-laments-liechtensteins-...\n\t\u00a0\n\tLiechtenstein constitutional court decisions accessed at: \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0\u00a0\n\thttp:\/\/www.gerichtsentscheidungen.li\/default.aspx?mode=suche\u0026txt=maryam\u0026...\n\t\u00a0\n\thttp:\/\/www.gerichtsentscheidungen.li\/default.aspx?mode=suche\u0026txt=maryam\u0026...\n\t\u00a0\n\thttp:\/\/www.gerichtsentscheidungen.li\/default.aspx?mode=suche\u0026txt=maryam\u0026...\n"},{"Case ID":"ARW-210","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hosni Mubarak (Spain)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Egypt","Position of Public Official(s) (yrs in office)":"President (1981-2011)","Jurisdiction of Asset Recovery":"Spain","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"","Intl.Cooperation: MLAT\/Letter of Request?":"Letter of Request","Basis for Intl Cooperation":"United Nations Convention against Corruption ","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"","Case Summary":"According to a December 13, 2012 press release by the National Police, EUR 28 million in financial instruments, properties in Madrid and Marbella, and luxury vehicles have been frozen. \u00a0The Spanish investigation into the assets located in Spain belonging to the former President Mubarak, his family, associates and related entities encompassed over 130 individuals. \u00a0(Source: \u00a0Cuerpo Nacional de Policia, Nota de Prensa, \u0022La Polic\u00eda Nacional ejecuta una comisi\u00f3n rogatoria internacional \/ Localizados en Espa\u00f1a 28.000.000\u20ac en productos financieros y propiedades inmobiliarias vinculados a Hosny Mubarak,\u0022 December 13, 2012.)","Disposition of Criminal Case(s)":"According to the New York Times and other sources, in May 2014, Mr. Mubarak was convicted on charge of embezzlement and sentenced to three years\u0027 imprisonment. (Source: \u00a0David Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Central Economic Crime Unit (Unidad Central de Delincuencia Econ\u00f3mica); Fiscal de la Comisar\u00eda General de Polic\u00eda Judicial","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Perez-Llorca Law Firm (Madrid)","Jurisdiction of Asset Recovery: Courts Involved":"Central Economic Crime Unit (Unidad Central de Delincuencia Econ\u00f3mica); Fiscal de la Comisar\u00eda General de Polic\u00eda Judicial","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_Spain_Asset_Freeze_National_Police_Dec_13_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_Embezzlement_Verdict_NYTimes_May_21_2014_1.pdf","Sources ":"Cuerpo Nacional de Policia, Notas de Prensa, \u0022La Polic\u00eda Nacional ejecuta una comisi\u00f3n rogatoria internacional \/ Localizados en Espa\u00f1a 28.000.000\u20ac en productos financieros y propiedades inmobiliarias vinculados a Hosny Mubarak,\u0022 December 13, 2012, at http:\/\/www.policia.es\/prensa\/20121213_1.html; \u00a0David Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014, at http:\/\/www.nytimes.com\/2014\/05\/22\/world\/middleeast\/hosni-mubarak-trial.html\n"},{"Case ID":"ARW-214","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (South Africa)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"South Africa","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"","Legal Basis for Asset Recovery":"United Nations Security Council Resolution","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Ongoing","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Other","Assets Frozen (USD)":"Unspecified","Assets Adjudicated, Not Yet Returned (USD)":"Unspecified Amount","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"","Case Summary":"In June 2013, South Africa\u0027s Minister of Finance announced that his country would return unspecified amount of assets to Libya. In a June 20, 2013 statement, the Minister stated: \u0022The facts of this matter are as follows: \uf0a7 There are Libyan shareholdings in South African entities that were made on a commercial basis. These include the Michelangelo Towers in Sandton, the Centurion Lake Hotel, the Commodore and Portswood Hotels in Cape Town, and the Kruger Park Lodge in Mpumalanga. \uf0a7 Then there have been allegations of Libyan funds and assets that were brought to South Africa under dubious circumstances. None of the people who have made these allegations have produced evidence regarding the transfer of these assets and funds to South Africa. Those who have evidence should hand it over to the relevant Libyan or United Nations authorities.\u0022 (Sources: Republic of South Africa, Ministry of Finance, Media Statement by Minister Gordhan on Repatriation from South Africa of Libyan Funds and Assets, June 13, 2013 and Statement by Minister Gordhan to Clarify the Issue of Libyan Assets and Funds, June 20, 2013.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Qaddafi_South_Africa-Finance_Min_Repatriate_Assets_Jun_13_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Qaddafi_South_Africa_Finance_Min_Clarification_Jun_20_2013.pdf","Sources ":"Republic of South Africa, Ministry of Finance, Media Statement by Minister Gordhan on Repatriation from South Africa of Libyan Funds and Assets, June 13, 2013, at http:\/\/www.treasury.gov.za\/comm_media\/press\/2013\/2013061301.pdf and Statement by Minister Gordhan to Clarify the Issue of Libyan Assets and Funds, June 20, 2013 at http:\/\/www.treasury.gov.za\/comm_media\/press\/2013\/2013062101.pdf\n"},{"Case ID":"ARW-84","Case Title (Name of Public Official or Entity Allegedly Involved)":"Carlos Garcia \/ Clarita Garcia \/ Timothy Mark D. Garcia (New York Bank Accounts)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"Former Comptroller of the Philippine Armed Forces (Carlos Garcia,1990-2004), Wife (Clarita Garcia), Son (Timothy Mark)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"2015","UNCAC Offenses Implicated":"Art.15, Art.17, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"","Case Summary":"Related to the General Carlos Garcia corruption cases in the Philippines, the U.S. filed criminal and civil actions against members of the Garcia family and their US assets.\u00a0 The actions include this 2012 civil asset forfeiture case filed against two bank accounts in New York totalling $245,520.94.\u00a0 According to the complaint filed in the case, the assets were proceeds of General Garcia\u0027s corruption and as part of the plea agreement in his Philippines case, his wife and son forfeited the accounts to the Government of Philippines.\u00a0 The US had alleged that Clarita Garcia had smuggled the cash into the US in 2003-2004 and deposited them into accounts belonging to herself and her son, and over $1.3 million were wire transferred from a Philippines bank to accounts in the U.S. On April 18, 2013, a Default Judgment was ordered in favor of the U.S. (Sources:\u00a0 US v. $201,166.08 in US Currency and [\u00a0 ] $44,354.86 in US currency [ ] in name of ICJ Access Worldwide, Case No. 1:12-cv-9388 (SDNY), Verified Claim filed December 26, 2012 and Default Judgment filed April 18, 2013).\nAccording to a statement by the US Embassy Manila, on June 3, 2015, \u0022U.S. Ambassador Philip S. Goldberg presented Ombudsman Conchita Carpio-Morales with a check in the amount of U.S. $1,384,940.28 payable to the Republic of the Philippines. The check represents \u201cill-gotten\u201d gains acquired by former AFP Comptroller General Carlos F. Garcia.\u00a0 [\u00a0 ]\u00a0 Philippine and U.S. investigators worked closely together to determine that General Garcia laundered a substantial portion of his criminal proceeds through the United States.\u00a0 In particular, investigators with the U.S. Department of Homeland Security traced the criminal proceeds to two Citibank accounts in New York and a condominium in Trump Tower in New York.\u00a0 The U.S. Attorney\u0027s Office for the Southern District of New York then initiated civil forfeiture proceedings against those assets and eventually obtained default judgments of forfeiture.\u00a0 The net proceeds resulting from the sale of the condominium and the funds from the two Citibank accounts were returned to the Philippines by the United States today.\u0022\u00a0 (Source: US Embassy Manila, \u0022U.S. Helps Philippines Recover \u0027Ill-Gotten Gains\u0027\u201d, June 3, 2015, at http:\/\/manila.usembassy.gov\/press-photo-releases-2015\/us-helps-philippines-recover-ill-gotten-gains.html.)\n\u00a0","Disposition of Criminal Case(s)":"According to a June 3, 2015 statement by the Ombudsman of the Philippines, \u0022the Office of the Ombudsman filed criminal cases of perjury, money laundering and plunder against [Carlos] Garcia who eventually was convicted of perjury by the Sandiganbayan.\u00a0 In the last two criminal cases, Garcia pleaded to the lesser offenses of Indirect Bribery and Facilitating Money Laundering, which plea bargaining is the subject of review by the Supreme Court.\u00a0 Meanwhile, forfeiture proceedings are pending with the Sandiganbayan.\u0022\u00a0 (Source:\u00a0 Office of the Ombudsman, \u0022US turns over $1.38M proceeds of Garcia\u2019s forfeited assets,\u0022 June 3,2015.)\nAccording to the April 5, 2005 Information against former Mr. Garcia, his wife Clarita Garcia and their sons Ian Carl, Juan Paulo and Timothy Mark D. Garcia, the Philippines Ombudsman\u0027s Office had charged them with committing the crime of Plunder.\u00a0 (Source:\u00a0 In the Matter of Extradition of Clarita Depakakibo Garcia, Case No. 2:09-mc-50231 (E.D. Mich.), Annex A to Extradition compaint filed on March 4, 2009).\u00a0 In November 2010, Ian Carl and Juan Paulo Depakakibo were sentenced to time served by U.S. District Court for the Northern District of California, subsequent to their guilty plea on bulk cash smuggling charge.\u00a0\u00a0 (Source: U.S. v. Ian Carl Depakakibo and Juan Paulo Depakakibo, Case No. 08-cr-00888-MHP (N.D. Cal.), Judgment in a Criminal Case, filed on December 1, 2010.)\n\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Ombudsman, Office of the Special Prosecutor","Jurisdiction of Origin: Courts Involved":"Sandiganbayan Supreme Court (Third Division)","Jurisdiction of Asset Recovery: Investigative Agency":"Department of Homeland Security","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"US Attorney for the Southern District of New York","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Garcia_SDNY_Currency_Forfeit_Complaint_Dec_26_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Garcia_SDNY_Currency_Default_Judgment_Apr_18_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Gacria_US_SDNY_Asset%20Return_USEmbassy%20Manila%20Press_Jun3_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Garcia_US%20Asset%20Return_Phil%20Ombudsman_statement_Jun3_2015.pdf","Sources ":"US v. $201,166.08 in US Currency and [\u00a0 ] $44,354.86 in US currency [ ] in name of ICJ Access Worldwide, Case No. 1:12-cv-9388 (SDNY), Verified Claim filed December 26, 2012 and Default Judgment filed April 18, 2013; US Embassy Manila, \u0022U.S. Helps Philippines Recover \u0027Ill-Gotten Gains\u0027\u201d, June 3, 2015, athttp:\/\/manila.usembassy.gov\/press-photo-releases-2015\/us-helps-philippines-recover-ill-gotten-gains.html; Office of the Ombudsman, \u0022US turns over $1.38M proceeds of Garcia\u2019s forfeited assets,\u0022 June 3,2015, at http:\/\/www.ombudsman.gov.ph\/index.php?home=1\u0026pressId=NjU3\n"},{"Case ID":"ARW-207","Case Title (Name of Public Official or Entity Allegedly Involved)":"Zine El Abidine Ben Ali (Lebanon)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Tunisia","Position of Public Official(s) (yrs in office)":"President (1987-2011)","Jurisdiction of Asset Recovery":"Lebanon","Jurisdiction of Asset Description":"Location of Recovery Effort; Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"2013","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Confiscation (Tunisia)","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Efforts by Tunisia, including Tunisian Financial Intelligence Unit, the Committee for the Return of Stolen Assets, and Ministry of Justice; International and Regional Cooperation, including through the Arab Forum on Asset Recovery organized by Qatar and United States Presidency of the G8 (Source: Jean Pierre Brun and Richard Miron, \u0022Tunisia\u0027s cash back: the start of more to come?,\u0022 Public Sector Development Blog, World Bank, April 15, 2013.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"","Case Summary":"According to a December 2012 decision by the Fifth Chamber of the Beirut Court of Appeals, upon examination and consideration of the petition submitted by the Republic of Tunisia by way of the Ministry of Justice, the Court granted the writ of execution for the decision rendered by the Fifth Criminal circuit of the Court of First Instance in Tunisia, ordering the confiscation of the assets of Leila Bent Mohammed Bent Rahouma-al-Trabelsi deposited in her bank account at the Lebanese Canadian Bank S.A.L. in Lebanon. \u00a0The petitioner was ordered to bear fully the fees and expenses in the case. \u00a0(Source: Unpublished decision issued in Case No. 893, December 12, 2012.) \u00a0 According to a blog by the Stolen Asset Recovery Initiative, the funds were \u0022handed over [by Lebanon] in the form of a check to Tunisia\u0027s current President Moncef Marzouki by Ali bin Fetais-al-Marri\u0022 Attorney General of Qatar and UNODC Special Advocate on Stolen Asset Recovery.\u0022 (Source: \u00a0Jean Pierre Brun and Richard Miron, \u0022Tunisia\u0027s cash back: the start of more to come?,\u0022 Public Sector Development Blog, World Bank, April 15, 2013.)","Disposition of Criminal Case(s)":"According to a January 26, 2011 media release by INTERPOL, Mr. Ben Ali\u0027s arrest was sought by Tunisia on charges of alleged property theft and illegal transfer of foreign currency. \u00a0(Source: INTERPOL media release, \u0022Tunisia seeks ousted President and family via INTERPOL,\u0022 January 26, 2011) \u00a0According to secondary sources, Mr. Ben Ali was convicted in absentia in June 2011 on theft and unlawful possesion of cash and jewelry; \u00a0in July 2011, he was convicted of property related charges. (Source: \u00a0BBC News, \u0022Tunisia\u0027s Ben Ali guilty on drugs and gun charges,\u0022 July 4, 2011 and \u0022Tunisia\u0027s Ben Ali guilty of corrupt property deals,\u0022 July 29, 2011) and in June 2012, he was sentenced \u00a0by a Tunisian military court to life imprisonment for his complicity in the murder and attempted murder of demonstrators; Human Rights Watch noted that Mr. Ben Ali has been tried and convicted in absentia and if he returned to Tunisia, he would be entitied to a new trial. (Source: \u00a0Clive Baldwin, \u0022After Ben-Ali\u0027s Conviction: The State of Tunisian Justice,\u0022 Human Rights Watch, June 16, 2012.) \u00a0\n\t\u00a0","Jurisdiction of Origin: Investigative Agency":"Tunisian Financial Intelligence Unit, the Committee for the Return of Stolen Assets, Ministry of Justice","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Ministry of Justice","Jurisdiction of Origin: Courts Involved":"Fifth Criminal Circuit of the Court of First Instance","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Ministry of Justice","Jurisdiction of Asset Recovery: Courts Involved":"Fifth Chamber of the Beirut Court of Appeals","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_Lebanon_StAR_blog_Apr_15_2013.pdf","Sources ":"Fifth Chamber of the Beirut Court of Appeals, Decision issued in Case No. 893, December 12, 2012 (unpublished); Jean Pierre Brun and Richard Miron, \u0022Tunisia\u0027s cash back: the start of more to come?,\u0022 Public Sector Development Blog, World Bank, April 15, 2013, accessed at http:\/\/blogs.worldbank.org\/psd\/tunisias-cash-back-the-start-of-more-to-come.)\n"},{"Case ID":"ARW-123","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hector Javier Villareal Hernandez \/ Bermuda","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mexico","Position of Public Official(s) (yrs in office)":"Former Secretary of Finance, State of Coahuila (2005-2011)","Jurisdiction of Asset Recovery":"Bermuda","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Execution of Foreign Warrant of Arrest in Rem (Bermuda); Non-Conviction Based Confiscation (in United States)","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"($2,275,544.41 frozen in Bermuda; amount included in US entry only to avoid double counting)","Assets Returned (USD)":"","Agreement for Returned Assets":"NA","Agreement for Returned Assets - Description":"","Case Summary":"\n\n\t\t\u00a0\n\n\n\tAccording to the Agreed Final Judgment of Forfeiture filed on January 15, 2015 in the US District Court for the Southern District of Texas, the assets were forfeited to the United States, including after Mr. Villareal Hernandez agreed to the forfeiture. \u00a0(Source: \u00a0US v. All Funds on Deposit At Sun Secured Advantage Account Number 26-2673-031320, Case No. 2:13-cv-00033 (S.D. Tex)). \u00a0\n\n\t\u00a0\n\n\tAccording to the US Department of Justice Press Release dated February 6, 2013, \u0022The United States has seized a bank account located in Bermuda alleged to have been owned by former State of Coahuila, Mexico, Secretary of Finance Hector Javier Villareal Hernandez [ \u00a0]. \u00a0The account, which is held in Bermuda, Sun Secured Advantage account at N.T. Butterfield and Son Limited, contained $2,275,544.41 as of Jan. 4, 2013. The government alleged, as its basis for forfeiture, that the funds in the account were involved in a money laundering transaction, that the property constitutes or was derived from proceeds traceable to offenses including bribery of a public official, or the misappropriation, theft or embezzlement of public funds by or for the benefit of a public official. [ \u00a0]\u00a0\n\n\t\u00a0\n\n\tIn approximately December 2005, Hernandez was appointed by then Governor of Coahuila Humberto Moreira to the position of Under Secretary of Program and Budget for Coahuila. In July 2008, Hernandez was appointed by the same governor to the position of Secretary of Finance for Coahuila. On Aug. 19, 2011, Hernandez resigned that position and became a subject of investigation by the government of Mexico. On Oct. 28, 2011, a local judge from Coahuila charged Hernandez with forging state documents to obtain fraudulent loans for several million pesos between 2008 and 2011. On Oct. 29, 2011, Hernandez was arrested and released on bond. He later fled and remains a fugitive on those charges.\n\n\t\u00a0\n\n\tAccording to the civil complaint, in 2011, Mexican law enforcement officials initiated an investigation involving fraudulent loans obtained from Mexican banks by Hernandez while he held the position of Secretary of Finance. The investigation includes three fraudulent loans from two different Mexican banks from July 2010 to March 2011 totaling more than $3 billion Mexican Pesos ($246 million U.S. dollars based on exchange rates on the dates of the loans). On Feb. 3 and March 8, 2012, Mexican government authorities filed false loan charges and issued arrest warrants for Hernandez\u2019s involvement in the false loans with two Mexican banks. The charges allege Hernandez and other co-conspirators acquired loans by providing false information to Mexican banks. The false information involved the use of false registry stamps or previously approved registry stamps used on the false loan contracts.\u00a0\n\n\t\u00a0\n\n\tThe conspiracy is alleged in the complaint to have begun when Hernandez requested a loan on behalf of the State of Coahuila. He then drafted and submitted a false loan contract for approval by the federal Treasury Department. Hernandez conspired to falsify the approval of the submitted loan contract. His alleged co-conspirators, who worked at the federal Treasury Department, placed a fraudulent federal registry stamp or a previously approved registry stamp on the loan contract to make it appear that the loan contract had been approved. After the loan contract obtained the false registry stamp or previously approved registry stamp and received \u0022approval,\u0022 the contract was submitted to a Mexican federal bank for issuance of a loan to the State of Coahuila. Once the loan proceeds were obtained, they were available for use by the State of Coahuila. [ ]\u00a0\n\n\t\u00a0\n\n\tHernandez opened an offshore investment account in Bermuda during this time period. Since April 2009, it is estimated that Hernandez and his associates received more than $35 million through foreign exchange transactions and cross border wires and subsequently purchased numerous real properties in San Antonio, Brownsville and South Padre Island with the illegal proceeds.\u0022 \u00a0(Source: \u00a0The United States Attorney\u0027s Office - Southern District of Texas, \u0022Bermuda Bank Account Allegedly Owned by Former Mexican Secretary of Finance Seized by US,\u0022 February 6, 2013.) \u00a0\n\n\t\u00a0\n\n\tOn March 3, 2013, a Senator from the Mexican state of Coahuila filed a claim, on behalf of himself and citizens of that state, for the seized funds on the basis that the funds were \u0022embezzled and stolen from and belong to the State of Coahuila, Mexico.\u0022 \u00a0He sought to \u0022recover the Defendant Funds fo return to the treasury of the State of Coahuila, Mexico.\u0022 \u00a0(Source: \u00a0US v. All Funds on Deposit At Sun Secured Advantage Account Number 26-2673-031320, Case No. 13-cv-33 (S.D. Tex), Verified Claim of Senator Luis Fernando Salazar Fernandez Contesting Asset Forfeiture, filed March 13, 2013.) \u00a0 On June 24, 2013, Senator Salazar withdrew his claim, stating \u0022he wil continue to pursue remission of the Defendant funds throught he Department of Justice.\u0022 \u00a0(Source: US v. All Funds on Deposit At Sun Secured Advantage Account Number 26-2673-031320, Case No. 13-cv-33 (S.D. Tex), Notice of Withdrawl of Claim filed June 24, 2013.)\n\n\t\u00a0\n\n\tIn January 2014, the US filed a notice of Mutual Legal Assistance request to Mexico, requesting assistance that notice of the asset forfeiture action be sent directly to anyone, including Mr. Hernandez (account holder) and his wife, who reasonably appears to have interest or claim in the property subject to forfeiture. \u00a0In March, Mr. Hernandez filed an answer to the complaint and a verified claim claiming that he was the lawful owner of the Defendant funds. \u00a0(Sources: \u00a0US v. All Funds on Deposit at Sun Secure Advantaged Account Number 26-2673-031320..., Case No. 2:13-cv-33 (S.D. Tex.), Notice of Mutual Legal Assistance filed on January 8, 2014; Answer to Complaint filed March 11, 2014; and Verified Claim filed March 18, 2014.)\u00a0","Disposition of Criminal Case(s)":"As of May 22, 2016, Mr. Villareal Hernandez\u0027s sentencing in US Federal Court for the Western District of Texas on money laundering conspiracy charge, to which he had plead guilty, was continued to October 5, 2016. \u00a0(Source: US v. Villarreal Hernandez, Case No. 5:14-cr-00100 (W.D. Tex), Agreed and Unopposed, Sealed Motion for Continuance of Sentencing filed February 8, 2016 and Court Docket Report as of May 22, 2016.)","Jurisdiction of Origin: Investigative Agency":"Unspecified investigative agency","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Origin: Courts Involved":"Court - State of Coahuila","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_US_DOJ_Press_Release_Feb_6_2013_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez-US_SDTEX_Complaint_Feb_6_2013_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_US_SDTEX_Claim_Mar_13_2013_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_US_SDTEX_Claim_Withdraw_Jun_24_2013_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Account_Answer_Mar_11_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Account_MLA_19-main_Jan_18_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Account_MLA_Doc_19-1_Jan_8_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Account_Verif_Claim_Mar_18_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Acct_Final_Forfeit_Jan_15_2015.pdf","Sources ":"The United States Attorney\u0027s Office - Southern District of Texas, \u0022Bermuda Bank Account Allegedly Owned by Former Mexican Secretary of Finance Seized by US,\u0022 February 6, 2013, accessed at http:\/\/www.justice.gov\/usao\/txs\/1News\/Releases\/2013%20February\/130206%20... \u00a0US v. All Funds on Deposit At Sun Secured Advantage Account Number 26-2673-031320, Case No. 13-cv-33 (S.D. Tex), Verified Complaint filed February 6, 2013; Verified Claim of Senator Luis Fernando Salazar Fernandez Contesting Asset Forfeiture, filed March 13, 2013 and Notice of Withdrawl of Claim filed June 24, 2013; Notice of Mutual Legal Assistance Request filed January 18, 2014; Answer to Complaint with Jury Demand filed March 11, 2014; and Verified Claim filed March 18, 2014. \u00a0US v. Villarreal Hernandez, Case No. 5:14-cr-00100 (W.D. Tex), Court Docket Report as of May 22, 2016.\n"},{"Case ID":"ARW-209","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hector Javier Villareal Hernandez \/ US Asset Forfeiture of Bermuda account","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mexico","Position of Public Official(s) (yrs in office)":"Former Secretary of Finance, State of Coahuila (2005-2011)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation and related Criminal Prosecution","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty (US-Mexico)","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"$2,275,544.41","Assets Returned (USD)":"","Agreement for Returned Assets":"NA","Agreement for Returned Assets - Description":"","Case Summary":"According to the Agreed Final Judgment of Forfeiture filed on January 15, 2015 in the US District Court for the Southern District of Texas, the assets were forfeited to the United States,including after Mr. Villareal Hernandez agreed to the forfeiture. \u00a0(Source: \u00a0US v. All Funds on Deposit At Sun Secured Advantage Account Number 26-2673-031320, Case No. 2:13-cv-00033 (S.D. Tex)).\u00a0\n\t\t\t\u00a0\n\t\t\tAccording to the US Department of Justice Press Release dated February 6, 2013, \u0022The United States has seized a bank account located in Bermuda alleged to have been owned by former State of Coahuila, Mexico, Secretary of Finance Hector Javier Villareal Hernandez [ \u00a0].\n\t\t\t\u00a0\n\t\t\tThe account, which is held in Bermuda at Sun Secured Advantage account at N.T. Butterfield and Son Limited, contained $2,275,544.41 as of Jan. 4, 2013. The government alleged, as its basis for forfeiture, that the funds in the account were involved in a money laundering transaction, that the property constitutes or was derived from proceeds traceable to offenses including bribery of a public official, or the misappropriation, theft or embezzlement of public funds by or for the benefit of a public official. [ \u00a0]\u00a0\n\t\t\t\u00a0\n\t\t\tIn approximately December 2005, Hernandez was appointed by then Governor of Coahuila Humberto Moreira to the position of Under Secretary of Program and Budget for Coahuila. In July 2008, Hernandez was appointed by the same governor to the position of Secretary of Finance for Coahuila. On Aug. 19, 2011, Hernandez resigned that position and became a subject of investigation by the government of Mexico. On Oct. 28, 2011, a local judge from Coahuila charged Hernandez with forging state documents to obtain fraudulent loans for several million pesos between 2008 and 2011. On Oct. 29, 2011, Hernandez was arrested and released on bond. He later fled and remains a fugitive on those charges.\n\t\t\t\u00a0\n\t\t\tAccording to the civil complaint, in 2011, Mexican law enforcement officials initiated an investigation involving fraudulent loans obtained from Mexican banks by Hernandez while he held the position of Secretary of Finance. The investigation includes three fraudulent loans from two different Mexican banks from July 2010 to March 2011 totaling more than $3 billion Mexican Pesos ($246 million U.S. dollars based on exchange rates on the dates of the loans). On Feb. 3 and March 8, 2012, Mexican government authorities filed false loan charges and issued arrest warrants for Hernandez\u2019s involvement in the false loans with two Mexican banks. The charges allege Hernandez and other co-conspirators acquired loans by providing false information to Mexican banks. The false information involved the use of false registry stamps or previously approved registry stamps used on the false loan contracts.\u00a0\n\t\t\t\u00a0\n\t\t\tThe conspiracy is alleged in the complaint to have begun when Hernandez requested a loan on behalf of the State of Coahuila. He then drafted and submitted a false loan contract for approval by the federal Treasury Department. Hernandez conspired to falsify the approval of the submitted loan contract. His alleged co-conspirators, who worked at the federal Treasury Department, placed a fraudulent federal registry stamp or a previously approved registry stamp on the loan contract to make it appear that the loan contract had been approved. After the loan contract obtained the false registry stamp or previously approved registry stamp and received \u0022approval,\u0022 the contract was submitted to a Mexican federal bank for issuance of a loan to the State of Coahuila. Once the loan proceeds were obtained, they were available for use by the State of Coahuila. [ ]\u00a0\n\t\t\t\u00a0\n\t\t\tHernandez opened an offshore investment account in Bermuda during this time period. Since April 2009, it is estimated that Hernandez and his associates received more than $35 million through foreign exchange transactions and cross border wires and subsequently purchased numerous real properties in San Antonio, Brownsville and South Padre Island with the illegal proceeds.\u0022 \u00a0(Source: \u00a0The United States Attorney\u0027s Office - Southern District of Texas, \u0022Bermuda Bank Account Allegedly Owned by Former Mexican Secretary of Finance Seized by US,\u0022 February 6, 2013.) \u00a0\n\t\t\t\u00a0\n\t\t\tOn March 3, 2013, a Senator from the Mexican state of Coahuila filed a claim, on behalf of himself and citizens of that state, for the seized funds on the basis that the funds were \u0022embezzled and stolen from and belong to the State of Coahuila, Mexico.\u0022 \u00a0He sought to \u0022recover the Defendant Funds fo return to the treasury of the State of Coahuila, Mexico.\u0022 \u00a0(Source: \u00a0US v. All Funds on Deposit At Sun Secured Advantage Account Number 26-2673-031320, Case No. 13-cv-33 (S.D. Tex), Verified Claim of Senator Luis Fernando Salazar Fernandez Contesting Asset Forfeiture, filed March 13, 2013.) \u00a0 On June 24, 2013, Senator Salazar withdrew his claim, stating \u0022he wil continue to pursue remission of the Defendant funds throught he Department of Justice.\u0022 \u00a0(Source: US v. All Funds on Deposit At Sun Secured Advantage Account Number 26-2673-031320, Case No. 13-cv-33 (S.D. Tex), Notice of Withdrawl of Claim filed June 24, 2013.)\n\t\t\t\u00a0\n\t\t\tIn January 2014, the US filed a notice of Mutual Legal Assistance request to Mexico, requesting assistance that notice of the asset forfeiture action be sent directly to anyone, including Mr. Hernandez (account holder) and his wife, who reasonably appears to have interest or claim in the property subject to forfeiture. \u00a0In March, Mr. Hernandez filed an answer to the complaint and a verified claim claiming that he was the lawful owner of the Defendant funds. \u00a0(Sources: \u00a0US v. All Funds on Deposit at Sun Secure Advantaged Account Number 26-2673-031320..., Case No. 2:13-cv-33 (S.D. Tex.), Notice of Mutual Legal Assistance filed on January 8, 2014; Answer to Complaint filed March 11, 2014; and Verified Claim filed March 18, 2014.)\u00a0\n\u00a0","Disposition of Criminal Case(s)":"As of May 22, 2016, Mr. Villareal Hernandez\u0027s sentencing in US Federal Court for the Western District of Texas on money laundering conspiracy charge, to which he had plead guilty, was continued to October 5, 2016. \u00a0(Source: US v. Villarreal Hernandez, Case No. 5:14-cr-00100 (W.D. Tex), Agreed and Unopposed, Sealed Motion for Continuance of Sentencing filed February 8, 2016 and Court Docket Report as of May 22, 2016.)","Jurisdiction of Origin: Investigative Agency":"Unspecified investigative agency","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified court - State of Coahuila","Jurisdiction of Asset Recovery: Investigative Agency":"Organized Crime Drug Enforcement Task Force; Internal Revenue Service - Criminal Investigation; Drug Enforcement Agency; Homeland Security Investigation; Texas Attorney General\u0027s Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney - Southern District of Texas","Jurisdiction of Asset Recovery: Courts Involved":"United States District Court - Southern District of Texas","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_US_DOJ_Press_Release_Feb_6_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez-US_SDTEX_Complaint_Feb_6_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_US_SDTEX_Claim_Mar_13_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_US_SDTEX_Claim_Withdraw_Jun_24_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Account_MLA_19-main_Jan_18_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Account_MLA_Doc_19-1_Jan_8_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Account_Verif_Claim_Mar_18_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Account_Answer_Mar_11_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Acct_Final_Forfeit_Jan_15_2015_0.pdf","Sources ":"The United States Attorney\u0027s Office - Southern District of Texas, \u0022Bermuda Bank Account Allegedly Owned by Former Mexican Secretary of Finance Seized by US,\u0022 February 6, 2013, accessed at http:\/\/www.justice.gov\/usao\/txs\/1News\/Releases\/2013%20February\/130206%20... \u00a0US v. All Funds on Deposit At Sun Secured Advantage Account Number 26-2673-031320, Case No. 2:13-cv-00033 (S.D. Tex), Verified Complaint filed February 6, 2013; Verified Claim of Senator Luis Fernando Salazar Fernandez Contesting Asset Forfeiture, filed March 13, 2013 and Notice of Withdrawl of Claim filed June 24, 2013; Notice of Mutual Legal Assistance Request filed January 18, 2014; Answer to Complaint with Jury Demand filed March 11, 2014; Verified Claim filed March 18, 2014; and Agreed Final Judgment of Forfeiture filed January 27, 2015. US v. Villarreal Hernandez, Case No. 5:14-cr-00100 (W.D. Tex), Court Docket Report as of May 22, 2016.\n"},{"Case ID":"ARW-206","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ferdinand Marcos and Imelda Marcos \/ Vilma Bautista New York Art Case \/ Human Rights Victims\u0027 Settlement","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"President (F. Marcos,1965-1986); First Lady, Governor of Metro Manila and Minister of Human Settlements (I. Marcos. Governor and Minister from 1978-1986); Foreign Service Officer and de facto Personal Secretary to Mrs. Marcos (Bautista, early 1970s through approx. 1986)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Location of Recovery Effort; Asset location \/ Alleged asset location","Asset Recovery Start":"2011","Asset Recovery End":"2013","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Private settlement agreement","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Settlement agreement with the current owners of the artwork","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$10,000,000","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"Private Settlement agreement","Case Summary":"On October 29, 2013, the US District Court in Hawaii approved a settlement agreement in the sum of $10 million between the Marcos-era human rights victims and the current owner of art that is currently the subject of a criminal action in New Yorl. \u00a0(Source: In re: Estate of Ferdinand Marcos Human Rights Litigation, Case No. 03-cv-11111 (D. Hawaii), Order of Settlement filed October 29, 2013).\u00a0\n\t\u00a0\n\tAccording to a statement by the lawyers representing the Marcos era human rights victims, \u0022Filipinos tortured, summarily executed or who disappeared during the Marcos regime may soon receive a second distribution. \u00a0Robert Swift, lead counsel for the 10,000 Filipino victims human rights abuses, announced a $10 million settlement over artwork owned by Imelda Marcos. \u00a0The settlement derives from litigation in New York City by the victims to recover on their judgments against the Marcoses.\n\t\u00a0\n\tImmediately after the Marcoses fled to Hawaii in February 1986, more than 200 pieces of artwork purchased by Imelda Marcos disappeared from the Marcoses townhouse in New York. \u00a0In 2010, the New York District Attorney indicted a former assistant to Imelda Marcos, Vilma Bautista, for the illegal sale of one of the paintings, an impressionist masterpiece by Claude Monet. \u00a0The District Attorney also recovered $15 million from the sale as well as three other valuable artworks. \u00a0Class counsel, who obtained a contempt judgment against Imelda Marcos and Senator Ferdinand R. Marcos for $353.6 million, immediately filed suit in New York to recover the paintings and the proceeds. \u00a0The $10 million settlement was paid by the current owner of the Monet painting, a good faith purchaser of that artwork. \u00a0The victims continue to sue all others involved in the sale of the painting.\n\t\u00a0\n\tRobert Swift commented: \u201cWith this settlement, the Class is just starting to recover on its judgment. \u00a0The Marcoses have hidden many of their assets and prevented the victims from making any significant recovery on their original 1995 judgment of $2 billion. \u00a0It is poetic justice that the victims are benefitting from a valuable painting that Imelda Marcos purchased and revered. \u00a0The Marcoses have thumbed their noses at the United States court and Filipino victims of \u00a0human rights violations ever since the original judgment was entered. \u00a0They were caught trying to dissipate the Marcos Estate\u2019s assets to re-capitalize their political dynasty in the Philippines. \u00a0This New York litigation may be the vehicle to discover the totality of the Marcos artwork trove and to recover still more money for the victims.\u201d\n\t\u00a0\n\tPhilippine co-counsel Rod C. Domingo, Jr. said \u201cthe recovery of $10 million will be welcome news to the victims, most of whom are now aged and poor. \u00a0The first distribution of $1,000 to each victim in 2011 was greeted joyously. \u00a0We anticipate a second distribution in early 2014 when perhaps even more money will have been recovered.\u201d \u00a0The approval of the settlement is pending before Judge Manuel Real of the Federal Court in Hawaii. \u00a0Any distribution must be approved by the Court.\u0022 \u00a0(Source: \u00a0Class Suit Lawyers Statement on Monet Painting Recovery, Press Statement, Re: Marcos Human Rights Litigation, July 18, 2013.)","Disposition of Criminal Case(s)":"\u00a0A trial in the U.S. District Court for the Southern District of New York on criminal racketeering and fraud charges concluded in an acquittal for Mrs. Marcos. \u00a0Mr. Marcos had also been indicted in the case, but the court had deemed him too ill to stand trial. (Sources: US v. Tantoco, et al, Case No. 1-87-cr-598-JFK (S.D.N.Y.), Docket Report accessed on January 2, 2011 and Indictment of October 22, 1988, obtained from US National Archives; Craig Wolff, \u0022The Marcos Verdict; Marcos Is Cleared of All Charges In Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990.) \u00a0On April 21, 2010, the GMA News reported that \u0022According to records of the Philippine anti-graft court Sandiganbayan as of 2005, Mrs. Marcos continues to face 11 criminal charges and 25 civil cases.\u0022 \u00a0(Source: Sophia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....). \u00a0In November 2013, Ms. Bautista was convicted in New York state court \u00a0of Criminal Tax Fraud in the First Degree, Conspiracy in the Fourth Degree, and Offering a False Instrument for Filing in the First Degree. \u00a0In October 2015, the New York State Appellate Court vacated the conspiracy conviction based on err in jury instructions but stated that the Manhattan District Attorney may retry the charge; the Court upheld the tax fraud conviction. \u00a0(Source: \u00a0New York County District Attorney\u0027s Office Press Release, \u0022DA VANCE: FORMER SECRETARY TO IMELDA MARCOS CONVICTED ON ALL COUNTS AT TRIAL INVOLVING DISAPPEARANCE OF MONET AND OTHER ARTWORKS,\u0022 November 18, 2013; James C. McKinley, Jr., \u0022Former Marcos Aide Sentenced in Art Sale,\u0022 New York Times, January 13, 2014, at http:\/\/www.nytimes.com\/2014\/01\/14\/nyregion\/aide-to-imelda-marcos-is-sent... New York State Court Appellate Division, People v. Bautista, 2015 NY Slip Op 07589)","Jurisdiction of Origin: Investigative Agency":"NA","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Robert Swift (Private Attorney)","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for Hawaii","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_HRs_Victims_Statement_Art_Settlement_July_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Hawaii_Art_Settle_Final_Order_Judgment_Oct_29_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Memo_Mtn__Settlement_Hrs_Victims_NY_Art_Jul_10_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Bautista_Conviction_NY_District_Attorney_PR_Nov_18_2013_0.pdf","Sources ":"\n\t\u00a0New York County District Attorney\u0027s Office Press Release, \u0022DA Vance: \u00a0Three Individuals Charged in Conspiracy Involving Monet Artworks that Disappeared with the Collapse of the Marcos Regime in the Philippines,\u0022 November 20, 2012, accessed at\n\n\thttp:\/\/www.manhattanda.org\/press-release\/da-vance-three-individuals-char..., and New York County District Attorney\u0027s Office Press Release, \u0022DA Vance: \u00a0Three Individuals Charged in Conspiracy Involving Monet Artworks that Disappeared with the Collapse of the Marcos Regime in the Philippines,\u0022 November 20, 2012, accessed at\n\n\thttp:\/\/www.manhattanda.org\/press-release\/da-vance-three-individuals-char... and \u0022DA VANCE: FORMER SECRETARY TO IMELDA MARCOS CONVICTED ON ALL COUNTS AT TRIAL INVOLVING DISAPPEARANCE OF MONET AND OTHER ARTWORKS,\u0022 November 18, 2013, at \u00a0http:\/\/manhattanda.org\/press-release\/da-vance-former-secretary-imelda-ma...\n\n\t\u00a0\n\n\tIn re: Estate of Ferdinand Marcos Human Rights Litigation, Case No. 03-cv-11111 (D. Hawaii), Order of Settlement filed October 29, 2013, and Memorandum in Support of Motion to Approve Settlement filed July 10, 2013;\u00a0\n\n\t\u00a0\n\n\tClass Suit Lawyers Statement on Monet Painting Recovery, Press Statement, Re: Marcos Human Rights Litigation, July 18, 2013, at http:\/\/claimants1081.org\/2013\/07\/20\/class-suit-lawyers-statement-on-mone...\n"},{"Case ID":"ARW-205","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ferdinand Marcos and Imelda Marcos \/ Vilma Bautista New York Art Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"President (F. Marcos,1965-1986); First Lady, Governor of Metro Manila and Minister of Human Settlements (I. Marcos. Governor and Minister from 1978-1986); Foreign Service Officer and de facto Personal Secretary to Mrs. Marcos (Bautista, early 1970s through approx. 1986)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking recovery effort; Asset location \/ Alleged asset location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Ongoing Case, but in announcing the indictment against Ms. Bautista and others,  District Attorney Vance \u0022thanked the New York State Department of Taxation and Finance for its contribution to the investigation, and thanked the auction house and fine art storage firm Christie\u2019s for its valuable assistance.\u0022  (Source:  New York County District Attorney\u0027s Office Press Release, \u0022DA Vance:  Three Individuals Charged in Conspiracy Involving Monet Artworks that Disappeared with the Collapse of the Marcos Regime in the Philippines,\u0022 November 20, 2012.)  ","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Other","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$0","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tIn January 2014, Ms. Bautista was sentenced to imprisonment and ordered to pay US$3.8 million in taxes owed from US $28 milion she had received from the sale of a Monet painting. \u00a0(Sources: \u00a0James C. McKinley, Jr., \u0022Former Marcos Aide Sentenced in Art Sale,\u0022 New York Time, January 13, 2014 and New York County District Attorney\u0027s Office Press Release, \u0022DA Vance: Three individuals Charged in Conspiracy Involving Monet Artworks that Disappeared with the Collapse of the Marcos Regime in the Philippines,\u0022 November 20, 2012.). \u00a0In November 2013, the Philippines\u0027 Presidential Commission on Good Government issued a statement welcoming Ms. Bautista\u0027s conviction and stated that the PCGG \u0022will now be working to recover the proceeds and assets which were confiscated from Ms. Bautista and which we assert to be owned by the Republic.\u0022 \u00a0(Source: Philippines Presidential Commission on Good Government, PCGG Statement on the Conviction of Vilma Bautista, November 19, 2013.)\u00a0\n\n\t\u00a0\n\n\tOn November 20, 2012, the District Attorney for New York County, New York, announced the indictment of \u0022VILMA BAUTISTA, 74, CHAIYOT JANSEN NAVALAKSANA (\u201cJANSEN\u201d), 37, and PONGSAK NAVALAKSANA (\u201cPONGSAK\u201d), 40, for illegally conspiring to possess and sell valuable works of art acquired by former First Lady of the Philippines Imelda Marcos during her husband\u2019s presidency, keeping the proceeds for themselves, and hiding those proceeds from New York State tax authorities and others. The art included a Claude Monet \u201cWater-Lily\u201d painting, which the defendants sold in September 2010 for $32 million. The indictment charges all three defendants with Conspiracy in the Fourth Degree, and also charges BAUTISTA with Criminal Tax Fraud in the First Degree and Offering a False Instrument for Filing in the First Degree. JANSEN is charged with Criminal Tax Fraud in the Fourth Degree and Offering a False Instrument for Filing in the First Degree. [ ] \u00a0\u00a0\n\n\tAccording to the indictment, BAUTISTA was employed by the Philippine government as a Foreign Service Officer assigned to the Philippine Mission to the United Nations in New York from the early 1970s through approximately 1986. During that period and for years after, BAUTISTA unofficially acted as the New York-based personal secretary of Imelda Marcos, whose husband, Ferdinand Marcos, now deceased, served as President of the Philippines from 1965 to 1986. During her husband\u2019s presidency, Imelda Marcos used state assets to acquire a vast collection of artwork and other valuables. Much of the art adorned official Philippine government property in the Philippines and Manhattan. Ferdinand and Imelda Marcos fled the Philippines in February 1986 following a popular revolt.\n\n\t\u00a0\n\n\tIn the period of time immediately before and after the fall of the Marcos regime, a significant amount of artwork and other valuables disappeared from Philippine government property, including from the Philippine Consulate townhouse in Manhattan. Since then, the Philippine government has engaged in a public campaign to recover missing and stolen property acquired by the Marcoses. BAUTISTA is accused of having been aware of and monitoring this campaign, even as she possessed some of the valuable works of art.\u0022 \u00a0(Source: \u00a0New York County District Attorney\u0027s Office Press Release, \u0022DA Vance: \u00a0Three Individuals Charged in Conspiracy Involving Monet Artworks that Disappeared with the Collapse of the Marcos Regime in the Philippines,\u0022 November 20, 2012.) \u00a0 \u00a0","Disposition of Criminal Case(s)":"A trial in the U.S. District Court for the Southern District of New York on criminal racketeering and fraud charges concluded in an acquittal for Mrs. Marcos. \u00a0Mr. Marcos had also been indicted in the case, but the court had deemed him too ill to stand trial. (Sources: US v. Tantoco, et al, Case No. 1-87-cr-598-JFK (S.D.N.Y.), Docket Report accessed on January 2, 2011 and Indictment of October 22, 1988, obtained from US National Archives; Craig Wolff, \u0022The Marcos Verdict; Marcos Is Cleared of All Charges In Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990.) \u00a0On April 21, 2010, the GMA News reported that \u0022According to records of the Philippine anti-graft court Sandiganbayan as of 2005, Mrs. Marcos continues to face 11 criminal charges and 25 civil cases.\u0022 \u00a0(Source: Sohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....). \u00a0In October 2015, the New York State Appellate Court overturned her conviction on conspiracy charge and remanded to trial court; it affirmed conviction on charges of Criminal Tax Fraud in the First Degree and Offering a False Instrument for Filing in the First Degree. \u00a0(Source: People v. Baptists, 2015 NY Slip Op 07589, October 20, 2015.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"New York County District Attorney\u0027s Office, Major Economic Crimes Bureau; New York State Department of Taxation and Finance","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"New York County District Attorney\u0027s Office","Jurisdiction of Asset Recovery: Courts Involved":"New York State Supreme Court (trial level); Appellate Division, First Department","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bautista_Statement%20on%20the%20Indictment%20of%20Vilma%20Bautista%20_%20PCGG_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Bautista_Conviction_NY_District_Attorney_PR_Nov_18_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Bautista_US_Sentenced%20in%20Art%20Sale_NYTimes_Jan_13_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Bautista_PCGG-statement-on-the-conviction-of-vhb1.pdf","Sources ":"\n\tNew York County District Attorney\u0027s Office Press Release, \u0022DA Vance: \u00a0Three Individuals Charged in Conspiracy Involving Monet Artworks that Disappeared with the Collapse of the Marcos Regime in the Philippines,\u0022 November 20, 2012, accessed at\n\n\thttp:\/\/www.manhattanda.org\/press-release\/da-vance-three-individuals-char... and \u0022DA VANCE: FORMER SECRETARY TO IMELDA MARCOS CONVICTED ON ALL COUNTS AT TRIAL INVOLVING DISAPPEARANCE OF MONET AND OTHER ARTWORKS,\u0022 November 18, 2013, at http:\/\/manhattanda.org\/press-release\/da-vance-former-secretary-imelda-ma...\n\n\t\u00a0\n\n\t\u00a0\n\n\tThe People of the State of New York vs. Vilma Bautista, et al, Indictment No. 4939\/2012), accessed at Russ Buettner, \u0022Imelda Marcos\u0027s Ex-Aide Charged in \u002780s Art Theft,\u0022 New York Times, November 20, 2012, at http:\/\/www.nytimes.com\/2012\/11\/21\/nyregion\/imelda-marcoss-ex-aide-charge...\n\n\tPresidential Commission on Good Government Statement on Bautista Conviction, at http:\/\/thenewcommission.files.wordpress.com\/2013\/11\/pcgg-statement-on-th... \u00a0New York State Court Appellate Division 2015 NY Slip Op 07589 (October 20, 2015);\n\n\t\u00a0\n\n\tUS v. Tantoco, et al, Case No. 1-87-cr-598-JFK (S.D.N.Y.), Docket Report accessed on January 2, 2011 and Indictment of October 22, 1988, obtained from US National Archives;\u00a0\n\n\t\u00a0\n\n\tCraig Wolff, \u0022The Marcos Verdict; Marcos Is Cleared of All Charges In Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990;\n\n\t\u00a0\n\n\tSohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica... \u00a0PCGG Statement on the Indictment of Vilma Bautista, undated, accessed at http:\/\/pcgg.gov.ph\/2012\/12\/04\/pcgg-statement-on-the-indictment-of-vilma-...\n\n\t\u00a0\n\n\tJames C. McKinley, Jr., \u0022Former Marcos Aide Sentenced in Art Sale,\u0022 New York Time, January 13, 2014, at http:\/\/www.nytimes.com\/2014\/01\/14\/nyregion\/aide-to-imelda-marcos-is-sent...\n"},{"Case ID":"ARW-208","Case Title (Name of Public Official or Entity Allegedly Involved)":"Weir Group plc","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United Kingdom","Position of Public Official(s) (yrs in office)":"NA","Jurisdiction of Asset Recovery":"Iraq [Development Fund for Iraq]","Jurisdiction of Asset Description":"","Asset Recovery Start":"2010","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Prosecution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"In announcing the return of some of the confiscated proceeds of crime, Scottish Culture and External Affairs ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"$0","Assets Adjudicated, Not Yet Returned (USD)":"$0","Assets Returned (USD)":"$2,375,790","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"United Nations Development Assistance Framework for Environmental Management initiatives; Scottish NGO for work in Iraq; Iraqi Youth Orchestra","Case Summary":"According to the Crown Office and Procurator Fiscal Service news release dated December 15, 2010, \u0022The Crown Office has secured \u00a313.9 million under Proceeds of Crime legislation after a Scottish engineering company pled guilty to paying \u2018kickbacks\u2019 in return for contracts from Saddam Hussein\u2019s government. The confiscation order, made against Glasgow-based Weir Group Plc, is the biggest ever made by a Scottish court. \u00a0At the High Court in Edinburgh today, the company was also fined \u00a33 million after pleading guilty to paying more than \u00a33m in \u2018kickbacks\u2019, in contravention of UN sanctions against Iraq, through a Swiss bank account. \u00a0The Weir Group also admitted facilitating the payment of kickbacks by paying a fee of more than \u00a31.4 m to their agent, an Iraqi national, to the same Swiss bank account. The agent made the payments to the Iraqi government on behalf of Weir. \u00a0The kickbacks were paid to the Iraqi Government from funds in the UN\u2019s Oil for Food Programme, which should have been used for humanitarian purposes. An Independent Inquiry Committee set up by the UN has estimated that, in total, about US $1.5 billion that could have been used to ease the suffering of the Iraqi people was paid as kickbacks to Saddam Hussein\u0027s government. The Lord Advocate, the Right Honourable Elish Angiolini QC, said: \u0027This case represents the biggest single confiscation order made so far in Scotland using the Proceeds of Crime legislation. It is the result of a highly successful collaboration between National Casework Division of the Crown Office and Procurator Fiscal Service, Strathclyde Police and the Serious Fraud Office. In this year alone we have recovered over \u00a324 million, a record amount under the Proceeds of Crime legislation.\u0027\u0022 \u00a0The news release added that in notes to editors: \u0022Weir Group companies secured 16 contracts for which they were paid \u00a334,340,204 by paying kickbacks of \u00a33,104,527. The confiscation order has been granted for \u00a313,945,962.\u0022 This includes Weir\u2019s gross profit of \u00a39, 414,283 from the contracts - plus the kickback of \u00a33,104,527 and the fee of \u00a31,427,152 paid to Weir\u2019s agent in Iraq.(Source: \u00a0The Crown Office and Procurator Fiscal Service news release, \u0022CROWN SECURES RECORD \u00a313.9M AS WEIR GROUP CONVICTED OF PAYING KICKBACKS FOR IRAQ CONTRACTS,\u0022 December 15, 2010.) \u00a0According to a February 13, 2011 press statement by the Government of Scotland, GBP1.5 million of the GBP 13.9 million seized under the Proceeds of Crime Act will support water development in Iraq and humanitarian programmes in Iraq and Afghanistan. Specifically, GBP1.4 million were to go towards projects in Iraq and GBP 100,000 to a Scottish charity for humanitarian work in Afghanistan. The remainder, GBP 12.4 million \u0022will be used to fund community projects in Scotland.\u0022 \u00a0(Source: The Scottish Government, \u0022Seized cash returned to Iraq,\u0022 February 13, 2011.)According to the Crown Office and Procurator Fiscal Service news release dated December 15, 2010, \u0022The Crown Office has secured \u00a313.9 million under Proceeds of Crime legislation after a Scottish engineering company pled guilty to paying \u2018kickbacks\u2019 in return for contracts from Saddam Hussein\u2019s government. The confiscation order, made against Glasgow-based Weir Group Plc, is the biggest ever made by a Scottish court. \u00a0At the High Court in Edinburgh today, the company was also fined \u00a33 million after pleading guilty to paying more than \u00a33m in \u2018kickbacks\u2019, in contravention of UN sanctions against Iraq, through a Swiss bank account. \u00a0The Weir Group also admitted facilitating the payment of kickbacks by paying a fee of more than \u00a31.4 m to their agent, an Iraqi national, to the same Swiss bank account. The agent made the payments to the Iraqi government on behalf of Weir. \u00a0The kickbacks were paid to the Iraqi Government from funds in the UN\u2019s Oil for Food Programme, which should have been used for humanitarian purposes. An Independent Inquiry Committee set up by the UN has estimated that, in total, about US $1.5 billion that could have been used to ease the suffering of the Iraqi people was paid as kickbacks to Saddam Hussein\u0027s government. The Lord Advocate, the Right Honourable Elish Angiolini QC, said: \u0027This case represents the biggest single confiscation order made so far in Scotland using the Proceeds of Crime legislation. It is the result of a highly successful collaboration between National Casework Division of the Crown Office and Procurator Fiscal Service, Strathclyde Police and the Serious Fraud Office. In this year alone we have recovered over \u00a324 million, a record amount under the Proceeds of Crime legislation.\u0027\u0022 \u00a0The news release added that in notes to editors: \u0022Weir Group companies secured 16 contracts for which they were paid \u00a334,340,204 by paying kickbacks of \u00a33,104,527. The confiscation order has been granted for \u00a313,945,962.\u0022 This includes Weir\u2019s gross profit of \u00a39, 414,283 from the contracts - plus the kickback of \u00a33,104,527 and the fee of \u00a31,427,152 paid to Weir\u2019s agent in Iraq.(Source: \u00a0The Crown Office and Procurator Fiscal Service news release, \u0022CROWN SECURES RECORD \u00a313.9M AS WEIR GROUP CONVICTED OF PAYING KICKBACKS FOR IRAQ CONTRACTS,\u0022 December 15, 2010.) \u00a0According to a February 13, 2011 press statement by the Government of Scotland, GBP1.5 million of the GBP 13.9 million seized under the Proceeds of Crime Act will support water development in Iraq and humanitarian programmes in Iraq and Afghanistan. Specifically, GBP1.4 million were to go towards projects in Iraq and GBP 100,000 to a Scottish charity for humanitarian work in Afghanistan. The remainder, GBP 12.4 million \u0022will be used to fund community projects in Scotland.\u0022 \u00a0(Source: The Scottish Government, \u0022Seized cash returned to Iraq,\u0022 February 13, 2011.)","Disposition of Criminal Case(s)":"According to the \u00a0Crown Prosecution and Procurator Fiscal Service, in 2010 the Weir Group pleaded guilty to charges of paying kick-backs to secure Iraqi contracts. \u00a0(Source: \u00a0Crown Prosecution and Procurator Fiscal Service News Release, \u0022Crown Secures record \u00a313.9 million as Weir Group convicted of paying kick-backs for Iraq contracts,\u0022 December 15, 2010.)","Jurisdiction of Origin: Investigative Agency":"Serious Fraud Office (Scotland)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Crown Office and Procurator Fiscal Service","Jurisdiction of Origin: Courts Involved":"High Court (Edinburgh)","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Weir_Group_COPFS_Settlement_Dec_15_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Scotland_Crown_Office_POCA_Record_News_Release_June_2011.pdf","Sources ":"Crown Office and Procurator Fiscal Service Press Release, \u0022Crown Secures record \u00a313.9 million as Weir Group convicted of paying kickbacks for Iraq contracts,\u0022 December 15, 2010, accessed at http:\/\/www.copfs.gov.uk\/News\/Releases\/2010\/12\/Crown-Secures-record-%C2%A... The Scottish Government, \u0022Seized cash returned to Iraq,\u0022 February 13, 2011, at http:\/\/www.scotland.gov.uk\/News\/Releases\/2011\/02\/14085030.\n"},{"Case ID":"ARW-12","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alstom S.A. (World Bank)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Zambia","Position of Public Official(s) (yrs in office)":"unspecified former government official","Jurisdiction of Asset Recovery":"World Bank","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Administrative Sanctions (Negotiated Resolution Agreement)","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"The World Bank\u0027s Negotiated Resolution Agreement with Alstom included a provision for the payment of restitution by the company. (Source:  World Bank Press Release, \u0022Enforcing Accountability: World Bank Debars Alstom Hydro France, Alstom Network Schweiz AG, and their Affiliates,\u0022 February 22, 2012.)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Other","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"$9,500,000","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the February 2012 press release by the World Bank\u0027s Integrity Vice Presidency, \u0022The World Bank Group today announced the debarment of Alstom Hydro France and Alstom Network Schweiz AG (Switzerland) - in addition to their affiliates - for a period of three years following Alstom\u2019s acknowledgment of misconduct in relation to a Bank-financed hydropower project.\n\tThe debarment is part of a Negotiated Resolution Agreement between Alstom and the World Bank which also includes a restitution payment by the two companies totaling approximately $9.5 million. [\u00a0 ]\u00a0\n\tIn 2002, Alstom made an improper payment of \u20ac110,000, to an entity controlled by a former senior government official for consultancy services in relation to the World Bank-financed Zambia Power Rehabilitation Project. During the debarment period of Alstom Hydro France and Alstom Network Schweiz AG, Alstom SA and its other affiliates are conditionally non-debarred.\u0022 (Source:\u00a0 World Bank Press Release, \u0022Enforcing Accountability: World Bank Debars Alstom Hydro France, Alstom Network Schweiz AG, and their Affiliates,\u0022 February 22, 2012.)\n\tIn the World Bank Intrgrity Vice Presidency\u0027s fiscal year 2012 Annual Report, the World Bank President Jim Yong Kim stated, \u0022the World Bank Group will continue to work with patience and perseverance on the thornier parts of fighting corruption: [\u00a0 ] designing an Anti-Corruption Fund that equitably and purposefully distributes recovered assets and restitution payments to those who would benefit the most.\u0022\u00a0 (Source: Integrity Vice Presidency, \u0022Annual Report Fiscal Year 2012: Finding the Right Balance,\u0022 The World Bank (October 2012), at iv.)","Disposition of Criminal Case(s)":"N\/A (Administrative sanctions)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"World Bank Integrity Vice Presidency","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"World Bank Integrity Vice Presidency","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alstom_World%20Bank_Debar_Press_Release_Feb_22_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alstom_World_Bank_Annual_Report_2012.pdf","Sources ":"\n\tWorld Bank Press Release, \u0022Enforcing Accountability: World Bank Debars Alstom Hydro France, Alstom Network Schweiz AG, and their Affiliates,\u0022 February 22, 2012, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,contentMDK:23123315~pagePK:64257043~piPK:437376~theSitePK:4607,00.html;\u00a0World Bank Integrity Vice Presidency Fiscal Year 2012 Annual Report, at http:\/\/www-wds.worldbank.org\/external\/default\/WDSContentServer\/WDSP\/IB\/2...\n\n\t\u00a0\n"},{"Case ID":"ARW-28","Case Title (Name of Public Official or Entity Allegedly Involved)":"C. Lotti and Associati Societa\u2019 di Ingegneria S.p.A. (Lotti)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Italy","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort (World Bank)","Asset Recovery Start":"","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.26","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Administrative Sanctions (Negotiated Resolution Agreement) ","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Unspecified cooperation","Contributing Factors in Asset Recovery":"In announcing the Negotiated Resolution Agreement, the Integrity Vice Presidency stated, \u201cThis moves us closer to answering a longstanding call by victim countries to return illicit gains.\u0022  (Source: World Bank Press Release, \u0022Enforcing Accountability: Italian Company Lotti to pay US$350,000 in restitution to Indonesia after acknowledging fraudulent misconduct in a World Bank-financed project,\u0022 December 22, 2010.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$350,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the World Bank press release of December 22, 2010, \u0022The World Bank Group debarred C. Lotti and Associati Societa\u2019 di Ingegneria S.p.A. (Lotti) in the wake of the company\u2019s acknowledged misconduct in a World Bank investigation relating to a Bank-financed public works project in the water sector in Indonesia.\u00a0\n\tUnder the negotiated resolution agreement, Lotti has committed to pay an estimated US$350,000 in restitution to Indonesia, where the World Bank-financed project was being implemented.\u00a0 This is the first time the World Bank included restitution payment in resolving an investigation into fraud in a Bank-financed project. The restitution amount of US$350,000 represents the unjustified payments received by Lotti as well as its partners as a result of fraudulent invoicing.\u0022\u00a0 (Source: World Bank Press Release, \u0022Enforcing Accountability: Italian Company Lotti to pay US$350,000 in restitution to Indonesia after acknowledging fraudulent misconduct in a World Bank-financed project,\u0022 December 22, 2010.)\u00a0","Disposition of Criminal Case(s)":"N\/A (Administrative Sanctions by the World Bank)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"World Bank Integrity Vice Presidency","Jurisdiction of Asset Recovery: Courts Involved":"N\/A","Documents":"","Sources ":"World Bank Press Release, \u0022Enforcing Accountability: Italian Company Lotti to pay US$350,000 in restitution to Indonesia after acknowledging fraudulent misconduct in a World Bank-financed project,\u0022 December 22, 2010, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/TOPICS\/EXTLAWJUSTICE\/0,,contentMDK:22796379~menuPK:2643814~pagePK:64020865~piPK:149114~theSitePK:445634,00.html;\n\tWorld Bank Integrity Vice Presidency Fiscal Year 2011 Annual Report, accessed at http:\/\/siteresources.worldbank.org\/INTDOII\/Resources\/588889-1316720250792\/INT_AR_FY11_web.pdf\n"},{"Case ID":"ARW-24","Case Title (Name of Public Official or Entity Allegedly Involved)":"James Ibori \/ Bhadresh Gohil (India)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Solicitor to James Ibori, Delta State Governor (1999-2007)","Jurisdiction of Asset Recovery":"India","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture (United Kingdom)","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the 2008 Restraint Order issued by the UK High Court, among the assets ordered restrained were two properties located in India: \u00a0\u0022\u0027 b) Flat X12. Ashoka, A building, Panch Tantra Road, Verova M, Mumbai, India, 401105 registered in the name of Babulal Gahil, c) Divine Sheraton Plaza Wing B, No 33, 3rd floor, Jesal Park, Bhayander East India, 404105 registered in the name of Babulal Gahil.\u0022 \u00a0(Source: UNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012.), Exhibit .B, UK High Court Order of Restraint against Mr. Gohil, November 17, 2008.)\n\t\u00a0\n\tIn July 2013, the US Government filed a response to the Court Order to Show Cause, urging the court not to terminate the action and to retain jurisdiction over the matter until confiscation proceedings in the UK conclude. \u00a0As of June 2016, the US case was ongoing. \u00a0(Source: \u00a0In Re: Enforcement of Restraining Order Issued by the High Court of England and Wales, Case No. 1:12-mc-00289 (D.D.C.), US Government Reponse to Order to Show Cause filed July 16, 2013; Court Docket Report as of June 2016.) \u00a0According to news reports, the UK confiscation hearing that was rescheduled for June 2016 was again postponed. \u00a0(Source: Today (Nigeria), \u0022London court postpones James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016; Vanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015.)","Disposition of Criminal Case(s)":"According to a May 2014 statement by Nigeria\u0027s Economic and Financial Crimes Commission, a lower court decision to strike out \u0022all 170-count charge of money laundering preferred against former governor of Delta State, James Onanefe Ibori by the Economic and Financial Crimes Commission, EFCC, a three-man panel of justices at the Benin Division of the Court of Appeal today, May 15, 2014 ruled that the ex- governor who is currently serving a 13-year jail term in a London prison, has a case to answer.\u0022 \u00a0(Source: EFCC, \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014.) \u00a0 According to the United States\u0027 Ex Parte Application to Enforce and Register Foreign Restraining Orders, Mr. Gohil was convicted in the UK \u0022in November 2010 of money laundering and prejudicing a money laundering investigation, and in December 2010, pleaded guilty to an additional eight offenses related to the V Mobile fraud. Gohil was sentenced to ten years imprisonment.\u0022 \u00a0(Source: UNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012.)","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission (Nigeria)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service (United Kingdom)","Jurisdiction of Origin: Courts Involved":"Southwark Crown Court (United Kingdom)","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Ex_Parte_Restrain_Order_DDC_May_2012_3.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Asset_Restraint_DOJ_PR_Jul_23_2012_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_Nigeria_Appeals_Ct_EFCC_May_15_2014_2.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_UK_London%20judge%20adjourns%20Ibori%27s%20case%20to%20June%206%2C%202016%20-%20Vanguard%20News_Apr_14_2015_2.pdf","Sources ":"\n\n\t\tNigeria Economic and Financial Crimes Commission (EFCC), \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014, at https:\/\/efccnigeria.org\/efcc\/index.php\/news\/870-money-laundering-ibori-h...\n\n\t\t\u00a0\n\n\t\tToday (Nigeria), \u0022London court suspends James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016;\n\n\t\t\u00a0\n\n\t\tVanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015);\n\n\t\t\u00a0\n\n\t\tUNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012), Exhibit B, UK High Court Order of Restraint against Mr. Gohil, November 17, 2008.);\u00a0\n\n\t\t\u00a0\n\n\t\tUS Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012, accessed at \u00a0http:\/\/www.justice.gov\/opa\/pr\/2012\/July\/12-crt-906.html\n\n\u00a0\n"},{"Case ID":"ARW-23","Case Title (Name of Public Official or Entity Allegedly Involved)":"James Ibori \/ Bhadresh Gohil (Hong Kong SAR, China)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Solicitor to James Ibori, Delta State Governor (1999-2007)","Jurisdiction of Asset Recovery":"Hong Kong SAR, China","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20, Art.25","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture (United Kingdom)","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the 2008 Restraint Order issued by the UK High Court, among the assets ordered restrained was \u0022An account held at HSBC Bank, Harcourt Road Branch, Central Hong Kong account number 102-397296-274, held in the name of Zetland Financial Group Ltd.\u0022 \u00a0(Source: UNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012.), Exhibit .B, UK High Court Order of Restraint against Mr. Gohil, November 17, 2008.)\n\t\u00a0\nIn July 2013, the US Government filed a response to the Court Order to Show Cause, urging the court not to terminate the action and to retain jurisdiction over the matter until confiscation proceedings in the UK conclude. \u00a0As of June 2016, the US case was ongoing. \u00a0(Source: \u00a0In Re: Enforcement of Restraining Order Issued by the High Court of England and Wales, Case No. 1:12-mc-00289 (D.D.C.), US Government Reponse to Order to Show Cause filed July 16, 2013; Court Docket Report as of June 17, 2016.) \u00a0According to news reports, the UK confiscation hearing that had been rescheduled for June 2016 was again postponed. \u00a0(Sources: Today (Nigeria), \u0022London court suspends James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016; Vanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015)","Disposition of Criminal Case(s)":"According to a May 2014 statement by Nigeria\u0027s Economic and Financial Crimes Commission, a lower court decision to strike out \u0022all 170-count charge of money laundering preferred against former governor of Delta State, James Onanefe Ibori by the Economic and Financial Crimes Commission, EFCC, a three-man panel of justices at the Benin Division of the Court of Appeal today, May 15, 2014 ruled that the ex- governor who is currently serving a 13-year jail term in a London prison, has a case to answer.\u0022 \u00a0(Source: EFCC, \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014.) \u00a0 According to the United States\u0027 Ex Parte Application to Enforce and Register Foreign Restraining Orders, Mr. Gohil was convicted in the UK \u0022in November 2010 of money laundering and prejudicing a money laundering investigation, and in December 2010, pleaded guilty to an additional eight offenses related to the V Mobile fraud. Gohil was sentenced to ten years imprisonment.\u0022 \u00a0(Source: UNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Economic and Financial Crimes Commission (Nigeria); Crown Prosecution Service (UK)","Jurisdiction of Origin: Courts Involved":"Southwark Crown Court (UK)","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Ex_Parte_Restrain_Order_DDC_May_2012_2.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Asset_Restraint_DOJ_PR_Jul_23_2012_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_Nigeria_Appeals_Ct_EFCC_May_15_2014_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_UK_London%20judge%20adjourns%20Ibori%27s%20case%20to%20June%206%2C%202016%20-%20Vanguard%20News_Apr_14_2015_1.pdf","Sources ":"Nigeria Economic and Financial Crimes Commission (EFCC), \u0022Money Laundering:\u00a0 Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014, at https:\/\/efccnigeria.org\/efcc\/index.php\/news\/870-money-laundering-ibori-has-case-to-answer-appeal-court;\n\tToday (Nigeria), \u0022London court suspends James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016;\n\tVanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015);\n\tUNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012), Exhibit B, UK High Court Order of Restraint against Mr. Gohil, November 17, 2008.);\n\tUS Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012, accessed at\u00a0 http:\/\/www.justice.gov\/opa\/pr\/2012\/July\/12-crt-906.html\n\u00a0\n"},{"Case ID":"ARW-11","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alstom S.A. (Tunisia)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"France","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"Tunisia","Jurisdiction of Asset Description":"","Asset Recovery Start":"2011","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Prosecution and Restitution (in Switzerland)","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Article 53 Swiss Criminal Code payment of reparations","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Funds were transferred to the International Committee of the Red Cross for use in ICRC projects in Tunisia, Latvia and Malaysia. (Source: The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Case Summary":"According to the November 2011 Summary punishment order imposed by the Swiss authorities, Alstom Network Schweiz AG (Swiss subsidiary of the French company Alstom S.A.) was convicted of not having taken all necessary and reasonable organizational precautions to precent bribery of foreign public officials in Latvia, Tunisia and Malaysia.\u00a0 In Tunisia, in connection with the RADES project by the Carthage Power Company (licensed by the state company STEG - Societee Tunisienne de l\u0027Electricite et du Gaz),\u00a0 Alstom concluded consultancy agreements with two offshore companies controlled by the son-in-law of former president of Tunisia and a payment was made to one of the entities which exceeded the internal threshold for consultancy fees.\u00a0 The Summary punishment order stated that as son-in-law of the former president, Slim Chiboub \u0022was obviously in a position to influence not only the contract awards for the RADES project [\u00a0 ] but to avert compensation payments that later threatened ALSTOM due to damages caused by late performance.\u0022 Alstom Schweiz was fined CHF 2.5 million; a compensatory claim of CHF 36.4 million was also imposed. The parent company Alstom S.A. paid the CHF 1 million in reparation, a third of which was to be used for International Committee of the Red Cross projects in Latvia. (Sources:\u00a0 Office of the Swiss Attorney General, Summary punishment order in the invesitgation of defendant Alstom Network Schweiz AG, November 22, 2011 and The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Disposition of Criminal Case(s)":"According to the November 2011 press release by The Federal Authorities of the Swiss Confederation, Alstom Network Schweiz AG was convicted under article 102 of the Swiss Criminal Code of not having taken \u0022all necessary and reasonable organizational precautions to prevent bribery of foreign public officials\u0022; proceedings against the French parent company Alstom S.A. were dismissed based on art. 53 of the Swiss Criminal Code, imposing costs of proceedings and payment of reparations.\u00a0 (Source: The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Office of the Swiss Attorney General, Summary punishment order in the investigation of defendant Alstom Network Schweiz AG, November 22, 2011, accessed at http:\/\/www.scribd.com\/doc\/73503009\/Summary-Punishment-Order;\n\tThe Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011, accessed at http:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=42300.\n"},{"Case ID":"ARW-9","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alstom S.A. (Malaysia)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"France","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"Malaysia","Jurisdiction of Asset Description":"","Asset Recovery Start":"2011","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Prosecution and Restitution (in Switzerland)","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Article 53 Swiss Criminal Code payment of reparations","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Funds were transferred to the International Committee of the Red Cross for use in ICRC projects in Tunisia, Latvia and Malaysia. (Source: The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Case Summary":"According to the November 2011 Summary punishment order imposed by the Swiss authorities, Alstom Network Schweiz AG (Swiss subsidiary of the French company Alstom S.A.) was convicted of not having taken all necessary and reasonable organizational precautions to precent bribery of foreign public officials in Latvia, Tunisia and Malaysia.\u00a0 In Malaysia, two executives of Alstom\u0027s client company, state-licensed TTPC (Teknologi Tenaga Perlis Consortium Sdtn Bhd) were deemed to be beneficiaries of consulting contracts signed by Alstom with offshore companies in connection with the PERLIS gas turbines contract.\u00a0 One of the beneficiaries of the bribe payments was also a local politician in the area where the power station was to be built. \u0022In return for payment, they influenced both the award of contracts as part of the project in previous years (including securing of financing) and ensured that any difficulties encountered by the client in the performance of the contract were resolved in favor of ALSTOM.\u0022 Alstom Schweiz was fined CHF 2.5 million; a compensatory claim of CHF 36.4 million was also imposed. The parent company Alstom S.A. paid the CHF 1 million in reparation, a third of which was to be used for International Committee of the Red Cross projects in Latvia. (Sources:\u00a0 Office of the Swiss Attorney General, Summary punishment order in the invesitgation of defendant Alstom Network Schweiz AG, November 22, 2011 and The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Disposition of Criminal Case(s)":"According to the November 2011 press release by The Federal Authorities of the Swiss Confederation, Alstom Network Schweiz AG was convicted under article 102 of the Swiss Criminal Code of not having taken \u0022all necessary and reasonable organizational precautions to prevent bribery of foreign public officials\u0022; proceedings against the French parent company Alstom S.A. were dismissed based on art. 53 of the Swiss Criminal Code, imposing costs of proceedings and payment of reparations.\u00a0 (Source: The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alstom_SA_Swiss_Attorney_General_Summary_Punishment_Order_PR_Nov_22_2011_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alstom_Company_Statement_Nov_2011.pdf","Sources ":"Office of the Swiss Attorney General, Summary punishment order in the investigation of defendant Alstom Network Schweiz AG, November 22, 2011, accessed at http:\/\/www.scribd.com\/doc\/73503009\/Summary-Punishment-Order;\n\tThe Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011, accessed at http:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=42300.\n"},{"Case ID":"ARW-8","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alstom S.A. (Latvia)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"France","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"Latvia","Jurisdiction of Asset Description":"","Asset Recovery Start":"2011","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution and Restitution (in Switzerland)","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Article 53 Swiss Criminal Code payment of reparations","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Funds were transferred to the International Committee of the Red Cross for use in ICRC projects in Tunisia, Latvia and Malaysia. (Source: The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Case Summary":"According to the November 2011 Summary punishment order imposed by the Swiss authorities, Alstom Network Schweiz AG (Swiss subsidiary of the French company Alstom S.A.) was convicted of not having taken all necessary and reasonable organizational precautions to precent bribery of foreign public officials in Latvia, Tunisia and Malaysia.\u00a0 In Latvia,\u0022from 2006 onwards, the state energy company LATVENERGO AS had contracts to award in various projects in Latvia relating to the modernization of power stations. ALSTOM Power Sweden and ALSTOM Hydro Sweden signed various consultancy agreements with companies of a former ALSTOM employee providing for success fees to be paid for the successful signing of delivery and maintenance contracts for power stations: Plavinas Hydo Power Plant 4, 5 and 7 and Plavinas Hydri Power Paint 1, 3, 6, 9 and 10.\u00a0 After the\u00a0 award of the two Plavinas projects to the Swedish Alstom companies, the companies paid the success fees to Alstom Network, which then transferred them to the former employee\/consultant who in turn transferred the funds to three executives of the state company LATVENERGO who \u0022were decisively involved in the decisions related to awarding projects. Apparently the sole interest was influencing LATVENERGO AS decision-makers with bribes to award the contract to ALSTOM.\u0022\u00a0 Alstom Schweiz was fined CHF 2.5 million; a compensatory claim of CHF 36.4 million was also imposed. The parent company Alstom S.A. paid the CHF 1 million in reparation, a third of which was to be used for International Committee of the Red Cross projects in Latvia. (Sources:\u00a0 Office of the Swiss Attorney General, Summary punishment order in the invesitgation of defendant Alstom Network Schweiz AG, November 22, 2011 and The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Disposition of Criminal Case(s)":"According to the November 2011 press release by The Federal Authorities of the Swiss Confederation, Alstom Network Schweiz AG was convicted under article 102 of the Swiss Criminal Code of not having taken \u0022all necessary and reasonable organizational precautions to prevent bribery of foreign public officials\u0022; proceedings against the French parent company Alstom S.A. were dismissed based on art. 53 of the Swiss Criminal Code, imposing costs of proceedings and payment of reparations.\u00a0 (Source: The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Office of the Swiss Attorney General, Summary punishment order in the investigation of defendant Alstom Network Schweiz AG, November 22, 2011, accessed at http:\/\/www.scribd.com\/doc\/73503009\/Summary-Punishment-Order;\n\tThe Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011, accessed at http:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=42300.\n"},{"Case ID":"ARW-190","Case Title (Name of Public Official or Entity Allegedly Involved)":"Vitol S.A.","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Switzerland, United States","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"Iraq [Development Fund for Iraq]","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort (United States)","Asset Recovery Start":"2007","Asset Recovery End":"2007","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution and Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified ","Contributing Factors in Asset Recovery":"Restitution to the People of Iraq via the Development Fund of Iraq was part of the plea agreement by Vitol SA and the New York County District Attorney\u0027s Office. (Source: New York County District Attorney\u0027s Office News Release on Vitol S.A., November 20, 2007.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$13,000,000","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Restitution to people of Iraq via Development Fund of Iraq","Case Summary":"According to the United States report to the OECD on enforcement of foreign bribery actions, \u0022[i]n 2007, the Manhattan (NY) District Attorney\u2019s Office charged Vitol, S.A. (Vitol), a Swiss oil trading firm, with Grand Larceny in the First Degree for its involvement in a scheme to pay kickbacks to Iraq in connection with oil purchases made under the United Nations Oil-for-Food Program (OFFP). According to court documents, while the OFFP was in effect, Vitol purchased Iraqi crude oil first as direct purchaser and later from third-parties. In June 2001, after an OPEC meeting, an agent of VITOL was told by Iraqi officials that surcharges had to be paid in order for Iraqi crude oil to be lifted. Over the next year, VITOL paid or caused surcharges to be paid on certain oil purchases in two ways. In direct purchases, VITOL had an associated entity called Vitol Bahrain send the surcharge monies to accounts controlled by the Iraqi regime. In indirect purchases, VITOL financed the purchase of oil through third parties who then paid the surcharge to the Iraqi regime. VITOL did not inform the UN about the surcharge payments. During the period from June 2001 through September 2002, approximately $13,000,000 in surcharge monies were paid directly to the Iraqi regime in connection with crude oil purchased directly or indirectly by VITOL. [ ] On November 20, 2007, Vitol pleaded guilty and was sentenced to pay restitution of $13 million to the Iraqi people through the Development Fund for Iraq, in addition to a payment of $4.5 million in lieu of fines, forfeiture and to cover the costs of prosecution.\u0022\u00a0 (Source: United States Department of Justice Report to the OECD, \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 \u2013 February 10, 2012,\u0022 Vitol S.A. matter at 101-102.)","Disposition of Criminal Case(s)":"In 2007, Vitol S.A. pleaded guilty to a charge of Grand Larceny for its misconduct in the UN Oil-for-Food scheme.\u00a0 (Source: New York County District Attorney\u0027s Office News Release on Vitol S.A., November 20, 2007.)","Jurisdiction of Origin: Investigative Agency":"New York County District Attorney\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"New York County District Attorney\u0027s Office","Jurisdiction of Origin: Courts Involved":"New York State Supreme Court","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/2013-02-25-steps-taken-oecd-anti-bribery-convention-us.pdf","Sources ":"New York County District Attorney\u0027s Office News Release on Vitol S.A., November 20, 2007;\n\tUnited States Department of Justice Report to the OECD, \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 \u2013 February 10, 2012,\u0022 Vitol S.A. matter at 101-102, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/2012-02-29-steps-taken-oecd-anti-bribery-convention.pdf.\n"},{"Case ID":"ARW-172","Case Title (Name of Public Official or Entity Allegedly Involved)":"Siemens A.G. \/ Greece Settlement","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Germany","Position of Public Official(s) (yrs in office)":"Various","Jurisdiction of Asset Recovery":"","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Settlement agreement ratified by Greek Parliament","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Civil settlement ratified by Greek Parliament.","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction (in part)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"Up to US$350,263,000; Please see Summary for details.","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Please see Summary for details.","Case Summary":"According to the April 2012 press release by Siemens, the Greek Parliament ratified the company\u0027s settlement agreement with Greek authorities to resolve multiple criminal and civil complaints regarding bribery in public contracts.\u00a0 The press release stated that the company, \u0022waives claims of \u20ac80 million that concern implemented projects and the delivery of equipment to the Greek State. Siemens will dispense up to the amount of 90 million Euro for transparency initiatives and anti-corruption programs, as well as for academic and research programs that aim at enhancing Greece\u2019s competitiveness. Finally, Siemens will spend over \u20ac100 million, in order to enhance its activities in Greece and preserve a significant number of jobs in the local market.\u0022 (Source: Siemens S.A. Press Release, \u0022Siemens and the Hellenic Republic reach a settlement agreement and mark a new beginning,\u0022 April 5, 2012.)\u00a0 Some details of the Greek investigation into Siemens\u0027 activities in that country and filing of lawsuit by the Hellenic Telecommunications Organization S.A. are noted in Siemens\u0027 regulatory filings in the United States.\u00a0 (Source: United States Securities and Exchange Commission, Form F-20, Siemens AG, 2011 and 2010)","Disposition of Criminal Case(s)":"N\/A (Civil Settlement)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Greek Parliamentary Investigation Committee; Greek Public Prosecutor","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Public Prosecutor","Jurisdiction of Asset Recovery: Courts Involved":"N\/A","Documents":"","Sources ":"Siemens S.A. Press Release, \u0022Siemens and the Hellenic Republic reach a settlement agreement and mark a new beginning,\u0022 April 5, 2012, accessed at http:\/\/www.siemens.com\/press\/en\/pressrelease\/?press=\/en\/pressrelease\/2012\/corporate\/axx20120420.htm;\n\tUnited States Securities and Exchange Commission, Form F-20, Siemens AG, 2011 and 2010.\n"},{"Case ID":"ARW-147","Case Title (Name of Public Official or Entity Allegedly Involved)":"Oxford University Press \/ World Bank Settlement","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United Kingdom","Position of Public Official(s) (yrs in office)":"N\/A","Jurisdiction of Asset Recovery":"","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2011","Asset Recovery End":"","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Negotiated Resolution Agreement ","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Cooperation in investigation with the UK Serious Fraud Office","Contributing Factors in Asset Recovery":"The $500,000 payment by the Oxford University Press -- \u0022in order to remedy part of the harm done by the misconduct\u0022 - was part of its Negotiated Resolution.  (Source:  The World Bank Press Release, \u0022World Bank Sanctions Oxford University Press for Corrupt Practices Impacting Education Projects in East Africa,\u0022 July 3, 2012.)\r\n","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$500,000","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"Unspecified","Case Summary":"According to the press release by the World Bank, on July 3, 2012, \u0022The World Bank Group today announced the debarment of two wholly-owned subsidiaries of Oxford University Press (OUP), namely: Oxford University Press East Africa Limited (OUPEA) and Oxford University Press Tanzania Limited (OUPT) - for a period of three years following OUP\u2019s acknowledgment of misconduct by its two subsidiaries in relation to two Bank-financed education projects in East Africa.\n\tThe debarment is part of a Negotiated Resolution Agreement between OUP and the World Bank Group. In May 2011, investigators from the World Bank\u2019s Integrity Vice Presidency (INT) approached OUP about potential misconduct in Africa. Following this, OUP conducted an internal investigation into its operations and reported its findings to INT. [\u00a0 ]\n\tThe two companies made improper payments to government officials for two contracts to supply text books in relation to two World Bank-financed projects. As a result, OUPEA and OUPT will be debarred for three years and OUP will receive a conditional non-debarment. In addition, in order to remedy part of the harm done by the misconduct, OUP has agreed to make a payment of US$500,000 to the World Bank as part of the Negotiated Resolution.\u0022 (Source:\u00a0 The World Bank Press Release, \u0022World Bank Sanctions Oxford University Press for Corrupt Practices Impacting Education Projects in East Africa,\u0022 July 3, 2012.)\n\tIn the World Bank Intrgrity Vice Presidency\u0027s fiscal year 2012 Annual Report, the World Bank President Jim Yong Kim stated, \u0022the World Bank Group will continue to work with patience and perseverance on the thornier parts of fighting corruption: [\u00a0 ] designing an Anti-Corruption Fund that equitably and purposefully distributes recovered assets and restitution payments to those who would benefit the most.\u0022\u00a0 (Source: Integrity Vice Presidency, \u0022Annual Report Fiscal Year 2012: Finding the Right Balance,\u0022 The World Bank (October 2012), at iv.","Disposition of Criminal Case(s)":"N\/A (Administrative sanctions case)","Jurisdiction of Origin: Investigative Agency":"UK Serious Fraud Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"World Bank Integrity Vice Presidency","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"World Bank Integrity Vice Presidency","Jurisdiction of Asset Recovery: Courts Involved":"N\/A","Documents":"","Sources ":"The World Bank Press Release, \u0022World Bank Sanctions Oxford University Press for Corrupt Practices Impacting Education Projects in East Africa,\u0022 July 3, 2012, acessed at http:\/\/www.worldbank.org\/en\/news\/2012\/07\/03\/world-bank-sanctions-oxford-university-press-corrupt-practices-impacting-education-projects-east-africa;\nWorld Bank Integrity Vice Presidency, \u0022Annual Report Fiscal Year 2012: Finding the Right Balance,\u0022 The World Bank (October 2012), accessed at\u00a0 http:\/\/www-wds.worldbank.org\/external\/default\/WDSContentServer\/WDSP\/IB\/2012\/10\/08\/000356161_20121008012319\/Rendered\/PDF\/731010AR0Box370C0disclosed010050120.pdf\n"},{"Case ID":"ARW-146","Case Title (Name of Public Official or Entity Allegedly Involved)":"Oxford University Press \/ UK Serious Fraud Office Settlement","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United Kingdom","Position of Public Official(s) (yrs in office)":"N\/A","Jurisdiction of Asset Recovery":"Various, unnamed jurisdictions","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Unilateral voluntary payment arising out of foreign bribery case","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"\u0022This was a reflection of the seriousness with which OUP [Oxford University Press] views the course of events that were subject to the investigation and a wish to acknowledge that the conduct of [its subsidiaries] OUPEA and OUPT fell short of that expected within its wider organisation.  The contribution would benefit the people within the affected region and be consistent with the overall mission of OUP.  The offer also confirmed that the funds would not be used so as to provide OUP with a commercial advantage.\u0022  (Source:  UK Serious Fraud Office Press Release, \u0022Oxford Publishing Ltd to pay almost \u00a31.9 million as settlement after admitting unlawful conduct in its East African operations,\u0022 July 3, 2012.)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Other","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Oxford University Press \u0022unilaterally offered to contribute \u00a32,000,000 to not-for-profit organisations for teacher training and other educational purposes in sub-Saharan Africa.\u0022 (Source:  UK Serious Fraud Office Press Release, \u0022Oxford Publishing Ltd to pay almost \u00a31.9 million as settlement after admitting unlawful conduct in its East African operations,\u0022 July 3, 2012.)","Case Summary":"According to the press release by the UK Serious Fraud Office, \u0022In 2011, OUP [Oxford University Press] became aware of the possibility of irregular tendering practices involving its education business in East Africa.\u00a0 OUP acted immediately to investigate the matter, instructing independent lawyers and forensic accountants to undertake a detailed investigation.\nAs a result of the investigation, in November 2011 OUP voluntarily reported certain concerns in relation to contracts arising from a number of tenders which its Kenyan and Tanzanian subsidiaries, OUPEA and OUPT, entered into between the years 2007 and 2010.\u0022\u00a0\u00a0\u00a0 As part of the agreed upon Civil Recovery Order, OUP agreed to pay GBP1,895,435 (US$2,971,300) and GBP 12,500 (US$19,595) for SFO\u0027s costs of pursuing the order.\u00a0\n\u0022In addition to the property recovered under the civil recovery order, OUP unilaterally offered to contribute \u00a32,000,000 to not-for-profit organisations for teacher training and other educational purposes in sub-Saharan Africa.\u00a0 This was a reflection of the seriousness with which OUP views the course of events that were subject to the investigation and a wish to acknowledge that the conduct of OUPEA and OUPT fell short of that expected within its wider organisation.\u00a0 The contribution would benefit the people within the affected region and be consistent with the overall mission of OUP.\u00a0 The offer also confirmed that the funds would not be used so as to provide OUP with a commercial advantage\nAlthough the benefits to the people of the affected region are acknowledged by the SFO, the SFO decided that the offer should not be included in the terms of the court order as the SFO considers it is not its function to become involved in voluntary payments of this kind.\u00a0\u00a0 However, the SFO welcomes OUP\u0027s commitment to make this contribution and to work with a range of not-for-profit organisations in sub-Saharan Africa to achieve the above objectives.\u0022\u00a0 (Source:\u00a0 UK Serious Fraud Office Press Release, \u0022Oxford Publishing Ltd to pay almost \u00a31.9 million as settlement after admitting unlawful conduct in its East African operations,\u0022 July 3, 2012.)\n\u00a0","Disposition of Criminal Case(s)":"N\/A (Civil Recovery Order)","Jurisdiction of Origin: Investigative Agency":"UK Serious Fraud Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Justice, Queen\u0027s Bench Division (UK)","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/application_notice_form_n244.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Oxford_Univ_Press_Settlement_SFO_Press_Release_Jul_3_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/part_8_claim_form_n208.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/sealed_consent_order.pdf","Sources ":"UK Serious Fraud Office Press Release, \u0022Oxford Publishing Ltd to pay almost \u00a31.9 million as settlement after admitting unlawful conduct in its East African operations,\u0022 July 3, 2012, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-20...\n\tConsent Order, accessed at http:\/\/www.sfo.gov.uk\/media\/215466\/sealed_consent_order.pdf;\n\t\u00a0\n\tClaim Form to the High Court, accessed at http:\/\/www.sfo.gov.uk\/media\/215458\/part_8_claim_form_n208.pdf;\n\t\u00a0\n\tApplication Notice to the High Court, accessed at http:\/\/www.sfo.gov.uk\/media\/215462\/application_notice_form_n244.pdf.\n\t\u00a0\n\t\u00a0\n\t\u00a0\n"},{"Case ID":"ARW-142","Case Title (Name of Public Official or Entity Allegedly Involved)":"Nicolau Dos Santos Neto","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Brazil","Position of Public Official(s) (yrs in office)":"Judge (inclusive 1991-1994)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Confiscation; Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT; Letter of Request","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Criminal and civil legal mechanisms employed in Switzerland and Brazil; more than a decade of international legal cooperation.  (Sources:  Swiss Federal Court decision 6B_688\/2011 (August 21, 2012) and Swiss Federal Department of Justice and Police, \u0022Strengthening co-operation in the fight against crime \/\r\nBrazilian delegation visits Bern,\u0022 Press Release October 14, 2002.)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction (in part)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"$2,100,000","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tAccording to a July 9, 2013 press release by the Swiss Federal Office of Justice, \u00a0\u0022The sum of USD 4.8 million has now been transferred to the Federative Republic of Brazil. The Federal Supreme Court also ordered that Nicolau Dos Santos Neto should pay a replacement value of USD 2.1 million to Brazil.\u0022 \u00a0(Source: \u00a0Swiss Federal Office of Justice, Press Release, \u0022USD 4.8 m returned to Brazil\u0022, July 9, 2013. )\n\n\tAccording to an August 2012 decision by the Swiss Federal Court, between 1991 and 1994, 18 transactions totalling $6.8 million were transferred into accounts in the names of Mr. Neto and his spouse. \u00a0 The funds were proceeds of fraud and embezzlement by Mr. Neto in connection with the construction of a Regional Labour Court of Sao Paulo, Brazil. \u00a0Preliminary criminal inquiry was opened in Switzerland in 1999 but the complicated nature of the case - which included the intervention of third parties, use of shell corporations and international ramifications requiring the sending of letters rogatory to Brazil - added to the length of the case. \u00a0(Source: \u00a0Swiss Federal Court decision 6B_688\/2011 (August 21, 2012). \u00a0The funds had been frozen and confiscated pursuant to a Swiss investigation launched in 1999; in 2005, following Mr. Neto\u0027s criminal conviction in Brazil, Brazil filed suit in Switzerland to recover the assets. \u00a0(Source: \u00a0Id. and Jamil Chade, \u0022Suica vai devolver ao Brasil parte do dinheiro desviado por \u0027Lalau\u0027,\u0022 Estado.com.br, September 3, 2012, both accessed at http:\/\/www.icc-ccs.org\/home\/news\/90-fraudnet-and-its-members-in-the-news....) \u00a0 According to a 2011 presentation on the case by Brazil\u0027s Swiss attorney Yves Klein, in 2001 Brazil was admitted to the Swiss criminal case as an injured party which provided Brazil with the \u0022Right to consult the file, to participate in the acts of investigation, to make determinations on the cause, and to request investigative acts from the examining magistrate: \u2022 investigate other bank accounts in Switzerland; \u2022 question bank employees so as to assess their criminal liability.\u0022 \u00a0(Source: Attorney Yves Klein, \u0022The TRT Case \u2013 The forfeiture of the assets of Nicolau Dos Santos Neto in Switzerland,\u0022 presentation at the International Fraud \u0026 Asset Recovery and Trans-Border Insolvency Cooperation conference of Escola Superior do Minist\u00e9rio P\u00fablico de S\u00e3o Paulo (November-December 2011).\u00a0","Disposition of Criminal Case(s)":"According to the August 2012 decision by the Swiss Federal Court, Mr. Neto had been convicted in Brazil in 2005 of bribery, embezzlement, fraud and money laundering, and his conviction was upheld on appeal.\u00a0 (Source:\u00a0 Swiss Federal Court decision 6B_688\/2011 (August 21, 2012)).","Jurisdiction of Origin: Investigative Agency":"Ministry of Justice; Federal Police","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Federal Prosecutor","Jurisdiction of Origin: Courts Involved":"Federal Regional Court of the 3rd Region","Jurisdiction of Asset Recovery: Investigative Agency":"Prosecutor General, Geneva canton; Swiss Federal Department of Justice and Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General - Geneva canton; Federal Republic of Brazil - Attorneys Enrico Monfrini and Yves Klein","Jurisdiction of Asset Recovery: Courts Involved":"Court of Justice, Geneva; Swiss Federal Court","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Neto_Switzerland_Fed_Office_Justice_PR_Return_Jul_9_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Neto_Swiss_Ct_Decision_Aug_21_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Neto_Swiss_Fed_Justice_Statement_Oct_13_2002.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Neto_Swiss_Klein_Presentation_Nov_Dec_2011.pdf","Sources ":"\n\tSwiss Federal Office of Justice, Press Release, \u0022USD 4.8 m returned to Brazil\u0022, July 9, 2013, at https:\/\/www.bj.admin.ch\/\/content\/bj\/en\/home\/dokumentation\/medieninformat...\n\n\tSwiss Federal Court decision 6B_688\/2011 (August 21, 2012), accessed at http:\/\/jumpcgi.bger.ch\/cgi-bin\/JumpCGI?id=21.08.2012_6B_688\/2011; Jamil Chade, \u0022Suica vai devolver ao Brasil parte do dinheiro desviado por \u0027Lalau\u0027,\u0022 Estado.com.br, September 3, 2012, accessed via link provided at http:\/\/www.icc-ccs.org\/home\/news\/90-fraudnet-and-its-members-in-the-news... Swiss Federal Department of Justice and Police, \u0022Strengthening co-operation in the fight against crime \/ Brazilian delegation visits Bern,\u0022 Press Release October 14, 2002, accessed at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2002\/2002... See also presentation on the case by Attorney Yves Klein (representing Brazil), at the International Fraud \u0026 Asset Recovery and Trans-Border Insolvency Cooperation conference of Escola Superior do Minist\u00e9rio P\u00fablico de S\u00e3o Paulo (November-December 2011), at: \u00a0http:\/\/www.icc-ccs.org\/jdownloads\/Publications\/111201_klein_presentation...\n\n\t\u00a0\n"},{"Case ID":"ARW-137","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi \/ Saadi Quaddafi \/ London Mansion Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"The case marks the first international asset recovery by Libya; contributing factors included (1) media publicity surrounding the purchase of the mansion by Mr. Qaddafi\u0027s son; (2) wide disparity between Mr. Saadi Qaddafi\u0027s official salary as a member of the armed forces and the purchase price of the mansion, as well as strict bar on ownership of foreign property by members of Libyan armed forces; and (3) failure of Mr. S. Qaddafi and Capitana Seas Limited to appear and challenge the suit.  (Source: Phone interview with Libya\u0027s UK attorney in the suit.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$14,200,000 (approximate value of mansion)","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a Judgment by the United Kingdom\u0027s High Court of Justice, Libya was granted a default judgment against Capitana Seas Limited, the legal owner of a mansion located at 7 Winnington Close, Hampstead Gardens Suburb, London N2 0UA.\u00a0 The Justice in the case wrote, \u0022I am satisfied, on the evidence which has been put before me, that Saadi Quaddafi is the sole ultimate beneficial owner of the Defendant company [Capitana Seas Limited] [and that] the property was wrongfully and unlawfully purchased with funds belonging to [Libya].\u00a0 In those circumstances, the beneficial interest in the property is held by the Defendant, for the Claimant, as constructive trustees.\u0022\u00a0 (Source:\u00a0 Between The State of Libya and Capitana Seas Limited, [2012] EWHC 602 (Com).]\u00a0 The British media had reported on the purchase of the mansion by Capitana Seas Limited, a British Virgin Islands registered entity, and when sanctions were imposed against Mr. Qaddafi\u0027s assets in the UK, the property was included on the sanctions list.\u00a0 (Source:\u00a0 Libya\u0027s UK attorney in the case; see also,\u00a0 Christopher Leake and Daniel Bouffe, \u0022Colonel Gaddafi\u0027s son buys \u00a310m Hampstead mansion,\u0022 MailOnline, August 23, 2009.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Mohamed Shaban (MS- Legal Solicitors)","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Justice, Commercial Cour","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Libya_v_Capitana_Seas_UK_High_Ct_Judgment_Mar_2012.pdf","Sources ":"Between The State of Libya and Capitana Seas Limited, [2012] EWHC 602 (Com);\n\tChristopher Leake and Daniel Bouffe, \u0022Colonel Gaddafi\u0027s son buys \u00a310m Hampstead mansion,\u0022 MailOnline, August 23, 2009, accessed at http:\/\/www.dailymail.co.uk\/news\/article-1208434\/Gaddafi-son-buys-10m-Hampstead-mansion.html;\n\tPhone interview with Libya\u0027s UK attorney (October 2012)\n"},{"Case ID":"ARW-116","Case Title (Name of Public Official or Entity Allegedly Involved)":"Lesotho Highlands Water Project \/ Jacob Michael du Plooy","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"South Africa","Position of Public Official(s) (yrs in office)":"Chief executive of the Lesotho Highlands Development Agency (Masupha Ephraim Sole, 1986-1995) and former delegates of Lesotho on the Highlands Water Commission (Reatile Mochebelele and Letiafuoa Molapo); Acres International Limited (Canada); Lahmeyer International GmbH (Germany); Impregilo SpA (Italy); Jacobus Michiel Du Plooy (Impregilo intermediary); Spie Batignolles (France)","Jurisdiction of Asset Recovery":"Lesotho","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"1999","Asset Recovery End":"2003","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Successful collaboration of OLAF [European Anti-Fraud Office] in prosecuting the European companies involved; mutual legal assistance from Switzerland in the prosecutions (Source:  LL Thetsane and GH Penzhorn SC, \u0022Case Study: The Lesotho bribery prosecutions,\u0022 presented at Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities, Rabat, May 14-16, 2007); World Bank investigation and debarment of involved companies, Acres International and Lahmeyer International GmbH (Source: World Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, which noted \u0022Once the indictments [in the case] were announced in mid-1999, the World Bank provided extensive evidentiary support to the Lesotho prosecutors and made bank staff available for interviews.\u0022)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$67,114","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the decision by the Lesotho High Court, Mr. Du Plooy pleaded guilty to bribery and in September 2003, was sentenced to pay a fine of US$67,114.\u00a0 (Source: R v Du Plooy (CRI\/T\/111\/1999), 2003 LSHC 122).\u00a0 The case arose out of the Lesotho Highlands Water Project, which the Lesotho Court of Appeal as \u0022[0]ne of the biggest and most ambitious dam projects in the world, which entailed inter alia the construction of the Katse Dam in a remote and inaccessible part of the highlands of Lesotho.\u0022\u00a0 (Source: In the matter between: Ephraim Masupha Sole and The Crown, Lesotho Court of Appeals, Case (CRI) 5 OF 2002, Judgment dated April 13, 2003).\u00a0 According to the 2003 Lesotho Court of Appeal judgment, the High Court of Lesotho had found Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, guilty of accepting bribes from various multinational companies that were attempting to secure contracts related to the project.\u00a0 In an earlier dispute involving Mr. Sole, the government hired Ernst and Young, whose audit discovered that Mr. Sole had Swiss bank accounts into which the project contractors and consultants had placed large sums of money.\u00a0 Four multinational companies also were convicted or pleaded guilty in the case. (Please see other Lesotho Highlands Water Project entries.)","Disposition of Criminal Case(s)":"According to the Lesotho Court of Appeal, Mr. Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, was found guilty of accepting bribes from various multinational companies in connection with the Lesotho Highlands Water Project. According to the decision by the Lesotho High Court, Mr. Du Plooy pleaded guilty to bribery and in September 2003, was sentenced to pay a fine of US$67,114.\u00a0 (Source: R v Du Plooy (CRI\/T\/111\/1999), 2003 LSHC 122).","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"European Anti-Fraud Office (OLAF)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions of Lesotho","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Lesotho; Court of Appeal of Lesotho","Documents":"","Sources ":"R v Du Plooy (CRI\/T\/111\/1999), 2003 LSHC 122, accessed at http:\/\/www.lesotholii.org\/ls\/judgment\/high-court\/2003\/122;\u00a0\n\tIn the Matter between Ephraim Masupha Sole and the Crown, in the Appeal Court of Lesotho, C. of A. (CRI) 5 of 2002, CRI\/T\/111\/91, April 2, 3, and 14, 2003;\n\t\u0022Case Study: The Lesotho bribery prosecutions,\u0022 Paper presented by LL Thetsane and GH Penzhorn SC, at the Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities,\u0022 Rabat, May 14-16, 2007.\u00a0\u00a0\n\tWorld Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,contentMDK:21116129~pagePK:64257043~piPK:437376~theSitePK:4607,00.html;\n\tEuropean Anti-Fraud Office Press Release, \u0022Three European Companies Guilty in African Aid Fraud Case,\u0022 October 3, 2006, accessed at http:\/\/ec.europa.eu\/anti_fraud\/cases\/aid_en.html.\u00a0\n\tLesotho Highlands Water Project, at http:\/\/ipocafrica.org which also provides a list and links to relevant documents.\n"},{"Case ID":"ARW-86","Case Title (Name of Public Official or Entity Allegedly Involved)":"James Ibori  (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Delta State Governor (1999-2007)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\n\t\tAccording to media reports, the confiscation hearings in Mr. Ibori\u0027s case which was to take place in June 2016, has been adjourned. (Source: \u00a0Today (Nigeria), \u0022London court suspends James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016.)\n\n\n\t\u00a0\n\n\tOn June 4, 2008, the UK High Court issued a Restraint Order against properties, accounts and other assets owned and\/or controlled by Governor Ibori and legal entities Haleway Properties Limited; Telaton Quays Limited, Stanhope Investments Limited, and \u00a0Erin Aviation Limited located within and outside of the United Kingdom. \u00a0(Source: IN THE MATTER OF James Onanefe IBORI, Restraint Order Prohibiting Disposal of Assets, UK High Court, Queen\u0027s Bench Division, June 4, 2008.). \u00a0In February 2012, in reporting on Mr. Ibori\u0027s guilty plea in the UK, the BBC News reported, \u0022Some $35m of his alleged UK assets were frozen in 2007.\u0022 \u00a0(Source: \u00a0BBC News, \u0022Nigeria ex-Delta state governor James Ibori guilty plea,\u0022 February 27, 2012.)\n\n\t\u00a0\n\n\tOn November 17, 2008, the High Court also issued a Restraint Order against assets related to Bhadresh Gohil, including in India, Hong Kong and the UK. \u00a0(Source: IN THE MATTER OF Bhadresh Babulal Gohil, Restraint Order Prohibiting Disposal of Assets, UK High Court, Queen\u0027s Bench Division, November 17, 2008.)\n\n\t\u00a0","Disposition of Criminal Case(s)":"According to a May 2014 statement by Nigeria\u0027s Economic and Financial Crimes Commission, a lower court decision to strike out \u0022all 170-count charge of money laundering preferred against former governor of Delta State, James Onanefe Ibori by the Economic and Financial Crimes Commission, EFCC, a three-man panel of justices at the Benin Division of the Court of Appeal today, May 15, 2014 ruled that the ex- governor who is currently serving a 13-year jail term in a London prison, has a case to answer.\u0022 \u00a0(Source: EFCC, \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014.) According to the US Department of Justice, \u0022Governor Ibori was convicted in the United Kingdom of money laundering and conspiracy to defraud and was sentenced by a British court on April 18, 2012, to 13 years in prison.\u0022 (Source: US Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012.)","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission ","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"Court of Appeals, Benin Division","Jurisdiction of Asset Recovery: Investigative Agency":"London Metropolitan Police, Proceeds of Corruption Unit","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service","Jurisdiction of Asset Recovery: Courts Involved":"High Court, Queen\u0027s Bench","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_UK_Restart_Confisc_Hearing_Channelstv_Oct_8_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_DDC_US_Response_Show_Cause_Order_Jul_16_2013_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Ex_Parte_Restrain_Order_DDC_May_2012_4.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Asset_Restraint_DOJ_PR_Jul_23_2012_2.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_UK_Restraint_Order_Nov_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_UK_London%20judge%20adjourns%20Ibori%27s%20case%20to%20June%206%2C%202016%20-%20Vanguard%20News_Apr_14_2015.pdf","Sources ":"\n\tNigeria Economic and Financial Crimes Commission (EFCC), \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014, at https:\/\/efccnigeria.org\/efcc\/index.php\/news\/870-money-laundering-ibori-h...\n\n\t\u00a0\n\n\n\t\t\u00a0\n\n\t\tToday (Nigeria), \u0022London court suspends James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016, at https:\/\/www.today.ng\/news\/national\/135296\/london-court-suspends-james-ib...\n\n\t\t\u00a0\n\n\n\tVanguard News, \u0022London judge adjourns Ibori\u0027s case to June 6, 2016,\u0022 April 15, 2015;\u00a0\n\n\t\u00a0\n\n\tIN THE MATTER OF James Onanefe IBORI, Restraint Order Prohibiting Disposal of Assets, UK High Court, Queen\u0027s Bench Division, June 4, 2008; IN THE MATTER OF Bhadresh Babulal Gohil, Restraint Order Prohibiting Disposal of Assets, UK High Court, Queen\u0027s Bench Division, November 17, 2008, attached as Exhibits to \u00a0In Re: Enforcement of Restraining Order Issued by the High Court of England and Wales, Case No. 1:12-mc-00289 (D.D.C.), Ex Parte application by United States filed on May 16, 2012 (both accessed via PACER);\n\n\t\u00a0\n\n\tUS Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012, accessed at http:\/\/www.justice.gov\/opa\/pr\/2012\/July\/12-crt-906.html;\n\n\t\u00a0\n\n\tBBC News, \u0022Nigeria ex-Delta state governor James Ibori guilty plea,\u0022 February 27, 2012. );\u00a0\n\n\t\u00a0\n\n\tChanneltv.com, \u0022UK Court May Restart $145m Ibori Asset-Confiscation Case,\u0022 October 8, 2013, at http:\/\/www.channelstv.com\/home\/2013\/10\/08\/uk-court-may-restart-145m-ibor...\n"},{"Case ID":"ARW-85","Case Title (Name of Public Official or Entity Allegedly Involved)":"James Ibori (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Delta State Governor (1999-2007)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2012","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Forfeiture; Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Instrument as Contemplated by Article 3(2) of the Agreement on Mutual Legal Assistance Between the United States of America and the European Union Signed 25 June 2003, as to the Application of the Treaty Between the United States of America and the Government of the United Kingdom of Great Britain and Northern Ireland on Mutual Legal Assistance in Criminal Matters Signed 6 January 1994, U.S.-U.K., Dec. 16, 2004, S. Treaty Doc. 109-13 (2006); Treaty with the United Kingdom on Mutual Legal Assistance on Criminal Matters, U.S.-U.K., Jan. 6, 1994","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\nAccording to the US Department of Justice Press Release, \u0022Through an application to register and enforce two orders from United Kingdom courts, the Department of Justice has secured a restraining order against more than $3 million in corruption proceeds located in the United States related to James Onanefe Ibori. [ ] The application, which was filed under seal on May 16, 2012, in U.S. District Court in the District of Columbia, seeks to restrain assets belonging to Governor Ibori and Bhadresh Gohil, Ibori\u2019s former English solicitor, that are proceeds of corruption.\u00a0 Specifically, it seeks to restrain a mansion in\u00a0 Houston and two Merrill Lynch brokerage accounts. [ ] The United States is working with the United Kingdom\u2019s Crown Prosecution Service and the Metropolitan Police Service to forfeit these corruption proceeds.\u0022\u00a0 (Source: US Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012.)\u00a0 According to the Ex Parte Application filed by the US Department of Justice, the Houston property is located at 931 Enclave Lake Drive and the Merrill Lynch accounts are: 1CA-07411 and 1CA-07246. (Source: In Re: Enforcement of Restraining Order Issued by the High Court of England and Wales, Case No.\u00a0Case No. 1:12-mc-00289 (D.D.C.), Ex Parte application by United States filed on May 16, 2012.)\nIn July 2013, the US Government filed a response to the Court Order to Show Cause, urging the court not to terminate the action and to retain jurisdiction over the matter until confiscation proceedings in the UK conclude.\u00a0 As of June 2016, the US case was ongoing.\u00a0 (Source:\u00a0 In Re: Enforcement of Restraining Order Issued by the High Court of England and Wales, Case No.\u00a01:12-mc-00289 (D.D.C.), US Government Reponse to Order to Show Cause filed July 16, 2013; Court Docket Report as of June 17, 2016.) \u00a0According to news reports, the UK confiscation hearing that was rescheduled for June 2016 was again postponed.\u00a0 (Source: Vanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015; Today (Nigeria), \u0022London court suspends James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016, at https:\/\/www.today.ng\/news\/national\/135296\/london-court-suspends-james-ib...)\n\n\u00a0","Disposition of Criminal Case(s)":"According to a May 2014 statement by Nigeria\u0027s Economic and Financial Crimes Commission, a lower court decision to strike out \u0022all 170-count charge of money laundering preferred against former governor of Delta State, James Onanefe Ibori by the Economic and Financial Crimes Commission, EFCC, a three-man panel of justices at the Benin Division of the Court of Appeal today, May 15, 2014 ruled that the ex- governor who is currently serving a 13-year jail term in a London prison, has a case to answer.\u0022 \u00a0(Source: EFCC, \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014.) According to the US Department of Justice, \u0022Governor Ibori was convicted in the United Kingdom of money laundering and conspiracy to defraud and was sentenced by a British court on April 18, 2012, to 13 years in prison.\u0022 (Source: US Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Asset Forfeiture and  Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the District of Columbia","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_DDC_US_Response_Show_Cause_Order_Jul_16_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Asset_Restraint_DOJ_PR_Jul_23_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Ex_Parte_Restrain_Order_DDC_May_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_Nigeria_Appeals_Ct_EFCC_May_15_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_UK_London%20judge%20adjourns%20Ibori%27s%20case%20to%20June%206%2C%202016%20-%20Vanguard%20News_Apr_14_2015_0.pdf","Sources ":"\nNigeria Economic and Financial Crimes Commission (EFCC), \u0022Money Laundering:\u00a0 Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014, at https:\/\/efccnigeria.org\/efcc\/index.php\/news\/870-money-laundering-ibori-has-case-to-answer-appeal-court;\nToday (Nigeria), \u0022London court suspends James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016, at https:\/\/www.today.ng\/news\/national\/135296\/london-court-suspends-james-ib...\nVanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015;\nUS Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012, accessed at http:\/\/www.justice.gov\/opa\/pr\/2012\/July\/12-crt-906.html;\u00a0\nIn Re: Enforcement of Restraining Order Issued by the High Court of England and Wales, Case No. 1:12-mc-00289 (D.D.C.), Ex Parte application by United States filed on May 16, 2012; US Government Response to Order to Show Cause filed July 16, 2013; Court Docket Report as of September 14, 2015.\n\n\u00a0\n"},{"Case ID":"ARW-80","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hosni Mubarak (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Egypt","Position of Public Official(s) (yrs in office)":"President (1981-2011)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case ","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to written evidence provided by the Chancellor of the Exchequer to the UK Parliament on Januaty 26, 2012, \u0022The sanctions in respect of Egypt impose an asset freeze against 19 individuals identified as responsible for the misappropriation of Egyptian state funds. A list of these individuals is available from the Treasury website http:\/\/www.hm-treasury.gov.uk\/fin_sanctions_egypt.htm and is reproduced here for convenience.\n\t(1) Ahmed, Abla Mohamed Fawzi Ali\n\t(2) Al Naggar, Shahinaz Abdel Aziz Abdel Wahab\n\t(3) El Gammal, Khadiga Mahmoud\n\t(4) El Gazaerly, Naglaa Abdallah\n\t(5) Eladli, Habib Ibrahim Habib\n\t(6) Eldin, Jaylane Shawkat Hosni Galal\n\t(7) Elmaghraby, Ahmed Alaeldin Amin Abdelmaksoud\n\t(8) Ezz, Ahmed Abdelaziz\n\t(9) Fahmy, Hania Mahmoud Abdel Rahman\n\t(10) Garrana, Amir Mohamed Zohir Mohamed Wahed\n\t(11) Garrana, Mohamed Zohir Mohamed Wahed\n\t(12) Hussein, Rachid Mohamed Rachid\n\t(13) Mubarak, Alaa Mohamed Hosni Elsayed\n\t(14) Mubarak, Gamal Mohamed Hosni Elsayed\n\t(15) Mubarak, Mohamed Hosni Elsayed\n\t(16) Rasekh, Heidy Mahmoud Magdy Hussein\n\t(17) Sharshar, Elham Sayed Salem\n\t(18) Thabet, Suzanne Saleh\n\t(19) Yassin, Khadiga Ahmed Ahmed Kamel\n\tFor reasons of confidentiality, the Treasury is unable to disclose the information requested about individuals and their assets frozen in the UK under the Egypt sanctions regime.\u0022\u00a0 (Source: UK Parliament, Commons Debates, Written Answers January 26, 2012, \u0022Treasury \/ Assets: Egypt.\u0022)\u00a0\nAccording to media reports in late May 2012, UK and Egyptian authorities met to discuss GBP85 million in Mubarak-related assets frozen in the UK.\u00a0 (Source: Amer Sultan, \u0022UK, Egypt resume talks on Mubarak assets recovery,\u0022 Ahramonline, May 27, 2012.)","Disposition of Criminal Case(s)":"According to the New York Times and other sources, in May 2014, Mr. Mubarak was convicted on charge of embezzlement and sentenced to three years\u0027 imprisonment. (Source: \u00a0David Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014.)","Jurisdiction of Origin: Investigative Agency":"Prosecutor-General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor-General\u0027s Office","Jurisdiction of Origin: Courts Involved":"Cairo Appeals Court","Jurisdiction of Asset Recovery: Investigative Agency":"UK Treasury","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Asset Recovery: Courts Involved":"NA","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_Embezzlement_Verdict_NYTimes_May_21_2014_2.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_UK_Asset_Freeze_uksi_20110887_en.pdf","Sources ":"\n\tUK Parliament, Commons Debates, Written Answers January 26, 2012, \u0022Treasury \/ Assets: Egypt,\u0022 accessed at http:\/\/www.publications.parliament.uk\/pa\/cm201212\/cmhansrd\/cm120126\/text...\n\n\t\u00a0\n\n\tSanctions: http:\/\/www.hm-treasury.gov.uk\/fin_sanctions_egypt.htm;\n\n\t\u00a0\n\n\tDavid Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014, at http:\/\/www.nytimes.com\/2014\/05\/22\/world\/middleeast\/hosni-mubarak-trial.html\n\n\t\u00a0\n\n\tAmer Sultan, \u0022UK, Egypt resume talks on Mubarak assets recovery,\u0022 Ahramonline, May 27, 2012, accessed at http:\/\/english.ahram.org.eg\/NewsContent\/3\/12\/43036\/Business\/Economy\/UK,-...\n"},{"Case ID":"ARW-71","Case Title (Name of Public Official or Entity Allegedly Involved)":"Haiti Teleco \/ Patrick Joseph","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Haiti","Position of Public Official(s) (yrs in office)":"Director General, Haiti Teleco (inclusive March 2001 through June 2003)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"Close cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"Mr. Joseph, a former Director General of Haiti Teleco, pleaded guilty to one count of conspiracy to commit money laundering, in connection with the Haiti Teleco bribery case.\u00a0 (Source: U.S. v. Joseph, Case No. 1:09-cr-21010-MGC (S.D. Fla.), Superseding Indictment filed July 12, 2011.)\u00a0\u00a0 As part of his sentence, Mr. Joseph was ordered to forfeit $955,596.69, the sum determined to represent the proceeds of his crime.\u00a0 (Source: U.S. v. Joseph, Case No. 1:09-cr-21010-MGC (S.D. Fla.), Order of Forfeiture filed July 6, 2012.)","Disposition of Criminal Case(s)":"According to the Judgement in his case, Mr. Joseph pleaded guilty to one count of conspiracy to commit money laundering and in July 2012, was sentenced to one year and one day of imprisonment. (Source: US v. Joseph, Case No. 1:09-cr-21010 (S.D. Fla.), Judgment in a Criminal Case, July 9, 2012.)","Jurisdiction of Origin: Investigative Agency":"N\/A","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Internal Revenue Service, Criminal Investigations -  Miami Field Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney\u0027s Office for the Southern District of Florida","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of Florida","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Patrick_Joseph_Order_Forfeiture_Jul_6_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Patrick_Joseph_Judgment_Jul_10_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Haiti_Teleco_Joseph_Superseding_Indictment_July_12_2011.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Haiti_Teleco_Joseph_Indictment_DOJ_PR_Jul-13-2011.pdf","Sources ":"U.S. v. Joseph,\u00a0 Case No. 1:09-cr-21010-MGC (S.D. Fla.), Superseding Indictment filed July 12, 2011; Order of Forfeiture filed July 6, 2012; Judgment in a Criminal Case filed July 9, 2012 (all accessed via PACER);\nUS Department of Justice Press Release, \u0022Florida Telecommunications Company, Two Executives, an Intermediary and Two Former Haitian Government Officials Indicted for Their Alleged Participation in Foreign Bribery Scheme,\u0022 July 13, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/July\/11-crm-910.html.\n"},{"Case ID":"ARW-69","Case Title (Name of Public Official or Entity Allegedly Involved)":"Gautam Sengupta","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"","Position of Public Official(s) (yrs in office)":"Task Manager, World Bank","Jurisdiction of Asset Recovery":"United States, World Bank","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2002","Asset Recovery End":"2002","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution and Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Mr. Sengupta\u0027s plea agreement with the US Department of Justice included provision for restitution to the World Bank, pursuant to 18 U.S.C. \u00a7 3663 (a)(3) [\u0022The court may also order restitution in any criminal case to the extent agreed to by the parties in a plea agreement.\u0022].  (Source: US v. Sengupta, Case No. 1:02-cr-00040 (D.D.C.), Plea Agreement filed January 30, 2002.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$127,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the Statement of Facts agreed to by Mr. Sengupta as part of his plea agreement, between 1997 and 1999 while employed as a task manager at the World Bank, Mr. Sengupta entered into agreements relating to projects in Ethiopia and Kenya resulting in consulting contracts for a Swedish consultant. The consultant then kicked back payments to Mr. Sengupta. He also admitted that \u0022sometime in January 1999, [ ] he received a request for money from a foreign government official in the Kenyan PIU for a $50,000 payment. Sengupta agreed with the foreign official that he would relay the request, and he did so with knowledge that the payment was to corruptly influence an act or decision of the foreign official in his official capacity.\u0022\u00a0 (Source: US v. Sengupta, Case No. 1:02-cr-00040 (D.D.C.), Statement of Facts filed January 30, 2002.)\u00a0 According to Mr. Sengupta\u0027s plea agreement, \u0022Pursuant to 18 U.S.C. \u00a7 3663 (a)(3), the defendant and the government agree that the amount of loss in this case is $127,000 and the defendant agrees to pay full restitution of this amount for all damage that resulted from his violations of the statutes listed in Section I herein. The United States and the Defendant agree that the Defendant has made such restitution, and The World Bank, Mr. Sengupta\u0027s former employer, has represented to the Department of Justice that it has no further claim against the defendant.\u0022\u00a0\u00a0 (Source: US v. Sengupta, Case No. 1:02-cr-00040 (D.D.C.), Plea Agreement filed January 30, 2002.)","Disposition of Criminal Case(s)":"According to the Judgment in his case, in 2006,\u00a0 Mr. Sengupta was sentenced to two months\u0027 imprisonment; in 2002, he had pleaded guilty to one count conspiracy to commit crimes against the United States and one count violation of the US Foreign Corrupt Practices Act.\u00a0 (Source: US v. Sengupta, Case No. 1:02-cr-40 (D.D.C.), Judgment filed on February 15, 2006).","Jurisdiction of Origin: Investigative Agency":"N\/A","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Criminal Division","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the District of Columbia","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Sengupta_Judgment_Feb_15_2006.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Sengupta_Plea_Agreement_Jan_30_2002.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Sengupta_Statement_Facts_Jan_30_2002.pdf","Sources ":"US v. Sengupta, Case No. 1:02-cr-00040 (D.D.C.), Plea Agreement and Statement of Facts filed January 30, 2002; Judgment filed February 15, 2006;\nUS Department of Justice Press Release, \u0022Former World Bank Employee Sentenced for Taking Kickbacks and Assisting in the Bribery of a Foreign Official,\u0022 April 25, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/April\/08-crm-341.html.\n"},{"Case ID":"ARW-59","Case Title (Name of Public Official or Entity Allegedly Involved)":"Bayoil Corporation \/ Oscar J. Wyatt, Jr.","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United States","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"Iraq [Development Fund for Iraq], United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort (United States)","Asset Recovery Start":"2005","Asset Recovery End":"2009","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution and Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"The Government Sentencing Memorandum stated the need to pay restitution to the victims, i.e. people of Iraq. (Source: US v. Wyatt, Case No. 1:05-cr-59 (SDNY), Government Sentencing Memorandum filed November 26, 2007.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$11,023,246","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Restitution to people of Iraq via Development Fund of Iraq","Case Summary":"In 2007, Mr. Wyatt, founder of the US energy company Coastal Corporation, entered into a plea agreement with the United States Attorney for the Southern District of New York in relation to his involvement in the UN Oil-for-Food scheme.\u00a0 As part of his plea agreement, Mr. Wyatt agreed to pay $11,023,245.91 in restitution to the victims of his crime.\u00a0 The Government\u0027s Sentencing Memorandum stated that the people of Iraq were among the victims of the scheme and that the restitution paid be transferred the Development Fund for Iraq for use to benefit the Iraqi people. (Source: US v. Wyatt, Case No. 1:05-cr-59 (D.D.C.), Government Sentencing Memorandum filed November 26, 2007.)","Disposition of Criminal Case(s)":"In 2007, Mr. Wyatt pleaded guilty to one count conspiracy to commit wire fraud, and subsequently sentenced to one year\u0027 imprisonment. (Source: United States Attorney for the Southern District of New York, \u0022Texas Oilman Sentenced to One Year in Prison for Conspiring to Make Illegal Payments to the Former Government of Iraq,\u0022 November 27, 2007.)","Jurisdiction of Origin: Investigative Agency":"N\/A","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, Criminal and Counterintelligence Divisions; Department of the Treasury, Office of Foreign Assets Control; Department of State; United Nations Office of Legal Affairs and the former Independent Inquiry Committee into the United Nations Oil-for-Food Program","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney for the Southern District of New York","Jurisdiction of Asset Recovery: Courts Involved":"United States District Court for the Southern District of New York","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Wyatt_SDNY_Second_Superseding_Indictment.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Wyatt_SDNY_Sentencing_Memorandum.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Wyatt_SDNY_Final_Judgment.pdf","Sources ":"US v. Wyatt, Case No. 1:05-cr-59 (SDNY), Government Sentencing Memorandum filed November 26, 2007; Judgment filed November 28, 2007;\n\tUnited States Attorney for the Southern District of New York Press Release, \u0022Texas Oilman Sentenced to One Year in Prison for Conspiring to Make Illegal Payments to the Former Government of Iraq,\u0022 November 27, 2007, accessed at http:\/\/abcnews.go.com\/images\/Blotter\/wyatt_sentencing071127.pdf\n"},{"Case ID":"ARW-58","Case Title (Name of Public Official or Entity Allegedly Involved)":"El Paso Corporation","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United States","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"Iraq [Development Fund for Iraq], United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort (United States)","Asset Recovery Start":"2005","Asset Recovery End":"2007","UNCAC Offenses Implicated":"","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Prosecution and Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"The United States Attorney for the Southern District of New York and El Paso\u0027s Non-Prosecution Agreement included a provision for forfeiture of funds which were then transferred the Development Fund of Iraq \u0022to be used as restitution to the people of Iraq asthe intended beneficiaries of the proceeds of the sale of all Iraqi oil made pursuant to the United Nations Oil-for-Food Program.\u0022 (Source: El Paso Non-Prosecution Agreement dated February 5, 2007.) ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$5,482,363","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Forfeited funds returned to people of Iraq via Development Fund of Iraq","Case Summary":"In 2007, El Paso entered into a Non-Prosecution Agreement with the United States Attorney for the Southern District of New York to resolve criminal charges filed against it in relation to the UN Oil-for-Food scheme.\u00a0 According to the agreement, El Paso agreed to forfeit to the United States $5,482,363, \u0022representing the benefits provided to the former Government of Iraq as a result of El Paso\u0027s conduct [ ] It is the intent of the United States Attorney\u0027s Office for the Southern District of New York to seek the transfer of these funds to the Development Fund of Iraq [ ] to be used as restitution to the people of Iraq as the intended beneficiaries of the proceeds of the sale of all Iraqi oil made pursuant to the United Nations Oil-for-Food Program.\u0022 (Source: El Paso Corporation Non-Prosecution Agreement, February 5, 2007.)","Disposition of Criminal Case(s)":"In 2007, El Paso Corporation entered into a Non-Prosecution Agreement with the United States Attorney for the Southern District of New York to resolve criminal charges filed against it.\u00a0 (Source: El Paso Corporation Non-Prosecution Agreement, February 5, 2007.)","Jurisdiction of Origin: Investigative Agency":"NA","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, Securities and Exchange Commission, Office of Foreign Assets Control  (Department of the Treasury)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney for the Southern District of New York","Jurisdiction of Asset Recovery: Courts Involved":"N\/A","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/El_Paso_SDNY_Non-Prosecution_Agreement_Feb_2007.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/ElPaso_US_SDNY_Prosecution_PR_Feb_7_2007.pdf","Sources ":"El Paso Non-Prosecution Agreement, Feb. 5, 2007; US Attorney for the Southern District of New York, \u0022U.S. Announces Oil-for-Food Settlement with El Paso Corporation,\u0022 Feb. 7, 2007, at http:\/\/lib.law.virginia.edu\/Garrett\/prosecution_agreements\/press_\u200brelease\/ElPaso.pdf\n"},{"Case ID":"ARW-41","Case Title (Name of Public Official or Entity Allegedly Involved)":"Chevron Corporation","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Iraq","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"Iraq [Development Fund for Iraq], United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2007","Asset Recovery End":"2007","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Prosecution and Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"The United States Attorney for the Southern District of New York and Chevron\u0027s Non-Prosecution Agreement included a provision for forfeiture of funds which were then transferred the Development Fund of Iraq \u0022to be used as restitution to the people of Iraq asthe intended beneficiaries of the proceeds of the sale of all Iraqi oil made pursuant to the United Nations Oil-for-Food Program.\u0022 (Source: Chevron Non-Prosecution Agreement dated November 8, 2007.) ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$20,000,000","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Forfeited funds returned to people of Iraq via Development Fund of Iraq","Case Summary":"In 2007, Chevron entered into a Non-Prosecution Agreement with US authorities, in relation to the UN Oil-for-Food scheme.\u00a0 According to the agreement, Chevron admitted that it had \u0022obtained Iraqi oil under the Program from third parties that paid secret, illegal surcharges to the former government of Iraq, in violation of United States wire fraud statutes and administrative regulations that prohibited transactions with the former Government of Iraq. Pursuant to the Agreement, CHEVRON will make the following payments totaling $27,000,000: (1) forfeiture of $20,000,000 to the U.S. Attorney\u0027s Office for the Southern District of New York (\u0022SDNY\u0022), which will seek to transfer that money to the Development Fund of Iraq (established on May 21, 2003, by United Nations Security Council Resolution 1483) to be paid as restitution for the benefit of the people of Iraq; (2) $5,000,000 to the New York County District Attorney\u0027s Office (\u0022DANY\u0022) to be distributed as DANY shall deem appropriate; and (3) $2,000,000 to OFAC in settlement of civil penalties. In a separate agreement, CHEVRON agreed to pay an additional monetary penalty of $3,000,000 to the Securities and Exchange Commission (\u0022SEC\u0022), and to pay disgorgement of $25,000,000, which will be satisfied by their payments to SDNY and DANY. (Source: United States Attorney Southern District of New York Press Release, \u0022Chevron Corporation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007.)","Disposition of Criminal Case(s)":"In 2007, Chevron entered into a Non-Prosecution Agreement with the US Attorney for the Southern District of New York and the New York County District Attorney\u0027s Office.\u00a0 (Source: United States Attorney Southern District of New York, \u0022Chevron Corporation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007.)","Jurisdiction of Origin: Investigative Agency":"NA","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, Securities and Exchange Commission, Office of Foreign Assets Control, New York Police Department","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney for the Southern District of New York, New York County District Attorney\u0027s Office","Jurisdiction of Asset Recovery: Courts Involved":"NA","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chevron_SDNY_Non-Prosecution_Agreement_2007.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chevron_SDNY_Agreement_PR_Mar_7_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chevron_SEC_Complaint_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chevron_SEC_Litigation_Release_Nov_2007.pdf","Sources ":"United States Attorney for Southern District of New York Press Release, \u0022Chevron Corporation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007 ;\n\tChevron Non-Prosecution Agreement dated November 8, 2007.\n"},{"Case ID":"ARW-40","Case Title (Name of Public Official or Entity Allegedly Involved)":"Chen Shui-Bian","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Taiwan, China","Position of Public Official(s) (yrs in office)":"President (2000-2008)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2010","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unspecified","Contributing Factors in Asset Recovery":"Ongoing Cases, but the U.S. Department of Justice stated in its press release that it was working closely with the Taiwan Supreme Prosecutors Office, Special Investigation Division to gather and exchange evidence (Source: U.S. Department of Justice, \u0022Forfeiture Complaint Seeks to Recover Bribery Proceeds Paid to Former Taiwan President and His Family,\u0022 July 14, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/July\/10-crm-812.html).","Status of Asset Recovery ":"","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tIn August 2012, the US Department of Justice and Avallo Ltd., the legal entity that purported to be the legal owner of the Manhattan condominium and Virginia house which were the subjects of civil forfeiture complaints in New York and Virginia, entered into a settlement agreement to resolve the cases. \u00a0Avallo Ltd. agreed to forfeit its interest in the two properties in exchange for $225,000 and $67,321 from the net proceeds from the sale of the Manhattan and Virginia properties, respectively to Avallo. \u00a0(Sources: \u00a0U.S. v. Real Property Known as Unit 5B Of The Onyx Chelsea Condominium Located at 261 West 28th Street, New York, New York 10001-5933, Case No. 1:10-cv-05390-GBD (S.D.N.Y.), Stipulation and Order of Settlement and Discontinuance filed August 30, 2012; U.S. v. Real Property Known as 2291 Ferndown Lane, Keswick, Virginia 22947-9195, Stipulation and Order of Settlement and Discontinuance filed August 30, 2012.) On July 14, 2010, civil asset forfeiture complaints were filed by U.S. Department of Justice in federal courts in the Southern District of New York and the Western District of Virginia against a Manhattan condominium and a Keswick, Virginia home. \u00a0The U.S. government alleged that the properties were purchased with proceeds of crime for which Mr. Chen and family had been convicted in Taiwan. \u00a0In New York, a post-complaint protective order was filed against the property in August 2010. \u00a0The properties were valued at $2 million total. \u00a0The complaints also noted the ongoing criminal prosecution of Florida attorney Stefan Seuss and that he had told investigators that he established the offshore structure allegedly used to conceal the corrupt proceeds. (Sources: U.S. v. Real Property Known as Unit 5B Of The Onyx Chelsea Condominium Located at 261 West 28th Street, New York, New York 10001-5933, Case No. 1:10-cv-05390-GBD (S.D.N.Y.), Complaint filed July 14, 2010; U.S. v. Real Property Known as 2291 Ferndown Lane, Keswick, Virginia 22947-9195, Case No. 3:10-cv-00037-nkm, (W.D. Va.), Complaint filed July 14, 2010. and U.S. v. Seuss, Case No. 09-cr-683 (E.D. Pa.). \u00a0On September 19, 2011, the US filed a First Amended Verified Complaint in the New York suit against the Manhattan condominium which the US alleged \u0022defendant property is owned by a New York limited liability company, West 28th Street LLC. West 28th Street LLC is owned by a British Virgin Island company, Avallo Ltd. HUANG, Jui-Ching, is the beneficial owner and director of Avallo Ltd. HUANG, Jui-Ching, is the daughter-in-law of the former president of Taiwan, CHEN, Shui-Bian and the spouse of CHEN, Chi-Chung, CHEN, Shui-Bian\u2019s son. Avallo Ltd. is held in trust by the\u00a0Knight Square Irrevocable Trust, an Island of Nevis trust, with\u00a0a British Virgin Islands Company, Global Fiduciaries Limited, as\u00a0trustee. HUANG, Jui-Ching is beneficiary of the Knight Square\u00a0Irrevocable Trust.\u0022 (Source: US v. Real Property Known as Unit 5B Of The Onyx Chelsea Condominium Located at 261 West 28th Street, New York, New York 10001-5933, Case No. 1:10-cv-05390-GBD (S.D.N.Y.), First Amended Verified Complaint filed September 19, 2011.) \u00a0According to a June 12, 2012 Court Scheduling Order, the trial date had not yet been determined but was to take place prior to March 15, 2013. \u00a0(Source: \u00a0US v. Real Property Known as Unit 5B Of The Onyx Chelsea Condominium Located at 261 West 28th Street, New York, New York 10001-5933, Case No. 1:10-cv-05390-GBD (S.D.N.Y.), Scheduling Order filed June 12, 2012.) \u00a0In the Virginia case, the US Government filed an amended complaint on July 12, 2011 and as of November 4, 2011, a Bench Trial is scheduled for October 29, 2012-November 2, 2012. \u00a0(Sources: U.S. v. Real Property Known as 2291 Ferndown Lane, Keswick, Virginia 22947-9195, Case No. 3:10-cv-00037-nkm, (W.D. Va.), First Amended Complaint for Forfeiture filed July 12, 2011; Second Amended Pretrial Order filed October 6, 2011.) \u00a0According to Taiwan News, the US and Taiwanese authorities were reported to be discussing the auctioning of the two properties. (Source: (Source: Taiwan News, \u0022SID seeking recovery of Chen Shui-bian\u2019s Swiss deposits,\u0022 October 6, 2013.)","Disposition of Criminal Case(s)":"According to a July 14, 2010 U.S. Department of Justice press release, \u0022The former president and his wife were convicted in Taiwan on Sept. 11, 2009, for bribery, embezzlement and money laundering. They are currently sentenced to 20 years in prison. Their convictions were upheld on appeal and are now pending before the Supreme Court in Taiwan. Wu Sue-Jen previously pleaded guilty to other money laundering and forgery charges and was also convicted of perjury. The former president and his wife are also currently under indictment in Taiwan for additional alleged acts of graft and money laundering.\u0022\u00a0 (Source: U.S. Department of Justice Press Release, \u0022Forfeiture Complaint Seeks to Recover Bribery Proceeds Paid to Former Taiwan President and His Family,\u0022 July 14, 2010.)\u00a0 According to a December 7, 2010 press release by the Federal Authorities of the Swiss Confederation, since January 7, 2008, the Swiss Attorney General had been conducting criminal proceedings against Chen Shui-Bian\u0027s son and daughter-in-law on suspicion of money laundering. (Source:\u00a0 The Federal Authorities of the Swiss Confederation Press Release, \u0022CHF 20 million returned to Taiwan,\u0022 December 7, 2010.)\u00a0\u00a0","Jurisdiction of Origin: Investigative Agency":"Taiwan Supreme Prosecutors Office, Special Investigation Panel","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Taiwan Supreme Prosecutors Office, Special Investigation Panel","Jurisdiction of Origin: Courts Involved":"Taipei District Court; Supreme Court","Jurisdiction of Asset Recovery: Investigative Agency":"Immigration and Customs Enforcement, Homeland Security Investigations Miami Field Office\u0027s Foreign Corruption Investigations Group and the Asset Identification and Removal Group; Immigration and Customs Enforcement Attache in the Hong Kong.","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York; U.S. District Court for the Western District of Virginia","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_SDNY_Settlement_Aug_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_WVA_Settlement_Aug_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_SDNY_First_Amended_Complaint_Sep_19_2011.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_Taiwan_Court_Decision.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_Switzerland_Recover_Funds_Taiwan_News_Oct_6_2013_0.pdf","Sources ":"\u00a0U.S. v. Real Property Known as Unit 5B Of The Onyx Chelsea Condominium Located at 261 West 28th Street, New York, New York 10001-5933, Case No. 1:10-cv-05390-GBD (S.D.N.Y.), Complaint filed July 14, 2010; Stipulation and Order of Settlement and Discontinuance filed August 30, 2012;\u00a0U.S. v. Real Property Known as 2291 Ferndown Lane, Keswick, Virginia 22947-9195,Complaint filed July 14, 2012; Stipulation and Order of Settlement and Discontinuance filed August 30, 2012;\u00a0U.S. Department of Justice Press Release, \u0022Forfeiture Complaint Seeks to Recover Bribery Proceeds Paid to Former Taiwan President and His Family,\u0022 July 14, 2010;\u00a0The Federal Authorities of the Swiss Confederation Press Release, \u0022CHF 20 million returned to Taiwan,\u0022 December 7, 2010;\u00a0aiwan News, \u0022SID seeking recovery of Chen Shui-bian\u2019s Swiss deposits,\u0022 October 6, 2013, at http:\/\/www.taiwannews.com.tw\/etn\/print.php\n"},{"Case ID":"ARW-39","Case Title (Name of Public Official or Entity Allegedly Involved)":"Chen Shui-Bian (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Taiwan, China","Position of Public Official(s) (yrs in office)":"President (2000-2008)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2007","Asset Recovery End":"2015","UNCAC Offenses Implicated":"Art.15, Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"MLAT","Contributing Factors in Asset Recovery":"\u0022Thanks to close and effective collaboration between the Taiwanese Supreme Prosecutors Office and the OAG [Office of the Attorney General], part of the funds deposited in Switzerland that are presumed to have originated from the criminal activities of former Taiwanese President has been returned to the Taiwanese authorities as an anticipated handover.  No objection was raised by any of the parties to the proceedings to the return of the sum of around CHF 20 million.\u0022 (Source: The Federal Authorities of the Swiss Confederation Press Release, \u0022CHF 29 million returned to Taiwan,\u0022 December 7, 2010.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$25,649,500","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tAccording to the September 4, 2015 news release by the Supreme Prosecutors Office of Taiwan China, the Swiss authorities returned US$6,429,018 in corruption proceeds. (Source: \u00a0Press release of the Supreme Prosecutors Office, issued September 4, 2015, at http:\/\/www.tps.moj.gov.tw\/public\/Data\/51013112053580.pdf) \u00a0In April the prosecutors\u0027 office had issued a statement noting that \u0022The Federal Supreme Court of Switzerland has ruled the decision to return the illegal proceeds to Taiwan at the amount of US$6,746,840 [ ] acquired by the former ROC President Mr. Chen Shui-bian as bribes from the merging case of Yuanta with Fuhua during the Second Financial Reform Case and remitted to Switzerland. \u00a0[ \u00a0] With the assistance of the Swiss judicial authorities, the bank accounts held by Chen Chih-chung and Huang Jui-ching at Bounchon of Merrill Lynch Bank (Suisse) SA and Galahad Management of RBS Coutts Bank AG, and the accounts of Avallo Ltd. and Bravo International Holdings, two companies controlled by Chen Chih-chung and Huang Jui-ching at Wegelin and Co. and Private Bankers, were frozen accordingly. [ \u00a0] \u00a0Among the said accounts, the two accounts of Bouchon and Galahad held the illegal proceeds acquired from the Lungtan Corruption Case, the Nangang Corruption Case, the State Affairs Confidential Funds Case, and their relevant money laundering cases, totaled as approximately US$22,614,850. [ \u00a0] \u00a0On April 1, 2014, Federal Prosecutors Office of Swiss granted its order to remit the assets under Avallo and Bravo accounts at the amount of US$6,746,840 (approximately equivalent to NT$200 million) to the designated account of the SID. But Chen Chih-chung et al. appealed to Swiss Federal Criminal Court, which in January 2015 ruled out the objection appeal. Chen Chih-chung et al, then appealed to the Supreme Court of Switzerland. On April 28, 2015, the SID received the notification from Federal Prosecutors Office stating that the Supreme Court of Switzerland has dismissed the appeal of Chen and the assets of US$6,746,840 will be remitted to the designated account of the SID accordingly. The remaining assets under Avallo and Bravo accounts should be continuously frozen awaiting the further requests from Taiwan.\u0022 (Source: \u00a0News release of the Supreme Prosecutors Office, April 29, 2015 on the Chen Shui Bian case).\u00a0\n\n\t\u00a0\n\n\tAccording to a December 7, 2010 press release by the Federal Authorities of the Swiss Confederation, \u0022The Attorney General of Switzerland has returned some CHF 20 million [$18,899,500 of the $34,964,000 total frozen] to the Supreme Prosecutors Office of Taiwan, part of the money that was deposited in Switzerland by the former Taiwanese President, Chen Shui-bian, who was recently convicted of corruption in his homeland.\u0022 \u00a0The same press release noted that as part of the Swiss criminal proceedings against Chen\u0027s son and daughter-in-law and in response to a request for mutual assistance filed by Taiwan, some CHF 37 million had been seized. \u00a0Swiss investigation on the origin of the remainder of the assets is continuing. \u00a0(Source: \u00a0The Federal Authorities of the Swiss Confederation Press Release, \u0022CHF 20 million returned to Taiwan,\u0022 December 7, 2010.)\u00a0","Disposition of Criminal Case(s)":"According to an April 2015 statement by Taiwan, China\u0027s Supreme Prosecutor\u0027s Office, \u0022In the final judgment [by the Supreme Court], Chen Shui-Bian was sentenced to the imprisonment of ten years, in addition thereto, being fined 100 million New Taiwan dollars. Wu Shu-Jen was sentenced to the imprisonment of eight years, in addition thereto, being fined 80 million New Taiwan dollars. For the proceeds of crime, Chen Shui-Bian and Wu Shu-Jen have the joint liability of restitution and confiscation for 200 million New Taiwan dollars.\u0022 \u00a0(Source: \u00a0News release of the Supreme Prosecutors Office, April 29, 2015 on the Chen Shui Bian case)\n\t\u00a0\n\tAccording to a December 7, 2010 press release by the Federal Authorities of the Swiss Confederation, since January 7, 2008, the Swiss Attorney General had been conducting criminal proceedings against Chen Shui-bian\u0027s son and daughter-in-law on suspicion of money laundering. (Source: \u00a0The Federal Authorities of the Swiss Confederation Press Release, \u0022CHF 20 million returned to Taiwan,\u0022 December 7, 2010.) \u00a0\u00a0","Jurisdiction of Origin: Investigative Agency":"Taiwan Supreme Prosecutors Office, Special Investigation Panel","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Taiwan Supreme Prosecutors Office, Special Investigation Panel","Jurisdiction of Origin: Courts Involved":"Taipei District Court, Supreme Court","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Office of the Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_Switzerland_CHF20M_Returned_PR_Dec_7_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_Switzerland_Return_Taipei_Times_June_3_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_US_Justice_Dept_PR_Jul_14_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_Switzerland_Recover_Funds_Taiwan_News_Oct_6_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_Shui%20Bian_Taiwan%20China_Supreme%20Prosecutors%20Office_PR_Swiss%20Assets_Apr29%202015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_Shui_Bian_Swiss%20Asset%20Return_Taipei%20Times_Sept6%202015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_Taiwan%20China_Swiss%20Return_PR_Sep%204%202015.pdf","Sources ":"\n\tNews releases of the Supreme Prosecutors Office, September 4, 2015 at http:\/\/www.tps.moj.gov.tw\/public\/Data\/51013112053580.pdf; and April 29, 2015 on Shui Bian case, at http:\/\/www.tps.moj.gov.tw\/public\/Data\/552612157236.pdf\n\n\t\u00a0\n\n\tTaipei Times, \u00a0\u0022Chen Shui-bian\u2019s Swiss illicit gains returned to Taiwan,\u0022 September 6, 2015, at http:\/\/www.taipeitimes.com\/News\/taiwan\/archives\/2015\/09\/06\/2003627068;\n\n\t\u00a0\n\n\tThe Federal Authorities of the Swiss Confederation Press Release, \u0022CHF 29 million returned to Taiwan,\u0022 December 7, 2010 (please note that the press release was obtained from www.news.admin.ch on December 15, 2010; the release notes that the information was \u0022corrected or amended after publication.\u0022), accessed at \u00a0http:\/\/www.news.admin.ch\/message\/?lang=en\u0026msg-id=36627); \u00a0U.S. Department of Justice press release, \u0022Forfeiture Complaint Seeks to Recover Bribery Proceeds Paid to Former Taiwan President and His Family,\u0022 July 14, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/July\/10-crm-812.html; See also Rich Chang, \u0022Swiss banks begin remitting money from Chen accounts,\u0022 Taipei Times, May 23, 2010; Staff Writers, \u0022Swiss bank remits more of Chen Family\u0027s money,\u0022 Taipei Times, June 3, 2010. \u00a0Taipei trial court decision (in Chinese) in the first Chen Shui Bian trial; Government Information Office, Republic of China (Taiwan) \u0022History\u0022 chapter under \u0022About Taiwan,\u0022 accessed at http:\/\/www.gio.gov.tw\/ct.asp?xItem=18690\u0026CtNode=2579\u0026mp=807; Taiwan News, \u0022SID seeking recovery of Chen Shui-bian\u2019s Swiss deposits,\u0022 October 6, 2013, at http:\/\/www.taiwannews.com.tw\/etn\/print.php\n"},{"Case ID":"ARW-26","Case Title (Name of Public Official or Entity Allegedly Involved)":"James Ibori \/ Bhadresh Gohil (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Gohil: Solicitor to James Ibori, Delta State Governor (1999-2007)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2012","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20, Art.25","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Enforcement of Foreign Restraint Order","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Instrument as Contemplated by Article 3(2) of the Agreement on Mutual Legal Assistance Between the United States of America and the European Union Signed 25 June 2003, as to the Application of the Treaty Between the United States of America and the Government of the United Kingdom of Great Britain and Northern Ireland on Mutual Legal Assistance in Criminal Matters Signed 6 January 1994, U.S.-U.K., Dec. 16, 2004, S. Treaty Doc. 109-13 (2006); Treaty with the United Kingdom on Mutual Legal Assistance on Criminal Matters, U.S.-U.K., Jan. 6, 1994","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\n\t\tSee related entry \u0022James Ibori - United Kingdom\u0022\n\n\t\t\u00a0\n\n\t\tAccording to the factual basis for the US ex parte application to enforce the UK restraint order, \u0022Governor Ibori and his associates misappropriated millions of dollars in Delta State funds and laundered those proceeds through a myriad of shell companies, intermediaries, and nominees in the United Kingdom. Governor Ibori, with the active assistance and participation of Gohil, fraudulently diverted and misappropriated millions of dollars in Delta State funds to various businesses he controlled through his relatives and associates.\u0022 (Source: UNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., 16 May 2012.). \u00a0The US federal court granted the restaint order. \u00a0(Source: US Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012.)\n\n\t\t\u00a0\n\n\t\tIn July 2013, the US Government filed a response to the Court Order to Show Cause, urging the court not to terminate the action and to retain jurisdiction over the matter until confiscation proceedings in the UK conclude. \u00a0As of June 2016, the US case was ongoing. \u00a0(Source: \u00a0In Re: Enforcement of Restraining Order Issued by the High Court of England and Wales, Case No. 1:12-mc-00289 (D.D.C.), US Government Reponse to Order to Show Cause filed July 16, 2013; Court Docket Report as of June 17, 2016.) \u00a0According to news reports, the UK confiscation hearing that was rescheduled for June 2016 was again postponed. \u00a0(Source: Vanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015.)\n\n\u00a0","Disposition of Criminal Case(s)":"According to a May 2014 statement by Nigeria\u0027s Economic and Financial Crimes Commission, a lower court decision to strike out \u0022all 170-count charge of money laundering preferred against former governor of Delta State, James Onanefe Ibori by the Economic and Financial Crimes Commission, EFCC, a three-man panel of justices at the Benin Division of the Court of Appeal today, May 15, 2014 ruled that the ex- governor who is currently serving a 13-year jail term in a London prison, has a case to answer.\u0022 \u00a0(Source: EFCC, \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014.) \u00a0 According to the United States\u0027 Ex Parte Application to Enforce and Register Foreign Restraining Orders, Mr. Gohil was convicted in the UK \u0022in November 2010 of money laundering and prejudicing a money laundering investigation, and in December 2010, pleaded guilty to an additional eight offenses related to the V Mobile fraud. Gohil was sentenced to ten years imprisonment.\u0022 \u00a0(Source: UNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012.)","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission (Nigeria)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service (UK)","Jurisdiction of Origin: Courts Involved":"Southwark Crown Court (UK)","Jurisdiction of Asset Recovery: Investigative Agency":"Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Columbia","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Gohil_UK_Restraint_Order_Nov_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Ex_Parte_Restrain_Order_DDC_May_2012_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Restrain_3_Million_Dept_Justice_Press_Release_Jul_23_2012_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_DDC_US_Response_Show_Cause_Order_Jul_16_2013_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_Nigeria_Appeals_Ct_EFCC_May_15_2014_4.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_UK_London%20judge%20adjourns%20Ibori%27s%20case%20to%20June%206%2C%202016%20-%20Vanguard%20News_Apr_14_2015_4.pdf","Sources ":"\n\tNigeria Economic and Financial Crimes Commission (EFCC), \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014, at https:\/\/efccnigeria.org\/efcc\/index.php\/news\/870-money-laundering-ibori-h...\n\n\t\u00a0\n\n\tToday (Nigeria), \u0022London court suspends James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016;\n\n\t\u00a0\n\n\tVanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015;\n\n\t\u00a0\n\n\tUNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012), Exhibit B, UK High Court Order of Restraint against Mr. Gohil, November 17, 2008.);\u00a0\n\n\t\u00a0\n\n\tUS Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012, accessed at \u00a0http:\/\/www.justice.gov\/opa\/pr\/2012\/July\/12-crt-906.html\n"},{"Case ID":"ARW-25","Case Title (Name of Public Official or Entity Allegedly Involved)":"James Ibori \/ Bhadresh Gohil (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Gohil: Solicitor to James Ibori, Delta State Governor (1999-2007)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20, Art.25","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"See related entry \u0022James Ibori - United Kingdom\u0022\n\t\u00a0\n\tAccording to the factual basis for the US ex parte application to enforce the UK restraint order, \u0022Governor Ibori and his associates misappropriated millions of dollars in Delta State funds and laundered those proceeds through a myriad of shell companies, intermediaries, and nominees in the United Kingdom. Governor Ibori, with the active assistance and participation of Gohil, fraudulently diverted and misappropriated millions of dollars in Delta State funds to various businesses he controlled through his relatives and associates.\u0022 \u00a0As of June 2016, the case was ongoing. (Source: UNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C.), filed May 16, 2012; court docket report as of June 17, 2016.)\n\t\u00a0\n\tAccording to news reports, the UK confiscation hearing that was rescheduled for June 2016 was again postponed. \u00a0(Sources: Today (Nigeria), \u0022London court postpones James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016; Vanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015.)","Disposition of Criminal Case(s)":"According to a May 2014 statement by Nigeria\u0027s Economic and Financial Crimes Commission, a lower court decision to strike out \u0022all 170-count charge of money laundering preferred against former governor of Delta State, James Onanefe Ibori by the Economic and Financial Crimes Commission, EFCC, a three-man panel of justices at the Benin Division of the Court of Appeal today, May 15, 2014 ruled that the ex- governor who is currently serving a 13-year jail term in a London prison, has a case to answer.\u0022 \u00a0(Source: EFCC, \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014.) \u00a0 According to the United States\u0027 Ex Parte Application to Enforce and Register Foreign Restraining Orders, Mr. Gohil was convicted in the UK \u0022in November 2010 of money laundering and prejudicing a money laundering investigation, and in December 2010, pleaded guilty to an additional eight offenses related to the V Mobile fraud. Gohil was sentenced to ten years imprisonment.\u0022 \u00a0(Source: UNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012.)","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified ","Jurisdiction of Asset Recovery: Investigative Agency":"Serious Fraud Office, City of London Police Overseas Anti-Corruption Unit","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service","Jurisdiction of Asset Recovery: Courts Involved":"Serious Fraud Office, City of London Police Overseas Anti-Corruption Unit","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Ex_Parte_Restrain_Order_DDC_May_2012_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Restrain_3_Million_Dept_Justice_Press_Release_Jul_23_2012_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_Nigeria_Appeals_Ct_EFCC_May_15_2014_3.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_UK_London%20judge%20adjourns%20Ibori%27s%20case%20to%20June%206%2C%202016%20-%20Vanguard%20News_Apr_14_2015_3.pdf","Sources ":"\n\tNigeria Economic and Financial Crimes Commission (EFCC), \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014, at https:\/\/efccnigeria.org\/efcc\/index.php\/news\/870-money-laundering-ibori-h...\n\n\t\u00a0\n\n\tToday (Nigeria), \u0022London court suspends James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016;\n\n\t\u00a0\n\n\tVanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015;\n\n\t\u00a0\n\n\tUNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012), Exhibit B, UK High Court Order of Restraint against Mr. Gohil, November 17, 2008.);\u00a0\n\n\t\u00a0\n\n\tUS Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012, accessed at \u00a0http:\/\/www.justice.gov\/opa\/pr\/2012\/July\/12-crt-906.html\n"},{"Case ID":"ARW-10","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alstom S.A. (Swiss Settlement)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"France","Position of Public Official(s) (yrs in office)":"Various - Latvia, Malaysia and Tunisia","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort","Asset Recovery Start":"2011","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Article 53 Swiss Criminal Code payment of reparations","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Funds were transferred to the International Committee of the Red Cross for use in ICRC projects in Tunisia, Latvia and Malaysia. (Source: The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Case Summary":"According to the November 2011 Summary punishment order imposed by the Swiss authorities, Alstom Network Schweiz AG (Swiss subsidiary of the French company Alstom S.A.) was convicted of not having taken all necessary and reasonable organizational precautions to precent bribery of foreign public officials in Latvia, Tunisia and Malaysia.\u00a0\u00a0 Alstom Schweiz was fined CHF 2.5 million; a compensatory claim of CHF 36.4 million was also imposed. The parent company Alstom S.A. paid the CHF 1 million in reparation, a third of which was to be used for International Committee of the Red Cross projects in Latvia, Malaysia and Tunisia. (Sources:\u00a0 Office of the Swiss Attorney General, Summary punishment order in the invesitgation of defendant Alstom Network Schweiz AG, November 22, 2011 and The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Disposition of Criminal Case(s)":"According to the November 2011 press release by The Federal Authorities of the Swiss Confederation, Alstom Network Schweiz AG was convicted under article 102 of the Swiss Criminal Code of not having taken \u0022all necessary and reasonable organizational precautions to prevent bribery of foreign public officials\u0022; proceedings against the French parent company Alstom S.A. were dismissed based on art. 53 of the Swiss Criminal Code, imposing costs of proceedings and payment of reparations.\u00a0 (Source: The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Jurisdiction of Origin: Investigative Agency":"N\/A","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Office of the Swiss Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"N\/A","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alstom_SA_Swiss_Attorney_General_Summary_Punishment_Order_PR_Nov_22_2011.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alstom_Summary_Punishment_Order_Nov_22_2011.pdf","Sources ":"Office of the Swiss Attorney General, Summary punishment order in the invesitgation of defendant Alstom Network Schweiz AG, November 22, 2011, accessed at http:\/\/www.scribd.com\/doc\/73503009\/Summary-Punishment-Order;\n\tThe Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011, accessed at http:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=42300.\n"},{"Case ID":"ARW-181","Case Title (Name of Public Official or Entity Allegedly Involved)":"Taiwan Frigates Case \/ Thales Payment","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Taiwan, China","Position of Public Official(s) (yrs in office)":"Navy Captain (Kuo Li-heng)","Jurisdiction of Asset Recovery":"France","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2001","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Other (Commercial Arbitration)","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"N\/A; international commercial arbitration","Contributing Factors in Asset Recovery":"International arbitration decision upheld by Paris Court of Appeals (Sources: The Thales Group, Half-yearly financial report 2011 (June 2011), \u0022Taiwan Arbitration\u0022, accessed at www.thalesgroup.com; Sebastian Moffett and Adam Mitchell, \u0022Thales Loses Appeal in Case with Taiwan,\u0022 Wall Street Journal, June 9, 2011.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$909,913,000","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the Thales company\u0027s Half-yearly financial report 2011 (June 2011), \u0022Thales has been notified of the decision of the Paris Court of Appeal on 9 June 2011, rejecting the petition filed by the company to set aside the award handed down on 3 May 2010 in the arbitration against Taiwan, in relation to the procurement of six Lafayette-class frigates. The decision of the Court of Appeal is enforceable and led Thales to disburse on 11 July 2011 an amount of \u20ac166 million, i.e. 27.46% of the total, corresponding to its industrial stake in the supply contract. This payment is neutral on the company\u0027s financial results, as this litigation had already been fully provisioned in previous years.\u0022 \u00a0(Source: The Thales Group, Half-yearly financial report 2011 (June 2011), Taiwan Arbitration at 13.) \u00a0\u0022Thales has also been informed by DCNI that the Republic of China Navy (Taiwan) initiated arbitration proceedings against DCNI during the second half of 2010 with respect to a contract related to the contract mentioned above. This arbitration is related to an alleged breach of the terms pertaining to the use of intermediaries contained in the contract. In its 2010 financial statements, Thales has booked a provision of \u20ac 15 million, which corresponds to the company\u2019s industrial share in the related contract.\u0022 (Ibid., at 40.) \u00a0According to a press release from the French Prime Minister\u0027s Office, date June 9, 2011, the French Government agreed to pay the remaining EUR 460 million ordered. (Source: \u0022Communiqu\u00e9 des services du Premier ministre, en date du 9 juin 2011, sur le rejet de l\u0027appel form\u00e9 par la soci\u00e9t\u00e9 Thal\u00e8s contre la sentence de la Cour d\u0027arbitrage de la Chambre de commerce internationale (ICC) \u00e0 la suite du litige concernant la vente de fr\u00e9gates \u00e0 Ta\u00efwan en 1991\u0022, accessed at \u00a0 http:\/\/discours.vie-publique.fr\/notices\/112001441.html , June 9, 2011).\n\t\u00a0","Disposition of Criminal Case(s)":"According to a November 2010 Taipei Times article, Taiwan prosecutors announced that they would not appeal the earlier acquittals against five co-defendants in the Taiwan frigates case but would appeal the acquittal of Mr. Kuo Li-heng, a Navy captain accused of taking bribes.\u00a0 (Source:\u00a0 Taipei Times, \u0022Prosecutors won\u0027t appeal acquittals in frigate case,\u0022 November 11, 2010, accessed at http:\/\/www.taipeitimes.com\/News\/taiwan\/archives\/2010\/11\/11\/2003488256.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Court of Appeals","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taiwan_Frigates_Thales_Press_Release_Arbirtration_Decision_May_3_2010_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taiwan_Frigates_Thales_Arbitration%20_%20Thales%20Group_Jun_9_2011.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taiwan_Frigates_Thales_Govt_France_PR_Jun_15_2011.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taiwan_Frigates_Thales_Payment_Le_Monde_Jun_9_2011.pdf","Sources ":"\n\tThe Thales Group, Half-yearly financial report 2011 (June 2011), \u0022Taiwan Arbitration\u0022, accessed at www.thalesgroup.com; Sebastian Moffett and Adam Mitchell, \u0022Thales Loses Appeal in Case with Taiwan,\u0022 Wall Street Journal, June 9, 2011, accessed at http:\/\/online.wsj.com\/article\/SB1000142405270230425930457637563119431410... Thales Group statement, \u0022Thales: Repubilc of China (Taiwan) Arbitration,\u0022 June 9, 2011 at https:\/\/www.thalesgroup.com\/en\/content\/thales-republic-china-taiwan-arbi... \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0French Prime Minister\u0027s Office, Press release, \u0022Communiqu\u00e9 des services du Premier ministre, en date du 9 juin 2011, sur le rejet de l\u0027appel form\u00e9 par la soci\u00e9t\u00e9 Thal\u00e8s contre la sentence de la Cour d\u0027arbitrage de la Chambre de commerce internationale (ICC) \u00e0 la suite du litige concernant la vente de fr\u00e9gates \u00e0 Ta\u00efwan en 1991\u0022, accessed at \u00a0 http:\/\/discours.vie-publique.fr\/notices\/112001441.html , (June 9, 2011) \u00a0 \u00a0Le Monde, Press article, \u0022Fr\u00e9gates de Ta\u00efwan : Thales et l\u0027Etat condamn\u00e9s \u00e0 rembourser 630 millions d\u0027euros\u0022, \u00a0accessed at: http:\/\/www.lemonde.fr\/economie\/article\/2011\/06\/09\/fregates-de-taiwan-tha... (June, 9, 2011)\u00a0\n\n\t\u00a0\n\n\t\u00a0\n"},{"Case ID":"ARW-180","Case Title (Name of Public Official or Entity Allegedly Involved)":"Taiwan Frigates Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Taiwan, China","Position of Public Official(s) (yrs in office)":"Navy Captain (Kuo Li-heng)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2001","Asset Recovery End":"2007, In part","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction; Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Federal International Mutual Legal Assistance Act","Contributing Factors in Asset Recovery":"2007 Asset Return:  Express consent of two account-holders concerned and Taiwan\u0027s guarantee that they would abide by the Swiss Federal Examining Magistrate\u0027s conditition that the \u0022legal proceedings against the two persons would comply with human rights principles.\u0022 (Source: Federal Office of Justice Press Release, \u0022USD 34 million handed over to Taiwan,\u0022 June 13, 2007.)","Status of Asset Recovery ":"Completed (in part) and Ongoing (in part)","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction (in part)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the Swiss Ministry of Foreign Affairs, as of September 30, 2009, $34 million was returned to Taiwan (in 2007) and $800 million remain frozen.\u00a0 According to the December 8, 2003 press release by the Swiss Federal Office of Justice, Switzerland provided legal assistance to Taiwan, France and Liechtenstein which had been requested in connection with legal proceedings related to the $2.5 billion sale of six frigates to Taiwan in 1991 by the then French company Thomson.\u00a0 According to the press release, \u0022Although a clause in the contract expressly forbids the payment of commission, the Taiwanese authorities concluded from the inflated price that the deal constituted a serious case of international corruption. On 6 November 2001 they submitted a request for legal assistance from Switzerland in connection with criminal proceedings on the grounds of fraud, money laundering and corruption.\u0022 The press release stated that the French authorities requested assistance \u0022in connection with criminal proceedings on the grounds of disloyal business management and handling stolen goods\u0022 and Liechtenstein request was in connection with \u0022criminal proceedings on the grounds of money laundering and participation in a criminal organization.\u0022 (Source: Federal Office of Justice Press Release, \u0022Frigate sale to Taiwan: Switzerland provides legal assistance,\u0022 December 12, 2003.)\u00a0\u00a0 The Swiss Federal Office of Justice announced, on\u00a0 June 13, 2007, that with the \u0022express consent of the two account-holders concerned, the competent Federal Examining Magistrate ordered the return of USD 34 million to Taiwan.\u0022\u00a0 According to the press release, on September 5, 2006, the Taiwanese authorities lodged an application for the handover of assets that had been frozen in Switzerland as part of criminal and international legal assistance proceedings.\u00a0 The Taiwanese application was not based on any court recovery order, but the press release noted that \u0022in exceptional cases - such as where the frozen assets are clearly of criminal origin - the Federal International Mutual Legal Assistance Act permits assets to be returned without a recovery order issued by the applicant state.\u0022\u00a0 The Taiwanese authorities had stated in their application that based on their review of the bank records provided to them by the Swiss authorities, the funds frozen can be proven to orginate from the frigate affair.\u00a0 (Source: Federal Office of Justice Press Release, \u0022USD 34 million handed over to Taiwan,\u0022 June 13, 2007.)\u00a0 On May 3, 2010, the French company Thales S.A. (formerly Thomson-CSF) announced that it had been notified of the award handed down that day in the arbitration case against Taiwan (The Navy of the Republic of China (Taiwan) v. Thales S.A. (formerly Thomson-CSF) (France).\u00a0 According to the company\u0027s release, the total amount of the award was around 630 million euros (plus interest).\u00a0 The company\u0027s share of the litigation was 27.463% of the total award, corresponding to its industrial share in the supply contract.\u00a0 Please see entry on \u0022Taiwan Frigates Case\u0022 Jurisdiction of Recovery Effort - France for an update. (Source:\u00a0 Thales, \u0022Thales: Results of the arbitration with the Republic of China (Taiwan), May 3, 2010.)","Disposition of Criminal Case(s)":"According to a November 2010 Taipei Times article, Taiwan prosecutors announced that they would not appeal the earlier acquittals against five co-defendants in the Taiwan frigates case but would appeal the acquittal of Mr. Kuo Li-heng, a Navy captain accused of taking bribes.\u00a0 (Source:\u00a0 Taipei Times, \u0022Prosecutors won\u0027t appeal acquittals in frigate case,\u0022 November 11, 2010, accessed at http:\/\/www.taipeitimes.com\/News\/taiwan\/archives\/2010\/11\/11\/2003488256.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Examining Magistrate (Geneva)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Swiss Federal Tribunal (Geneva); [ICC Paris]","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taiwan_Frigates_Swiss_EJPD_Press_Release_Assistance_Dec_8_2003.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taiwan_Frigates_Swiss_EJPD_Press_Release_34M_Handed_Over_Jun_13_2007.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taiwan_Frigates_Thales_Press_Release_Arbirtration_Decision_May_3_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taiwan_Frigates_Prosecutors_No_Appeal_Taipei%20Times_Nov_11_2010.pdf","Sources ":"Swiss Ministry of Foreign Affairs, September 30, 2009;\u00a0\n\tSwiss Federal Office of Justice Press Releases, \u0022Frigate sale to Taiwan: Switzerland provides legal assistance,\u0022 December 8, 2003, accessed at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2003\/ref_2003-12-08.html, and \u0022USD 34 million handed over to Taiwan,\u0022 June 13, 2007, accessed at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2007\/ref_2007-06-13.html;\n\tThales Press Release, \u0022Thales: Result of the arbitration with the Republic of China (Taiwan),\u0022 May 3, 2010, posted on company website, at http:\/\/www.thalesgroup.com\/Pages\/PressRelease.aspx?id=12795;\n\tAFP (Taipei), \u0022Prosecutors won\u0027t appeal acquittals in frigate case,\u0022 printed in Taipei Times, November 11, 2010, accessed at http:\/\/www.taipeitimes.com\/News\/taiwan\/archives\/2010\/11\/11\/2003488256.\n"},{"Case ID":"ARW-168","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha \/ United Kingdom Mutual Legal Assistance Treaty Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2000","Asset Recovery End":"2004","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"MLAT","Contributing Factors in Asset Recovery":"A 2001 judgment by the UK Courts backed the decision of The Home Secretary, thereby enabling various governmental bodies concerned, such as the Serious Fraud Office and the National Criminal Investigation Service (NCIS), to proceed officially with their work.  (Source: Tim Daniel and James Maton, \u0022General Sani Abacha - a nation\u0027s thief,\u0022 in Mark Pieth, ed., Recovering Stolen Assets [Peter Lang, 2008].)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to Attorney Enrico Monfrini, in June 2000, a request for mutual assistance was lodged with the United Kingdom\u0027s Home Office, providing evidence of suspect transfers to London banks in excess of $1 billion.  In May 2001, the Home Office decided to execute the Nigerian request, and the Abacha family sought judicial review.  The family\u0027s application was rejected by the High Court on October 18, 2001. (Source: Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets [Peter Lang, 2008] and Abacha \u0026 Ors \u0026 Secretary of State for the Home Department [2001] EWHC Admin 787 (18th October 2001)). As noted by Attorneys Tim Daniel and James Maton, in March 2001, United Kingdom\u0027s Financial Services Authority issued a press release which stated that a total of $1.3 billion was found to have passed through accounts in British banks controlled by the Abacha family.\u0022  In 2004, the Home Office indicated that it was ready to submit evidence to Nigeria, the family again challenged the decision; \u0022The challenge was rejected by the English High Court towards the end of 2004.\u0022 (Source: Tim Daniel and James Maton, \u0022General Sani Abacha - a nation\u0027s thief,\u0022 in Mark Pieth, ed., Recovering Stolen Assets [Peter Lang, 2008] and United Kingdom Financial Services Authority Press Release, \u0022FSA publishes results of money laundering investigation,\u0022 FSA\/PN\/029\/2001, March 8 2001).","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate.  (Source:  Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"Special Panel established to investigate Abacha looting","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Home Department, Financial Services Authority; Serious Fraud Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Edwards Angell Palmer \u0026 Dodge (Attorneys James Maton and Tim Daniel)","Jurisdiction of Asset Recovery: Courts Involved":"High Court","Documents":"","Sources ":"Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008);\nAbacha \u0026 Ors \u0026 Secretary of State for the Home Department [2001] EWHC Admin 787 (18th October 2001), accessed at http:\/\/www.bailii.org\/cgi-bin\/markup.cgi?doc=\/ew\/cases\/EWHC\/Admin\/2001\/7... and ICC FraudNet at http:\/\/www.icc-ccs.org\/home\/resources\/118-leading-cases\/697-abacha-case;\nUnited Kingdom Financial Services Authority press release, \u0022FSA publishes results of money laundering investigation,\u0022 FSA\/PN\/029\/2001, March 8 2001, accessed at http:\/\/www.fsa.gov.uk\/Pages\/Library\/Communication\/PR\/2001\/029.shtml; and \nTim Daniel and James Maton, \u0022General Sani Abacha - a nation\u0027s thief,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008).\n"},{"Case ID":"ARW-169","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha\/Ajaokuta Steel Plant debt buy-back case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"2003","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Private civil action","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$198,484,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to Attorneys Tim Daniel and James Maton, Russian debt had financed the construction of the massive Ajaokuta Steel Plant in Nigeria\u0027s Kogi State:  \u0022Construction, mainly by Russian contractors, took place at substantial cost over a period of fifteen years but, by 1998, few products had been manufactured by the plant...In an effort to cut their losses, the Russians started selling off the debt...through the use of a British Virgin Islands company called Mecosta that was beneficially owned by Mohammed Abacha and Abubakar Bagudu.  Mecosta (indirectly) acquired the debt from the Russians and sold it to the Nigerian government for twice the sum it had paid, taking payment partly in cash and partly in Nigerian par bonds. The Abachas\u0027 profit was approximately DM 500 million (GBP 166 million), and was held by the London branch of a major bank.\u0022  In 1999, Nigeria brought civil proceedings against a number of parties.  In 2001, Mr. Justice Rix  ordered the Abachas to pay DM332,818,786.94 to Nigeria.  This was paid from the frozen proceeds of the sale.  In 2003, Mr. Justice Rix\u0027s judgment was upheld by the Court of Appeals and permission was refused to apply to the House of Lords. (Source: Tim Daniel and James Maton, \u0022General Sani Abacha - a nation\u0027s thief,\u0022 in Mark Pieth, ed., Recovering Stolen Assets [Peter Lang, 2008]) and Compagnie Noga D\u0027importation Et D\u0027exportation SA v Abacha \u0026 Ors [2003] EWCA Civ 1100 (23 July 2003) and related decisions.)","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate.  (Source:  Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"Special Panel established to investigate Abacha looting","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Kendall Freeman solicitors (Mr David Railton QC; Mr Andrew Mitchell) for the Federal Government of Nigeria; Harwood Stephenson solicitors (Mr Steven Gee QC, Miss Vasanti Selvaratnam QC) for Compagnie Noga D\u0027importation S.A.","Jurisdiction of Asset Recovery: Courts Involved":"Court of Appeals (Civil Division); High Court, Queen\u0027s Bench Division (Commercial Court)","Documents":"","Sources ":"Compagnie Noga D\u0027importatation Et D\u0027exportation SA v Abacha \u0026 Ors [2003] EWCA Civ 1100 (23 July 2003) and related decisions accessed at http:\/\/www.bailii.org\/ew\/cases\/EWCA\/Civ\/2003\/1100.html;  \nTim Daniel and James Maton, \u0022General Sani Abacha - a nation\u0027s thief,\u0022 in Mark Pieth, ed., Recovering Stolen Assets [Peter Lang, 2008]) and an earlier version of the article accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.\n"},{"Case ID":"ARW-171","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sheikh Hamad Bin Jassim Bin Jaber Al Thani","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Qatar","Position of Public Official(s) (yrs in office)":"Emir (1972-1995)","Jurisdiction of Asset Recovery":"Jersey","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1998","Asset Recovery End":"2002","UNCAC Offenses Implicated":"Art.16, Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Other (Voluntary Payment)","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"As noted in the Royal Court\u0027s December 2, 2002 decision in Between Jersey Evening Post and His Excellency Sheikh Hamad Bin Jassim Bin Japer Al-Thani and four additional respondents, a \u0022press release issued on behalf of the Attorney General on 28th May 2002 with the agreement of the legal advisers of Sheikh Hamad. That press release indicated that a criminal investigation into the conduct of Sheikh Hamad was at an end and that the Sheikh had voluntarily paid GBP 6 million towards the costs of the investigation into the affairs of his three Jersey trusts.\u0022 (Source: Royal Court (Samedi Division), Case No. 2002-227, at paragraph 7.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$8,740,800","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the May 28, 1999 decision by the Jersey Royal Court, following Mr. Hamad\u0027s ouster as Emir in 1995, Qatar instituted legal proceedings, alleging that Mr. Hamad transferred public funds to private accounts.  The Royal Court wrote, \u0022On November 9th, 1998 the Deputy Bailiff made an Order ex parte at the instance of the State of Qatar restraining the defendant, inter alia, from removing any of his assets from the jurisdiction save to the extent that those assets exceeded GBP 913m. The history of the matter, as it appears from the Order of Justice, is as follows. The defendant was Emir of Qatar from 1972 until 1995. On June 27th, 1995, he was removed from office. The Government of Qatar opened an enquiry into the defendant\u0027s use of public funds entrusted to him whilst he was Emir. It is alleged that substantial amounts of public funds had been transferred during his reign to accounts around the world in violation of Qatari law. A significant part of those funds is said to have come from overdrafts of the defendant in the accounts of the Emiri Diwan at the Qatar National Bank. In June 1996, the plaintiff commenced proceedings against, inter alia, the defendant and obtained a Mareva injunction against his assets with certain third parties in Jersey. Parallel proceedings were commenced against the defendant in a number of other jurisdictions. In October 1996, the action was settled upon terms which were amended by an addendum in February 1997. The plaintiff [Qatar] now claims that the defendant has failed to comply with the terms of the settlement. In November 1998, the plaintiff commenced attachment proceedings against the defendant in Switzerland as well as bringing proceedings before this court and elsewhere.\u0022  The Royal Court dismissed Mr. Hamad\u0027s appeal against the order.  (Source: State of Qatar v. Al Thani, [1999] JLR 118 (May 28, 1999)).   As noted in the Royal Court\u0027s December 2, 2002 decision in Between Jersey Evening Post and His Excellency Sheikh Hamad Bin Jassim Bin Japer Al-Thani and four additional respondents, a \u0022press release issued on behalf of the Attorney General on 28th May 2002 with the agreement of the legal advisers of Sheikh Hamad. That press release indicated that a criminal investigation into the conduct of Sheikh Hamad was at an end and that the Sheikh had voluntarily paid GBP 6 million towards the costs of the investigation into the affairs of his three Jersey trusts.\u0022 (Royal Court (Samedi Division), Case No. 2002-227, at paragraph 7.  See also, Anthony Lewis, \u0022The Qatar Case,\u0022 Jersey Evening Post, March 24, 2003; Jimmy Burns and Michael Peel, \u0022SFO is \u0027actively\u0027 pursuing corruption allegations,\u0022 Financial Times, February 8, 2007.  The actual text of the Jersey Attorney General\u0027s May 28, 2002 press release could not be located.)","Disposition of Criminal Case(s)":"As noted in the Isle of Jersey Royal Court\u0027s December 2, 2002 decision in Between Jersey Evening Post and His Excellency Sheikh Hamad Bin Jassim Bin Japer Al-Thani and others, a \u0022press release issued on behalf of the Attorney General on 28th May 2002 with the agreement of the legal advisers of Sheikh Hamad. That press release indicated that a criminal investigation into the conduct of Sheikh Hamad was at an end.\u0022  (Soource:  Between Jersey Evening Post and His Excellency Sheikh Hamad Bin Jassim Bin Japer Al-Thani, and four additional respondents, Royal Court (Samedi Division), Case No. 2002-227, at paragraph 7.  The actual text of the Jersey Attorney General\u0027s May 28, 2002 press release could not be located.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Jersey Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"Royal Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Al-Thani_Jersey_1999_JLR_118.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Jersey_Evening_Post_Qatar_Case.pdf .pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sheikh_Hamad_Al_Thani_Jersey_Evening_Post_2002_%20JLR%20542.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sheikh_Hamad_Al_Thani_Qatar_Case_Jersey_Evening_Post_Mar_24_2003.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sheikh_Hamad_SFO_Investigation_Financial_Times_Feb_8_2007.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Al-Thani_Jersey_1999_JLR_118.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Al-Thani_Jersey_1999_JLR_118.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Jersey_Evening_Post_Qatar_Case.pdf .pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sheikh_Hamad_Al_Thani_Jersey_Evening_Post_2002_%20JLR%20542.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sheikh_Hamad_Al_Thani_Qatar_Case_Jersey_Evening_Post_Mar_24_2003.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sheikh_Hamad_SFO_Investigation_Financial_Times_Feb_8_2007.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Sheikh_Hamad_SFO_Investigation_Financial_Times_Feb_8_2007.pdf","Sources ":"State of Qatar v. Al Thani, [1999] JLR 118 (May 28, 1999), accessed at http:\/\/www.jerseylaw.je\/Judgments\/JerseyLawReports\/Display.aspx?Cases\/JL... \nAnthony Lewis, \u0022The Qatar Case,\u0022 Jersey Evening Post, March 24, 2003; Jimmy Burns and Michael Peel, \u0022SFO is \u0027actively\u0027 pursuing corruption allegations,\u0022 Financial Times, February 8, 2007, accessed at http:\/\/www.ft.com\/cms\/s\/0\/a752039c-b718-11db-8bc2-0000779e2340.html#axzz... \nJersey Evening Post, \u0022The Qatar Case: Secrecy case, Sheikh backs down,\u0022 and December 2, 2002 Judgment of the Royal Court (Samedi Division) by the Jersey Royal Court in Between Jersey Evening Post Limited (Representor) And His Excellency Sheikh Hamad Bin Jassim Bin Japer Al-Thani (and on behalf of the adult beneficiaries of the Y Trust, the H Trust and the Y No. 2 Trust) (First Respondent) And David Fisher Le Quesne, Advocate (on behalf of the minor and unborn beneficiaries of the said Trusts) (Second Respondent) And Standard Chartered Grindlays Trust Corporation (Jersey) Limited (Third Respondent) And The State of Qatar (Fourth Respondent) And Her Majesty\u0027s Attorney General (Fifth Respondent), accessed at http:\/\/www.thisisjersey.co.uk\/qatar\/index.html.\n"},{"Case ID":"ARW-177","Case Title (Name of Public Official or Entity Allegedly Involved)":"Stanley Mombo Amuti","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kenya","Position of Public Official(s) (yrs in office)":"Financial Controller, National Water Conservation and Pipeline Corporation (Inclusive September 2007); Finance Manager, Water Services Regulatory Board (2004 or 2005-2007)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"On May 13, 2011, the Court of Appeal of Kenya in Nairobi upheld the freezing of Mr. Amuti\u0027s bank accounts and other assets pending the outcome his appeal in a case brought against him on September 18, 2008 by the Kenya Anti-Corruption Commission (KACC).  One of the bank accounts frozen was Account Number 32757182, National Westminster Bank PLC-London Branch, 60-15-49.   (Source: Between Kenya Anti-Corruption Commission and Stanley Mombo Amuti [2011] eKLR, Civil Application No. NAL 30 of 2011 (UR 25\/2011), Court of Appeal at Nairobi, May 13, 2011).  According to the May 13, 2011 ruling, the KACC had filed an originating summons before the superior court, \u0022stating that it had conducted investigations which established that Stanley Mombo Amuti [ ] was in possession of unexplained assets\u0022 that were grossly disportionate to his income.  The KACC affidavit posited that a court authorized search of Mr. Amuti\u0027s office and residence revealed cash and checks in excess of Kshs. 21 million (USD 276,316), which were seized and further searches of his bank accounts established that he had deposited sums in excess of Kshs. 140 million (USD 1,842,110) and withdrawn in exces sof Kshs. 85 million (USD1,118,420) over a period if ten months between September 2007 and June 2008, as well as several immovable properties being traced to him.  Mr. Amuti\u0027s gross salary as financial controller of the National Water Conservation and Pipeline Corporation was Kshs. 306,000 (USD 4,026.32) per month and net salary of Kshs. 180,031 (USD 2,368.83).  Previously as finance manager with the Water Services Regulatory Board, he earned a gross salary of Kshs. 225,4000  (USD 3,965.79) for a period of three years.  Mr. Amuti had been given an opportunity to explain the origin of his assets, but the KACC did not find the explanation satisfactory and filed its case. (Source: Ibid.)","Disposition of Criminal Case(s)":"According to the May 13, 2011 ruling by the Court of Appeal of Kenya in Nairobi, on September 18, 2008 the Kenyan Anti-Corruption Commission filed an originating summon before the superior court invoking section 55 of the Anti-Corruption and Economic Crimes Act.  The case is ongoing, as of May 13, 2011. (Source: Between Kenya Anti-Corruption Commission and Stanley Mombo Amuti [2011] eKLR, Civil Application No. NAL 30 of 2011 (UR 25\/2011), Court of Appeal at Nairobi, May 13, 2011).","Jurisdiction of Origin: Investigative Agency":"Kenya Anti-Corruption Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Kenya Anti-Corruption Commission","Jurisdiction of Origin: Courts Involved":"Court of Appeal at Nairobi, High Court at Nairobi, superior court","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Between Kenya Anti-Corruption Commission and Stanley Mombo Amuti [2011] eKLR, Civil Application No. NAL 30 of 2011 (UR 25\/2011), Court of Appeal at Nairobi, May 13, 2011 (overturning High Court decision of February 4, 2011, acessed at http:\/\/www.kenyalaw.org\/CaseSearch\/view_preview1.php?link=84516167880392...), via link provided in May 20, 2011 newsletter of the Kenya Law Reports at  http:\/\/www.kenyalaw.org\/newsletter; \nFebruary 2011 decision accessed at http:\/\/kenyalaw.org\/Downloads_FreeCases\/81903.pdf; Kenya Anti-Corruption Commission v. Stanley Mombo Amuti, [2008] eKLR, Civil Case 448 of 2008 (OS), High Court at Nairobi, Ruling November 21, 2008, accessed at http:\/\/www.kenyalaw.org\/CaseSearch\/view_preview1.php?link=77620306260192....\n"},{"Case ID":"ARW-178","Case Title (Name of Public Official or Entity Allegedly Involved)":"Steve Ferguson \/ Piarco Airport case  (Bahamas)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Trinidad and Tobago","Position of Public Official(s) (yrs in office)":"Former Chairman of the National Gas Company (1998- unspecified)","Jurisdiction of Asset Recovery":"Bahamas","Jurisdiction of Asset Description":"Location of Recovery Effort\u00a0","Asset Recovery Start":"","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Unspecified","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Unknown","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In June 2009, Assistant Director Janice Ayala of the U.S. Immigration and Customs Enforcement testified before a U.S. Senate Committee that the case involved accounts of shell companies which were held in the Bahamas, and that the restitution ordered by U.S. courts had yet to be paid.  (Source: Statement of Janice Ayala, Deputy Assistant Director, Office of Investigations, U.S. Immigration and Customs Enforcement, Department of Homeland Security, regarding a Hearing on \u0022Examining State Business Incorporation Practices: A Discussion of the Incorporation Transparency and Law Enforcement Assistance Act (S. 569),\u0022 Before the U.S. Senate Committee on Homeland Security and Governmental Affairs, June 18, 2009.)","Disposition of Criminal Case(s)":"According to official documents filed in U.S. District Court for the Southern District of Florida, Mr. Ferguson is under indictment on multiple counts of fraud and money laundering charges.  Mr. Ferguson is challenging his extradition from Trinidad and Tobago to the U.S.  (Sources:  US v. Gutierrez, et al, Case no: 1:05-cr-20859-PCH (S.D. Fla),  Superseding indictment filed on March 29, 2006; Court Docket Report as of August 21, 2014.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Origin: Courts Involved":"High Court, Court of Appeals","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Bahamas_Ayala_Testimony_Jun_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Status_Rept_Extradition_Apr_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Superseding_Indictment_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Appeals_Court_Civil_Appeal_108_2009_Judgment_May_3_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Galbaransingh_SDFLA_Updated_Status_Report_Sep_7_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Trinidad_High_Court_Extradition_Denied_Trinidad_Express_Nov_7_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ferguson_Bahamas_Ayala_Testimony_Jun_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Bahamas_Ayala_Testimony_Jun_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Status_Rept_Extradition_Apr_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Superseding_Indictment_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Appeals_Court_Civil_Appeal_108_2009_Judgment_May_3_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Galbaransingh_SDFLA_Updated_Status_Report_Sep_7_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Trinidad_High_Court_Extradition_Denied_Trinidad_Express_Nov_7_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Steve_Ferguson_US_SDFLA_Status_Rept_Extradition_Apr_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Bahamas_Ayala_Testimony_Jun_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Status_Rept_Extradition_Apr_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Superseding_Indictment_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Appeals_Court_Civil_Appeal_108_2009_Judgment_May_3_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Galbaransingh_SDFLA_Updated_Status_Report_Sep_7_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Trinidad_High_Court_Extradition_Denied_Trinidad_Express_Nov_7_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Steve_Ferguson_Trinidad_Appeals_Court_Civil_Appeal_108_2009_Judgment_May_3_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Bahamas_Ayala_Testimony_Jun_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Status_Rept_Extradition_Apr_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Superseding_Indictment_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Appeals_Court_Civil_Appeal_108_2009_Judgment_May_3_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Galbaransingh_SDFLA_Updated_Status_Report_Sep_7_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Trinidad_High_Court_Extradition_Denied_Trinidad_Express_Nov_7_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Steve_Ferguson_Extradition_Refused_Trinidad_Express_Nov_7_2011.pdf","Sources ":"Statement of Janice Ayala, Deputy Assistant Director, Office of Investigations, U.S. Immigration and Customs Enforcement, Department of Homeland Security, regarding a Hearing on \u0022Examining State Business Incorporation Practices: A Discussion of the Incorporation Transparency and Law Enforcement Assistance Act (S. 569),\u0022 Before the U.S. Senate Committee on Homeland Security and Governmental Affairs, June 18, 2009.  \nUS v. Gutierrez, et al, Case no: 1:05-cr-20859-PCH (S.D. Fla.),  Superseding indictment filed on March 29, 2006; Court Docket Report as of August 21, 2014.\n"},{"Case ID":"ARW-179","Case Title (Name of Public Official or Entity Allegedly Involved)":"Steve Ferguson \/ Piarco Airport case (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Trinidad and Tobago","Position of Public Official(s) (yrs in office)":"Former Chairman of the National Gas Company (1998- ?)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2005","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution; Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Completed (in part) and Ongoing (in part)","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In a criminal case in U.S. District Court for the Southern District of Florida, the following restitution was ordered against Mr. Ferguson\u0027s co-defendants, to be paid to Trinidad and Tobago: Mr. Gutierrez $4 million, Mr. Hillman $2 million, and Mr. Mora $100,000.  (Source: U.S. v. Gutierrez, et al, Case No. 1:05-cr-20859-PCH (S.D. Fla) Superseding indictment filed March 29, 2006, Restitution hearing minutes, filed March 17, 2007, judgments (various)).  As of October 2013, Mr. Ferguson and Mr. Galbaransingh still faced criminal charges in the United States.  (Source: Ferguson and Galbaransingh (Appellants) and The Commissioner of Prisons, Civil Appeal No. 108 of 2009, Republic of Trinidad and Tobago Court of Appeal, judgment of May 3, 2010 and Between Steve Ferguson and Ishwar Galbaransingh (Appellants) and His Worship Mr. Sherman McNicholls, Claim No.: CV2008-03639, Republic of Trinidad and Tobago High Court of Justice, judgment of October 7, 2008 (extradition related hearings).  Trinidad and Tobago also brought civil complaint against them in Florida state courts. (Source: Trinidad and Tobago v. Birk Hillman Consultants, No. 04-11813 CA 30 (11th Fla. Cir. Ct. April 13, 2007.)","Disposition of Criminal Case(s)":"According to official documents filed in U.S. District Court for the Southern District of Florida, Mr. Ferguson is under indictment on multiple counts of fraud and money laundering charges.  Mr. Ferguson is challenging his extradition from Trinidad and Tobago to the U.S. (Sources:  US v. Gutierrez, et al, Case no: 1:05-cr-20859-PCH (S.D. Fla),  Superseding indictment filed on March 29, 2006; Court Docket Report as of August 21, 2014.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Origin: Courts Involved":"High Court, Court of Appeals","Jurisdiction of Asset Recovery: Investigative Agency":"Immigration and Customs Enforcement, Foreign Corruption Investigations Group","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Criminal: United States Attorney for the Southern District of Florida; Civil: Astigarraga David (Edward H. Davis, Jr., representing Trinidad and Tobago)","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of Florida","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_US_SDFLA_Status_Rept_Extradition_Apr_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Appeals_Court_Civil_Appeal_108_2009_Judgment_May_3_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Claim_CV2008_03639_High_Court_Judgment_Oct_7_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part1_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part2_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part3_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part4_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part5_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_ICE_Investigation_Oct_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Gutierrez_Amended_Judgment_Mar_19_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Hillman_Waller_Judgment_Jan_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Restitution_Hearing_Mar_17_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Superseding_Indictment_Mar_26_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Galbaransingh_SDFLA_Updated_Status_Report_Sep_7_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Trinidad_High_Court_Extradition_Denied_Trinidad_Express_Nov_7_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ferguson_Trinidad_High_Court_Extradition_Denied_Trinidad_Express_Nov_7_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_US_SDFLA_Status_Rept_Extradition_Apr_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Appeals_Court_Civil_Appeal_108_2009_Judgment_May_3_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Claim_CV2008_03639_High_Court_Judgment_Oct_7_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part1_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part2_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part3_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part4_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part5_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_ICE_Investigation_Oct_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Gutierrez_Amended_Judgment_Mar_19_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Hillman_Waller_Judgment_Jan_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Restitution_Hearing_Mar_17_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Superseding_Indictment_Mar_26_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Galbaransingh_SDFLA_Updated_Status_Report_Sep_7_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Trinidad_High_Court_Extradition_Denied_Trinidad_Express_Nov_7_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ferguson_US_SDFL_Restitution_sharing_ag_Disclosure_Aug_21_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_US_SDFLA_Status_Rept_Extradition_Apr_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Appeals_Court_Civil_Appeal_108_2009_Judgment_May_3_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Claim_CV2008_03639_High_Court_Judgment_Oct_7_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part1_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part2_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part3_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part4_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part5_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_ICE_Investigation_Oct_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Gutierrez_Amended_Judgment_Mar_19_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Hillman_Waller_Judgment_Jan_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Restitution_Hearing_Mar_17_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Superseding_Indictment_Mar_26_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Galbaransingh_SDFLA_Updated_Status_Report_Sep_7_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Trinidad_High_Court_Extradition_Denied_Trinidad_Express_Nov_7_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ferguson_US_SDFL_Transcript_Status_Conf_Feb_22_2013.pdf","Sources ":"U.S. v. Gutierrez, et al, Case No. 1:05-cr-20859-PCH (S.D. Fla) Superseding indictment filed March 29, 2006, Restitution hearing minutes \u00a0filed March 17, 2007, Amended Judgment against Raul Gutierrez filed March 19, 2007, Eduardo Hillman-Waller filed January 29, 2007, Government of Trinidad and Tobago Restutiton Determination Motion against Leonardo Mora-Rodriguz, filed April 16, 2007, Status Report (Ferguson extradition) filed April 27, 2011; Between Steve Ferguson and Ishwar Galbaransingh (Appellants) and The Commissioner of Prisons, Civil Appeal No. 108 of 2009, Republic of Trinidad and Tobago Court of Appeal, judgment of May 3, 2010 and Between Steve Ferguson and Ishwar Galbaransingh (Appellants) and His Worship Mr. Sherman McNicholls, Claim No.: CV2008-03639, Republic of Trinidad and Tobago High Court of Justice, judgment of October 7, 2008 (extradition related hearings); Civil complaint in Trinidad and Tobago v. Birk Hillman Consultants, No. 04-11813 CA 30 (11th Fla. Cir. Ct. Apr. 13, 2007); The Cornerstone Report by the U.S. Immigration and Customs Enforcement, \u0022ICE Investigates Birk Hillman, et al\u0022 (October 2008). US v. Ferguson and Galbaransingh, Case No. 1:05-cr-20859 (S.D. Fla.), Court Docket Report as of August 21, 2014. \u00a0See also, Denyse Renne, \u0022No extradition for Ish and Steve,\u0022 Trinidad Express, November 10, 2011, accessed at http:\/\/www.trinidadexpress.com\/news\/No_extradition_for_Ish_and_Steve-133....\n"},{"Case ID":"ARW-183","Case Title (Name of Public Official or Entity Allegedly Involved)":"Teodoro Nguema Obiang Mbasogo \/ Teodoro Nguema Obiang Mangue (France)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Equatorial Guinea","Position of Public Official(s) (yrs in office)":"President (Teodoro Nguema Obiang Mbasogo: 1979-current); Minister of Agriculture and Forestry and son of President (Teodoro Nguema Obiang Mangue: current)","Jurisdiction of Asset Recovery":"France","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2007","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case, but Transparency International stated that this is the first time French courts allowed such a complaint by nongovernmental organizations to proceed. Source: Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision: The complaint filed by Transparency International France is ruled admissible,\u0022 November 9, 2010.","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to Transparency International France, on May 23, 2016, the French Prosecutor\u0027s Office filed an indictment against Mr. Obiang for a trial in the Criminal Court of Paris. (Source: Transparency International France, \u0022Bien Mal Acquis: le Procurer de la Republiquw demande l\u0027ouverture d\u0027un proces contre Obiang,\u0022 May 26, 2016, at https:\/\/transparency-france.org\/project\/bma-procureur-ouverture-proces-o...) In November 2010, the French Supreme Court overturned a lower court decision and permitted the \u0022Biens Mal Acquis\u0022 (\u201cIll-Gotten Gains\u201d) complaint, originally filed in March 2007 by Transparency International France and  SHERPA to proceed.  The civil society organizations had filed a complaint against assets allegedly belonging to three African public officials: Omar Bongo, Dennis Sassou Nguesso, and Teodoro Obiang, and their relatives.  Transparency International stated that \u0022this decision stands as a considerable legal milestone that goes beyond the \u0027Biens Mal Acquis\u0027 case.  For the first time in France, the collective action of an anti-corruption association is deemed admissible before a criminal court.\u0022 (Source: Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision: The complaint filed by Transparency International France is ruled admissible,\u0022 November 9, 2010.)  According to secondary sources, including GTSpirit.com, on September 29, 2011, the French National Police seized 11 supercars belonging to Mr. Obiang; among the cars seized from the Obiang Paris residence at 42 Avenue Foch were two Bugati Veyrons, a Maserati MC12, a Porsche Carrera GT, a Ferrari Enzo, a Ferrari 599 GTO, Aston Martin V8 V600 LM, Rolls Royce Drophead Coupe, and a Bentley (model not identified) valued at total of $5 million.  (Source: Des, Car News, \u002211 Supercars of Teodoro Obiang Nguema Mbasogo Seized by French Police,\u0022 September 29, 2011). According to the Agence France-Presse (AFP), French authorities have seized and auctioned luxury goods purchased by Mr. Obiang in February and July 2012 (respectively, valuable artwork and antiquities, and a 1,000 square metre property on 40\/ 42 avenue Foch in Paris detained through French and Swiss companies which were alleged to be beneficially owned by Mr. Obiang (two French companies, Foch Services and SCI Avenue du Bois; and five Swiss companies, Ganesha, Re Entreprise, Gep, Nordi And Shipping, Raya Holding) (Source: Decision confirmed by the French Supreme court on March 5, 2014: Cour de cassation,  criminelle, Chambre criminelle, 5 March 2014, N\u00b0 de pourvoi: 13-84977). French authorities issued an Europe-wide arrest warrant against him in July 2012 (Sources: Decision confirmed by the French Supreme court: Cour de cassation, criminelle, Chambre criminelle, 5 mars 2014, N\u00b0 de pourvoi: 13-84.705, Publi\u00e9 au bulletin; Cour de cassation, criminelle, Chambre criminelle,19 f\u00e9vrier 2014, N\u00b0 de pourvoi: 13-84.705). French newspaper Liberation press release, \u0022Biens mal acquis: saisie record chez Teodoro Obiang\u0022, February 2012, available at: http:\/\/www.liberation.fr\/monde\/2012\/02\/24\/biens-mal-acquis-saisie-record... AFP press release, \u0022Biens mal acquis: le fils du pr\u00e9sident de Guin\u00e9e \u00e9quatoriale mis en examen\u0022, March 19, 2014.)  According to a press release from the NGOs Transparency International France and Sherpa, the Paris court (the Tribunal de Grande Instance) issued an indictment against Teodoro Nguema Obiang Mangue on money-laundering charges on March 19, 2014. (Sources: Transparency International press release, \u0022Teodorin Obiang Nguema indicted in Bien Mal Acquis case\u0022,  March 20, 2014;  Human Right Watch news release, \u0022Equatorial Guinea: Indictment of President\u2019s Son in France\u0022, March 20, 2014.) .   According to Sherpa in December 2015, the Court of Cassation rejected Mr. Obiang\u0027s petition to have his case dismissed on grounds of diplomatic immunity, thus paving the way for the trial to proceed.  (Source: Sherpa Press Release, \u0022No immunity for Teodoro Obiang: a trial is imminent,\u0022 December 15, 2015.)\n                                                                                                                                                                               In parallel, the Obiang family brought several defamation cases in France notably against two NGOs, the Catholic Committee Against Hunger (CCFD -Terre Solidaire) and Transparency International France, and a French news magazine L\u0027Express. According to RFI, the Paris court dismissed the defamation case against Transparency International France on June 26, 2014, and dismissed the one brought against l\u2019Express on July 4, 2014. The libel suit against CCFD was also dismissed and this decision upheld on appeal on April 25, 2013. (Sources: UNCAC Coalition, \u201cLandmark French rulings dismiss Teodorin Nguema Obiang defamation cases\u201d,  July 23, 2014; RFI press release, \u201cEquatorial Guinea leader\u0027s son Obiang loses legal case against French magazine\u201d, July 5, 2014;  Leexpres.fr, \u201cTeodorin Obiang perd son proc\u00e8s en diffamation\u201d, June 26, 2014; RFI, \u201cGuinea\u0027s Obiang loses libel case against French NGO\u201d, April 26, 2013.).","Disposition of Criminal Case(s)":"In November 2010, the French Supreme Court held that the criminal complaint filed earlier by Transparency International and other non-governmental organizations against Mr. Obiang may proceed. (Source: Supreme Court of France, Case No. 6092, decision of November 9, 2010, L\u0027association Transparence International France, partie civile, reversing High Court of Paris, section 2, judgment of October 29, 2009.)\u00a0 In July 2012, a French court issued an international arrest warrant when for the second time, Mr. Obiang, Jr. did not appear before the Investigating Magistrates \u0022for preliminary examination - a legal procedural step that precedes a criminal indictment under French Law.\u0022 (Source:\u00a0 Sherpa Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: Teodorin Obiang refuses to appear before judicial authorities,\u0022 July 13, 2012.) According to a press release from the NGOs Transparency International France and Sherpa, the Paris court (Tribunal de Grande Instance) issued an indictment against Teodoro Nguema Obiang Mangue on money-laundering charges on March 19, 2014 (Source: Transparency International press release, \u0022Teodorin Obiang Nguema indicted in Bien Mal Acquis case\u0022,  March 20, 2014.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Investigating Magistrate","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Public Prosecutor; (Transparency International France and SHERPA - filed complaint)","Jurisdiction of Asset Recovery: Courts Involved":"Supreme Court, Court of Appeals","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_France_SCt_Judgment_Nov_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_France_TransparencyIntl_Sherpa_Press_Release_Nov_9_2010.docx, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang-cars-seized-photos-www.gtspirit_Sep_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_France_Biens%20mal%20acquis_%20Vers%20l%27ouverture%20d%27un%20proc%C3%A8s%20contre%20Obiang_May2016.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_France_SCt_Judgment_Nov_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_France_TransparencyIntl_Sherpa_Press_Release_Nov_9_2010.docx, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang-cars-seized-photos-www.gtspirit_Sep_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_Ill-Gotten%20Gains_%20The%20Public%20Prosecutor%20Requests%20the%20Opening%20of%20a%20Trial%20against%20Obiang%20-%20SHERPA_May2016.pdf","Sources ":"Transparency International France, \u0022Bien Mal Acquis: le Procurer de la Republique demande l\u0027ouverture d\u0027un proces contre Obiang,\u0022 May 26, 2016, at https:\/\/transparency-france.org\/project\/bma-procureur-ouverture-proces-o... \u00a0French Supreme Court\u0027s November 9, 2010 ruling, reversing appeals court decision and permitting civil suit by Transparency International France and SHERPA to proceed: \u00a0Cour de cassation sans renvoi, No. 6092; See also Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision: The complaint filed by Transparency International France is ruled admissible,\u0022 November 9, 2010. \u00a0Sherpa Press Releases, \u0022No immunity for Teodoro Obiang: a trial is imminent,\u0022 December 15, 2015, at https:\/\/www.asso-sherpa.org\/no-immunity-teodoro-obiang-trial-imminent and \u0022\u0027Biens Mal Acquis\u0027 Case: Teodorin Obiang refuses to appear before judicial authorities,\u0022 July 13, 2012, accessed at http:\/\/asso-sherpa.org\/sherpa-content\/docs\/newsroom\/Communiques_de_press.... See also, United States Senate, Permanent Subcommittee on Investigations, Committee on Homeland Security and Governmental Affairs, Majority and Minority Staff Report, \u0022Keeping Foreign Corruption Out of the United States: Four Case Histories,\u0022 released in conjunction with the Permanent Subcommittee on Investigations, February 4, 2010 Hearing, posted at http:\/\/hsgac.senate.gov\/public\/index.cfm?FuseAction=Hearings.Hearing\u0026Hea... links to witness testimonies also at same. \u00a0See also, Des, Car News, \u002211 Supercars of Teodoro Obiang Nguema Mbasogo Seized by French Police,\u0022 September 29, 2011, accessed at http:\/\/www.gtspirit.com\/2011\/09\/29\/11-supercars-of-teodoro-obiang-nguema.... \u00a0Cour de cassation, \u00a0criminelle, Chambre criminelle, 5 March 2014, N\u00b0 de pourvoi: 13-84977. Cour de cassation, criminelle, Chambre criminelle, 5 mars 2014, N\u00b0 de pourvoi: 13-84.705, Publi\u00e9 au bulletin; Cour de cassation, criminelle, Chambre criminelle,19 f\u00e9vrier 2014, N\u00b0 de pourvoi: 13-84.705. French newspaper Liberation press release, \u0022Biens mal acquis: saisie record chez Teodoro Obiang\u0022, February 2012, available at: http:\/\/www.liberation.fr\/monde\/2012\/02\/24\/biens-mal-acquis-saisie-record... AFP press release, \u0022Biens mal acquis: le fils du pr\u00e9sident de Guin\u00e9e \u00e9quatoriale mis en examen\u0022, March 19, 2014, available at: https:\/\/fr.news.yahoo.com\/biens-mal-acquis-fils-pr%C3%A9sident-guin%C3%A.... Transparency International press release, \u0022Teodorin Obiang Nguema indicted in Bien Mal Acquis case\u0022, \u00a0March 20, 2014, available at: http:\/\/www.transparency.org\/news\/pressrelease\/teodorin_obiang_nguema_ind... Human Right Watch news release, \u0022Equatorial Guinea: Indictment of President\u2019s Son in France\u0022, March 20, 2014, available at: http:\/\/www.hrw.org\/news\/2014\/03\/20\/equatorial-guinea-indictment-presiden.... See also regarding the defamation cases: UNCAC Coalition, \u201cLandmark French rulings dismiss Teodorin Nguema Obiang defamation cases\u201d, \u00a0July 23, 2014, available at: http:\/\/www.uncaccoalition.org\/en\/learn-more\/blog\/350-landmark-french-rul... RFI press release, \u201cEquatorial Guinea leader\u0027s son Obiang loses legal case against French magazine\u201d, July 5, 2014, available at: http:\/\/www.english.rfi.fr\/africa\/20140705-equatorial-guinea-leaders-son-... \u201cTeodorin Obiang perd son proc\u00e8s en diffamation\u201d, June 26, 2014, available at: http:\/\/www.lexpress.fr\/actualites\/1\/societe\/teodorin-obiang-perd-son-pro... RFI, \u201cGuinea\u0027s Obiang loses libel case against French NGO\u201d, April 26, 2013, available at: http:\/\/www.english.rfi.fr\/africa\/20130426-guineas-obiang-loses-libel-cas...\n"},{"Case ID":"ARW-182","Case Title (Name of Public Official or Entity Allegedly Involved)":"Teodoro Nguema Obiang Mbasogo (Spain)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Equatorial Guinea","Position of Public Official(s) (yrs in office)":"President (1979-current)","Jurisdiction of Asset Recovery":"Spain","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In July 2004, the U.S. Senate Permanent Subcommittee on Investigations issued its report, \u0022Money Laundering and Foreign Corruption: Enforcement and Effectiveness of the PATRIOT Act, Case Study Involving Riggs Bank\u0022 examining the Bank\u0027s extensive relationship with Equatorial Guinea and with Mr. Obiang and his family and associates.  The Senate Report stated, \u0022Over three and one-half years, from June 2000 to December 2003, sixteen wire transfers were sent from the E.G. [Equatorial Guinea] oil account to Kulunga Company SA, an E.G. corporation, totaling over $26.5 million.\u0022  The Senate Report stated that all sixteen wire transfers were made from Riggs Bank to the Kalunga Company accounts held at Bank Santander in Madrid, Spain.  (Source: Senate Report, at 54 and 55)  The Senate Report added that the Subcommittee had reasons to believe that at least one of the accounts opened under the Kalunga Company or another company\u0027s name may be \u0022owned in whole or in part by\u0022 Mr. Obiang. (Source: Senate Report, at 6.)  According to the Open Society Foundations, investigations undertake by the Asociacion Pro Derechos Humanos de Espana (APDHE), a Spanish human rights organization \u0022revealed close correlations in timeing between at least five of these transfers and nine real estate purchases in Madrid, Gijon, and Las Palmas de Gran Canaris in the Canary Islands on behalf of the President, members of his family, and other close associates.\u0022  (Source: Open Society Foundations, APDHE v. Obiang Family,\u0022 last accessed on March 29, 2011.)   On October 22, 2008, APDHE submitted its complaint to Instructing Judge Baltasar Garzon and the next day, Judge Garzon referred the case to the office of the National Criminal Court Prosecutor.  On January 21, 2009, the Office of the Prosecutor (Fiscalia) concluded that there is a case to answer and opened an official investigation in the Pre-Trial Investigative Court and that the investigation should commence in Gran Canaria rather than in Madrid, because the Kalunga account where the money was received was not in Madrid , but at the Banco Santander in Las Palmas, Gran Canaria.  On February 6, 2009, Judge Garzon issued an order ratifying the determination of the Prosecutor requiring transfer of the case to the Pre-Trial Investigative Court in Las Palmas.  The case is pending investigation. (Source: Open Society Foundations, APDHE v. Obiang Family,\u0022 last accessed on November 7, 2013.)   The APDHE complaint named as defendants Marcellino Owono Edu (Minister for Mining, Industry and Energy) and his wife, Constancia Nchama Angue; Miguel Abia Biteco (former Prime Minister) and his wife, Dorotea Anita Roka Elobo; Gabriel Nguema Lima (son of President Obiang, also known as Gabriel M. Obiang Lima; also former Deputy Minister for Mining, Industry and Energy) and his wife, Virginia Esther Maye Mba; Teodoro Biyogo Nsue (Ambassador to Brazil, U.S. and UN and brother in law of President Obiang) and his wife, Elena Mensa; Pastor Micha Ondo Bile (Minister of Foreign Affairs, International Cooperation and Francophony) and his wife Magdalena Ayang; Atanasio Ela Ntugu (former Minister for Mining, Industry and Energy) and any additional persons who may appear to be criminal liable during the course of investigation for money laundering.  (Source: English translation of APDHE\u0027s complaint dated September 22, 2008.)   The complaint stated that Kalunga Company S.A. was a shell entity which did not conduct any business, and that the funds transferred to its Spain account had originated from the \u0022Oil Account\u0022 at Riggs Bank for which President Obiang, his son Gabriel M. Obiang Lima and his nephew Melchor Esono Edjo were signatories.  Two signatories were sufficient to authorize withdrawals from the Oil Account, and one of them always had to be President Obiang.  Total of nine properties alleged to have been purchased in Spain with the Kalunga funds included two properties registered in President Obiang\u0027s name: (1) Housing unit at calle Dolores de la Rocha SN, 4th floor, door C, CP 35001, Las Palmas de Gran Canaria, registered with the Land Registry of Las Palmas de Gran Canaria number one in the name of Teodoro Obiang Nguema Mbasogo, and (2) property located at calle Eufemiano Jurado SN, 2nd floor, CP 35106, Finca Las Labradoras, Las Palmas de Gran Canaria, registered with the Land Registry of Las Palmas de Gran Canaria number one in the name of Teodoro Obiang Nguema Mbasogo.  (Source: English translation of APDHE\u0027s complaint dated September 22, 2008.)","Disposition of Criminal Case(s)":"In November 2010, the French Supreme Court held that the criminal complaint filed earlier by Transparency International and other non-governmental organizations against Mr. Obiang may proceed. (Source: Supreme Court of France, Case No. 6092, decision of November 9, 2010, L\u0027association Transparence International France, partie civile, reversing High Court of Paris, section 2, judgment of October 29, 2009.)\u00a0 In July 2012, a French court issued an international arrest warrant when for the second time, Mr. Obiang, Jr. did not appear before the Investigating Magistrates \u0022for preliminary examination - a legal procedural step that precedes a criminal indictment under French Law.\u0022 (Source:\u00a0 Sherpa Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: Teodorin Obiang refuses to appear before judicial authorities,\u0022 July 13, 2012.) According to a press release from the NGOs Transparency International France and Sherpa, the Paris court (Tribunal de Grande Instance) issued an indictment against Teodoro Nguema Obiang Mangue on money-laundering charges on March 19, 2014 (Source: Transparency International press release, \u0022Teodorin Obiang Nguema indicted in Bien Mal Acquis case\u0022,  March 20, 2014.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Instructing Judge Baltasar Garzon; Fiscalia de la Audiencia Nacional (National Criminal Court Prosecutor); Asocacion Pro Derechos Humanos de Espana (Attorneys Manuel Olle Sese and Almudena Bernabeu)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"[Juzgado de Instruccion, Las Palmas de Gran Canaria?]","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_Spain_APDHE_Complaint_English_Oct_22_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_Spain_APDHEvObiang_Soros_Fdn_March_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Investigation_Riggs_Bank_July_2004.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/APDHE%20v%20Obiang_Open_Society_Fdn_Jan_22_2015.pdf","Sources ":"U.S. Senate Permanant Subcommittee on Investigations Minority Staff Report, \u0022Money Laundering and Foreign Corruption: Enforcement and Effectiveness of the Patriot Act, Case Study Involving Riggs Bank,\u0022 July 15, 2004, accessed at http:\/\/hsgac.senate.gov\/public\/_files\/ACF5F8.pdf;  Open Society Justice Initiative of the Open Society Foundations, \u0022APDHE v. Obiang Family,\u0022 last accessed on January 22, 2015, at http:\/\/www.soros.org\/initiatives\/justice\/litigation\/obiangfamily (which also provides links at bottom to text of APDHE\u0027s complaint in Spanish and English translation). Sherpa Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: Teodorin Obiang refuses to appear before judicial authorities,\u0022 July 13, 2012, accessed at http:\/\/asso-sherpa.org\/sherpa-content\/docs\/newsroom\/Communiques_de_press....\n"},{"Case ID":"ARW-184","Case Title (Name of Public Official or Entity Allegedly Involved)":"Teodoro Nguema Obiang Mbasogo \/ Teodoro Nguema Obiang Mangue (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Equatorial Guinea","Position of Public Official(s) (yrs in office)":"President (Teodoro Nguema Obiang Mbasogo: 1979-current); Second Vice President and son of President (Teodoro Nguema Obiang Mangue: current)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Other \/ Settlement Agreement in Non-Conviction Based Confiscation Case","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"Unspecified amount (includes Malibu mansion, Ferrari, two statues and US$11.3 million)","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"Ongoing but returned funds to be used to establish a charity for benefit of people of Equatorial Guinea","Case Summary":"On October 10, 2014, Mr. Obiang announced that he had reached a settlement with the Department of Justice in which he agreed to forfeit his Malibu mansion, a Ferrari, two statues, US$10.3 million being held in escrow and to make a payment for US$1 million.  The proceeds are to be used to establish a charity that would benefit the people of Equatorial Guinea.  (Source:  US v. One White Crystal-Covered \u0022Bad Tour\u0022 Glove and Other Michael Jackson Memorabilia; Real Property Located on Sweetwater Mesa Road in Malibu, California; One 2011 Ferrari 599 GTO, et al, Case No. 2:11-cv-03582-GW-SS (C.D. Cal), Joint Stipulation and Settlement Agreement filed October 10, 2014; PR Newswire, \u0022Vice President of Equatorial Guinea Settles Case with Justice Department.\u0022)  In October 2011, the US Department of Justice had announced the filing of two civil asset forfeiture suits, in California and in Washington, D.C., against more than $70.8 million in alleged proceeds of corruption by Mr. Teodoro Nguema Obiang Mangue.  The Justice Department stated that the cases originated as part of its Kleptocracy Asset Recovery Initiative. (Source: US Department of Justice Press Release, \u0022Department of Justice Seeks to Recover More Than $70.8 Million in Proceeds of Corruption from Government Minister of Equatorial Guinea,\u0022 October 25, 2011.)  In February 2010, the U.S. Senate Permanent Subcommittee on Investigations had conducted hearings and released an extensive investigative report which concluded that \u0022From 2004 to 2008, Teodoro Nguema Obiang Mangue, son of the President of Equatorial Guinea, has used U.S. lawyers, bankers, real estate agents, and escrow agents to move over $110 million in suspect funds into the United States. Mr. Obiang is the subject of an ongoing U.S. criminal investigation, has been identified in corruption complaints filed in France, and was a focus of a 2004 Subcommittee hearing showing how Riggs Bank facilitated officials from Equatorial Guinea in opening accounts and engaging in suspect transactions.\u0022 (Sources: U.S. Senate Permanent Subcommittee on Investigations Majority and Minority Staff Report, \u0022Keeping Foreign Corruption Out of the United States: Four Case Studies\u0022 and report of the Senate Hearing 111-540 on February 4, 2010.)   The assets involved in the California suit included a Malibu mansion on Sweetwater Mesa Road, a 2011 Ferrari, and Michael Jackson Memorabilia; the Washington, DC suit involves a Gulfstream G-V private jet.  In August 2013, the California court granted a summary judgment, dismissing the case against the assets but declining to rule on the charge of bank fraud.  (Sources: US v. One White Crystal-Covered \u0022Bad Tour\u0022 Glove, et al, Case No. 2:11-cv-03582-GW-SS (C.D. Cal), First Amended Verified Claim for Forfeiture In Rem filed October 13, 2011, US v. One Gulfstream G-V Jet Aircraft Displaying Tail Number VPCES, et al, Case No. 1:11-cv-01874-ABJ (D.D.C.), Complaint for Forfeiture In Rem filed October 25, 2011).  As part of the settlement, the civil forfeiture action filed in Washington DC was to be dropped.","Disposition of Criminal Case(s)":"In November 2010, the French Supreme Court held that the criminal complaint filed earlier by Transparency International and other non-governmental organizations against Mr. Obiang may proceed. (Source: Supreme Court of France, Case No. 6092, decision of November 9, 2010, L\u0027association Transparence International France, partie civile, reversing High Court of Paris, section 2, judgment of October 29, 2009.)\u00a0 In July 2012, a French court issued an international arrest warrant when for the second time, Mr. Obiang, Jr. did not appear before the Investigating Magistrates \u0022for preliminary examination - a legal procedural step that precedes a criminal indictment under French Law.\u0022 (Source:\u00a0 Sherpa Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: Teodorin Obiang refuses to appear before judicial authorities,\u0022 July 13, 2012.) According to a press release from the NGOs Transparency International France and Sherpa, the Paris court (Tribunal de Grande Instance) issued an indictment against Teodoro Nguema Obiang Mangue on money-laundering charges on March 19, 2014 (Source: Transparency International press release, \u0022Teodorin Obiang Nguema indicted in Bien Mal Acquis case\u0022,  March 20, 2014.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Senate Permanent Subcommittee on Investigations; Foreign Corruption Investigations Group (Miami) and HSI Asset identification and Removal Group (Miami) of the Immigration and Customs Enforcement; HSI Office of the Special Agent in Charge (Los Angeles)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the Central District of California; US District Court for the District of Columbia","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Investigation_Riggs_Bank_July_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_Suits_Filed_DOJ_PR_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_CDCA_First_Amended_Verified_Complaint_Oct_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_DDC_Complaint_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Visa_Mansion_NYTimes_Nov_17_2009\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_US_CDCA_Ruling_Mtn_Summary_Judg_Aug_20_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Investigation_Riggs_Bank_July_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_Suits_Filed_DOJ_PR_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_CDCA_First_Amended_Verified_Complaint_Oct_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_DDC_Complaint_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Visa_Mansion_NYTimes_Nov_17_2009\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_US_DDC_Amended_Complaint_Main_Jun_17_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Investigation_Riggs_Bank_July_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_Suits_Filed_DOJ_PR_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_CDCA_First_Amended_Verified_Complaint_Oct_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_DDC_Complaint_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Visa_Mansion_NYTimes_Nov_17_2009\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_US_DDC_Mtn_DIsmiss_Exhibit_5_Oct_4_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Investigation_Riggs_Bank_July_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_Suits_Filed_DOJ_PR_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_CDCA_First_Amended_Verified_Complaint_Oct_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_DDC_Complaint_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Visa_Mansion_NYTimes_Nov_17_2009\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_Statement_Settlement_Oct_10_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Investigation_Riggs_Bank_July_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_Suits_Filed_DOJ_PR_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_CDCA_First_Amended_Verified_Complaint_Oct_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_DDC_Complaint_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Visa_Mansion_NYTimes_Nov_17_2009\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_CDCA_Stip_Settlement_Ag_10102014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Investigation_Riggs_Bank_July_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_Suits_Filed_DOJ_PR_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_CDCA_First_Amended_Verified_Complaint_Oct_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_DDC_Complaint_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Visa_Mansion_NYTimes_Nov_17_2009\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_CDCA_Notice_settlement_10102014.pdf","Sources ":"U.S. Senate Permanent Subcommittee on Investigations Majority and Minority Staff Report, \u0022Keeping Foreign Corruption Out of the United States: Four Case Studies\u0022 and report of the Senate Hearing 111-540 on February 4, 2010, available at the website of the Government Printing Office at http:\/\/www.gpo.gov\/fdsys\/pkg\/CHRG-111shrg56840\/html\/CHRG-111shrg56840.htm; U.S. Senate Permanant Subcommittee on Investigations Minority Staff Report, \u0022Money Laundering and Foreign Corruption: Enforcement and Effectiveness of the Patriot Act, Case Study Involving Riggs Bank,\u0022 July 15, 2004, accessed at http:\/\/hsgac.senate.gov\/public\/_files\/ACF5F8.pdf. \u00a0US Department of Justice Press Release, \u0022Department of Justice Seeks to Recover More Than $70.8 Million in Proceeds of Corruption from Government Minister of Equatorial Guinea,\u0022 October 25, 2011; US v. One White Crystal-Covered \u0022Bad Tour\u0022 Glove and Other Michael Jackson Memorabilia; Real Property Locted on Sweetwater Mesa Road in Malibu, California; One 2011 Ferrari 599 GTO, et al, Case No. 2:11-cv-03582-GW-SS, First Amended Verified Claim for Forfeiture In Rem filed October 13, 2011 and Final Ruling on Defendant\u0027s Motion for Summary Judgment, August 20, 2013, \u00a0Joint Stipulation and Settlement Agreement filed October 10, 2014, 2014; US v. One Gulfstream G-V Jet Aircraft Displaying Tail Number VPCES, et al, Case No. 1:11-cv-01874-ABJ (D.D.C.), Complaint for Forfeiture In Rem filed October 25, 2011 and Amended Complaint filed June 17, 2013, and Defendant\u0027s Motion to Dismiss filed October 4, 2013. See also, Ian Urbina, \u0022Taint of Corruption Is No Barrier to U.S. Visa,\u0022 New York Times, November 16, 2009 (which valued the Malibu mansion at $35 million and showed a photo of it.) and Sherpa Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: Teodorin Obiang refuses to appear before judicial authorities,\u0022 July 13, 2012, accessed at http:\/\/asso-sherpa.org\/sherpa-content\/docs\/newsroom\/Communiques_de_press... PR Newswire, \u0022Vice President of Equatorial Guinea Settles Case with Justice Department,\u0022 October 10, 2014, at http:\/\/www.prnewswire.com\/news-releases\/vice-president-of-equatorial-gui...\n"},{"Case ID":"ARW-186","Case Title (Name of Public Official or Entity Allegedly Involved)":"Tommy Suharto (also known as Hutomo Mandala Putra)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Indonesia","Position of Public Official(s) (yrs in office)":"Son of President (Mohamed Suharto, 1967-1998)","Jurisdiction of Asset Recovery":"Guernsey","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Ongoing Case, but the Guernsey court wrote that \u0022The defendant [BNP Paribas (Suisse) S.A. bank] considered its duties under the provisions of the Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law 1999 and disclosed its position to the Financial Intelligence Service (\u0022FIS\u0022) of the States of Guernsey.\u0022 (Source: Garnet Investments Investments Limited v. BNP Paribas (Suisse) S.A. and Government of Republic of Indonesia, Guernsey Law Reports 2007\u201308 GLR 73 (Royal Court), Judgment of May 23rd, 2007.","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"As noted in the August 22, 2011 Media Release by Guernsey\u0027s Financial Investigative Unit, the Guernsey Court of Appeals ruled in favor of the Chief of Customs and Excise, Immigration and Nationality Service which had appealed a lower court ruling  in favour of Garnet Investments Ltd (Garnet), who had applied for judicial review of the Financial Intelligence Service\u2019s (FIS) decision not to give consent for the bank BNP Paribas (BNP) to make payments, requested by Garnet from its account at the Bank.  (Source: Guernsey Financial Investigation Unit Agency Media Release, \u0022Judicial Review \/ THE CHIEF OFFICER CUSTOMS \u0026 EXCISE, IMMIGRATION \u0026 NATIONALITY SERVICE \u2013 (Now known as the Guernsey Border Agency - GBA) And GARNET INVESTMENTS, August 22, 2011.)  According to a statement by the Government of Guernsey, \u0022On Tuesday 20 November 2012, the Judicial Committee of the Privy Council notified Garnet Investments Limited that it had refused its application to appeal the decision of the Guernsey Court of Appeal which had found in favour of the Chief Officer Customs \u0026 Excise, Immigration \u0026 Nationality.  The Privy Council\u0027s written decision advised Garnet Investments Limited that its \u0022application for permission to appeal had been considered by the Board and permission to appeal had been refused because the application does not raise an arguable point of law and the Board is not persuaded that the decision of the Court of Appeal is arguably wrong.\u0022\u0022  (Source: States of Guernsey, \u0022Judicial Committee of the Privy Council refuses Garnet Investments Ltd application to appeal,\u0022 January 4, 2013.)\nAssets of Garnet Investments Limited, of which Mr. Suharto was identified as the beneficial owner, remain restrained in Guernsey.   In 2002, the BNP Paribas (Suisse) Bank - Guernsey branch disclosed to the Guernsey financial intelligence unit that Tommy Suharto was the beneficial owner of the Garnet Investments Limited account and sought the FIS\u0027s consent to transfer the funds, as requested by Garnet Investments.  The FIU denied consent and the Government of Indonesia was informed and given opportunity to join the proceedings between the Bank and Garnet Investments.  The Guernsey court cited the lack of progress by Indonesia to institute proceedings against Suharto in Indonesia as jusitification for not extending the freeze of the funds but the FIU continued to deny consent to transfer the funds. (Source: Garnet Investments Limited v. BNP Paribas (Suisse) S.A. and Government of Indonesia, Guernsey Law Reports, 2007-08 GLR 73.)  In late 2010, Suharto\u0027s defunct car company found liable to Ministry of Finance for tax evasion; Indonesia may attempt to recover the Guernsey funds again. (Source: Reuters, \u0022Indonesia to keep assets of ex-president Suharto\u0027s son,\u0022 July 16, 2010.)","Disposition of Criminal Case(s)":"According to the January 29, 2007 \u0022Trade and Investment News\u0022 by The Coordinating Ministry for Economic Affairs of the Republic of Indonesia, \u0022Tommy [Suharto], 44, was released from prison last October after serving five years of a 15-year sentence for ordering the murder of an Indonesian judge who had convicted him of corruption in connection with a land-scam case.\u0022  (Source: The Coordinating Ministry for Economic Affairs, Republic of Indonesia, \u0022Trade and Investment News,\u0022 January 29, 2007, accessed on the website of The Indonesian Consulate General Chicago,\u0022 at http:\/\/www.indonesiachicago.org\/economic-N012907.html)","Jurisdiction of Origin: Investigative Agency":"Ministry of Justice and Human Rights","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Financial Investigative Unit, Guernsey Border Agency","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"Royal Court; Court of Appeals","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Conviction_Indonesian_Consulate_Jan_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_2009-10_GLR_1.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_73.pdf Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_442.pdf Suharto_Guernsey_Media Release_Guernsey Court of Appeal_Garnet_Aug_22_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_73.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Conviction_Indonesian_Consulate_Jan_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_2009-10_GLR_1.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_73.pdf Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_442.pdf Suharto_Guernsey_Media Release_Guernsey Court of Appeal_Garnet_Aug_22_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_442.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Conviction_Indonesian_Consulate_Jan_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_2009-10_GLR_1.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_73.pdf Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_442.pdf Suharto_Guernsey_Media Release_Guernsey Court of Appeal_Garnet_Aug_22_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Suharto_Guernsey_Media%20Release_Guernsey%20Court%20of%20Appeal_Garnet_Aug_22_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Conviction_Indonesian_Consulate_Jan_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_2009-10_GLR_1.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_73.pdf Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_442.pdf Suharto_Guernsey_Media Release_Guernsey Court of Appeal_Garnet_Aug_22_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Suharto_Guernsey_Chief%20Officer%20v%20Garnet%20Application%20for%20Leave%20to%20appeal%20to%20the%20PC%20Judgement_19%2012%2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Conviction_Indonesian_Consulate_Jan_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_2009-10_GLR_1.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_73.pdf Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_442.pdf Suharto_Guernsey_Media Release_Guernsey Court of Appeal_Garnet_Aug_22_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Suharto_Guernsey_Customs_v_Garnet_Appeals_Ct_Jul_5_6_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Conviction_Indonesian_Consulate_Jan_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_2009-10_GLR_1.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_73.pdf Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_442.pdf Suharto_Guernsey_Media Release_Guernsey Court of Appeal_Garnet_Aug_22_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Suharto_Guernsey_Privy_Council_Deny_Appeal_Jan_4_2013.pdf","Sources ":"Garnet Invs. Ltd. v. BNP Paribas (Suisse) S.A. and the Government of the Republic of Indonesia (Royal Court) 2007-08 GLR 73; Garnet Invs. Ltd. v. BNP Paribas (Suisse) S.A. and the Government of the Republic of Indonesia (Royal Court) 2007-08 GLR 442; Garnet Invs. Ltd. v. BNP Paribas (Suisse) S.A. and the Government of the Republic of Indonesia (C.A.) 2009-10 GLR 1, all available at Guernsey Legal Resources: http:\/\/www.guernseylegalresources.gg\/ccm\/portal\/; States of Guernsey, \u0022Judicial Committee of the Privy Council refuses Garnet Investments Ltd application to appeal,\u0022 January 4, 2013, at http:\/\/www.gov.gg\/article\/105231\/Judicial-Committee-of-the-Privy-Council...\n The Coordinating Ministry for Economic Affairs, Republic of Indonesia, \u0022Trade and Investment News,\u0022 January 29, 2007, accessed on the website of The Indonesian Consulate General Chicago, at http:\/\/www.indonesiachicago.org\/economic-N012907.html.  See also Reuters, \u0022Indonesia to keep assets of ex-president Suharto\u0027s son,\u0022 July 16, 2010 and The Jakarta Post, \u0022\u0027Tommy\u0027 Soeharto loses appeal in Guernsey,\u0022 August 24, 2011, accessed at http:\/\/www.thejakartapost.com\/news\/2011\/08\/24\/tommy-soeharto-loses-appea....). Guernsey Financial Investigation Unit Agency Media Release, \u0022Judicial Review \/\nTHE CHIEF OFFICER CUSTOMS \u0026 EXCISE, IMMIGRATION \u0026 NATIONALITY SERVICE \u2013 (Now known as the Guernsey Border Agency - GBA) And GARNET INVESTMENTS, August 22, 2011, accessed at http:\/\/www.guernseyfiu.gov.gg\/ccm\/portal\/) and  Court of Appeal decisions (5 and 6 July 2011 and 19 December 2011) in the case;  Frederic Raffray, \u0022The rule of law and \u0027Tommy Suharto\u0027 - son of (former) President Suharto,\u0022 at 29-50, in Emerging Trends in Asset Recovery (Bern: Peter Lang, 2013)\n"},{"Case ID":"ARW-187","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ukrainian Goverment \/ Ukrvaktsina v. Olden Group, LLC and Interfarm, LLC","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Unspecified","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2010","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/","Contributing Factors in Asset Recovery":"Private civil action","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA (private civil action)","Case Summary":"On September 17, 2010, Ukrvaktsina filed a civil suit in Oregon federal court, alleging that \u0022Interfarm and Olden Group conspired to overcharge Ukrvaktsina for millions of dollars in vaccine purchases through acts of fraud, money laundering and other criminal acts.\u0022  Ukrvaktsins is seeking $26 million in damages. (Source: Ukrvaktsina v. Olden Group, LLC, Case No. 6:10-cv-06297-AA (D. Ore.), Complaint filed September 17, 2010).  On June 8, 2011, the US District Court for the District of Oregon issued an Order of Default Judgment for the plaintiff against Olden Group LLC, an Oregon incorporated entity. The Court stated that Olden Group failed to make an appearance or otherwise answer the plaintiff\u0027s amended complaint, and orderd Olden Group to pay a principal of $59,785,291.50 and post-judgment interest until principal was paid. (Source: Ukrvaktsina v. Olden Group, LLC, Case No. 6:10-cv-06297-AA (D. Ore.), Default Judgment Against Defendant Olden Group, LLC filed June 9, 2011).  On October 30, 2011, the Court dismissed the case against co-defendant Interfarm LLC, holding that the court did not have personal or specific jurisdiction over the Ukrainian company.  (Source: Ukrvaktsina v. Olden Group, LLC, Case No. 6:10-cv-06297-AA (D. Ore.), Opinion and Order, and Judgment, both filed on October 30, 2011.)","Disposition of Criminal Case(s)":"Unspecified","Jurisdiction of Origin: Investigative Agency":"Government of Ukraine, Ministry of Finance, Main Control and Revision Office; Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP, Kroll Inc. ","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP, Kroll Inc.","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Trout Cacheris PLLC (Attorney Plato Cacheris); Akin Gump Strauss Hauer \u0026 Feld LLP (Attorney Mark J. MacDougall); Davis Wright Tremaine LLP (Attorney Kevin H. Kono)","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Oregon","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Min_Finance_Investigation_Report_Oct_14_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Ukrvaktsina_Oregon_Default_Judgment_Order_Jun_9_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Ukravaktsina_Interfarm_Oregon_Opinion_Case_Dismissed_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ukraine_Ukrvaktsina_Oregon_Default_Judgment_Order_Jun_9_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Min_Finance_Investigation_Report_Oct_14_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Ukrvaktsina_Oregon_Default_Judgment_Order_Jun_9_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Ukravaktsina_Interfarm_Oregon_Opinion_Case_Dismissed_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Olden_Group_DORE_Opinion_Case_Dismissed_Oct_30_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Min_Finance_Investigation_Report_Oct_14_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Ukrvaktsina_Oregon_Default_Judgment_Order_Jun_9_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Ukravaktsina_Interfarm_Oregon_Opinion_Case_Dismissed_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Olden_Group_US_DOR_Ct_Dkt_July_2011_to_Oct_2013.pdf","Sources ":"Ukravaktsina v. Olden Group, LLC and Interfarm, LLC, Case No. 6:10-cv-06297-AA (D. Ore.), Complaint filed September 17, 2010 and Docket Report as of October 2013; Default Judgment Order filed June 9, 2011;  \nGovernment of Ukraine, Ministry of Finance, Main Control and Revision Office, \u0022Report of Investigative Findings, pursuant to Agreement on Performance of Audit on the Efficiency of Use by the Respective Controllers of the Budget Funds in 2008-2009 and in the First Quarter of 2010,\u0022 October 14, 2010 by Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP and Kroll Inc. posted on the wesbite of the Ministry of Finance at http:\/\/minfin.gov.ua\/document\/274231\/report1.pdf\n"},{"Case ID":"ARW-188","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ukrainian Government \/ Ministry of Emergency Situations","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Unspecified","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2010","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"On October 11, 2010, the Ministry of Emergency Situations of Ukraine (represented by Nabarro LLP) filed a civil claim in the High Court of Justice, Queen\u0027s Bench Division, against Legal Business Consultants Ltd., a UK company that is alleged to be part of an international conspiracy involving the inflated purchase price of depreciated vehicles to the ministry.  The claim seeks damages for conspiracy and deceit.  (Source: Government of Ukraine, Ministry of Finance, Main Control and Revision Office, \u0022Report of Investigative Findings: Pursuant to Agreement on Performance of Audit on the Efficiency of Use by the Respective Controllers of the Budget Funds in 2008-2009 and in the First Quarter of 2010,\u0022 October 14, 2010 Report by Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP, Kroll Inc.)","Disposition of Criminal Case(s)":"Unspecified","Jurisdiction of Origin: Investigative Agency":"Government of Ukraine, Ministry of Finance; Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP, Kroll Inc. ","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP, Kroll Inc.","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP","Jurisdiction of Asset Recovery: Courts Involved":"High Court, Queen\u0027s Bench","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Min_Finance_Investigation_Report_Oct_14_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Ukrvaktsina_Oregon_Complaint_Sep_17_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Ukrvaktsina_Oregon_Court_Docket_Report_May_5_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ukraine_UK_Lawsuit_Interfax_Ukraine_Dec_10_2010.pdf","Sources ":"Government of Ukraine, Ministry of Finance, Main Control and Revision Office, \u0022Report of Investigative Findings: Pursuant to Agreement on Performance of Audit on the Efficiency of Use by the Respective Controllers of the Budget Funds in 2008-2009 and in the First Quarter of 2010,\u0022 October 14, 2010 Report by Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP, Kroll Inc. posted on the website of the Ministry of Finance at http:\/\/minfin.gov.ua\/document\/274231\/report1.pdf; Interfax-Ukraine (Ukraine News Agency, \u0022Ukrainian government sues in UK, alleges corrupt scheme in purchases of emergency vehicles,\u0022 December 10, 2010, at http:\/\/en.interfax.com.ua\/news\/general\/50622.html.\n"},{"Case ID":"ARW-189","Case Title (Name of Public Official or Entity Allegedly Involved)":"Unnamed Case \/ Burkina Faso","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Burkina Faso","Position of Public Official(s) (yrs in office)":"Unspecified","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"2009","UNCAC Offenses Implicated":"","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Unspecified","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Unknown","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$500,000","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"\u0022Agreement to return the assets through selected NGO projects to the benefit of the population of Burkina Faso\u0022 (Source: Swiss Ministry of Foreign Affairs, September 30, 2009)","Case Summary":"According to the Swiss Ministry of Foreign Affairs, the asset return was completed in 2009.  The name of the case was not disclosed, but there was an \u0022Agreement to return the assets through selected NGO [Non-Governmental Organization] projects to the benefit of the population of Burkina Faso.\u0022  (Source:  Swiss  Ministry of Foreign Affairs, September 30, 2009.)","Disposition of Criminal Case(s)":"Unspecified","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Swiss Ministry of Foreign Affairs, September 30, 2009.\n"},{"Case ID":"ARW-191","Case Title (Name of Public Official or Entity Allegedly Involved)":"Vladimiro Montesinos (Cayman Islands)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Peru","Position of Public Official(s) (yrs in office)":"De facto chief of intelligence and main advisor of former Peruvian President Alberto Fujimori (1990-2000)","Jurisdiction of Asset Recovery":"Cayman Islands","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2001","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Letter of Request","Basis for Intl Cooperation":"Powers Granted to Cayman Grand Court under the Proceeds of Criminal\r\nConduct Law","Contributing Factors in Asset Recovery":"\u0022Effective results were achieved because of the willingness on the part of the Cayman authorities, to take recourse to restrain the money itself in rem out of concern that the local laws were also being violated, instead\r\nof awaiting a judgment in personam which may never have been forthcoming because of the fugitive status of the perpetrator and which would have to be also enforced to recover the proceeds which would have no doubt\r\ntaken flight within the restraint. Thus, what began simply as a letter of request to \u0022lift the bank, financial and stock market secrecy procedures, as well as to execute a preventive attachment in the form of a restraining order\u0022 on all and any bank accounts held in Grand Cayman in the name of Vladimiro Montesinos-Torres or in the name of several other related parties; ended in the repatriation of some $44 million dollars to Peru, without a trial between the parties having to take place. This happened because in urgent response to the Judicial Request from Peru, a restraint order was obtained from the Cayman Court, freezing the bank accounts which could be identified. This afforded the Peruvian Government the time it needed to prepare and present its case for the ultimate declaration of its ownership over those accounts as containing the proceeds of the crime.\u0022   (Source: Cayman Islands Government webpage on Enforcement of Judgments in Practice,\u0022 posted at http:\/\/www.gov.ky\/portal\/page?_pageid=1142,1687439\u0026_dad=portal\u0026_schema=PORTAL).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$44,000,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to Professor Guillermo Jorge, two sets of Montesinos-related funds were involved in the Cayman Islands:  (1) Assets restrained in rem with assistance of newly created Financial Intelligence Unit; Waivers signed by account holders, pursuant to their plea bargaining agreements with Peruvian authorities. [Cayman did not have provisions for adopting provisional measures. Order of restraint could only be made where shown there were already proceedings instituted.  But the Peruvian request for lifting bank secrecy and freezing assets transformed ex officio into a criminal complaint for money laundering, thereby eliminating the need to wait for an in personam judgment from Peru.] (2) Criminal complaint filed in Cayman against Wiese Sudameris International for suspicion of money laundering and freezing order in rem; financial analysis showed funds were never transferred to Cayman, but stayed in Peru; confiscation orders against funds located in Lima resulted in \u0022repatriation\u0022 of $33 milion. (Source: Professor Guillermo Jorge, \u0022The Peruvian efforts to recover the proceeds from Montesinos\u0027 criminal network of corruption,\u0022 presented at Asian Development Bank Regional Seminar, Bali\/Indonesia, September 5-7, 2007).","Disposition of Criminal Case(s)":"According to a case study by Professor Guillermo Jorge, as of September 2007, Mr. Montesinos had been convicted in 13 different trials and more than 70 trials were ongoing.  (Source:  Guillermo Jorge, \u0022The Peruvian Efforts to Recover Proceeds from Montesinos\u0027s Criminal Network of Corruption,\u0022 in  ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational Held in Bali, Indonesia, on 5-7 September 2007 and hosted by the Corruption Eradication Commission, Indonesia, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.)","Jurisdiction of Origin: Investigative Agency":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of theSpecial State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Financial Reporting Authority (CAYFIN) of the Cayman Islands","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"Grand Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Montesinos_Cayman_Islands_Chief_Justice_Speech_May_2006.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Montesinos_Cayman_Islands_Enforcement_Judgments.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Montesinos_Jorge_Case_Study_ADB_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Montesinos_StAR_Case_Study.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Montesinos_Cayman_Islands_Chief_Justice_Speech_May_2006.PDF","Sources ":"StAR Case study at http:\/\/www1.worldbank.org\/publicsector\/star_site\/documents\/Case_Studies_... Professor Guillermo Jorge, \u0022The Peruvian efforts to recover proceeds from Montesinos\u0027 criminal network of corruption,\u0022 Backgrounder paper presented at the Asian Development Bank\u0027s Regional Seminar for Asia-Pacific, \u0022Making international anti-corruption standards operational: Asset Recovery and mutual legal assistance,\u0022 September 5-7, 2007 (Bali, Indonesia), at 1 and 23 and fn 56, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.; Cayman Islands Government webpage on Enforcement of Judgments in Practice,\u0022 posted at http:\/\/www.gov.ky\/portal\/page?_pageid=1142,1687439\u0026_dad=portal\u0026_schema=P...) and a speech by Hon. Anthony Smellie, Chief Justice and Mututal Legal Assistance Authority, The Royal Cayman Islands, \u0022FORFEITING THE PROCEEDS OF CORRUPTION,\u0022 A Seminar on Asset Forfeiture and Money Laundering for Member States of the Organization of American States, May 2-5, 2006 in Miami, Florida.\n"},{"Case ID":"ARW-192","Case Title (Name of Public Official or Entity Allegedly Involved)":"Vladimiro Montesinos (Luxembourg)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Peru","Position of Public Official(s) (yrs in office)":"De facto chief of intelligence and main advisor of former Peruvian President Alberto Fujimori (1990-2000)","Jurisdiction of Asset Recovery":"Luxembourg","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Unspecified","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a Case Study by Professor Guillermo Jorge, citing official figures of the Office of the Special State Attorney for the Montesinos\/Fujimori Case, as of 2007, accounts valued at $ 47 million remain frozen in Switzerland, Mexico, Luxembourg and Panama. (Source: Professor Guillermo Jorge, \u0022The Peruvian efforts to recover the proceeds from Montesinos\u0027 criminal network of corruption,\u0022 presented at Asian Development Bank Regional Seminar, Bali\/Indonesia, September 5-7, 2007.)","Disposition of Criminal Case(s)":"According to a case study by Professor Guillermo Jorge, as of September 2007, Mr. Montesinos had been convicted in 13 different trials and more than 70 trials were ongoing.  (Source:  Guillermo Jorge, \u0022The Peruvian Efforts to Recover Proceeds from Montesinos\u0027s Criminal Network of Corruption,\u0022 in  ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational Held in Bali, Indonesia, on 5-7 September 2007 and hosted by the Corruption Eradication Commission, Indonesia, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.)","Jurisdiction of Origin: Investigative Agency":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of theSpecial State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Professor Guillermo Jorge, \u0022The Peruvian efforts to recover proceeds from Montesinos\u0027 criminal network of corruption,\u0022 Backgrounder paper presented at the Asian Development Bank\u0027s Regional Seminar for Asia-Pacific, \u0022Making international anti-corruption standards operational: Asset Recovery and mutual legal assistance,\u0022 September 5-7, 2007 (Bali, Indonesia), at 1 and 23 and fn 56, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf; Peru, Congreso de la Republica, Comision Investigadora sobre Los Delitos Economicos y Financieros Cometidos entre 1990-2001, Informe Final de Investigacion (June 2002), accessed at http:\/\/www.congreso.gob.pe\/comisiones\/2002\/CIDEF\/oscuga\/informecideffina....\n"},{"Case ID":"ARW-193","Case Title (Name of Public Official or Entity Allegedly Involved)":"Vladimiro Montesinos (Mexico)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Peru","Position of Public Official(s) (yrs in office)":"De facto chief of intelligence and main advisor of former Peruvian President Alberto Fujimori (1990-2000)","Jurisdiction of Asset Recovery":"Mexico","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Unspecified","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a Case Study by Professor Guillermo Jorge, citing official figures of the Office of the Special State Attorney for the Montesinos\/Fujimori Case, as of 2007, accounts valued at $47 million remain frozen in Switzerland, Mexico, Luxembourg and Panama. (Source: Professor Guillermo Jorge, \u0022The Peruvian efforts to recover the proceeds from Montesinos\u0027 criminal network of corruption,\u0022 presented at Asian Development Bank Regional Seminar, Bali\/Indonesia, September 5-7, 2007.)","Disposition of Criminal Case(s)":"According to a case study by Professor Guillermo Jorge, as of September 2007, Mr. Montesinos had been convicted in 13 different trials and more than 70 trials were ongoing.  (Source:  Guillermo Jorge, \u0022The Peruvian Efforts to Recover Proceeds from Montesinos\u0027s Criminal Network of Corruption,\u0022 in  ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational Held in Bali, Indonesia, on 5-7 September 2007 and hosted by the Corruption Eradication Commission, Indonesia, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.)","Jurisdiction of Origin: Investigative Agency":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of theSpecial State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Professor Guillermo Jorge, \u0022The Peruvian efforts to recover proceeds from Montesinos\u0027 criminal network of corruption,\u0022 Backgrounder paper presented at the Asian Development Bank\u0027s Regional Seminar for Asia-Pacific, \u0022Making international anti-corruption standards operational: Asset Recovery and mutual legal assistance,\u0022 September 5-7, 2007 (Bali, Indonesia), at 1 and 23 and fn 56, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf. Peru, Congreso de la Republica, Comision Investigadora sobre Los Delitos Economicos y Financieros Cometidos entre 1990-2001, Informe Final de Investigacion (June 2002), accessed at http:\/\/www.congreso.gob.pe\/comisiones\/2002\/CIDEF\/oscuga\/informecideffina....\n"},{"Case ID":"ARW-194","Case Title (Name of Public Official or Entity Allegedly Involved)":"Vladimiro Montesinos (Panama)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Peru","Position of Public Official(s) (yrs in office)":"De facto chief of intelligence and main advisor of former Peruvian President Alberto Fujimori (1990-2000)","Jurisdiction of Asset Recovery":"Panama","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Unspecified","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a Case Study by Professor Guillermo Jorge, citing official figures of the Office of the Special State Attorney for the Montesinos\/Fujimori Case, as of 2007, accounts valued at $47 million remain frozen in Switzerland, Mexico, Luxembourg and Panama. Professor Jorge wrote that bankers in Panama reported transactions related to Mr. Montesinos while he was a fugitive, and that the Financial Intelligence Unit of Panama initiated a case for suspected money laundering upon receiving several reports from its financial institutions.  Most of the acocunts in Panama, however, had been closed by the time the reports were made.   Professor Jorge\u0027s source for this information was his August 5, 2007 interview with Ms. Maribel Cornejo Batista, then-anticorruption prosecutor in Panama City.  (Source: Professor Guillermo Jorge, \u0022The Peruvian efforts to recover the proceeds from Montesinos\u0027 criminal network of corruption,\u0022 presented at Asian Development Bank Regional Seminar, Bali\/Indonesia, September 5-7, 2007).","Disposition of Criminal Case(s)":"According to a case study by Professor Guillermo Jorge, as of September 2007, Mr. Montesinos had been convicted in 13 different trials and more than 70 trials were ongoing.  (Source:  Guillermo Jorge, \u0022The Peruvian Efforts to Recover Proceeds from Montesinos\u0027s Criminal Network of Corruption,\u0022 in  ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational Held in Bali, Indonesia, on 5-7 September 2007 and hosted by the Corruption Eradication Commission, Indonesia, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.)","Jurisdiction of Origin: Investigative Agency":"Office of the Special State Attorney for the Montesinos \/Fujimori Case, Peru","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Unida de Analisis Financiero (Financial Intelligence Unit of Panama)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Professor Guillermo Jorge, \u0022The Peruvian efforts to recover proceeds from Montesinos\u0027 criminal network of corruption,\u0022 Backgrounder paper presented at the Asian Development Bank\u0027s Regional Seminar for Asia-Pacific, \u0022Making international anti-corruption standards operational: Asset Recovery and mutual legal assistance,\u0022 September 5-7, 2007 (Bali, Indonesia), at 1 and 23 and fn 56, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf. Peru, Congreso de la Republica, Comision Investigadora sobre Los Delitos Economicos y Financieros Cometidos entre 1990-2001, Informe Final de Investigacion (June 2002), accessed at http:\/\/www.congreso.gob.pe\/comisiones\/2002\/CIDEF\/oscuga\/informecideffina....\n"},{"Case ID":"ARW-195","Case Title (Name of Public Official or Entity Allegedly Involved)":"Vladimiro Montesinos (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Peru","Position of Public Official(s) (yrs in office)":"De facto chief of intelligence and main advisor of former Peruvian President Alberto Fujimori (1990\u20132000)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2000","Asset Recovery End":"2002, In part","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"International Mutual Assistance in Criminal Matters\r\n","Contributing Factors in Asset Recovery":"\u0022The return of the assets in the Montesinos case was made possible by efficient\r\ncooperation between the Swiss and Peruvian authorities and in particular by Swiss\r\nlaws against money laundering. On the basis of an obligation arising from the Money\r\nLaundering Act, the banks informed the Money Laundering Reporting Office at the\r\nFederal Office for Police Matters in October 2000 about the assets belonging to\r\nMontesinos and Hermoza Rios. The Money Laundering Reporting Office forwarded this\r\ninformation immediately to the Examining Magistrate\u0027s Office IV Canton of Zurich,\r\nwhich blocked the funds and initiated a criminal investigation. The knowledge gained in\r\nZurich was transferred by the Federal Office for Justice to the Peruvian judicial\r\nauthorities, which in turn made investigations and submitted the corresponding request\r\nfor legal assistance to Switzerland.\u0022\r\n","Status of Asset Recovery ":"Completed (in part) and Ongoing (in part)","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction (in part)","Assets Frozen (USD)":"$17,000,000","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$93,000,000","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Establishment of Special Fund for Management of Illegally Obtained Money against Interests of the State; a board comprised of representatives of Peruvian government agencies involved in the fight against corruption (Source: StAR Case Study, \u0022Vladimiro Montesinos.\u0022)","Case Summary":"According to the Swiss Ministry of Foreign Affairs, as of September 30, 2009, $93 million have been returned to Peru and $17 million remain frozen.  (Source: Swiss Ministry of Foreign Affairs, September 30, 2009.) An August 20, 2002 Swiss Federal Department of Justice press release had stated that, \u0022The account at Banco de la Nacion del Peru at Citibank in New York today received a credit of 77.5 million US dollars from Switzerland. This consisted largely of the blocked assets of Vladimiro Montesinos Torres and the former Peruvian general, Nicolas de Bari Hermoza Rios. The investigations carried out by the Examining Magistrate\u0027s Office IV Canton of Zurich revealed that the funds belonging to Montesinos that were frozen in Switzerland (totalling 49.5 million US dollars) originated from corruption-related crimes. Since 1990 Montesinos received \u0022commissions\u0022 on arms deliveries to Peru and had this bribe money paid to his bank accounts in Luxembourg, the USA and Switzerland. Montesinos received bribes for at least 32 transactions, each worth 18% of the purchase price. Montesinos also collected 10.9 million US dollars in \u0022commissions\u0022 on the purchase of three MIG29 planes, bought by the Peruvian airforce from the state owned Russian arms factory \u0022Rosvoorouzhenie\u0022. In return, Montesinos used his position to ensure that certain arms dealers were given preference when these orders were issued. On the basis of these facts, the Examining Magistrate\u0027s Office IV Canton of Zurich issued a decision on 12 June 2002 ordering the transfer of the assets belonging to Montesinos to Peru. This decision was not appealed and has since come into force. \/ Voluntary return \/ One of the arms dealers who enjoyed preferential treatment is voluntarily repatriating his commission from these transactions (7 million US dollars), hitherto held in Swiss bank accounts. General Nicolas de Bari Hermoza Rios also accepted bribes relating to arms deliveries to Peru. He too misappropriated funds from the military budget. All unlawfully obtained funds were ultimately paid into his bank accounts in Switzerland. Nicolas de Bari Hermoza Rios has agreed to this money (21 million US dollars) being returned to Peru.\u0022  The press release also stated that, \u0022In the Montesinos case, assets totalling 33 million US dollars remain blocked in Switzerland.\u0022 (Source:  Swiss Federal Department of Justice Press Release, \u0022Switzerland transfers 77 million U.S. dollars to Peru,\u0022 August 20, 2002.)","Disposition of Criminal Case(s)":"According to a case study by Professor Guillermo Jorge, as of September 2007, Mr. Montesinos had been convicted in 13 different trials and more than 70 trials were ongoing.  (Source:  Guillermo Jorge, \u0022The Peruvian Efforts to Recover Proceeds from Montesinos\u0027s Criminal Network of Corruption,\u0022 in  ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational Held in Bali, Indonesia, on 5-7 September 2007 and hosted by the Corruption Eradication Commission, Indonesia, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.)","Jurisdiction of Origin: Investigative Agency":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"The Money Laundering Reporting Office at the Federal Office for Police Matters; Examining Magistrate\u0027s Office IV Canton of Zurich; Federal Office for Justice","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Swiss Federal Supreme Court (BGE) decision, 129 II 462, 8 September 2003, posted as part of Montesinos case study at www.assetrecovery.org; Montesinos case: Swiss Federal Department of Justice Press Releases,\u0022Switzerland transfers 77 million U.S. dollars to Peru,\u0022 August 20, 2002, posted at http:\/\/www.bj.admin.ch\/content\/bj\/en\/home\/dokumentation\/medieninformatio... and \u0022Montesinos Torres affair: U.S.D 50 million blocked in Switzerland, November 3, 2000, posted at http:\/\/www.bj.admin.ch\/content\/bj\/en\/home\/dokumentation\/medieninformatio.... Montesinos Case study by Victor A. Dumas, in \u0022Stolen Asset Recovery (StAR) Initiative: Challenges, Opportunities and Tasks Ahead\u0022; Professor Guillermo Jorge, \u0022The Peruvian efforts to recover proceeds from Montesinos\u0027 criminal network of corruption,\u0022 Backgrounder paper presented at the Asian Development Bank\u0027s Regional Seminar for Asia-Pacific, \u0022Making international anti-corruption standards operational: Asset Recovery and mutual legal assistance,\u0022 September 5-7, 2007 (Bali, Indonesia), at 1 and 23 and fn 56, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.\n"},{"Case ID":"ARW-196","Case Title (Name of Public Official or Entity Allegedly Involved)":"Vladimiro Montesinos \/ Victor Alberto Venero Garrido","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Peru","Position of Public Official(s) (yrs in office)":"De facto chief of intelligence and main advisor of former Peruvian President Alberto Fujimori (Montesinos, 1990-2000) \/ Montesinos\u0027 Associate (Venero Garrido)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2000","Asset Recovery End":"2004","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation; Actions Initiated by Foreign Jurisdiction ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"\u0022Venero and his activities were brought to the attention of the FBI [Federal Bureau of Investigation] by the filing of a Suspicious Activity Report by Citibank\u0027s compliance officer in Long Island City, New York... Initially, the account opening did not raise any suspicion because Latin Americans often opened dollar-denominated bank accounts in the U.S. to protect their assets from inflation in their home countries.  However, Citibank and other financial institutions holding bank and brokerage accounts owned or controlled by Venero, Cheryle Mangino Diaz, and others gradually noticed unusual activity in the accounts and filed SARs with the U.S. Government.\u0022 Diaz was a California banker who was married to Venero\u0027s cousin and a former member of the board of directors of Hacienda Bank who had since 1996 helped Venero conceal more than $20 million in the U.S. (Source: Linda M. Samuel, \u0022Repatriation Obligations under the United Nations Convention Against Corruption,\u0022 Resource Material Series No. 65, accessed at the website of the United Nations Asia and Far East Institute for the Prevention of Crime and the Treatment of Offenders (UNAFEI)).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$34,736,372.08","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Agreement between U.S. and Peru that Peru would invest the returned assets in anti-corruption efforts.  Establishment of Special Fund for Management of Illegally Obtained Money against Interests of the State; a board comprised of representatives of Peruvian government agencies involved in the fight against corruption (Source: Acuerdo Entre el Gobierno de la Republica del Peru y El Gobierno de Los Estados Unidos de America Sobre Transferencia de Activos Decomisados, January 21, 2004.)","Case Summary":"According to Linda M. Samuel, then-Deputy Chief, Asset Forfeiture and Money Laundering Section of the U.S. Department of Justice, the U.S. Attorney\u0027s Office for the Central District of California and the Asset Forfeiture and Money Laundering Section of the Department of Justice restrained approximately $17.3 million connected to Mr. Venero-Garrido, ultimately forfeiting $15.9 million plus interest accrued.  During the investigation, U.S. law enforcement agents identified and forfeited approximately $4.3 million, plus interest accrued, in additional assets.  The combined net forfeited amount from these two judgments was $20,277,618.32.  She also notes that the investigation resulted in forfeiture of additional $358,753.76.  In addition, investigation by the FBI and the U.S. Attorney\u0027s Offie for the Southern District of Florida contributed to Montesinos\u0027 arrest and the direct return of additional assets to Peru, including at least $14.1 million repatriated directly by Mr. Venero-Garrido.  Ms. Samuel wrote that, \u0022The United States Department of Justice has approved transferring $20,277,618.32 in forfeited funds to the Government of Peru (GOP) in recognition of its assistance in the Venero case. The forfeited funds represent the proceeds of a broad range of fraud, corruption and money laundering offences committed in Peru and the United States that were connected to former Peruvian intelligence Chief Vladimiro Montesinos, his associate Victor Alberto Venero-Garrido, and other associates of Montesinos and former Peruvian President Alberto Fujimori. The statutory basis for the transfer under U.S. law is Title 18, United States Code, section 981(i)(1) authorizes the Attorney General to transfer money laundering proceeds and instrumentalities forfeited under 18 U.S.C. [Sections] 981 and\/or 982 to a foreign country that participated directly or indirectly in acts leading to the seizure and forfeiture of the property.\u0022 (Source: Linda M. Samuel, \u0022Repatriation Obligations under the United Nations Convention Against Corruption,\u0022 Resource Material Series No. 65 for the United Nations Asia and Far East Institute for the Prevention of Crime and the Treatment of Offenders (UNAFEI).  See also, US v. $17,317,700.38 in US currency, Case No. 1:01-cv-03444 (S.D.Fla.) and US v. $4,362,761.02 in US currency, Case No. 1:02-cv-21779 (S.D.Fla.).","Disposition of Criminal Case(s)":"According to a case study by Professor Guillermo Jorge, as of September 2007, Mr. Montesinos had been convicted in 13 different trials and more than 70 trials were ongoing.  (Source:  Guillermo Jorge, \u0022The Peruvian Efforts to Recover Proceeds from Montesinos\u0027s Criminal Network of Corruption,\u0022 in  ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational Held in Bali, Indonesia, on 5-7 September 2007 and hosted by the Corruption Eradication Commission, Indonesia, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.)","Jurisdiction of Origin: Investigative Agency":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation (Miami)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney\u0027s Office for the Southern District of Florida, with assistance from the United States Attorney\u2019s Office for the Central District of California and Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of Florida; U.S. District Court for the Central District of California","Documents":"","Sources ":"Linda M. Samuel, \u0022Repatriation Obligations under the United Nations Convention Against Corruption,\u0022 Resource Material Series No. 65, accessed at the website of the United Nations Asia and Far East Institute for the Prevention of Crime and the Treatment of Offenders (UNAFEI): http:\/\/www.unafei.or.jp\/english\/pdf\/PDF_rms\/no65\/RESOURCE-DivisionNo06.pdf; US v. $17,317,700.38 in US currency, Case No. 1:01-cv-03444 (S.D.Fla.), Complaint for Forfeiture in Rem filed August 9, 2001; Stipulation and Settlement Agreement filed April 25, 2003 and Final Order of Forfeiture filed April 29, 2002; US v. $4,362,761.02 in US currency, Case No. 1:02-cv-21779 (S.D.Fla.), Complaint for Forfeiture in Rem filed June 14, 2002 and Final Order of Forfeiture filed February 25, 2003. Professor Guillermo Jorge, \u0022The Peruvian efforts to recover proceeds from Montesinos\u0027 criminal network of corruption,\u0022 Backgrounder paper presented at the Asian Development Bank\u0027s Regional Seminar for Asia-Pacific, \u0022Making international anti-corruption standards operational: Asset Recovery and mutual legal assistance,\u0022 September 5-7, 2007 (Bali, Indonesia), at 1 and 23 and fn 56, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf. U.S. Department of Justice Press Release, \u0022Attorney General Eric Holder at the Opening Plenary of the VI Ministerial Global Forum on Fighting Corruption and Safeguarding Integrity\u0022 (Doha, Qatar), November 7, 2009, posted at http:\/\/www.justice.gov\/ag\/speeches\/2009\/ag-speech-091107.html; Acuerdo Entre el Gobierno de la Republica del Peru y El Gobierno de Los Estados Unidos de America Sobre Transferencia de Activos Decomisados, January 21, 2004, accessed at http:\/\/www.rree.gob.pe\/portal\/Tratados.nsf\/22ad71c70685eaa805256ea100718...$FILE\/B-3047%20ACUERDO%20PER%C3%9A%20-%20USA%20SOBRE%20TRANSFERENCIA%20DE%20ACTIVOS%20DECOMISADOS.pdf\n"},{"Case ID":"ARW-197","Case Title (Name of Public Official or Entity Allegedly Involved)":"Vladimiros Montesinos \/ Marco Antonio Rodriguez Huerta","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Peru","Position of Public Official(s) (yrs in office)":"De facto chief of intelligence and main advisor of former Peruvian President Alberto Fujimori (Montesinos, 1990-2000) \/ Brigadier General, Head of the Peruvian military and national Police Pension Fund (Huerta, 1995-1997)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"2009","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation; Actions Initiated by Foreign Jurisdiction ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"In furtherance of the U.S. investigation into the flow of illicit funds to the U.S. by Vladimiro Montesinos, Victor Alberto Venero Garrido, Marco Antonio Rodriguez Huerta and others, the Complaint in this case stated that  the Federal Bureau of Investigation and Immigration and Customs Enforcement worked closely with Peruvian law enforcement and prosecutorial authorities involved in the investigation of the criminal conduct in Peru.  A contingent of U.S. law enforcement agents and analysts travelled to Peru on a number of occasions.  Vast amounts of information and documents, including witness statements were exchanged between the two countries.  FBI and ICE also conducted additional witness interviews, both in Peru and in the U.S.  (Source:  U.S. v. Account No. 7630743391 et al, Case No. 1:04-cv-23073-PCH (S.D. Fla.), Complaint for Forfeiture In Rem filed on December 10, 2004.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$750,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a September 2, 2009 press release by the U.S. Department of Justice, more than $750,000 in forfeited funds from Mr. Rodriguez Huerta\u0027s embezzlement scheme was transferred by the U.S. to the Government of Peru. The press release noted that, \u0022The forfeited funds were taken from the private account of Marco Antonio Rodriguez Huerta, a former Peruvian Army General, who was also on the board of directors of the Peruvian Military and Police Pension Fund in 1996. According to court documents, by abusing those positions, Rodriguez Huerta was able to divert funds intended for use as retirement benefits for retired military and police officers into fraudulent real estate investments. These diverted funds were then transferred into the private accounts of Rodriguez Huerta and other high officials of the Peruvian government. According to court documents, Rodriguez Huerta and his associates utilized banking institutions in the United States to hide their illicit profits from the Peruvian government. For these crimes and other illegal activities, Rodriguez Huerta was arrested and convicted by Peruvian authorities in 2002, and sentenced to 15 years in prison in Peru.\u0022  In 2004, pursuant to a request by the Peruvian government, the U.S. Immigration and Customs Enforcement located assets in bank accounts in Florida.  The U.S. initiated a civil complaint in the District Court for the Southern District of Florida, which issued a Final Order of Forfeiture in 2005.  In May 2008, Peru submitted a petition for remission of forfeited property (under 28 C.F.R. section 9).  In U.S. Department of Justice approved repatriation to the Government of Peru and the Peruvian pension fund.  (Sources: U.S. v. Account No. 7630743391 et al, Case No. 1:04-cv-23073-PCH (S.D. Fla. 2004); DOJ Press Release, \u0022United States Transfers More than $750,000 in Forfeited Funds to Government of Peru,\u0022 September 2, 2009).  The U.S. Government\u0027s December 10, 2004 Complaint for Forfeiture in Rem had alleged that \u0022Rodriguez Huerta was involved in the laundering of in excess of five million dollars.\u0022 (Source: US v. The Contents of Paribas Investment Services, LLC Account, et al, Case No. 04-cv-23073-PCH (S.D. Fla.), Complaint for Forfeiture In Rem filed on December 10, 2004.)","Disposition of Criminal Case(s)":"According to a case study by Professor Guillermo Jorge, as of September 2007, Mr. Montesinos had been convicted in 13 different trials and more than 70 trials were ongoing.  (Source:  Guillermo Jorge, \u0022The Peruvian Efforts to Recover Proceeds from Montesinos\u0027s Criminal Network of Corruption,\u0022 in  ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational Held in Bali, Indonesia, on 5-7 September 2007 and hosted by the Corruption Eradication Commission, Indonesia, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.)  According to the U.S. Government\u0027s civil asset forfeiture complaint filed on December 10, 2004, \u0022Rodriguez Huerta was arrested and prosecuted in Peru for public corruption charges and illicit enrichment charges for money belonging to Peru.\u0022 (Source: US v. The Contents of BNP Paribas Investment Services, LLC Account, et al, Case No. 1:04-cv-23073-PCH (S.D. Fla.), Complaint for Forfeiture In Rem filed on December 10, 2004).","Jurisdiction of Origin: Investigative Agency":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Immigration and Customs Enforcement, Office of Investigations (Miami); Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section; U.S. Attorney for the Southern District of Florida","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of Florida","Documents":"","Sources ":"US v. The Contents of BNP Paribas Investment Services, LLC Account, et al, Case No. 04-cv-23073-PCH (S.D. Fla.), Complaint for Forfeiture In Rem filed on December 10, 2004 and Final Order of Forfeiture filed on September 22, 2005; U.S. Department of Justice Press Release, \u0022United States Transfers More Than $750,000 in Forfeited Funds to Government of Peru,\u0022 September 2, 2009, accesed at http:\/\/www.justice.gov\/opa\/pr\/2009\/September\/09-crm-909.html.\n"},{"Case ID":"ARW-198","Case Title (Name of Public Official or Entity Allegedly Involved)":"Xu Chaofan (also known as Hui Yat Fai), Xu Guojun (also known as Hui Kit Shun), Yu Zhendong","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"China","Position of Public Official(s) (yrs in office)":"Bank of China, Guangdong Province Sub-Branch, Kaiping County, Executive Managers (successive):  Xu Chaofan (1992-1998);  Yu Zhendong (1998-2000); Xu Guojun (2000-2001)","Jurisdiction of Asset Recovery":"Hong Kong SAR, China","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2001","Asset Recovery End":"2010","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"US Department of Justice press release following the Bank of China Managers\u0027 sentencing cited the \u0022substantial assistance\u0022 by the government of the People\u0027s Republic of China, in particular the Ministries of Justice and Public Security along with the Hong Kong Department of Justice and Hong Kong Police Force, in producing evidence and making witnesses available, both for testimony at trial and videotaped depositions. (Source: U.S. Department of Justice Press Release, \u0022Former Bank of China Managers and Their Wives Sentenced for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 May 6, 2009.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"Bank of China (China) Ltd. brought civil action against its former managers and their corporate vehicles and related  bank accounts, and their co-conspirators. (Source: Hong Kong Appeals Court decision 2841\/2006)  The preliminary court decisions do not mention the amount being recovered, but noted that the scheme involved misappropriation of over 1 billion renminbi.  One of the corporate entities used to funnel the embezzled funds, Yau Hip Trading, held accounts at Bank of China (HK) Limited of more than HK $120 million.  (Source: Hong Kong Appeals Court decision, 5291\/2001)  Bank of China (Hong Kong) Ltd. was also involved in the recovery efforts.  In Hong Kong, civil cases are not public, hence a copy of the final judgment is not publicly available.)","Disposition of Criminal Case(s)":"According to a U.S. Department of Justice press release, Mr. Xu Chaofan and Mr. Xu Guojun were convicted on August 29, 2008, by a federal jury in Las Vegas on charges of racketeering, money laundering, international transportation of stolen property as well as passport and visa fraud. Mr. Yu Zhendong, pleaded guilty to engaging in a racketeering enterprise on Feb. 18, 2004, and voluntarily returned to China, where he was convicted for embezzlement for his role in the bank theft.  (Source: U.S. Department of Justice Press Release, Former Bank of China Managers and Their Wives Convicted for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 September 2, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/September\/08-crm-764.html.)","Jurisdiction of Origin: Investigative Agency":"China Ministry of Justice; Public Security Bureau, Guangdong Province ","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"Intermediate People\u0027s Court of Jiangmen City, Guangdong Province (secondary source)","Jurisdiction of Asset Recovery: Investigative Agency":"Department of Justice; Hong Kong Police Force","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice","Jurisdiction of Asset Recovery: Courts Involved":"Court of Appeal (Civil); District Court (criminal - co-conspirators)","Documents":"","Sources ":"Bank of China Ltd. v. Ever Joint Properties Limited and 18 additional defendants, HCA 2841\/2006 (October 12, 2007 decision), accessed at http:\/\/legalref.judiciary.gov.hk\/lrs\/common\/search\/search_result_detail_... Bank of China v. Kwong Wa Po and Ching Fo Chu, HCA 5291\/2001 (July 18, 2005 decision)\n"},{"Case ID":"ARW-199","Case Title (Name of Public Official or Entity Allegedly Involved)":"Xu Chaofan (also known as Hui Yat Fai), Xu Guojun (also known as Hui Kit Shun), Yu Zhendong","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"China","Position of Public Official(s) (yrs in office)":"Bank of China, Guangdong Province Sub-Branch, Kaiping County, Executive Managers (successive):  Xu Chaofan (1992-1998);  Yu Zhendong (1998-2000); Xu Guojun (2000-2001)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"2009","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Criminal Restitution ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"US Department of Justice press release following the Bank of China Managers\u0027 sentencing cited the \u0022substantial assistance\u0022 by the government of the People\u2019s Republic of China, in particular the Ministries of Justice and Public Security along with the Hong Kong Department of Justice and Hong Kong Police Force, in producing evidence and making witnesses available, both for testimony at trial and videotaped depositions. (Source: U.S. Department of Justice Press Release, \u0022Former Bank of China Managers and Their Wives Sentenced for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 May 6, 2009.)  Bank of China had filed a Petition Pursuant to 18 U.S.C Section 1963 Regarding Property Subject to Forfeiture requesting that the property named in the Forfeiture Allegations be applied to restitution. (Source: U.S. v. Chao Fan Xu, et al, Case No. 2:02-cr-0674-PMP (LRL) (D. Nev.), Final Order of Forfeiture filed on December 15, 2009).  ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"$482,000,000 (Restitution ordered to be paid to Bank of China)","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"As part of their sentence, the U.S. District Court for the District of Nevada ordered that the Mr. Xu and Mr. Xu pay $482 million in restitution to the Bank of China; the defendants were ordered jointly and severally liable for payment of the restitution.  (Source: U.S. v. Xu Guojun, Case No. 2:02-cr-00674-PMP-LRL (D. Nev.), Judgment in a Criminal Case, filed on May 11, 2009; U.S. Department of Justice Press Release, \u0022Former Bank of China Managers and Their Wives Sentenced for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 May 6, 2009.)  In addition, the court ordered the criminal forfeiture of cash, watches and jewelry seized at the time of their arrest.  (U.S. currency and foreign currency totalling $166,000 [note: foreign currency, where amounts were noted was converted using exchange rate as of December 15, 2009, the date of final forfeiture order.  No value was given for the numerous seized watches and jewelry.]  In June 2009, Bank of China had filed a Petition Pursuant to 18 U.S.C Section 1963 Regarding Property Subject to Forfeiture requesting that the property named in the Forfeiture Allegations be applied to restitution.  The court granted a Joint Motion for Various Relief Relating to Assets Subject to Forfeiture, and Bank of China agreed to dimiss, without prejudice, its Petition.  The Bank was granted the forfeited cash and property as described in Attachment A of the final forfeiture order. (Source: U.S. v. Chao Fan Xu, et al, Case No. 2:02-cr-0674-PMP (LRL) (D. Nev.), Final Order of Forfeiture filed on December 15, 2009).","Disposition of Criminal Case(s)":"According to a U.S. Department of Justice press release, Mr. Xu Chaofan and Mr. Xu Guojun were convicted on August 29, 2008, by a federal jury in Las Vegas on charges of racketeering, money laundering, international transportation of stolen property as well as passport and visa fraud. Mr. Yu Zhendong, pleaded guilty to engaging in a racketeering enterprise on Feb. 18, 2004, and voluntarily returned to China, where he was convicted for embezzlement for his role in the bank theft.  (Source: U.S. Department of Justice Press Release, Former Bank of China Managers and Their Wives Convicted for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 September 2, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/September\/08-crm-764.html.)","Jurisdiction of Origin: Investigative Agency":"China Ministry of Justice and Public Security Bureau, Guangdong Province; Hong Kong Department of Justice and Hong Kong Police Force","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"Intermediate People\u0027s Court of Jiangmen City, Guangdong Province (secondary source)","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, Las Vegas Field Office; U.S. Immigration and Customs Enforcement; Support provided by Federal Bureau of Investigation, Beijing and Hong Kong offices","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the District of Nevada; Department of Justice, Cirminal Division, Organized Crime \u0026 Racketeering Section and Public Integrity Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Nevada; Supreme Court of British Columbia","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_Guojun_US_Judgment_May_11_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_DOJ_Press_Release_Conviction_Sep_2_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_DOJ_Press_Release_Sentencing_May_6_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Final_Order_Forfeiture_Dec_15_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Second_Superseding_Indictment_Jan_31_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Yu_Zhendong_Indictment_Dec_17_2002.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Yu_Zhendong_Return_Embassy_Press_Release_Apr_20_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Yu_Zhendong_Sentence_News_Guangdong_Apr_3_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Yu_Zhendong_Stipulation_Jan_22_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Yu_Zhengdong_Extradition_Lewis.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yu_Banker%20in%20Guangdong%20sentenced%2012%20years%20in%20prison_Guangdong_Times_Apr_3_2006_0.pdf","Sources ":"U.S. v. Xu Chaofan, Xu Guojun, et al Case No. 2:02-cr-00674-PMP-LRL (D. Nev.), Second Superseding Indictment filed January 31, 2006 and Judgment in a Criminal Case (Xu Guojun) filed on May 11, 2009, and Final Order of Forfeiture filed on December 15, 2009; U.S. Department of Justice Press Release, \u0022Former Bank of China Managers and Their Wives Sentenced for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 May 6, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/May\/09-crm-446.html and \u0022Former Bank of China Managers and Their Wives Convicted for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 September 2, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/September\/08-crm-764.html.\n"},{"Case ID":"ARW-200","Case Title (Name of Public Official or Entity Allegedly Involved)":"Xu Chaofan (also known as Hui Yat Fai), Xu Guojun (also known as Hui Kit Shun), Yu Zhendong","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"China","Position of Public Official(s) (yrs in office)":"Bank of China, Guangdong Province Sub-Branch, Kaiping County, Executive Managers (successive):  Xu Chaofan (1992-1998);  Yu Zhendong (1998-2000); Xu Guojun (2000-2001)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"2004","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"News Guangdong article noted that Mr. Yu \u0022is the first corrupt Chinese official to be repatriated since China ratified the United Nation\u0027s Convention Against Corruption in October, 2005.\u0022 (Source: News Guangdong, \u0022Banker in Guangdong Sentenced 12 Years in Prison,\u0022 April 3, 2006.); U.S. Department of Justice press release following the Bank of China Managers\u0027 convictions cited the \u0022substantial assistance\u0022 by the government of the People\u2019s Republic of China, in particular the Ministries of Justice and Public Security along with the Hong Kong Department of Justice and Hong Kong Police Force, in producing evidence and making witnesses available, both for testimony at trial and videotaped depositions. (Source: U.S. Department of Justice Press Release, \u0022Former Bank of China Managers and Their Wives Convicted for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 September 2, 2008.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$3,750,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"Yu Zhendong, one of the defendants in the criminal case against the three Bank of China managers, pleaded guilty and agreed to be extradited to China.  The agreement came after extensive negotiations between China and the U.S. which resulted in agreement that Mr. Yu would not face execution upon his return to China.  Mr. Yu also agreed to forfeiture of money embezzled from the Bank of China, including approximately $3,750,000 in U.S. currency that had already been seized and returned to China.  (Sources: U.S. v. Zhen Dong Yu, Case No. 2:02-cr-00673-RLH-RJJ (D.C. Nev.), Indictment filed on December 17, 2002 and Stipulation to Continue Trial Date, filed January 22, 2004; U.S. Embassy Beijing Press Release, \u0022Chinese National Sentenced on Racketeering Charges Returned to China After Embezzling Approximately $485 Million from the Bank of China,\u0022 April, 20, 2004). According to the News Guangdong, upon his return to China, Mr. Yu was tried by the Intermediate People\u0027s Court of Jiangmen City, Guangdong Province and sentenced to 12 years\u0027 imprisonment and confiscation of 1 million yuan ($125,000) on graft and embezzlement of public funds. The article noted that Mr. Yu \u0022is the first corrupt Chinese official to be repatriated since China ratified the United Nation\u0027s Convention Against Corruption in October, 2005.\u0022 (Source: News Guangdong, \u0022Banker in Guangdong Sentenced 12 Years in Prison,\u0022 April 3, 2006.)","Disposition of Criminal Case(s)":"According to a U.S. Department of Justice press release, Mr. Xu Chaofan and Mr. Xu Guojun were convicted on August 29, 2008, by a federal jury in Las Vegas on charges of racketeering, money laundering, international transportation of stolen property as well as passport and visa fraud. Mr. Yu Zhendong, pleaded guilty to engaging in a racketeering enterprise on Feb. 18, 2004, and voluntarily returned to China, where he was convicted for embezzlement for his role in the bank theft.  (Source: U.S. Department of Justice Press Release, Former Bank of China Managers and Their Wives Convicted for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 September 2, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/September\/08-crm-764.html.)","Jurisdiction of Origin: Investigative Agency":"China Ministry of Justice; Public Security Bureau, Guangdong Province; Hong Kong Department of Justice and Hong Kong Police Force","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"Intermediate People\u0027s Court of Jiangmen City, Guangdong Province (secondary source)","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, Las Vegas Field Office; U.S. Immigration and Customs Enforcement; Support provided by Federal Bureau of Investigation, Beijing and Hong Kong offices","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the District of Nevada; Department of Justice, Cirminal Division, Organized Crime \u0026 Racketeering Section and Public Integrity Section; Criminal Division, Office of International Affairs; U.S. Attorney for the Central District of California","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Nevada; Supreme Court of British Columbia","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_DOJ_Press_Release_Sentencing_May_6_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Yu_Zhendong_Indictment_Dec_17_2002.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Yu_Zhendong_Return_Embassy_Press_Release_Apr_20_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Yu_Zhendong_Sentence_News_Guangdong_Apr_3_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Yu_Zhendong_Stipulation_Jan_22_2004.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yu_Banker%20in%20Guangdong%20sentenced%2012%20years%20in%20prison_Guangdong_Times_Apr_3_2006.pdf","Sources ":"U.S. v. Zhen Dong Yu, Case No. 2:02-cr-00673-RLH-RJJ (D.C. Nev.), Indictment filed on December 17, 2002 and Stipulation to Continue Trial Date, filed January 22, 2004; U.S. Department of Justice Press Release, \u0022Former Bank of China Managers and Their Wives Convicted for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 September 2, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/September\/08-crm-764.html. U.S. Embassy Beijing Press Release, \u0022Chinese National Sentenced on Racketeering Charges Returned to China After Embezzling Approximately $485 Million from the Bank of China,\u0022 April, 20, 2004; News Guangdong, \u0022Banker in Guangdong Sentenced 12 Years in Prison,\u0022 April 3, 2006, accessed at http:\/\/www.newsgd.com\/citiesandtowns\/jiangmen\/news\/200604030074.htm.) Margaret K. Lewis, \u0022Mutual Legal Assistance and Extradition: Human Rights Implications,\u0022 accessed at http:\/\/papers.ssrn.com\/sol3\/papers.cfm?abstract_id=1432469.\n"},{"Case ID":"ARW-201","Case Title (Name of Public Official or Entity Allegedly Involved)":"Zine El Abidine Ben Ali \/ Belhassen Trabelsi (Canada)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Tunisia","Position of Public Official(s) (yrs in office)":"President (Ben Ali, 1987-2011); Son-in-law of President (Trabelsi)","Jurisdiction of Asset Recovery":"Canada","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tFor detailed background on the freeze of assets related to Mr. Ben Ali and associated individuals, see \u0022Freezing Assets of Corrupt Foreign Officials (Tunisia and Egypt) Regulations, SOR\/2011-78, at http:\/\/laws-lois.justice.gc.ca\/eng\/regulations\/sor-2011-78\/fulltext.html).\n\n\t\u00a0\n\n\tOn March 3, 2011, Foreign Affairs Minister Lawrence Cannon and Minister of Justice Rob Nicholson \u0022introduced legislation that would make it easier for the country to unilaterally freeze the assets of corrupt foreign leaders. The Freezing Assets of Corrupt Regimes Act comes amid pressure on the government to freeze assets belonging to ousted Tunisian leader Zine El Abidine Ben Ali and his family, some of whom have taken refuge in Canada.\u0022 (Source: \u00a0Joe Palazzolo, \u0022Canadian Gov\u2019t Introduces Asset Freeze Bill,\u0022 Wall Street Journal Corruption Currents blog, March 3, 2011. \u00a0Official text of the Bill C-61 can be accessed at website of the Parliament of Canada. \u00a0Please see source column for link.) \u00a0\u00a0\n\n\t\u00a0\n\n\tAccording to the June 27, 2014 decision by the Canadian Federal Court in Montreal, \u0022Zohra Djilani and Belhassen Trabelsi, and their four minor children, are subject to the Freezing Assets of Corrupt Foreign Officials (Tunisia and Egypt) Regulations, SOR\/2011 (Regulations), which were adopted by the Minister of Foreign Affairs and International Trade (Minister) following the events of the Arab Spring. This is an application for judicial review of the Minister\u2019s decision dated June 26, 2013, rejecting their application for a certificate filed pursuant to section 15 of the Freezing Assets of Corrupt Foreign Officials Act, SC 2001, c 10 (Act). By that application, the applicants were seeking to exclude the amount of $109,680 from the application of the Regulations to then transfer it into their lawyers\u2019 trust accounts.\u0022 \u00a0(Source: Trabelsi Et al v. MSPPC, Et al, 2014 FC 631, full text available at http:\/\/decisions.fct-cf.gc.ca\/fc-cf\/decisions\/en\/item\/72380\/index.do?r=A...) \u00a0 According to the Judgment, \u0022In that new application, the applicants explained that the amount must be used to pay for certain living expenses (including counsel fees), but also luxury products and services such as a chauffeur for the family, a non-subsidized private English school for the couple\u2019s children and their apartment, the monthly rent of which is $5,000.\u0022 \u00a0for period of six months beginning January 2013. The Court held that the Minister\u0027s decision was reasonable and rejected the application. \u00a0Mr. Trabelsi, wife and two children are seeking asylum in Canada. (Source: Belhassen Trabelsi Et al v. MSPPC, Et al, Case number IMM\u00ad3644\u00ad12, Docket as of February 5, 2015)\n\n\t\u00a0\n\n\tAccording to media reports, a Canadian Civil Society Organization has alleged that former president Ben Ali\u0027s son-in-law Sakhr El Makeri (married to daughter Nesrine) purchased, in 2008, a CAD 2.8 million mansion in Westmount section of Montreal. \u00a0Abdelijelil Ouanes, president of the Canadian Tunisian Chamber of Commerce in Montreal was quoted as saying that Ben Ali family members also held bank accounts in Canada. \u00a0(Source: Andrew Chung, \u0022Montreal lawyer launches effort to freeze Ben Ali Assets,\u0022 Thestar.com (Montreal), January 24, 2011). \u00a0According to a May 25, 2012 article in Foreign Policy, a $2.5 million mansion and $100,000 bank account belonging to the Ben Ali family have been \u0022seized\u0022 in Canada. \u00a0(Source: Fadil Aliriza, \u0022The godfathers of Tunis,\u0022 Foreign Policy, May 25, 2012.)","Disposition of Criminal Case(s)":"According to a January 26, 2011 media release by INTERPOL, Mr. Ben Ali\u0027s arrest was sought by Tunisia on charges of alleged property theft and illegal transfer of foreign currency. (Source: INTERPOL media release, \u0022Tunisia seeks ousted President and family via INTERPOL,\u0022 January 26, 2011, accessed at http:\/\/www.interpol.int\/public\/ICPO\/PressReleases\/PR2011\/PR007.asp.) According to secondary sources, Mr. Ben Ali was convicted in absentia in June 2011 on theft and unlawful possesion of cash and jewelry; in July 2011, he was convicted of property related charges. (Source: BBC News, \u0022Tunisia\u0027s Ben Ali guilty on drugs and gun charges,\u0022 July 4, 2011 and \u0022Tunisia\u0027s Ben Ali guilty of corrupt property deals,\u0022 July 29, 2011) and in June 2012, he was sentenced by a Tunisian military court to life imprisonment for his complicity in the murder and attempted murder of demonstrators; Human Rights Watch noted that Mr. Ben Ali has been tried and convicted in absentia and if he returned to Tunisia, he would be entitied to a new trial. (Source: Clive Baldwin, \u0022After Ben-Ali\u0027s Conviction: The State of Tunisian Justice,\u0022 Human Rights Watch, June 16, 2012.)","Jurisdiction of Origin: Investigative Agency":"Commission for the Investigation of Corruption and Embezzlement; Attorney Enrico Monfrini (civil asset recovery)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Asset Recovery: Courts Involved":"Federal Court (Montreal)","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Montreal_Assets_Thestar_Jan_24_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Summary_Law_Freeze_Assets_Corrupt_Regimes_Mar_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Text_Bill_C-61_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_INTERPOL_Alert_Jan_26_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Trabelsi_Asylum_CBC_News_Jan_31_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_Canada_Freeze_Assets_Corrupt_Foreign_Officals_Act.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Montreal_Assets_Thestar_Jan_24_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Summary_Law_Freeze_Assets_Corrupt_Regimes_Mar_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Text_Bill_C-61_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_INTERPOL_Alert_Jan_26_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Trabelsi_Asylum_CBC_News_Jan_31_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_Canada_Trabelsi_Fed_Ct_Judgment_Jun_27_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Montreal_Assets_Thestar_Jan_24_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Summary_Law_Freeze_Assets_Corrupt_Regimes_Mar_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Text_Bill_C-61_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_INTERPOL_Alert_Jan_26_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Trabelsi_Asylum_CBC_News_Jan_31_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_Trabelsi_Canada_Fed_Ct_immigration-docket_Feb_5_2015.pdf","Sources ":"\n\t\u0022Freezing Assets of Corrupt Foreign Officials (Tunisia and Egypt) Regulations, SOR\/2011-78, at http:\/\/laws-lois.justice.gc.ca\/eng\/regulations\/sor-2011-78\/fulltext.html;\u00a0\n\n\t\u00a0\n\n\tCanada News Centre, \u0022Harper Government Introduces Freezing Assets of Corrupt Regimes Act,\u0022 March 3, 2011, accessed at http:\/\/news.gc.ca\/web\/article-eng.do?m=\/index\u0026nid=593199; Text of Bill C-61, \u0022An Act to provide for the taking of restrictive measures in respect of the property of officials and former officials of foreign states and of their family members\u0022 and related documents can be accessed at the official website of the Parliament of Canada, LEGISinfo, at http:\/\/www2.parl.gc.ca\/Sites\/LOP\/LEGISINFO\/index.asp?Language=E\u0026Chamber=...\n\n\t\u00a0\n\n\tTrabelsi Et al v. MSPPC, Et al, 2014 FC 631, full text available at http:\/\/decisions.fct-cf.gc.ca\/fc-cf\/decisions\/en\/item\/72380\/index.do?r=A...); Belhassen Trabelsi Et al v. MSPPC, Et al, Case number IMM\u00ad3644\u00ad12, Docket as of February 5, 2015, accessible at http:\/\/cas-ncr-nter03.cas-satj.gc.ca\/portal\/page\/portal\/fc_cf_en\/Court_I...\n\n\t\u00a0\n\n\tCBC News, \u0022Canada keen to extradite Tunisian billionaire,\u0022 January 28, 2011; Montreal Gazette, \u0022Trabelsi loses bid to stay in Canada,\u0022 May 8, 2012;\u00a0\n\n\t\u00a0\n\n\tFadil Aliriza, \u0022The godfathers of Tunis,\u0022 Foreign Policy, May 25, 2012 "},{"Case ID":"ARW-202","Case Title (Name of Public Official or Entity Allegedly Involved)":"Zine El Abidine Ben Ali (European Union)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Tunisia","Position of Public Official(s) (yrs in office)":"President (1987-2011)","Jurisdiction of Asset Recovery":"European Union","Jurisdiction of Asset Description":"Undertaking Recovery Effort","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tThe Council Regulation and Implementing Regulations were subsequently amended, including in early 2015. See Council Implementing Regulation (EU) No. 2015\/147 (OJL 26, January 31, 2015, at http:\/\/eur-lex.europa.eu\/legal-content\/EN\/TXT\/?uri=OJ:JOL_2015_026_R_0002.\n\n\t\u00a0\n\n\tAs summarized in an article by Edwards Wildman Palmer attorneys, \u0022On 28 May 2013, the EU General Court (\u201cthe Court\u201d), attached to the European Court of Justice, gave three judgments in Cases T-187\/11 Trabelsi, T-188\/11 Chiboub and T-200\/11 Al Matri, in which it annulled the sanctions listing of three relatives of former President Ben Ali of Tunisia.\n\n\t\u00a0\n\n\tMr Al Matri and Mr Chiboub are the sons-in-law of former President Ben Ali and Mr Mohamed Trabelsi is the nephew of his wife. The three individuals and other persons connected to Mr Trabelsi brought proceedings contesting the freezing of their assets pursuant to Council Decisions 2011\/72\/CFSP and 2011\/79\/CFSP.\n\n\t\u00a0\n\n\tThe Court reached similar conclusions in each of the three cases annulling the sanctions. In reaching a decision, the Court noted that Article 1(1) of 2011\/72\/CFSP required that only persons \u201cresponsible for misappropriation of Tunisian State funds\u201d and those associated with them may be subject to an asset freeze, while Decision 2011\/79\/CFSP froze the assets of the applicants on the basis that they were subject to \u201cjudicial investigation by the Tunisian authorities in respect of the acquisition of movable and immovable property, the opening of bank accounts and the holding of financial assets in several countries as part of money laundering operations.\u201d\n\n\t\u00a0\n\n\tThe Court held that the Council had not established that under Tunisian law, \u201cmisappropriation of public funds\u201d encompassed \u201cmoney laundering\u201d (offences for which the Tunisian authorities were stated to be investigating the applicants). The Court held that the Council had not established that the investigations had been launched in relation to the laundering of public rather than private funds. The Court further held that the fact that the applicants were related to Ben Ali was not sufficient to imply that the money laundering investigations related to the misappropriation of state funds, since there was no such presumption in any of the legislation.\n\n\t\u00a0\n\n\tIn all three cases, the Court annulled Decision 2011\/79\/CFSP insofar as it related to them. The funds will not be immediately released because the European Council has two months to challenge the decision. If this does not happen, the freeze will end.\u0022 (Source: \u00a0Antonio Suarez-Martinez and Nicole Grow, Edwards Wildman Palmer LLP, \u0022Tunisian asset recovery efforts: one step forward and two steps back?,\u0022 June 11, 2013.) \u00a0The applications, judgments and orders in these and other related cases are listed in the source field and may be accessed at European Union Case-Law website at http:\/\/europa.eu\/eu-law\/case-law\/index_en.htm.\n\n\t\u00a0\n\n\tAccording to the statement issued by the Tunisian-European Union Task Force at the conclusion of its first meetings on September 28-29, 2011 in Tunis, the group stressed the importance of recovering stolen assets, including overcoming barriers and challenges related to it, as part of their joint work. \u00a0(Source: Meeting of the Tunisia - European Union Task Force, September 28-29, 2011 in Tunis, Co-chairs Conclusions.) \u00a0On February 7, 2011, the Council of the European Union had announced that they had \u0022adopted a decision and a regulation imposing the freezing of assets owned or controlled by persons deemed to be responsible for the misappropriation of state funds in Tunisia and persons associated with them.\u0022 The decision and regulation, \u0022which target a list of 48 persons, including former president Zine El Abidine Ben Ali and his wife, were published on 5 February 2011 in the EU Official Journal. The decision amends and updates decision 2011\/72\/CFSP, adopted on 31 January.\u0022 (Source: Council of The European Union Press Release, \u0022Tunisia: Council imposes assets freeze,\u0022 February 7, 2011. Council Regulation (EU) No 101\/2011- concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Tunisia.) \u00a0The Council Regulation and Implementing Regulations were subsequently amended, including in early 2015. See Council Implementing Regulation (EU) No. 2015\/147 (OJL 26, January 31, 2015, at http:\/\/eur-lex.europa.eu\/legal-content\/EN\/TXT\/?uri=OJ:JOL_2015_026_R_0002.","Disposition of Criminal Case(s)":"According to a January 26, 2011 media release by INTERPOL, Mr. Ben Ali\u0027s arrest was sought by Tunisia on charges of alleged property theft and illegal transfer of foreign currency. (Source: INTERPOL media release, \u0022Tunisia seeks ousted President and family via INTERPOL,\u0022 January 26, 2011, accessed at http:\/\/www.interpol.int\/public\/ICPO\/PressReleases\/PR2011\/PR007.asp.) According to secondary sources, Mr. Ben Ali was convicted in absentia in June 2011 on theft and unlawful possesion of cash and jewelry; in July 2011, he was convicted of property related charges. (Source: BBC News, \u0022Tunisia\u0027s Ben Ali guilty on drugs and gun charges,\u0022 July 4, 2011 and \u0022Tunisia\u0027s Ben Ali guilty of corrupt property deals,\u0022 July 29, 2011) and in June 2012, he was sentenced by a Tunisian military court to life imprisonment for his complicity in the murder and attempted murder of demonstrators; Human Rights Watch noted that Mr. Ben Ali has been tried and convicted in absentia and if he returned to Tunisia, he would be entitied to a new trial. (Source: Clive Baldwin, \u0022After Ben-Ali\u0027s Conviction: The State of Tunisian Justice,\u0022 Human Rights Watch, June 16, 2012.)","Jurisdiction of Origin: Investigative Agency":"Commission for the Investigation of Corruption and Embezzlement; Attorney Enrico Monfrini (asset recovery)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_European_Union_Council_Decision_Feb_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_European_Union_Council_PR_Feb_7_2011.pdf Ben_Ali_Tunisia_EU_Taskforce_Meeting_Statement_Sep_29_2011 Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_EU_Edwards_Wildman_Article_EU_General_Court_Judgments_Jun_11_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_European_Union_Council_Decision_Feb_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_European_Union_Council_PR_Feb_7_2011.pdf Ben_Ali_Tunisia_EU_Taskforce_Meeting_Statement_Sep_29_2011 Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_EU_General_Court_Judgment_Cases_Trabelsi_Choboub_Al_Matri_May_28_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_European_Union_Council_Decision_Feb_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_European_Union_Council_PR_Feb_7_2011.pdf Ben_Ali_Tunisia_EU_Taskforce_Meeting_Statement_Sep_29_2011 Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_EU_Council_Impl_Reg_2015_147_Jan_30_2015.pdf","Sources ":"\n\tCouncil Implementing Regulation (EU) No. 2015\/147 (OJL 26, January 31, 2015, at http:\/\/eur-lex.europa.eu\/legal-content\/EN\/TXT\/?uri=OJ:JOL_2015_026_R_0002;\n\n\t\u00a0\n\n\tJudgments, EU General Court, Case T-187\/11 Trabelsi, Case T-188\/11 Chiboub and T-200\/11 Al Matri at http:\/\/eur-lex.europa.eu\/LexUriServ\/LexUriServ.do?uri=OJ:C:2013:225:0068... \u00a0\n\n\t\u00a0\n\n\tTrabelsi and Others v. Council (Case T-187\/11); Chiboub v. Council (Case T-188\/11); El-Matri v. Council (Case T-200\/11); Ben Ali v. Council (Case T-301-11); Ben Ali v. Council (Case T-133\/12); CW v. Council (Case T-162\/12); Al Matri v. Council (Case T-545\/13); Ben Ali v. Council (Case T-200\/14); Mabrouk v. Council (Case T-218\/14) - Orders, Judgments and Applications accessible at European Union Case-Law, http:\/\/europa.eu\/eu-law\/case-law\/index_en.htm;\n\n\t\u00a0\n\n\tAntonio Suarez-Martinez and Nicole Grow, Edwards Wildman Palmer LLP, \u0022Tunisian asset recovery efforts: one step forward and two steps back?,\u0022 June 11, 2013, accessed at http:\/\/www.lexology.com\/library\/detail.aspx?g=796ed555-372b-4c78-ac1a-0b...\n\n\t\u00a0\n\n\tMeeting of the Tunisia - European Union Task Force, September 28-29, 2011 in Tunis, Co-chairs Conclusions, accessed at http:\/\/www.eeas.europa.eu\/tunisia\/docs\/20110929_taskforce_en.pdf; Council of The European Union Press Release, \u0022Tunisia: Council imposes assets freeze,\u0022 February 7, 2011, at http:\/\/www.consilium.europa.eu\/uedocs\/cms_data\/docs\/pressdata\/EN\/foraff\/... \u00a0Text of Decision at http:\/\/eur-lex.europa.eu\/LexUriServ\/LexUriServ.do?uri=OJ:L:2011:031:0040... Text of Regulation at http:\/\/eur-lex.europa.eu\/LexUriServ\/LexUriServ.do?uri=OJ:L:2011:031:0001... INTERPOL Alert, \u0022Tunisia seeks ousted President and family via INTERPOL,\u0022 January 26, 2011, accessed at http:\/\/www.interpol.int\/public\/ICPO\/PressReleases\/PR2011\/PR007.asp; BBC News, \u0022Tunisia\u0027s Ben Ali guilty on drugs and gun charges,\u0022 July 4, 2011, accessed at http:\/\/www.bbc.co.uk\/news\/world-africa-14014757 and \u0022Tunisia\u0027s Ben Ali guilty of corrupt property deals,\u0022 July 29, 2011, accessed at http:\/\/www.bbc.co.uk\/news\/world-africa-14340863.\n"},{"Case ID":"ARW-203","Case Title (Name of Public Official or Entity Allegedly Involved)":"Zine El Abidine Ben Ali (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Tunisia","Position of Public Official(s) (yrs in office)":"President (1987-2011)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual legal assistance","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"$66,149,000","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tAccording to Swissinfo.ch. in April 2014, the Swiss Federal Prosecutor\u0027s Office announced that it would unfreeze US $40 million being held in Swiss banks: \u00a0\u201cThe decision is the result of good collaboration with the Tunisian authorities,\u201d Federal Prosecutor Michael Lauber told Swiss public radio, SRF, on Friday.\n\n\t\u00a0\n\n\tThe Tunisian authorities were able to provide enough evidence to allow the monies, which were linked to Tunisia\u2019s former autocrat Zine el-Abidine Ben Ali, to be returned prematurely.\n\n\t\u00a0\n\n\tHowever, the decision is still not definitive, as an appeal could be lodged at the Federal Criminal Court.\n\n\t\u00a0\n\n\tThe cabinet blocked around CHF60 million ($68.5 million) in assets from Tunisia after the fall of Ben Ali in January 2011.\n\n\t\u00a0\n\n\tThe Federal Prosecutor\u2019s Office hopes that the rest of the funds can also be returned soon. \u201cThere are other millions that are blocked in Switzerland. We are trying to go forward there as well,\u201d Lauber stated.\u0022 (Source: Swissinfo.ch, \u0022Swiss unfreeze $40 million of Tunisian assets,\u0022 April 11, 2014.)\n\n\t\u00a0\n\n\tAccording to a media release by the Swiss Federal Department of Foreign Affairs of January 19, 2011, the Swiss government announced that it had frozen assets connected to Mr. Ben Ali. \u00a0The ordinances which originally applied for three years was further extended in 2014 for three additional years. \u00a0(Source: Swiss Federal Department of Foreign Affairs Media Release, \u0022Federal Council orders freeze of any assets held by former Tunisian President Ben Ali in Switzerland,\u0022 January 19, 2011; Swiss Federal Department of Foreign Affairs, \u0022Freezing of Assets: Tunisia\u0022, last updated April 28, 2016.) \u00a0 The Swiss government subsequently announced that it had received a request for assistance from Tunisian authorities, and the January 19th Special Ordinance was amended on January 28th and February 4 with an updated list of individuals whose assets are to be frozen. \u00a0(Source: \u00a0Swiss Ordinance, Verordnung uber Massnahmen gegen gewisse Personen aus Tunesien, Anderung, February 4, 2011 (amending ordinances of January 28, 2011 and January 19, 2011.) \u00a0 According to a September 27, 2011 statement by the Swiss Federal Department of Foreign Affairs, \u0022Soon after the overthrow of Ben Ali, Switzerland became the first country in the world to freeze the assets of persons associated with the regime. \u00a0These total some 60 million Swiss francs. \u0027Returning illicit funds is our first priority, and is a core element in the support that Switzerland would like to provide for Tunisia\u0027s transformation process,\u0027 said Federal President Calmy-Rey before the conference [of the EU-Tunisia Task Force].\u0022 (Source: Swiss Federal Department of Foreign Affairs, \u0022Federal President Calmy-Rey at EU-Tunisia Task Force meeting in Tunis,\u0022 September 27, 2011.)\n\n\t\u00a0","Disposition of Criminal Case(s)":"According to a January 26, 2011 media release by INTERPOL, Mr. Ben Ali\u0027s arrest was sought by Tunisia on charges of alleged property theft and illegal transfer of foreign currency. (Source: INTERPOL media release, \u0022Tunisia seeks ousted President and family via INTERPOL,\u0022 January 26, 2011, accessed at http:\/\/www.interpol.int\/public\/ICPO\/PressReleases\/PR2011\/PR007.asp.) According to secondary sources, Mr. Ben Ali was convicted in absentia in June 2011 on theft and unlawful possesion of cash and jewelry; in July 2011, he was convicted of property related charges. (Source: BBC News, \u0022Tunisia\u0027s Ben Ali guilty on drugs and gun charges,\u0022 July 4, 2011 and \u0022Tunisia\u0027s Ben Ali guilty of corrupt property deals,\u0022 July 29, 2011) and in June 2012, he was sentenced by a Tunisian military court to life imprisonment for his complicity in the murder and attempted murder of demonstrators; Human Rights Watch noted that Mr. Ben Ali has been tried and convicted in absentia and if he returned to Tunisia, he would be entitied to a new trial. (Source: Clive Baldwin, \u0022After Ben-Ali\u0027s Conviction: The State of Tunisian Justice,\u0022 Human Rights Watch, June 16, 2012.)","Jurisdiction of Origin: Investigative Agency":"Commission for the Investigation of Corruption and Embezzlement; Attorney Enrico Monfrini (asset recovery)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Prosecutors Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Federal Prosecutor\u0027s Office","Jurisdiction of Asset Recovery: Courts Involved":"Geneva","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_INTERPOL_Alert_Jan_26_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Asset_Freeze_Swissinfo_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Fed_Council_Press_Release_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Change_Feb_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Change_Jan_28_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/EU_Tunisia_Task_Force_Meeting_Swiss_Statement_Sep_27_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Assets_Frozen_Swissinfo_May_2_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_Switzerland_Time_Needed_Swissinfo_May_2_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_INTERPOL_Alert_Jan_26_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Asset_Freeze_Swissinfo_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Fed_Council_Press_Release_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Change_Feb_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Change_Jan_28_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/EU_Tunisia_Task_Force_Meeting_Swiss_Statement_Sep_27_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Assets_Frozen_Swissinfo_May_2_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_Switzerland_Asset_Freeze_Extended_Swiss_Admin_News_Dec_18_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_INTERPOL_Alert_Jan_26_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Asset_Freeze_Swissinfo_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Fed_Council_Press_Release_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Change_Feb_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Change_Jan_28_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/EU_Tunisia_Task_Force_Meeting_Swiss_Statement_Sep_27_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Assets_Frozen_Swissinfo_May_2_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_Switzerland_Funds%20freed_Swiss%20unfreeze%20%2440%20million%20of%20Tunisian%20assets_Swissinfo_April_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_INTERPOL_Alert_Jan_26_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Asset_Freeze_Swissinfo_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Fed_Council_Press_Release_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Change_Feb_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Change_Jan_28_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/EU_Tunisia_Task_Force_Meeting_Swiss_Statement_Sep_27_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Assets_Frozen_Swissinfo_May_2_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Tunisia_Swiss%20OAG_Statement_Oct12%202015.pdf","Sources ":"\n\tSwiss Federal Department of Foreign Affairs, \u0022Freezing of Assets: Tunisia,\u0022 last updated April 28, 2016, at https:\/\/www.fdfa.admin.ch\/eda\/en\/fdfa\/foreign-policy\/financial-centre-ec... \u00a0Media Release, \u0022Federal Council orders freeze of any assets held by former Tunisian President Ben Ali in Switzerland,\u0022 January 19, 2011, accessed at http:\/\/www.eda.admin.ch\/eda\/en\/home\/recent\/media\/single.html?id=37285;\n\n\tSwiss Ordinance, Verordnung uber Massnahmen gegen gewisse Personen aus Tunesien, Anderung, February 4, 2011 (amending ordinances of January 28, 2011 and January 19, 2011 which are also included here, all accessed at http:\/\/www.admin.ch\/dokumentation\/gesetz\/00068\/index.html?lang=de\u0026unters.... See also Luca Beti, \u0022Freezing of presidential accounts welcomed,\u0022 Swissinfo.ch, January, 19, 2011 and Eveline Kobler, \u0022Time needed before Ben-Ali assets returned,\u0022\n\n\tSwissinfo.ch, May 2, 2011, accessed at http:\/\/www.swissinfo.ch\/eng\/specials\/the_arab_spring\/Time_needed_before_... INTERPOL Alert, \u0022Tunisia seeks ousted President and family via INTERPOL,\u0022 January 26, 2011, accessed at http:\/\/www.interpol.int\/public\/ICPO\/PressReleases\/PR2011\/PR007.asp; Swiss Federal Department of Foreign Affairs, \u0022Federal President Calmy-Rey at EU-Tunisia Task Force meeting in Tunis,\u0022 September 27, 2011, accessed at http:\/\/www.eda.admin.ch\/eda\/en\/home\/recent\/media\/single.html?id=41409; SwissInfo.ch, \u0022Tunisia launches new bid for Ben Ali assets,\u0022 October 5, 2011, accessed at http:\/\/www.swissinfo.ch\/eng\/politics\/Tunisia_launches_new_bid_for_Ben_Al... BBC News, \u0022Tunisia\u0027s Ben Ali guilty on drugs and gun charges,\u0022 July 4, 2011, accessed at http:\/\/www.bbc.co.uk\/news\/world-africa-14014757 and \u0022Tunisia\u0027s Ben Ali guilty of corrupt property deals,\u0022 July 29, 2011, accessed at http:\/\/www.bbc.co.uk\/news\/world-africa-14340863; Swiss Federal Administration, \u0022The Federal Council extends the freezing of assets of several individuals from Tunisia and Egypt,\u0022 December 18, 2013, at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=51477;\n\n\tSwissinfo.ch, \u0022Swiss unfreeze $40 million of Tunisian assets,\u0022 April 11, 2014 at http:\/\/www.swissinfo.ch\/eng\/politics\/Swiss_unfreeze_$40_million_of_Tunisian_assets.html?cid=38369152;\n\n\t\u00a0\n\n\tSee also, Swiss Office of the Attorney General press statement, \u0022St\u00e4rkung der Geldw\u00e4schereiverfahren,\u0022 October 12, 2015, at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=59054\n"},{"Case ID":"ARW-204","Case Title (Name of Public Official or Entity Allegedly Involved)":"Zine El Abidine Ben Ali (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Tunisia","Position of Public Official(s) (yrs in office)":"President (1987-2011)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"European Union sanctions ","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the United Kingdom\u0027s Parliamentary website (http:\/\/services.parliament.uk\/hansard\/Lords\/bydate\/20111003\/writtenanswe...), On October 3, 2011, the following written response was given to \u0022Question Asked by Lord Hylton: To ask Her Majesty\u2019s Government whether they, or international institutions of which they are a member, are holding frozen Tunisian funds; if so, whether they are taking action to release them in order to aid the Tunisian economy.[HL11926] The Minister of State, Foreign and Commonwealth Office (Lord Howell of Guildford): An EU-wide asset freeze was imposed against 48 Tunisian individuals on 4 February. The Treasury subsequently introduced criminal penalties for breaches of the asset freeze and notified the financial sector of the measures. The Treasury also added the list of Tunisia targets to its consolidated list of financial sanctions which is checked by the sector against client and customer databases. A small amount of assets have been frozen within the UK. We cannot disclose further details at this stage but are working with the Tunisian Government to ensure they understand the legal processes involved in releasing and repatriating these assets. Assets have been frozen in other jurisdictions across Europe.\u0022","Disposition of Criminal Case(s)":"According to a January 26, 2011 media release by INTERPOL, Mr. Ben Ali\u0027s arrest was sought by Tunisia on charges of alleged property theft and illegal transfer of foreign currency. (Source: INTERPOL media release, \u0022Tunisia seeks ousted President and family via INTERPOL,\u0022 January 26, 2011, accessed at http:\/\/www.interpol.int\/public\/ICPO\/PressReleases\/PR2011\/PR007.asp.) According to secondary sources, Mr. Ben Ali was convicted in absentia in June 2011 on theft and unlawful possesion of cash and jewelry; in July 2011, he was convicted of property related charges. (Source: BBC News, \u0022Tunisia\u0027s Ben Ali guilty on drugs and gun charges,\u0022 July 4, 2011 and \u0022Tunisia\u0027s Ben Ali guilty of corrupt property deals,\u0022 July 29, 2011) and in June 2012, he was sentenced by a Tunisian military court to life imprisonment for his complicity in the murder and attempted murder of demonstrators; Human Rights Watch noted that Mr. Ben Ali has been tried and convicted in absentia and if he returned to Tunisia, he would be entitied to a new trial. (Source: Clive Baldwin, \u0022After Ben-Ali\u0027s Conviction: The State of Tunisian Justice,\u0022 Human Rights Watch, June 16, 2012.)","Jurisdiction of Origin: Investigative Agency":"Commission for the Investigation of Corruption and Embezzlement; Attorney Enrico Monfrini (civil asset recovery)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Treasury","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"http:\/\/Ben_Ali_UK_Parliament_Written_Answer_Tunisia_Oct_3_2011 Ben_Ali_Sentence_BBC_News_Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_UK_Parliament_Written_Answers_Oct_3_2011.pdf","Sources ":"UK Parliament, Written Answer 3 October 2011 on Tunisia, submitted by The Minister of State, Foreign and Commonwealth Office, accessed at http:\/\/www.publications.parliament.uk\/pa\/ld201011\/ldhansrd\/text\/111003w0...\n"},{"Case ID":"ARW-99","Case Title (Name of Public Official or Entity Allegedly Involved)":"Juthamas Siriwan (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Thailand","Position of Public Official(s) (yrs in office)":"Governor of Tourism (2002-2006)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"\n\tAs of May 22, 2016, the US criminal case was ongoing. \u00a0( U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Court Docket Report as of May 22, 2016.)\n\n\t\u00a0\n\n\tIn January 2009, United States authorities filed a criminal indictment against Ms. Siriwan and her daughter on charges of money laundering and transporting funds to support unlawful activity. The indictment included criminal forfeiture allegations against bank accounts located in Isle of Jersey (HSBC Bank International Limited, Acct #11108670 in amount of $411,434.80; Singapore (Citibank Bank, Acct #0259766-001 in the amount of $543,456.79 and Standard Chartered Bank, Acct #25-0-852573-6); United Kingdom (HSBC Bank PLC, Acct #22751518). \u00a0The indictment also noted that under Section 152 of Thailand\u0027s Penal Code, it is unlawful for any government official, having the duty of managing or looking after any activity, to take the interest for the benefit of herself or another person concerning such activity. (Source: U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Indictment filed January 28, 2009.) \u00a0Ms. Siriwan has filed a Motion to Dismiss the Indictment in January 2012. (Source: \u00a0U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Court Docket Report, entry for January 30, 2012.) \u00a0 See also \u0022Disposition of criminal case\u0022 for update on the case in Thailand.","Disposition of Criminal Case(s)":"According to the Joint Status Report and Indictment filed by Thai Special Prosecutor (Exh A in Thai and Exh B in English translation), Ms. Siriwan has been charged with violations of Thai laws pertaining to conduct of Thai officials and the Criminal Code pertaining to acceptance of bribery. The US criminal case against Ms. Siriwan is ongoing as of May 22, 2016. (Source: US v. Siriwan, Case No. 2:09-cr-81 (C.D. Cal), Joint Status Report of the Parties filed on October 13, 2015 and Exhibits A and B; Court Docket Report as of May 22, 2016.","Jurisdiction of Origin: Investigative Agency":"National Anti-Corruption Commission of Thailand; Attorney General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney for the Central District of California, Criminal Division, Major Frauds Section; Department of Justice, Frauds Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Central District of California","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_UK_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_UK_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_USG_Supplemental_Resp_Jan_11_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_UK_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_USG_Supplemental_Resp_Thai_Govt_Exhibit_A_Jan_11_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_UK_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_Siriwan_Response_Feb_01_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_UK_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_Status_Rept_Mar_10_2014_3.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_UK_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_CDCA_Joint_Stip_Exhibit_Nov_19_2014_3.pdf","Sources ":"U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.),  Indictment filed January 28, 2009;  Joint Stipulation to Continue Hearing Date; and Order filed October 17, 2011; Government\u0027s Third Supplemental Brief in Opposition to Defendant\u0027s Motion to Dismiss and Exhibit A, filed January 11, 2013; Status Report by US and Exhibit A (Letter by Thailand\u0027s Office of the National Anti-Corruption Commission) filed March 10, 2014; Joint Status Report of the Parties and Exhibits A and B,filed October 13, 2015 and Court Docket Report as of May 22, 2016.)\nThe indictment can also be downloaded at the U.S. Department of Justice website: http:\/\/www.justice.gov\/criminal\/fraudsiriwan.html.\/fcpa\/cases\/.\nSee also Bangkok Post, \u0022US wants Juthamas extradited,\u0022 August 4, 2012 .\n"},{"Case ID":"ARW-100","Case Title (Name of Public Official or Entity Allegedly Involved)":"Juthamas Siriwan \/ Gerald and Patricia Green Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Thailand","Position of Public Official(s) (yrs in office)":"Governor of Tourism (Siriwan, 2002-2006) \/ Bribe givers (Greens)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2007","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Criminal Fine; Criminal Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Unknown if Thailand was recipient of restitution ordered in the Greens\u0027 case, but US Sentencing Memorandum submitted to the court in January 2010 stated that \u0022Restitution to Thailand of bribe amounts is discretionary under federal statute, but is necessary to comply with U.S. treaty obligations and to serve the ends of justice.\u0022  (Source: U.S. v. Green, Case No. 2:08-cr-00059-GW (C.D. Cal), Government\u0027s Combined Sentencing Position for Defendants Gerald Green and Patricia Green filed January 14, 2010.)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"Judgment under appeal; restitution ($250,000 - joint and several liability; $1,049, 465 plus shares in Artist Design Corp Defined Benefit Plan; Unspecified in judgment how much, if any, restitution may be given to Thailand]\u00a0","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"Gerald and Patricia Green, convicted in the U.S. District Court for the Central District of California, of paying bribes to Juthamas Siriwan were ordered to pay $250,000 in restitution as part of their September 10, 2010 Amended Judgment. The Judgment does not indicate the recipients of the restitution, but the Government\u0027s sentencing memorandum requested that the court \u0022inpose restitution to Thailand of $1,822,494 on defendants jointly and severally.\u0022  (Source: U.S. v. Green, Case No. 2:08-cr-00059-GW (C.D. Cal.), Government\u0027s Supplemental Sentencing Memorandum for Defendants Gerald Green and Patricia Green and Exhibit E (Letter by the National Anti-Corruption Commission of Thailand regarding their investigation of the Juthamas Siriwan bribery case), both filed on March 12, 2010; Government\u0027s Combined Sentencing Position for Defendants Gerald Green and Patricia Green filed January 14, 2010.)  The Greens were also ordered to pay a money judgment of $1,049,465 and their share in their company Artist Design Corp\u0027s Defined Benefit Plan.","Disposition of Criminal Case(s)":"According to the Joint Status Report and Indictment filed by Thai Special Prosecutor (Exh A in Thai and Exh B in English translation), Ms. Siriwan has been charged with violations of Thai laws pertaining to conduct of Thai officials and the Criminal Code pertaining to acceptance of bribery. The US criminal case against Ms. Siriwan is ongoing as of May 22, 2016. (Source: US v. Siriwan, Case No. 2:09-cr-81 (C.D. Cal), Joint Status Report of the Parties filed on October 13, 2015 and Exhibits A and B; Court Docket Report as of May 22, 2016.)","Jurisdiction of Origin: Investigative Agency":"National Anti-Corruption Commission of Thailand","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Central District of California; Department of Justice","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Central District of California","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Amended_Judgment_Sep_10_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Exhibit_E_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Forfeiture_Order_Aug_13_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Mtn_Amend_Forfeiture_Order_Nov_11_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_Status_Rept_Mar_10_2014_4.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Amended_Judgment_Sep_10_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Exhibit_E_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Forfeiture_Order_Aug_13_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Mtn_Amend_Forfeiture_Order_Nov_11_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_Status_Exhibit_A_Filed_Mar_10_2014_4.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Amended_Judgment_Sep_10_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Exhibit_E_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Forfeiture_Order_Aug_13_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Mtn_Amend_Forfeiture_Order_Nov_11_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_CDCA_Joint_Stip_Exhibit_Nov_19_2014_4.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Amended_Judgment_Sep_10_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Exhibit_E_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Forfeiture_Order_Aug_13_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Mtn_Amend_Forfeiture_Order_Nov_11_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_CDCA_Joint%20Stipulation_Sept14_2015_4.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Amended_Judgment_Sep_10_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Exhibit_E_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Forfeiture_Order_Aug_13_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Mtn_Amend_Forfeiture_Order_Nov_11_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_CDCA_Joint%20Stipulation_Exhibit%20A_Sept14_2015_4.pdf","Sources ":"U.S. v. Green, Case No. 2:08-cr-00059-GW (C.D. Cal), Amended Judgment filed September 10, 2010 and General Order of Forfeiture as to Defendants Gerald Green and Patricia Green filed on August 13, 2010, and Government\u0027s Motion to Amend Forfeiture Order and Substitute Property filed on November 11, 2010 and for which a hearing was scheduled for January 24, 2011; Government\u0027s Supplemental Sentencing Memorandum for Defendants Gerald Green and Patricia Green and Exhibit E (Letter by the National Anti-Corruption Commission of Thailand regarding their investigation of the Juthamas Siriwan bribery case), both filed on March 12, 2010; Government\u0027s Combined Sentencing Position for Defendants Gerald Green and Patricia Green filed January 14, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/greeng\/01-14-10green-se... U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Indictment filed January 28, 2009; Joint Stipulation to Continue Hearing Date; and Order filed October 17, 2011; Government\u0027s Third Supplemental Brief in Opposition to Defendant\u0027s Motion to Dismiss and Exhibit A, filed January 11, 2013; Status Report by US and Exhibit A (Letter by Thailand\u0027s Office of the National Anti-Corruption Commission) filed March 10, 2014; Joint Status Report of the Parties and Exhibits A and B,filed October 13, 2015 and Court Docket Report as of May 22, 2016.)\n"},{"Case ID":"ARW-101","Case Title (Name of Public Official or Entity Allegedly Involved)":"Kazakhstan Oil Mining \/ James Giffen - Mercator Corporation (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kazakhstan","Position of Public Official(s) (yrs in office)":"Unnamed senior officials (\u0022KO-1,\u0022 \u0022KO-2,\u0022 and \u0022KO-3\u0022)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2003","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Other (Memorandum of Understanding)","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"Memorandum of Understanding","Contributing Factors in Asset Recovery":"Memorandum of Understanding by Kazakhstan, Switzerland and the United States; World Bank signed a Service Agreement to assist in the establishment of the BOTA Foundation and implement the BOTA Program.  The Government of the Republic of Kazakhstan pays a fixed annual fee to the World Bank for the contracted Services; these payments are posted to government accounts and are not disclosed in the Foundation\u0027s special purpose financial statements. (Source:  BOTA Foundation, Independent Auditor\u0027s Report and special financial statements for the year ended 31 December 2010.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"The 2008 Amended Memorandum of Understanding among the Governments of Kazakhstan, Switzerland and the United States provided that the recovered assets would be used to establish a social welfare foundation in Kazakhstan, the Bota Foundation.  The Foundation is being overseen by the World Bank.","Case Summary":"See also US entry. \u00a0Pursuant to an Amended Memorandum of Understanding signed in May 2008 by the Governments of Kazakhstan, Switzerland and the United States, $84 million were to be returned to Kazakhstan. The funds were to be used to establish the BOTA Foundation, with its operations overseen by the World Bank. \u00a0(Source: Amended Memorandum of Understanding by the Swiss Confederation, United States and the Republic of Kazakhstan (May 2008). \u00a0According to the BOTA Foundation Independent Auditor\u0027s Report and special financial statements for the year ended 31 December 2013, the BOTA Program is funded with US$ 115 million (principal and interest) held on account No. T-94025 with Pictet and Cie in Switzerland in the name of the Treasury of the Ministry of Finance of the Republic of Kazakhstan. \u00a0The Foundation subsequently announced that it had completed its mission and ceased operations. \u00a0(Source: \u00a0BOTA Foundation Final Summative Report, February 12, 2015, at https:\/\/www.irex.org\/sites\/default\/files\/BOTA%20Summative%20Report%20FIN....) \u00a0","Disposition of Criminal Case(s)":"Unknown as to Unnamed Senior Officials 1-3.  According to the Judgment in a Criminal Case filed in the U.S. District Court for the Southern District of New York, Mercator Corporation pleaded guilty to one count violation of Foreign Corrupt Practices Act and was fined $32,000, which it satisfied on November 30, 2010.  (Sources: US v. Mercator Corporation, Case No. 1:03-cr-00404-WHP (S.D.N.Y.), Judgment in a Criminal Case filed on November 23, 2010 and Satisfaction of Judgment filed on December 9, 2010.)  According to the Judgment in a Criminal Case filed in US v. James Giffen in the U.S. District Court for the Southern District of New York, Mr. Giffen pleaded guilty to one count of willful failure to supply information regarding foreign bank accounts and sentenced to time served. (Source: US v. Giffen, Case No. 1:03-cr-00404-WHP (S.D.N.Y.), Judgment in a Criminal Case, filed on November 23, 2010.)","Jurisdiction of Origin: Investigative Agency":"N\/A","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"N\/A","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Asset Recovery: Courts Involved":"N\/A","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Switzerland_MOU.CH.US.KZ_BOTA_FDN_2008.pdf Bota_Foundation_Indepent_Auditor_Report_FY_End_Dec_31_2010\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bota_Fdn_Annual_Report_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Switzerland_MOU.CH.US.KZ_BOTA_FDN_2008.pdf Bota_Foundation_Indepent_Auditor_Report_FY_End_Dec_31_2010\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bota_Fdn_Indep_Audit_Dec_31_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Switzerland_MOU.CH.US.KZ_BOTA_FDN_2008.pdf Bota_Foundation_Indepent_Auditor_Report_FY_End_Dec_31_2010\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Kazakh_Oil_Bota_Audit_Report_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Switzerland_MOU.CH.US.KZ_BOTA_FDN_2008.pdf Bota_Foundation_Indepent_Auditor_Report_FY_End_Dec_31_2010\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Kazakh_Oil_BOTA%20Fdn_End_Announcement_Dec_2014.pdf","Sources ":"\n\tSwiss Ministry of Foreign Affairs, September 30, 2009; Amended Memorandum of Understanding by the Swiss Confederation, United States and the Republic of Kazakhstan (May 2008). \u00a0\n\n\t\u00a0\n\n\tBOTA Foundation Final Summative Report, February 12, 2015, at https:\/\/www.irex.org\/sites\/default\/files\/BOTA%20Summative%20Report%20FIN... Independent Auditor\u0027s Report and special financial statements for the year ended December 31, 2013 at http:\/\/www.bota.kz\/uploads\/538478d53d7ca.pdf. \u00a0For additional information on the BOTA Foundation\u0027s charter and copies of financial statements, please see the Foundation\u0027s website at \u00a0 http:\/\/www.bota.kz\/en\/index.php\/main\/index\/0 (Resources); \u00a0BOTA Foundation 2012 Annual Report, \u0022Summary Details from BDO Kazakhstan\u0027s Audit of BOTA\u0027s,\u0022 at http:\/\/www.bota.kz\/uploads\/51911a859a66c.pdf; BOTA Foundation Independent Auditor\u0027s Report and Special Purpose Financial Statements for the Year Ended 31 December 2012, at http:\/\/www.bota.kz\/uploads\/51b9fa19cffaf.pdf;\u00a0\n\n\t\u00a0\n\n\tBOTA Foundation Announcement, \u0022BOTA Foundation completed its mission.\u0022 \u00a0December 31, 2014, at http:\/\/www.bota.kz\/en\/index.php\/announcements\/index\/51.\n"},{"Case ID":"ARW-102","Case Title (Name of Public Official or Entity Allegedly Involved)":"Kazakhstan Oil Mining \/ James Giffen - Mercator Corporation (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kazakhstan","Position of Public Official(s) (yrs in office)":"Unnamed senior officials (\u0022KO-1,\u0022 \u0022KO-2,\u0022 and \u0022KO-3\u0022)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2003","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Settlement agreements; Non-conviction based confiscation ","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"Memorandum of Understanding","Contributing Factors in Asset Recovery":"Memorandum of Understanding by Kazakhstan, Switzerland and the United States; World Bank administration of project","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$115,000,000","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Memorandum of Understanding","Case Summary":"\n\tSee also Swtizerland entry. \u00a0Pursuant to an Amended Memorandum of Understanding signed in May 2008 by the Governments of Kazakhstan, Switzerland and the United States, $84 million were to be returned to Kazakhstan. The funds were to be used to establish the BOTA Foundation, with its operations overseen by the World Bank. \u00a0(Source: Amended Memorandum of Understanding by the Swiss Confederation, United States and the Republic of Kazakhstan (May 2008). \u00a0According to the BOTA Foundation Independent Auditor\u0027s Report and special financial statements for the year ended 31 December 2013, the BOTA Program is funded with US$ 115 million (principal and interest) held on account No. T-94025 with Pictet and Cie in Switzerland in the name of the Treasury of the Ministry of Finance of the Republic of Kazakhstan. \u00a0The Foundation subsequently announced that it had completed its mission and ceased operations. \u00a0(Source: \u00a0BOTA Foundation Final Summative Report, February 12, 2015, at https:\/\/www.irex.org\/sites\/default\/files\/BOTA%20Summative%20Report%20FIN....) \u00a0\n\n\t\u00a0\n\n\tIn addition, as part of their August 6, 2010 plea agreements, U.S. citizen \u00a0James Giffen and The Mercator Corporation relinquished any right or title they may have to additional Swiss accounts. (Sources: U.S. v. Approximately $84 million on deposit in account no. T-94025 in the name of the Treasury of the Ministry of Finance of the Republic of Kazakhstan, Case No. 2:07-cv-03559-LAP (S.D.N.Y.); August 6, 2010 plea agreements and information in U.S. v James H. Giffen, Case No. S4 03 Cr. 404 (WHP) and U.S. v The Mercator Corporation, Case No. S3 03 Cr. 404 (WHP) (S.D.N.Y.)).","Disposition of Criminal Case(s)":"Unknown as to Unnamed Senior Officials 1-3.  According to the Judgment in a Criminal Case filed in the U.S. District Court for the Southern District of New York, Mercator Corporation pleaded guilty to one count violation of Foreign Corrupt Practices Act and was fined $32,000, which it satisfied on November 30, 2010.  (Sources: US v. Mercator Corporation, Case No. 1:03-cr-00404-WHP (S.D.N.Y.), Judgment in a Criminal Case filed on November 23, 2010 and Satisfaction of Judgment filed on December 9, 2010.)  According to the Judgment in a Criminal Case filed in US v. James Giffen in the U.S. District Court for the Southern District of New York, Mr. Giffen pleaded guilty to one count of willful failure to supply information regarding foreign bank accounts and sentenced to time served. (Source: US v. Giffen, Case No. 1:03-cr-00404-WHP (S.D.N.Y.), Judgment in a Criminal Case, filed on November 23, 2010.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Southern District of New York; Department of Justice, Fraud Section; Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_$84m_Verified_Complaint_May_3_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Final_Order_Jun_1_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Giffen_Judgment_Nov_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Mercator_Judgment_Nov_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Mercator_Judgment_Satified_Dec_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Status_Rept_Dec_10_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_US_Giffen_Plea_Ag_Aug_6_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_US_Mercator_Information_Aug_6_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bota_Fdn_Annual_Report_2012_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_$84m_Verified_Complaint_May_3_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Final_Order_Jun_1_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Giffen_Judgment_Nov_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Mercator_Judgment_Nov_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Mercator_Judgment_Satified_Dec_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Status_Rept_Dec_10_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_US_Giffen_Plea_Ag_Aug_6_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_US_Mercator_Information_Aug_6_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bota_Fdn_Indep_Audit_Dec_31_2012_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_$84m_Verified_Complaint_May_3_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Final_Order_Jun_1_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Giffen_Judgment_Nov_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Mercator_Judgment_Nov_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Mercator_Judgment_Satified_Dec_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Status_Rept_Dec_10_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_US_Giffen_Plea_Ag_Aug_6_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_US_Mercator_Information_Aug_6_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Kazakh_Oil_Bota_Audit_Report_2013_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_$84m_Verified_Complaint_May_3_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Final_Order_Jun_1_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Giffen_Judgment_Nov_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Mercator_Judgment_Nov_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Mercator_Judgment_Satified_Dec_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Status_Rept_Dec_10_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_US_Giffen_Plea_Ag_Aug_6_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_US_Mercator_Information_Aug_6_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Kazakh_Oil_BOTA%20Fdn_End_Announcement_Dec_2014_0.pdf","Sources ":"\n\tU.S. v. Approximately $84 million on deposit in account no. T-94025 in the name of the Treasury of the Ministry of Finance of the Republic of Kazakhstan, Case No. 2:07-cv-03559-LAP (S.D.N.Y.), Verified Complaint filed on May 3, 2007, Final Order filed on June 1, 2009 and Status Report filed on December 10, 2009; August 6, 2010 plea agreements and information in U.S. v. James H. Giffen, Case No. S4 03 Cr. 404 (WHP) and U.S. v. The Mercator Corporation, Case No. S3 03 Cr. 404 (WHP) (S.D.N.Y.); and Satisfaction of Judgement on December 9, 2010 in U.S. v. The Mercator Corporation, Case No. S3 03 Cr. 404 (WHP) (S.D.N.Y.); BOTA Foundation 2012 Annual Report, \u0022Summary Details from BDO Kazakhstan\u0027s Audit of BOTA\u0027s,\u0022 at http:\/\/www.bota.kz\/uploads\/51911a859a66c.pdf; BOTA Foundation, Independent Auditor\u0027s Report and special financial statements for the year ended December 31, 2013 at http:\/\/www.bota.kz\/uploads\/538478d53d7ca.pdf;\n\n\t\u00a0\n\n\tBOTA Foundation, Final Summative Report, February 12, 2016; Announcement, \u0022BOTA Foundation completed its mission.\u0022 \u00a0December 31, 2014, at http:\/\/www.bota.kz\/en\/index.php\/announcements\/index\/51.\n"},{"Case ID":"ARW-103","Case Title (Name of Public Official or Entity Allegedly Involved)":"Kuwaiti Investment Organization","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kuwait","Position of Public Official(s) (yrs in office)":"Kuwaiti Investment Organization Management (inclusive 1989-1992)","Jurisdiction of Asset Recovery":"Bahamas","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"\u0022The following items were critical to the success of asset recovery in the Kuwaiti case. -The establishment of a dedicated and competent National Team was critical to the success of the initiative. - Political will was secured to ensure the success of asset recovery. - The elimination of pressures helped to achieve breakthrough successes for stolen assets recovery efforts. - Processes were initiated against individuals, rather than institutions, resulting in less resistance and fewer legal battles. - Private law actions, for several reasons, were a well-established route for asset recovery.\u0022  (Source: Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unspecified","Case Summary":"The United Kingdom\u0027s Privy Council wrote that Sheikh Fahad Mohammed Al Sabah, as the former head of the Kuwait Investment Authority in London, had \u0022embarked on a huge programme of investment in Spain through a Spanish company named  Grupo Torras  SA (\u0022GT\u0022).  With the help of co-conspirators the debtor defrauded GT on a very large scale. The misappropriations were effected by four separate fraudulent schemes between 1988 and 1990. After a long civil trial in London the debtor [the Sheikh] was found liable for very large damages (see  Grupo Torras  SA v Al Sabah [1999] CLC 1, 469). There have subsequently been various proceedings in different parts of the world by which GT, and more recently the [Sheikh\u0027s] Bahamian trustee in bankruptcy, have sought to recover funds in order to satisfy the judgment. The Sheikh was a resident of Bahamas, and on 29 June 2001 he was adjudicated bankrupt under the Bahamian Bankruptcy Act 1870. The bankruptcy was deemed to have commenced on 6 February 2001. GT\u0027s proof of debt was for a sum of the order of U.S.$800m. On 30 July 2001 the first meeting of creditors was held and Mr Clifford Culmer, a partner in BDO Mann Judge of Nassau, was appointed as trustee in bankruptcy.  The Sheikh was the settlor of two trusts governed by the law of the Cayman Islands. On 14 February 2002 the trustee in bankruptcy made an ex parte application to the Bahamian Grand Court for an order under section 122 of the Bankruptcy Act 1914 of the United Kingdom (or alternatively under the inherent jurisdiction) requesting aid from the Grand Court of the Cayman Islands\u0022 which was subsequently granted.  (Source: Al Sabah \u0026 Anor v. Grupo Torras SA \u0026 Anor (Cayman Islands) [2005] UKPC 1 (11 January 2005), at http:\/\/www.bailii.org\/uk\/cases\/UKPC\/2005\/1.html)","Disposition of Criminal Case(s)":"Unspecified","Jurisdiction of Origin: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization; Kuwaiti Public Prosecutor","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Courts Involved":"Grand Court, Court of Appeals, Supreme Court","Documents":"","Sources ":"Al Sabah \u0026 Anor v. Grupo Torras SA \u0026 Anor (Cayman Islands) [2005] UKPC 1 (11 January 2005), accessed at http:\/\/www.bailii.org\/uk\/cases\/UKPC\/2005\/1.html); \nSheikh Fahad Mohammed Al-Sabah v. George Clifford Culmer (Trustee in Bankruptcy of the Property of Sheikh Fahad Mohammed Al-Sabah), Court of Appeal of the Commonwealth of the Bahamas, Civil Appeal No. 22 of 2003 (Judgment dated April 1, 2004), accessed at http:\/\/www.courtofappeal.org.bs\/download\/22of2003sheikhfahad.pdf; \nGrupo Torras SA v Meespierson (Bahamas) Limited et al, Supreme Court of Commonwealth of Bahamas (March 1998) Sawyer CJ Court of Appeal of Commonwealth of Bahamas (April 1999).  \nDr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery Initiative\u0027s Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009.)\n"},{"Case ID":"ARW-104","Case Title (Name of Public Official or Entity Allegedly Involved)":"Kuwaiti Investment Organization","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kuwait","Position of Public Official(s) (yrs in office)":"Kuwaiti Investment Organization Management  (inclusive 1989-1992)","Jurisdiction of Asset Recovery":"Cayman Islands","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"\u0022The following items were critical to the success of asset recovery in the Kuwaiti case. -The establishment of a dedicated and competent National Team was critical to the success of the initiative. - Political will was secured to ensure the success of asset recovery. - The elimination of pressures helped to achieve breakthrough successes for stolen assets recovery efforts. - Processes were initiated against individuals, rather than institutions, resulting in less resistance and fewer legal battles. - Private law actions, for several reasons, were a well-established route for asset recovery.\u0022  (Source: Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unspecified","Case Summary":"The Kuwaiti Investment Organization sought enforcement of the English judgment in the Cayman Islands.  Early restraint orders were obtained by the Kuwaiti Investment Organization, enabling them to freeze trust assets belonging to Sheikh Fahad. Trusts maintained in Cayman by Sheikh Fahad were made to surrender their more than $30 million in assets, in partial satisfaction of the English judgment. (Source:  Cayman Islands Government, \u0022Enforcement of Judgments in Practice,\u0022 posted at Cayman Islands Government website, at http:\/\/www.gov.ky\/portal\/page?_pageid=1142,1687439\u0026_dad=portal\u0026_schema=P....)","Disposition of Criminal Case(s)":"Unspecified","Jurisdiction of Origin: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization; Kuwaiti Public Prosecutor","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Courts Involved":"Grand Court","Documents":"","Sources ":"In the Matter of Al-Sabah, 2002 CILR 148; Grupo Torras S.A. v. Bank of Butterfied International (Cayman) Limited and Five Others, 2000 CILR 452;  \nGrupo Torras S.A. v. Bank of Butterfield International (Cayman) Limited and Nine Others, Al-Sabah v. Grupo Torras S.A., Pictet Bank and Trust (Cayman) Limited and Pictet Trustee Company S.A. 2002 CILR 550; \nGrupo Torras S.A. v. Bank of Butterfied International (Cayman) Limited and Nine Others; Al-Sabah v. Grupo Torras S.A., Pictet Bank and Trust (Cayman) Limited and Pictet Trustee Company S.A. 2003 CILR 413; \nIn the matter of Al Sabah, B.A. Al Sabah and M.R. Al Sabah v. Grupo Torras S.A. and Culmer (as Trustee of the Property of Sheikh Fahad Mohammed Al Sabah, Bankrupt), 2004\u201305 CILR 373.  \nAll Cayman Islands court decisions accessed via World Bank Law Library and http:\/\/www.caymanjudicial-legalinfo.ky\/Judgments\/Cayman-Islands-Law-Reports. \nDr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009), accessed at http:\/\/www1.worldbank.org\/publicsector\/star_site\/publications\/non_convic... \nCayman Islands Government, \u0022Enforcement of Judgments in Practice,\u0022 posted at Cayman Islands Government website, at http:\/\/www.gov.ky\/portal\/page?_pageid=1142,1687439\u0026_dad=portal\u0026_schema=P....\n"},{"Case ID":"ARW-105","Case Title (Name of Public Official or Entity Allegedly Involved)":"Kuwaiti Investment Organization","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kuwait","Position of Public Official(s) (yrs in office)":"Kuwaiti Investment Organization Management (inclusive 1989-1992)","Jurisdiction of Asset Recovery":"Jersey","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"\u0022The following items were critical to the success of asset recovery in the Kuwaiti case. -The establishment of a dedicated and competent National Team was critical to the success of the initiative. - Political will was secured to ensure the success of asset recovery. - The elimination of pressures helped to achieve breakthrough successes for stolen assets recovery efforts. - Processes were initiated against individuals, rather than institutions, resulting in less resistance and fewer legal battles. - Private law actions, for several reasons, were a well-established route for asset recovery.\u0022  (Source: Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"The National Team established by the Kuwaiti Investment Organization sought to enforce the United Kingdom judgment in the Isle of Jersey where its former Sheikh Fahad held assets. The Jersey courts stated in the cases of In the Matter of the Esteem Settlement and the No. 52 Trust (Abacus (C.I.) Limited as Trustee) and Grupo Torras S.A. v. Al Sabah and six others [2002] JLR 53 that between May 1988 and October 1990, Sheikh Fahad conspired with others to defraud Grupo Torras of a total sum of approximately $430 million, of which $120 million was paid to Sheikh Fahad.  The court held that (a) Grupo Torras has a proprietary interest of 4.75% of 97 Dulwich Village and 4.27% of 242 Turney Road. Grupo Torras is entitled to an order which enables these interests to be realized. (b) The gift of Ceyla to the Esteem Settlement is to be set aside. Ceyla is entitled to recover the amount owed to it by the Esteem Settlement. (c) The gift of GBP 4 million to the No. 52 Trust is to be set aside. Grupo Torras is entitled to recover the net assets of the No. 52 Trust. (d) The gifts of GBP 1,693,500 and GBP 3,514,339 to the Esteem Settlement are to be set aside to the extent of 9.975% of the current value of 97 Dulwich Village.","Disposition of Criminal Case(s)":"Unspecified","Jurisdiction of Origin: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization; Kuwaiti Public Prosecutor","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"In the Matter of the Esteem Settlement and the No. 52 Trust (Abacus (C.I.) Limited as Trustee), Grupo Torras S.A. v. Al Sabah and Six Others, 2002 JLR 53; In the Matter of the Esteem Settlement (Abacus (C.I.) Limited as Trustees), Grupo Torras S.A. and Culmer v. Al Sabah and Four Others, 2003 JLR 188; Al-Sabah and Another v. Grupo Torras S.A. and Others (Jersey) [2000] UKPC 38 (10th October, 2000) (denial of interlocutory appeal).  Jersey court decisions accessed at, http:\/\/www.jerseylaw.je\/Judgments\/JerseyLawReports.  See also, Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009), accessed at http:\/\/www1.worldbank.org\/publicsector\/star_site\/publications\/non_convic....\n"},{"Case ID":"ARW-106","Case Title (Name of Public Official or Entity Allegedly Involved)":"Kuwaiti Investment Organization","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kuwait","Position of Public Official(s) (yrs in office)":"Kuwaiti Investment Organization Management (inclusive 1989-1992)","Jurisdiction of Asset Recovery":"Kuwait","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"1991","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"\u0022The following items were critical to the success of asset recovery in the Kuwaiti case. -The establishment of a dedicated and competent National Team was critical to the success of the initiative. - Political will was secured to ensure the success of asset recovery. - The elimination of pressures helped to achieve breakthrough successes for stolen assets recovery efforts. - Processes were initiated against individuals, rather than institutions, resulting in less resistance and fewer legal battles. - Private law actions, for several reasons, were a well-established route for asset recovery.\u0022  (Source: Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009).","Status of Asset Recovery ":"Unknown","Stage in Asset Recovery Chain":"Unknown [UK judgment noted criminal proceedings in Kuwait]","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unspecified","Case Summary":"The UK High Court - Queen\u0027s Bench, Commercial Court wrote in its June 24, 1999 decision that \u0022According to Sheikh Fahad, [criminal] proceedings have been on foot in Kuwait since 26th October 1992 against him and others for misappropriation of public funds.\u0022 (Source: Grupo Torras SA \u0026 Ors v Sheikh Fahad \u0026 Ors [1999] EWHC 300 (Comm) (24 June 1999), at 109.)   The same decision notes that the Kuwaiti Public Prosecutor in Kuwait brought criminal proceedings against Sheikh Fahad and others who are \u0022wanted for having embezzled large sums from these companies... that is from GT and THL [Grupo Torras and Torras Hostench London Limited].\u0022   (Source: Grupo Torras SA \u0026 Ors v Sheikh Fahad \u0026 Ors [1999] EWHC 300 (Comm) (24 June 1999), at 108.)","Disposition of Criminal Case(s)":"Unspecified","Jurisdiction of Origin: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization; Kuwaiti Public Prosecutor","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Grupo Torras SA \u0026 Ors v Sheikh Fahad \u0026 Ors [1999] EWHC 300 (Comm) (24 June 1999), accessed at www.bailii.org. See also, Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009), accessed at http:\/\/www1.worldbank.org\/publicsector\/star_site\/publications\/non_convic....\n"},{"Case ID":"ARW-107","Case Title (Name of Public Official or Entity Allegedly Involved)":"Kuwaiti Investment Organization","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kuwait","Position of Public Official(s) (yrs in office)":"Kuwaiti Investment Organization Management (inclusive 1989-1992)","Jurisdiction of Asset Recovery":"Spain","Jurisdiction of Asset Description":"Undertaking Asset Recovery, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1993","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"\u0022The following items were critical to the success of asset recovery in the Kuwaiti case. -The establishment of a dedicated and competent National Team was critical to the success of the initiative. - Political will was secured to ensure the success of asset recovery. - The elimination of pressures helped to achieve breakthrough successes for stolen assets recovery efforts. - Processes were initiated against individuals, rather than institutions, resulting in less resistance and fewer legal battles. - Private law actions, for several reasons, were a well-established route for asset recovery.\u0022  (Source: Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009).","Status of Asset Recovery ":"Unknown","Stage in Asset Recovery Chain":"Unknown","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a press report, in January 1993, the Kuwaiti Investment Organization (KIO) issued writs in the Spanish high court against Sheikh Fahad, Fouad Jaffar, Mr. de la Rosa and four other Spaniards who worked for the KIO. It accuses them of falsifying mercantile and public documents, fraud, manipulating prices and tax evasion, producing losses of well over 100 billion pesetas ($870 million).  The KIO also sought a freeze on their assets to cover the alleged financial responsibilities. (Source: Justin Webster, \u0022Kio\u0027s Spanish inquisition: The growing scandal of Kuwait\u0027s massive losses in Spain is exposing the dirty linen of one of the world\u0027s most secretive investment agencies and ringing government alarm bells. As the feud spills into the courts, Justin Webster looks at what lies behind the Grupo Torras disaster,\u0022 The Independent (UK), January 10, 1993. Grupo Torras SA \u0026 Ors v Sheikh Fahad \u0026 Ors [1999] EWHC 300 (Comm) (24 June 1999) mentions a case in Spain, at 108.)","Disposition of Criminal Case(s)":"Unspecified","Jurisdiction of Origin: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization; Kuwaiti Public Prosecutor","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Grupo Torras SA \u0026 Ors v Sheikh Fahad \u0026 Ors [1999] EWHC 300 (Comm) (24 June 1999) mentions a case in Spain. See also, Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009), accessed at http:\/\/www1.worldbank.org\/publicsector\/star_site\/publications\/non_convic... Justin Webster, \u0022Kio\u0027s Spanish inquisition: The growing scandal of Kuwait\u0027s massive losses in Spain is exposing the dirty linen of one of the world\u0027s most secretive investment agencies and ringing government alarm bells. As the feud spills into the courts, Justin Webster looks at what lies behind the Grupo Torras disaster,\u0022 The Independent (UK), January 10, 1993.\n"},{"Case ID":"ARW-108","Case Title (Name of Public Official or Entity Allegedly Involved)":"Kuwaiti Investment Organization","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kuwait","Position of Public Official(s) (yrs in office)":"Kuwaiti Investment Organization Management (inclusive 1989-1992)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"\u0022The following items were critical to the success of asset recovery in the Kuwaiti case. -The establishment of a dedicated and competent National Team was critical to the success of the initiative. - Political will was secured to ensure the success of asset recovery. - The elimination of pressures helped to achieve breakthrough successes for stolen assets recovery efforts. - Processes were initiated against individuals, rather than institutions, resulting in less resistance and fewer legal battles. - Private law actions, for several reasons, were a well-established route for asset recovery.\u0022  (Source: Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009).","Status of Asset Recovery ":"Unknown","Stage in Asset Recovery Chain":"Unknown [UK judgment noted criminal and civil proceedings in Switzerland]","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"Unknown","Assets Returned (USD)":"","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unspecified","Case Summary":"Grupo Torras SA \u0026 Ors v Sheikh Fahad \u0026 Ors [1999] EWHC 300 (Comm) (24 June 1999)\nmakes mention of criminal case in Switzerland.  The court noted that the State of Kuwait requested judicial cooperation in June 1997 to the Swiss Police.  The court notes, on several instances, that Swiss Investigating Magistrate Juge Tappolet obtained numerous bank account documents in connection with his criminal investigation of the case. (Source: Grupo Torras SA \u0026 Ors v Sheikh Fahad \u0026 Ors [1999] EWHC 300 (Comm) (24 June 1999), at 108 and throughout).","Disposition of Criminal Case(s)":"Unspecified","Jurisdiction of Origin: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization; Kuwaiti Public Prosecutor","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Grupo Torras SA \u0026 Ors v Sheikh Fahad \u0026 Ors [1999] EWHC 300 (Comm) (24 June 1999) makes mention of criminal case in Switzerland. See also, Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009), accessed at http:\/\/www1.worldbank.org\/publicsector\/star_site\/publications\/non_convic....\n"},{"Case ID":"ARW-109","Case Title (Name of Public Official or Entity Allegedly Involved)":"Kuwaiti Investment Organization","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kuwait","Position of Public Official(s) (yrs in office)":"Kuwaiti Investment Organization Management (inclusive 1989-1992)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1993","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"\u0022The following items were critical to the success of asset recovery in the Kuwaiti case. -The establishment of a dedicated and competent National Team was critical to the success of the initiative. - Political will was secured to ensure the success of asset recovery. - The elimination of pressures helped to achieve breakthrough successes for stolen assets recovery efforts. - Processes were initiated against individuals, rather than institutions, resulting in less resistance and fewer legal battles. - Private law actions, for several reasons, were a well-established route for asset recovery.\u0022  (Source: Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$548,000,000 (worldwide total for which ARW has official documentation; please see Summary field)","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009) provides an overview of Kuwaiti Investment Organization\u0027s worldwide recovery efforts.  The Case Study noted that legal actions took place in a total of nineteen jurisdictions, including the Bahamas, Cayman Islands, Jersey, Kuwait, Spain, Switzerland the United Kingdom. (Please see separate entries.)  In 1993, the Kuwaiti Investment Organization initiated civil proceedings which resulted in a 1999 judgment in the UK commercial court in its favor of $687 million in damages. [1999 EWHC 300 (Comm) - Grupo Torras SA and Torras Hostench London Limited (in liquidation), Plaintiffs, -and- Sheikh Fahad Mohammed Al-Sabah, and others (total 56 defendants, comprised of natural persons and associated corporate vehicles).  The United Kingdom judgment was the basis for proceedings in the Bahamas, Cayman Islands, and Jersey where trusts and other assets belonging to the main defendant Sheikh Fahad were located.","Disposition of Criminal Case(s)":"Unknown","Jurisdiction of Origin: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization; Kuwaiti Public Prosecutor","Jurisdiction of Origin: Courts Involved":"Unknown","Jurisdiction of Asset Recovery: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Justice, Queen\u0027s Bench Division, Commercial Court","Documents":"","Sources ":"Grupo Torras SA \u0026 Ors v Sheikh Fahad \u0026 Ors [1999] EWHC 300 (Comm) (24 June 1999), accessed at http:\/\/www.bailii.org\/ew\/cases\/EWHC\/Comm\/1999\/300.html#VI2. See also, Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009), accessed at http:\/\/www1.worldbank.org\/publicsector\/star_site\/publications\/non_convic... The Independent, \u0022Kuwaiti Sheikh to fight ruling,\u0022 June 27, 1999, accessed at http:\/\/www.independent.co.uk\/news\/business\/kuwaiti-sheikh-to-fight-rulin....\n"},{"Case ID":"ARW-110","Case Title (Name of Public Official or Entity Allegedly Involved)":"Leonid Reiman \/ Jeffrey Galmond \/ IPOC International Growth Fund Ltd. (Bermuda)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Russian Federation","Position of Public Official(s) (yrs in office)":"Telecommunications Minister and Advisor to President (Reiman, to 2010); Attorney to Mr. Reiman (Galmond)","Jurisdiction of Asset Recovery":"Bermuda","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2004","Asset Recovery End":"2008","UNCAC Offenses Implicated":"Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Other","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Investigative cooperation between British Virgin Islands and Bermuda - exact mechanism unknown","Contributing Factors in Asset Recovery":"Joint investigation by the British Virgin Islands and Bermuda into the corporate vehicles domiciled in their respective jurisdictions.  The British Virgin Islands High Court noted in its judgment against IPOC International Growth Fund Limited and co-defendants that \u0022In his concluding remarks, Mr Hodge QC [Queen\u0027s Counsel] commended the work done by the Bermuda Police and the Royal Virgin Islands Police Force as well as the Attorney General\u0027s Chambers in both jurisdictions saying that well over one-half million pages of documents were produced during the 17 month investigation signifying the complexity and density of this case.\u0022  (Source: In the Matter of the Proceeds of Criminal Conduct Act (No. 5 of 1997) of the Laws of the Virgin Islands between The Queen v. (1) IPOC International Growth Fund Limited, (2) Lapal Limited, (3) Albany Invest Limited, (4) Mercury Import Limited, The Eastern Caribbean Supreme Court in the High Court of Justice (Criminal Jurisdiction), Criminal Case. No. 12 of 2008.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"Please see entry case entry for British Virgin Islands.  In a Ministerial address of May 18, 2008, Bermuda\u0027s then-Minister of Finance Paula Cox stated that on May 7, 2008, in the Supreme Court of Bermuda, Justice Kwaley ordered that a group of companies collectively referred to as IPOC be wound up under the provisions of sections 1232(10)(a) and 161 (g) of the Companies Act 1981.  Minister Cox, acting as Finance Minister under authority of section 132 of the Companies Act to initiate investigation of companies, hired the consulting firm, KPMG to investigate the IPOC International Growth Fund.  Based on KPMG\u0027s findings, the wind-up petition was presented to the Supreme Court in 2007. Bermuda cooperated with British Virgin Islands in that jurisdiction\u0027s investigation of IPOC and she stated that \u0022As a result of the criminal conviction in the BVI, some $45 million of assets belonging to IPOC has been confiscated and will be shared equally between the British Virgin Islands and Bermuda.  Bermuda\u0027s share of these proceeds will be placed in the Confiscated Assets Fund.\u0022  (Source: Ministerial Statement by Minister Paula Cox, May 18, 2008 at http:\/\/www.plp.bm\/node\/1273, posted at http:\/\/www.plp.bm\/node\/1273.)","Disposition of Criminal Case(s)":"According to a judgment by the British Virgin Islands High Court of Justice, in 2008, the IPOC International Growth Fund and three associated international business companies formed in BVI (Lapal Limited, Albany Invest Limited, and Mercury Import Limited) pleaded guilty and were each convicted of two counts of perverting the course of justice and furnishing false information, in violation of the BVI Criminal Code. (Source: Judgement in AG v. IPOC International Growth Fund Limited, Jeffrey Galmond, and others, Claim No. BVIHCV2007\/0088, British Virgin Islands High Court of Justice (civil) and In the Matter of the Proceeds of Criminal Conduct Act (No. 5 of 1997) of the Laws of the Virgin Islands, between The Queen v. IPOC International Growth Fund Limited and others, Crim Case No. 12 of 2008, British Virgin Islands, High Court of Justice (criminal jurisdiction).","Jurisdiction of Origin: Investigative Agency":"N\/A","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Bermuda Police Service; Attorney General\u0027s Chambers; Ministry of Finance; Bermuda Monetary Service","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Registrar of Companies","Jurisdiction of Asset Recovery: Courts Involved":"Supreme Court (Commercial Court) of Bermuda; Court of Appeal for Bermuda; [International Court of Arbitration, Zurich and Geneva]","Documents":"","Sources ":"Ministerial Statement by Minister Paula Cox on IPOC, May 18, 2008, as posted on the website of the Bermuda Progressive Labour Party, at http:\/\/www.plp.bm\/node\/1273; \nGovernment of Bermuda, The Cabinet Office, Department of Communication and Information, \u0022Press Statement by the Minister of Finance, the Hon. Paula A. Cox, JP, MP, \u0022IPOC Group of Companies,\u0022 May 1, 2008;  \nIn the matter of (12) IPOC International Growth Fund Limited, and others, Supreme Court of Bermuda (Commercial Court), Companies (winding-up), case 2007: Nos. 12, 12A-12H (December 6, 2007 judgment) and Between IPOC International Growth Fund Ltd. and OAO \u0022CT-Mobile\u0022, LV Finance Group, In the Court of Appeal for Bermuda, Civil Appeal No. 22 \u0026 23 of 2006 (23 March 2007 judgment), obtained September 2010 from the website of the Bermuda Judiciary, Government of Bermuda at http:\/\/www.gov.bm\/portal\/server.pt?open=512\u0026objID=204\u0026\u0026PageID=226633\u0026mod....  \nGovernment press release and related court decisions can also be downloaded from the Government of Bermuda, The Cabinet Office webpage at http:\/\/www.oagbermuda.gov.bm\/portal\/server.pt?in_hi_space=SearchResult\u0026i... \nJonathan Kent, \u0022Bermuda, BVI to share IPOC confiscation,\u0022 The Royal Gazette (Bermuda), May 2, 2008, accessed at accessed at http:\/\/www.royalgazette.com\/siftology.royalgazette\/Article\/article.jsp?a....\n"},{"Case ID":"ARW-111","Case Title (Name of Public Official or Entity Allegedly Involved)":"Leonid Reiman \/ Jeffrey Galmond \/ IPOC International Growth Fund Ltd. (BVI)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Russian Federation","Position of Public Official(s) (yrs in office)":"Telecommunications Minister and Advisor to President (Reiman, to 2010); Attorney to Mr. Reiman (Galmond)","Jurisdiction of Asset Recovery":"British Virgin Islands","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2006","Asset Recovery End":"2008","UNCAC Offenses Implicated":"Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Investigative cooperation between British Virgin Islands and Bermuda - exact mechanism unknown","Contributing Factors in Asset Recovery":"Joint investigation by the British Virgin Islands and Bermuda into the corporate vehicles domiciled in their respective jurisdictions.  The British Virgin Islands High Court noted in its judgment against IPOC International Growth Fund Limited and co-defendants that \u0022In his concluding remarks, Mr Hodge QC [Queen\u0027s Counsel] commended the work done by the Bermuda Police and the Royal Virgin Islands Police Force as well as the Attorney General\u0027s Chambers in both jurisdictions saying that well over one-half million pages of documents were produced during the 17 month investigation signifying the complexity and density of this case.\u0022  (Source: In the Matter of the Proceeds of Criminal Conduct Act (No. 5 of 1997) of the Laws of the Virgin Islands between The Queen v. (1) IPOC International Growth Fund Limited, (2) Lapal Limited, (3) Albany Invest Limited, (4) Mercury Import Limited, The Eastern Caribbean Supreme Court in the High Court of Justice (Criminal Jurisdiction), Criminal Case. No. 12 of 2008.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"As part of their 2008 conviction in the British Virgin Islands,  IPOC International Growth Fund Limited (Bermuda) and three associated companies were In May 2006, an international arbitration tribunal in Zurich \u0022found that Minister Reiman of the Russian Government was the beneficial owner of IPOC [International Growth Fund Limited (Bermuda)] and that he committed criminal acts under Russian law.\u0022 (Source: as cited by the British Virgin Islands Court of Appeal, 18 June 2008, Civil Appeal No. 30 of 2006, in IPOC International Growth Fund Limited (Bermuda) v. LV Finance Group Limited (British Virgin Islands)).  IPOC and its associated corporate vehicles formed in Bermuda and BVI were the subject of a lengthy joint investigation by those jurisdictions for alleged money laundering activities.  In 2008, IPOC and three associated international business companies formed in BVI (Lapal Limited, Albany Invest Limited, and Mercury Import Limited) pleaded guilty and were each convicted of two counts of perverting the course of justice and furnishing false information, in violation of the BVI Criminal Code. (Source: Judgement in AG v. IPOC International Growth Fund Limited, Jeffrey Galmond, and others, Claim No. BVIHCV2007\/0088, British Virgin Islands High Court of Justice (civil) and In the Matter of the Proceeds of Criminal Conduct Act (No. 5 of 1997) of the Laws of the Virgin Islands, between The Queen v. IPOC International Growth Fund Limited and others, Crim Case No. 12 of 2008, British Virgin Islands, High Court of Justice (criminal jurisdiction).","Disposition of Criminal Case(s)":"According to a 2008 judgment by the British Virgin Islands High Court of Justice, the IPOC International Growth Fund and three associated international business companies formed in BVI (Lapal Limited, Albany Invest Limited, and Mercury Import Limited) pleaded guilty and were each convicted of two counts of perverting the course of justice and furnishing false information, in violation of the BVI Criminal Code. (Source: Judgement in AG v. IPOC International Growth Fund Limited, Jeffrey Galmond, and others, Claim No. BVIHCV2007\/0088, British Virgin Islands High Court of Justice (civil) and In the Matter of the Proceeds of Criminal Conduct Act (No. 5 of 1997) of the Laws of the Virgin Islands, between The Queen v. IPOC International Growth Fund Limited and others, Crim Case No. 12 of 2008, British Virgin Islands, High Court of Justice (criminal jurisdiction).","Jurisdiction of Origin: Investigative Agency":"N\/A","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Royal Virgin Islands Police Force; Attorney General\u0027s Chambers; Financial Investigations Agency","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General\u0027s Chambers, Director of Public Prosecutions","Jurisdiction of Asset Recovery: Courts Involved":"The Eastern Caribbean Supreme Court, High Court of Justice (Criminal Jurisdiction); High Court of Justice (Civil); [International Court of Arbitration, Zurich and Geneva]","Documents":"","Sources ":"In the Matter of the Proceeds of Criminal Conduct Act (No. 5 of 1997) of the Laws of the Virgin Islands between The Queen v. (1) IPOC International Growth Fund Limited, (2) Lapal Limited, (3) Albany Invest Limited, (4) Mercury Import Limited, The Eastern Caribbean Supreme Court in the High Court of Justice (Criminal Jurisdiction), Criminal Case. No. 12 of 2008; \nIPOC International Growth Fund Limited (Bermuda) v. LV Finance group Limited (BVI), BVI No. 1 Court of Appeal, 18 June 2008, Civil Appeal No. 30 of 2006;  \nIn the matter of (12) IPOC International Growth Fund Limited,,, and in the Matter of the Companies Act 1981, In the Supreme Court of Bermuda, Commercial Court, Companies (Winding-up), 2007: Nox. 12, 12A-12H (Decision dated December 6, 2007); \nIn her Ministerial address of May 18, 2008, Bermuda\u0027s then-Minister of Finance Paula Cox stated that \u0022As a result of the criminal conviction in the BVI, some $45 million of assets belonging to IPOC has been confiscated and will be shared equally between the British Virgin Islands and Bermuda.  \nBermuda\u0027s share of these proceeds will be placed in the Confiscated Assets Fund.\u0022 Ministerial Statement by Minister Paula Cox, May 18, 2008 at http:\/\/www.plp.bm\/node\/1273, posted at http:\/\/www.plp.bm\/node\/1273.  \nJonathan Kent, \u0022Bermuda, BVI to share IPOC confiscation,\u0022 The Royal Gazette (Bermuda), May 2, 2008, accessed at http:\/\/www.royalgazette.com\/siftology.royalgazette\/Article\/article.jsp?a....\n"},{"Case ID":"ARW-112","Case Title (Name of Public Official or Entity Allegedly Involved)":"Lesotho Highlands Water Project (Canada)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Canada","Position of Public Official(s) (yrs in office)":"Chief executive of the Lesotho Highlands Development Agency (Masupha Ephraim Sole, 1986-1995) and former delegates of Lesotho on the Highlands Water Commission (Reatile Mochebelele and Letiafuoa Molapo); Acres International Limited (Canada); Lahmeyer International GmbH (Germany); Impregilo SpA (Italy); Jacobus Michiel Du Plooy (Impregilo intermediary); Spie Batignolles (France)","Jurisdiction of Asset Recovery":"Lesotho","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"1999","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Successful collaboration of OLAF [European Anti-Fraud Office] in prosecuting the European companies involved; mutual legal assistance from Switzerland in the prosecutions (Source:  LL Thetsane and GH Penzhorn SC, \u0022Case Study: The Lesotho bribery prosecutions,\u0022 presented at Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities, Rabat, May 14-16, 2007); World Bank investigation and debarment of involved companies, Acres International and Lahmeyer International GmbH (Source: World Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, which noted \u0022Once the indictments [in the case] were announced in mid-1999, the World Bank provided extensive evidentiary support to the Lesotho prosecutors and made bank staff available for interviews.\u0022)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$2,042,710","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"On August 15, 2003, the Lesotho Court of Appeal upheld the bribery conviction of Acres International Limited (Canada) and increased the company\u0027s fine to R15 million.  (Source: Acres International Limited v The Crown, Lesotho Court of Appeal, case number C of A (CRI) 8 of 2002, Judgment of August 15, 2003.)  The case arose out of the Lesotho Highlands Water Project, which the Lesotho Court of Appeal as \u0022[0]ne of the biggest and most ambitious dam projects in the world, which entailed inter alia the construction of the Katse Dam in a remote and inaccessible part of the highlands of Lesotho.\u0022  (Source: In the matter between: Ephraim Masupha Sole and The Crown, Lesotho Court of Appeals, Case (CRI) 5 OF 2002, Judgment dated April 13, 2003).  According to the 2003 Lesotho Court of Appeal judgment, the High Court of Lesotho had found Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, guilty of accepting bribes from various multinational companies that were attempting to secure contracts related to the project.  In an earlier dispute involving Mr. Sole, the government hired Ernst and Young, whose audit discovered that Mr. Sole had Swiss bank accounts into which the project contractors and consultants had placed large sums of money.  Four multinational companies were convicted or pleaded guilty in the case, including Acres International Limited.  (Please see Lesotho Highlands Water Project entries.)","Disposition of Criminal Case(s)":"According to the Lesotho Court of Appeal, Mr. Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, was found guilty of accepting bribes from various multinational companies in connection with the Lesotho Highlands Water Project.  (Source: In the matter between: Ephraim Masupha Sole and The Crown, Lesotho Court of Appeals, Case (CRI) 5 OF 2002, Judgment dated April 13, 2003).  According to the Lesotho Court of Appeal, two other Lesotho officials, Reatile Mochebelele and Letiafuoa Molano, were also found guilty of accepting bribes. (Source: R v Mochebelele and Another (C of A (CRI) 02\/08) [2008] LSCA 30 (17 October 2008)).  Four foreign companies were convicted or pleaded guilty in Lesotho to corruption related charges:  Acres International Limited (Canada);  Lahmeyer International GmbH (Germany); Spie Batignolles (now Schneider Electric SA, France), and Impregilo SpA (Italy) (and Jacobus Michiel Du Plooy (Impregilo intermediary).  (Sources: In the matter between: Schneider Electric S.A. (formally Spie Batignolles) (Applicant) and Director of Public Prosecutions (Respondent), High Court of Lesotho, CRI\/APN\/751\/2003; In the Matter between Lahmeyer International GmbH (Appellant) and The Crown (Respondent), C of A (CRI) 6 OF 2002 (April 7, 2004); Crown v Impregilo Spa (Registration Number 104217) Tribunal of Milan (CRI\/T\/174\/2004 CIV\/APN\/437\/05) [2006] LSHC 48 (3 February 2006); and Acres International Limited v The Crown, Lesotho Court of Appeal, case number C of A (CRI) 8 of 2002. Judgment of August 15, 2003.)","Jurisdiction of Origin: Investigative Agency":"European Anti-Fraud Office (OLAF)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions (Lesotho)","Jurisdiction of Origin: Courts Involved":"High Court of Lesotho; Court of Appeal of Lesotho ","Jurisdiction of Asset Recovery: Investigative Agency":"European Anti-Fraud Office (OLAF)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions (Lesotho)","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Lesotho; Court of Appeal of Lesotho","Documents":"","Sources ":"Acres International Limited v The Crown, Lesotho Court of Appeal, case number C of A (CRI) 8 of 2002 delivered on 15 August 2003, accessed at http:\/\/www.saflii.org\/ls\/cases\/LSHC\/2003\/88.pdf; In the Matter between Ephraim Masupha Sole and the Crown, in the Appeal Court of Lesotho, C. of A. (CRI) 5 of 2002, CRI\/T\/111\/91, Judgment dated April 13, 2003; \u0022Case Study: The Lesotho bribery prosecutions,\u0022 Paper presented by LL Thetsane and GH Penzhorn SC, at the Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities,\u0022 Rabat, May 14-16, 2007. World Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,contentMDK:21116129~pag... European Anti-Fraud Office Press Release, \u0022Three European Companies Guilty in African Aid Fraud Case,\u0022 October 3, 2006, accessed at http:\/\/ec.europa.eu\/anti_fraud\/cases\/aid_en.html. Lesotho Highlands Water Project, at http:\/\/ipocafrica.org which also provides a list and links to relevant documents. United Nations Office on Drugs and Crime, United Nations Handbook on Practical Anti-Corruption Measures for Prosecutors and Investigators (Vienna, 2004), Annex: Lesotho Case Study, at 137ff.\n"},{"Case ID":"ARW-113","Case Title (Name of Public Official or Entity Allegedly Involved)":"Lesotho Highlands Water Project (France)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"France","Position of Public Official(s) (yrs in office)":"Chief executive of the Lesotho Highlands Development Agency (Masupha Ephraim Sole, 1986-1995) and former delegates of Lesotho on the Highlands Water Commission (Reatile Mochebelele and Letiafuoa Molapo); Acres International Limited (Canada); Lahmeyer International GmbH (Germany); Impregilo SpA (Italy); Jacobus Michiel Du Plooy (Impregilo intermediary); Spie Batignolles (France)","Jurisdiction of Asset Recovery":"Lesotho","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"1999","Asset Recovery End":"2004","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Successful collaboration of OLAF [European Anti-Fraud Office] in prosecuting the European companies involved; mutual legal assistance from Switzerland in the prosecutions (Source:  LL Thetsane and GH Penzhorn SC, \u0022Case Study: The Lesotho bribery prosecutions,\u0022 presented at Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities, Rabat, May 14-16, 2007); World Bank investigation and debarment of involved companies, Acres International and Lahmeyer International GmbH (Source: World Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, which noted \u0022Once the indictments [in the case] were announced in mid-1999, the World Bank provided extensive evidentiary support to the Lesotho prosecutors and made bank staff available for interviews.\u0022)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$1,417,490","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In February 2004, Spie Batignolles (now Schneider Electric SA, France) pleaded guilty and paid R10 million in fines.  (Source: In the matter between: Schneider Electric S.A. (formally Spie Batignolles) (Applicant) and Director of Public Prosecutions (Respondent), High Court of Lesotho, CRI\/APN\/751\/2003 (11 December 2003)).  The case arose out of the Lesotho Highlands Water Project, which the Lesotho Court of Appeal as \u0022[0]ne of the biggest and most ambitious dam projects in the world, which entailed inter alia the construction of the Katse Dam in a remote and inaccessible part of the highlands of Lesotho.\u0022  (Source: In the matter between: Ephraim Masupha Sole and The Crown, Lesotho Court of Appeals, Case (CRI) 5 OF 2002, Judgment dated April 13, 2003).  According to the 2003 Lesotho Court of Appeal judgment, the High Court of Lesotho had found Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, guilty of accepting bribes from various multinational companies that were attempting to secure contracts related to the project.  In an earlier dispute involving Mr. Sole, the government hired Ernst and Young, whose audit discovered that Mr. Sole had Swiss bank accounts into which the project contractors and consultants had placed large sums of money.  Four multinational companies were convicted or pleaded guilty in the case, including Acres International Limited. (Please see Lesotho Highlands Water Project entries.)","Disposition of Criminal Case(s)":"According to the Lesotho Court of Appeal, Mr. Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, was found guilty of accepting bribes from various multinational companies in connection with the Lesotho Highlands Water Project.  (Source: In the matter between: Ephraim Masupha Sole and The Crown, Lesotho Court of Appeals, Case (CRI) 5 OF 2002, Judgment dated April 13, 2003).  According to the Lesotho Court of Appeal, two other Lesotho officials, Reatile Mochebelele and Letiafuoa Molano, were also found guilty of accepting bribes. (Source: R v Mochebelele and Another (C of A (CRI) 02\/08) [2008] LSCA 30 (17 October 2008)).  Four foreign companies were convicted or pleaded guilty in Lesotho to corruption related charges:  Acres International Limited (Canada);  Lahmeyer International GmbH (Germany); Spie Batignolles (now Schneider Electric SA, France), and Impregilo SpA (Italy) (and Jacobus Michiel Du Plooy (Impregilo intermediary).  (Sources: In the matter between: Schneider Electric S.A. (formally Spie Batignolles) (Applicant) and Director of Public Prosecutions (Respondent), High Court of Lesotho, CRI\/APN\/751\/2003; In the Matter between Lahmeyer International GmbH (Appellant) and The Crown (Respondent), C of A (CRI) 6 OF 2002 (April 7, 2004); Crown v Impregilo Spa (Registration Number 104217) Tribunal of Milan (CRI\/T\/174\/2004 CIV\/APN\/437\/05) [2006] LSHC 48 (3 February 2006); and Acres International Limited v The Crown, Lesotho Court of Appeal, case number C of A (CRI) 8 of 2002. Judgment of August 15, 2003.)","Jurisdiction of Origin: Investigative Agency":"European Anti-Fraud Office (OLAF) ","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions (Lesotho)","Jurisdiction of Origin: Courts Involved":"High Court of Lesotho; Court of Appeal of Lesotho ","Jurisdiction of Asset Recovery: Investigative Agency":"European Anti-Fraud Office (OLAF)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions (Lesotho)","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Lesotho; Court of Appeal of Lesotho","Documents":"","Sources ":"In the matter between: Schneider Electric S.A. (formally Spie Batignolles) (Applicant) and Director of Public Prosecutions (Respondent), High Court of Lesotho, CRI\/APN\/751\/2003 (11 December 2003), accessed at http:\/\/www.saflii.org\/ls\/cases\/LSHC\/2003\/150.pdf; In the matter between Ephraim Masupha Sole and the Crown, in the Appeal Court of Lesotho, C. of A. (CRI) 5 of 2002, CRI\/T\/111\/91, Judgment dated April 13, 2003 and R v Mochebelele and Another (C of A (CRI) 02\/08) [2008] LSCA 30 (17 October 2008), both accessed at www.saflii.org; \u0022Case Study: The Lesotho bribery prosecutions,\u0022 Paper presented by LL Thetsane and GH Penzhorn SC, at the Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities,\u0022 Rabat, May 14-16, 2007. World Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,contentMDK:21116129~pag... European Anti-Fraud Office Press Release, \u0022Three European Companies Guilty in African Aid Fraud Case,\u0022 October 3, 2006, accessed at http:\/\/ec.europa.eu\/anti_fraud\/cases\/aid_en.html. Lesotho Highlands Water Project, at http:\/\/ipocafrica.org which also provides a list and links to relevant documents.\n"},{"Case ID":"ARW-114","Case Title (Name of Public Official or Entity Allegedly Involved)":"Lesotho Highlands Water Project (Germany)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Germany","Position of Public Official(s) (yrs in office)":"Chief executive of the Lesotho Highlands Development Agency (Masupha Ephraim Sole, 1986-1995) and former delegates of Lesotho on the Highlands Water Commission (Reatile Mochebelele and Letiafuoa Molapo); Acres International Limited (Canada); Lahmeyer International GmbH (Germany); Impregilo SpA (Italy); Jacobus Michiel Du Plooy (Impregilo intermediary); Spie Batignolles (France)","Jurisdiction of Asset Recovery":"Lesotho","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"1999","Asset Recovery End":"2004","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Successful collaboration of OLAF [European Anti-Fraud Office] in prosecuting the European companies involved; mutual legal assistance from Switzerland in the prosecutions (Source:  LL Thetsane and GH Penzhorn SC, \u0022Case Study: The Lesotho bribery prosecutions,\u0022 presented at Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities, Rabat, May 14-16, 2007); World Bank investigation and debarment of involved companies, Acres International and Lahmeyer International GmbH (Source: World Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, which noted \u0022Once the indictments [in the case] were announced in mid-1999, the World Bank provided extensive evidentiary support to the Lesotho prosecutors and made bank staff available for interviews.\u0022)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$1,894,750","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"On April 7, 2004, Lahmeyer International GmbH (Germany)\u0027s conviction was upheld by the Lesotho Court of Appeal and fined R12 million. (Source: In the Matter between Lahmeyer International GmbH (Appellant) and The Crown (Respondent), C of A (CRI) 6 OF 2002 (April 7, 2004)).  The case arose out of the Lesotho Highlands Water Project, which the Lesotho Court of Appeal as \u0022[0]ne of the biggest and most ambitious dam projects in the world, which entailed inter alia the construction of the Katse Dam in a remote and inaccessible part of the highlands of Lesotho.\u0022  (Source: In the matter between: Ephraim Masupha Sole and The Crown, Lesotho Court of Appeals, Case (CRI) 5 OF 2002, Judgment dated April 13, 2003).  According to the 2003 Lesotho Court of Appeal judgment, the High Court of Lesotho had found Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, guilty of accepting bribes from various multinational companies that were attempting to secure contracts related to the project.  In an earlier dispute involving Mr. Sole, the government hired Ernst and Young, whose audit discovered that Mr. Sole had Swiss bank accounts into which the project contractors and consultants had placed large sums of money.  Four multinational companies were convicted or pleaded guilty in the case, including Acres International Limited. (Please see Lesotho Highlands Water Project entries.)","Disposition of Criminal Case(s)":"According to the Lesotho Court of Appeal, Mr. Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, was found guilty of accepting bribes from various multinational companies in connection with the Lesotho Highlands Water Project.  (Source: In the matter between: Ephraim Masupha Sole and The Crown, Lesotho Court of Appeals, Case (CRI) 5 OF 2002, Judgment dated April 13, 2003).  According to the Lesotho Court of Appeal, two other Lesotho officials, Reatile Mochebelele and Letiafuoa Molano, were also found guilty of accepting bribes. (Source: R v Mochebelele and Another (C of A (CRI) 02\/08) [2008] LSCA 30 (17 October 2008)).  Four foreign companies were convicted or pleaded guilty in Lesotho to corruption related charges:  Acres International Limited (Canada);  Lahmeyer International GmbH (Germany); Spie Batignolles (now Schneider Electric SA, France), and Impregilo SpA (Italy) (and Jacobus Michiel Du Plooy (Impregilo intermediary).  (Sources: In the matter between: Schneider Electric S.A. (formally Spie Batignolles) (Applicant) and Director of Public Prosecutions (Respondent), High Court of Lesotho, CRI\/APN\/751\/2003; In the Matter between Lahmeyer International GmbH (Appellant) and The Crown (Respondent), C of A (CRI) 6 OF 2002 (April 7, 2004); Crown v Impregilo Spa (Registration Number 104217) Tribunal of Milan (CRI\/T\/174\/2004 CIV\/APN\/437\/05) [2006] LSHC 48 (3 February 2006); and Acres International Limited v The Crown, Lesotho Court of Appeal, case number C of A (CRI) 8 of 2002. Judgment of August 15, 2003.)","Jurisdiction of Origin: Investigative Agency":"European Anti-Fraud Office (OLAF) ","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions of Lesotho","Jurisdiction of Origin: Courts Involved":"High Court of Lesotho; Court of Appeal of Lesotho ","Jurisdiction of Asset Recovery: Investigative Agency":"European Anti-Fraud Office (OLAF)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions of Lesotho","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Lesotho; Court of Appeal of Lesotho","Documents":"","Sources ":"In the Matter between Lahmeyer International GmbH (Appellant) and The Crown (Respondent), C of A (CRI) 6 OF 2002 (April 7, 2004), accessed at http:\/\/www.saflii.org\/ls\/cases\/LSHC\/2004\/60.pdf; In the Matter between Ephraim Masupha Sole and the Crown, in the Appeal Court of Lesotho, C. of A. (CRI) 5 of 2002, CRI\/T\/111\/91, Judgment dated April 13, 2003; \u0022Case Study: The Lesotho bribery prosecutions,\u0022 Paper presented by LL Thetsane and GH Penzhorn SC, at the Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities,\u0022 Rabat, May 14-16, 2007. World Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,contentMDK:21116129~pag... European Anti-Fraud Office Press Release, \u0022Three European Companies Guilty in African Aid Fraud Case,\u0022 October 3, 2006, accessed at http:\/\/ec.europa.eu\/anti_fraud\/cases\/aid_en.html. Lesotho Highlands Water Project, at http:\/\/ipocafrica.org which also provides a list and links to relevant documents.\n"},{"Case ID":"ARW-115","Case Title (Name of Public Official or Entity Allegedly Involved)":"Lesotho Highlands Water Project (Italy)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Italy","Position of Public Official(s) (yrs in office)":"Chief executive of the Lesotho Highlands Development Agency (Masupha Ephraim Sole, 1986-1995) and former delegates of Lesotho on the Highlands Water Commission (Reatile Mochebelele and Letiafuoa Molapo); Acres International Limited (Canada); Lahmeyer International GmbH (Germany); Impregilo SpA (Italy); Jacobus Michiel Du Plooy (Impregilo intermediary); Spie Batignolles (France)","Jurisdiction of Asset Recovery":"Lesotho","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"1999","Asset Recovery End":"2006","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Successful collaboration of OLAF [European Anti-Fraud Office] in prosecuting the European companies involved; mutual legal assistance from Switzerland in the prosecutions (Source:  LL Thetsane and GH Penzhorn SC, \u0022Case Study: The Lesotho bribery prosecutions,\u0022 presented at Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities, Rabat, May 14-16, 2007); World Bank investigation and debarment of involved companies, Acres International and Lahmeyer International GmbH (Source: World Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, which noted \u0022Once the indictments [in the case] were announced in mid-1999, the World Bank provided extensive evidentiary support to the Lesotho prosecutors and made bank staff available for interviews.\u0022)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$2,367,450","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In 2006, Impregilo SpA (Italy) pleaded guilty and was fined R15 million. (Jacobus Michiel Du Plooy, an intermediary for Impregilo also pleaded guilty and was fined.) (Sources: Routledges Incorporated t\/a Routledge Modise Moss Morris v Crown; Crown v Impregilo Spa (Registration Number 104217) Tribunal of Milan (CRI\/T\/174\/2004 CIV\/APN\/437\/05) [2006] LSHC 48 (3 February 2006).  The case arose out of the Lesotho Highlands Water Project, which the Lesotho Court of Appeal as \u0022[0]ne of the biggest and most ambitious dam projects in the world, which entailed inter alia the construction of the Katse Dam in a remote and inaccessible part of the highlands of Lesotho.\u0022  (Source: In the matter between: Ephraim Masupha Sole and The Crown, Lesotho Court of Appeals, Case (CRI) 5 OF 2002, Judgment dated April 13, 2003).  According to the 2003 Lesotho Court of Appeal judgment, the High Court of Lesotho had found Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, guilty of accepting bribes from various multinational companies that were attempting to secure contracts related to the project.  In an earlier dispute involving Mr. Sole, the government hired Ernst and Young, whose audit discovered that Mr. Sole had Swiss bank accounts into which the project contractors and consultants had placed large sums of money.  Four multinational companies were convicted or pleaded guilty in the case, including Acres International Limited.  (Please see Lesotho Highlands Water Project entries.)","Disposition of Criminal Case(s)":"According to the Lesotho Court of Appeal, Mr. Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, was found guilty of accepting bribes from various multinational companies in connection with the Lesotho Highlands Water Project.  (Source: In the matter between: Ephraim Masupha Sole and The Crown, Lesotho Court of Appeals, Case (CRI) 5 OF 2002, Judgment dated April 13, 2003).  According to the Lesotho Court of Appeal, two other Lesotho officials, Reatile Mochebelele and Letiafuoa Molano, were also found guilty of accepting bribes. (Source: R v Mochebelele and Another (C of A (CRI) 02\/08) [2008] LSCA 30 (17 October 2008)).  Four foreign companies were convicted or pleaded guilty in Lesotho to corruption related charges:  Acres International Limited (Canada);  Lahmeyer International GmbH (Germany); Spie Batignolles (now Schneider Electric SA, France), and Impregilo SpA (Italy) (and Jacobus Michiel Du Plooy (Impregilo intermediary).  (Sources: In the matter between: Schneider Electric S.A. (formally Spie Batignolles) (Applicant) and Director of Public Prosecutions (Respondent), High Court of Lesotho, CRI\/APN\/751\/2003; In the Matter between Lahmeyer International GmbH (Appellant) and The Crown (Respondent), C of A (CRI) 6 OF 2002 (April 7, 2004); Crown v Impregilo Spa (Registration Number 104217) Tribunal of Milan (CRI\/T\/174\/2004 CIV\/APN\/437\/05) [2006] LSHC 48 (3 February 2006); and Acres International Limited v The Crown, Lesotho Court of Appeal, case number C of A (CRI) 8 of 2002. Judgment of August 15, 2003.)","Jurisdiction of Origin: Investigative Agency":"European Anti-Fraud Office (OLAF)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions of Lesotho","Jurisdiction of Origin: Courts Involved":"High Court of Lesotho; Court of Appeal of Lesotho ","Jurisdiction of Asset Recovery: Investigative Agency":"European Anti-Fraud Office (OLAF)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions of Lesotho","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Lesotho; Court of Appeal of Lesotho","Documents":"","Sources ":"Routledges Incorporated t\/a Routledge Modise Moss Morris v Crown; Crown v Impregilo Spa (Registration Number 104217) Tribunal of Milan (CRI\/T\/174\/2004 CIV\/APN\/437\/05) [2006] LSHC 48 (3 February 2006), accessed at http:\/\/www.saflii.org\/ls\/cases\/LSHC\/2006\/48.pdf; In the Matter between Ephraim Masupha Sole and the Crown, in the Appeal Court of Lesotho, C. of A. (CRI) 5 of 2002, CRI\/T\/111\/91, April 2, 3, and 14, 2003; \u0022Case Study: The Lesotho bribery prosecutions,\u0022 Paper presented by LL Thetsane and GH Penzhorn SC, at the Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities,\u0022 Rabat, May 14-16, 2007. World Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,contentMDK:21116129~pag... European Anti-Fraud Office Press Release, \u0022Three European Companies Guilty in African Aid Fraud Case,\u0022 October 3, 2006, accessed at http:\/\/ec.europa.eu\/anti_fraud\/cases\/aid_en.html. Lesotho Highlands Water Project, at http:\/\/ipocafrica.org which also provides a list and links to relevant documents.\n"},{"Case ID":"ARW-117","Case Title (Name of Public Official or Entity Allegedly Involved)":"Luis Roldan","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Spain","Position of Public Official(s) (yrs in office)":"Head of Guardia Civil (1986-1994)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1986","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Unknown, but Mr. Roldan\u0027s case received international attention when he was captured in Laos after ten months as a fugitive.  (Source: New York Times, \u0022Fugitive returned to Spain,\u0022 March 1, 1995.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$15,000,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"The Swiss Ministry of Foreign Affairs noted that $15 million had been returned to Spain in Mr. Roldan\u0027s case.  (Source: Swiss Ministry of Foreign Affairs, September 30, 2009.)","Disposition of Criminal Case(s)":"According to a Spanish tribunal, Mr. Roldan was sentenced in February 1998 by the Madrid Provincial Court to 28 years in prison on charges of embezzling public funds, bribery, embezzlement and tax fraud. (Source: http:\/\/www.tribunalconstitucional.es\/en\/jurisprudencia\/Pages\/Auto.aspx?c...).","Jurisdiction of Origin: Investigative Agency":"The Committee of Inquiry, House of Representatives","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Origin: Courts Involved":"Madrid Provincial Court","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"","Sources ":"Swiss Ministry of Foreign Affairs, September 30, 2009; Recurso e amparo interpuesto por don Luis Roldan Ibanez, Tribunal Constitucional de Espana, Seccion Cuarta, Auto 39\/2003, de 10 de Febrero de 2003, accessed at http:\/\/www.tribunalconstitucional.es\/en\/jurisprudencia\/Pages\/Auto.aspx?c.... BBC News, \u0022Spanish police chief\u0027s $14m costs him 28 years,\u0022 February 26, 1998; New York Times, \u0022Fugitive returned to Spain,\u0022 March 1, 1995; Constitucion Espanola, Art. 76 synopsis on Legislative Development, accessed at http:\/\/www.congreso.es\/consti\/constitucion\/indice\/sinopsis\/sinopsis.jsp?...\n"},{"Case ID":"ARW-118","Case Title (Name of Public Official or Entity Allegedly Involved)":"Mabey \u0026 Johnson (Iraq)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United Kingdom","Position of Public Official(s) (yrs in office)":"Saddam Hussein (President, 1979-2003)","Jurisdiction of Asset Recovery":"Iraq [Development Fund for Iraq]","Jurisdiction of Asset Description":"","Asset Recovery Start":"2007","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Restitution was paid to the Development Fund for Iraq.","Contributing Factors in Asset Recovery":"The Serious Fraud Office cited Mabey and Johnson\u0027s guilty plea and cooperation.  (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd sentencing,\u0022 September 25, 2009.)   The SFO also noted that \u0022A Development Fund for Iraq was set up internationally and payments in Oil for Food cases are made to that fund.  There is therefore an international mechanism for compensation.\u0022 (Source: UK House of Commons International Development, Financial Crime and Development, Eleventh Report of Session 2010-12 (15 November 2011), Volume 1, at Ev38.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$1,002,790","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Restitution was paid to the Development Fund for Iraq, which was established for payments in Oil for Food cases.","Case Summary":"According to information presented by the Serious Fraud Office to the UK Parliamentary Committee on International Development, the sums ordered against Mabey and Johnson were returned to Iraq through the Development Fund for Iraq. (Source:  UK House of Commons International Development, Financial Crime and Development, Eleventh Report of Session 2010-12, Volume 1, at Ev38.)  On September 25, 2009, Mabey and Johnson was ordered to pay in reparations of GBP 618,000 to Iraq, for its activities in contravention of United Nations sanctions against Iraq.  (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd sentencing,\u0022 September 25, 2009, and Prosecution Opening Notes.)  In February 2011, the Serious Fraud Office announced the conviction of two former directors of Mabey \u0026 Johnson, and included mention that the company had paid GBP 618,000 to the Iraq Reconstruction Fund [also known as the Development Fund for Iraq.].  (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson directors made illegal payments to Sadam Hussein\u0027s Iraq to gain contract,\u0022 February 10, 2011.)   On February 23, 2011, Richard Charles Edward Forsyth, former managing director, was ordered to pay prosecution costs of GBP75,000 (US$121,241) and David Mabey, former sales director, was ordered to pay prosecution costs of GBP125,000 (US$202,069).  No monetary penalty was assessed against a third executive, Richard Gledhill, former sales manager. (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd: Former executives jailed for helping finance Saddam Hussein\u0027s government,\u0022 February 23, 2011.)","Disposition of Criminal Case(s)":"Unknown as to Iraqi Public Officials.  According to a September 25, 2009 press release by the UK\u0027s Serious Fraud Office, Mabey \u0026 Johnson appeared before the Southwark Crown Court that day to be sentenced for admitted offences of overseas corruption offences and breaching UN sanctions. (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd sentencing,\u0022 September 25, 2009.)  The Serious Fraud Office also issued a press release on February 11, 2011, accouncing the conviction of two former Mabey \u0026 Johnson directors in the case.  (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson directors made illegal payments to Sadam Hussein\u0027s Iraq to gain contract,\u0022 February 10, 2011.)","Jurisdiction of Origin: Investigative Agency":"UK Serious Fraud Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service","Jurisdiction of Origin: Courts Involved":"Southwark Crown Court","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd sentencing,\u0022 September 25, 2009, and Prosecution Opening Notes, posted at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-20... UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson directors made illegal payments to Sadam Hussein\u0027s Iraq to gain contract,\u0022 February 10, 2011 and UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd: Former executives jailed for helping finance Saddam Hussein\u0027s government,\u0022 February 23, 2011; UK House of Commons International Development, Financial Crime and Development, Eleventh Report of Session 2010-12 (15 November 2011), Volume 1, at Ev38, accessed at http:\/\/www.publications.parliament.uk\/pa\/cm201012\/cmselect\/cmintdev\/847\/...\n"},{"Case ID":"ARW-119","Case Title (Name of Public Official or Entity Allegedly Involved)":"Mabey \u0026 Johnson (Jamaica)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United Kingdom","Position of Public Official(s) (yrs in office)":"Unspecified","Jurisdiction of Asset Recovery":"Jamaica","Jurisdiction of Asset Description":"","Asset Recovery Start":"2007","Asset Recovery End":"","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified but cooperation in the investigation","Contributing Factors in Asset Recovery":"The Serious Fraud Office cited Mabey and Johnson\u0027s guilty plea and cooperation.  (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd sentencing,\u0022 September 25, 2009.) ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$225,546","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to to a UK Parliamentary committee report, the Serious Fraud Office informed the committee that it was the agency\u0027s understanding that Mabey and Johnson had made reparation payments to \u0022the Jamaican customer.\u0022  (Source: UK House of Commons International Development, Financial Crime and Development, Eleventh Report of Session 2010-12, Volume 1, at Ev38.)  On September 25, 2009, Mabey and Johnson was ordered to pay in reparations of GBP 139,000 to Jamaica, for bribes paid to a Jamaican official.  (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd sentencing,\u0022 September 25, 2009, and Prosecution Opening Notes).","Disposition of Criminal Case(s)":"Unknown as to Jamaican Public Officials.  Unknown as to Ghanian public officials.  According to a September 25, 2009 press release by the UK\u0027s Serious Fraud Office, Mabey \u0026 Johnson appeared before the Southwark Crown Court that day to be sentenced for admitted offences of overseas corruption offences and breaching UN sanctions. (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd sentencing,\u0022 September 25, 2009.)","Jurisdiction of Origin: Investigative Agency":"UK Serious Fraud Office ","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service","Jurisdiction of Origin: Courts Involved":"Southwark Crown Court","Jurisdiction of Asset Recovery: Investigative Agency":"Director of Public Prosecutions, Office of the Contractor General","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd sentencing,\u0022 September 25, 2009, and Prosecution Opening Notes, posted at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-20... UK House of Commons International Development, Financial Crime and Development, Eleventh Report of Session 2010-12 (15 November 2011), Volume 1, at Ev38, accessed at http:\/\/www.publications.parliament.uk\/pa\/cm201012\/cmselect\/cmintdev\/847\/...\n"},{"Case ID":"ARW-121","Case Title (Name of Public Official or Entity Allegedly Involved)":"Mansoor ul-Haq [also spelled Mansur ul Haq]","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Pakistan","Position of Public Official(s) (yrs in office)":"Chief of Naval Staff (Unspecified - 1997)","Jurisdiction of Asset Recovery":"Pakistan [mention of illegal foreign assets]","Jurisdiction of Asset Description":"Undertaking Recovery Effort","Asset Recovery Start":"1999","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Letter of Request","Basis for Intl Cooperation":"28 U.S.C. Section 1782 [Letter of Request from Pakistan to U.S.]","Contributing Factors in Asset Recovery":"\u0022legal assistance from foreign expert organizations which led to a major breakthrough towards collection of concrete evidence and discovery of his illegal foreign assets.\u0022   (Source: Case study #16 \u0022Mansoor ul-Haq\u0022 by the National Accountability Bureau of Pakistan, accessed at http:\/\/www.nab.gov.pk\/Downloads\/Case_studies\/mansoorulhaq.pdf.)","Status of Asset Recovery ":"Completed (in part) and Ongoing (in part)","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$6,279,200","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a case study by Pakistan\u0027s National Accountability Bureau (NAB), \u0022After NAB\u0027s inception in 1999, fresh investigations into the alleged kickbacks of the accused in collaboration with legal assistance from foreign expert organizations which led to a major breakthrough towards collection of concrete evidence and discovery of his illegal foreign assets. The former admiral was arrested by U.S. authorities on 17 April 2001 and a reference back in his home country was filed against him in Accountability Court, Rawalpindi on 12 May 2001.  2. The accused was indicted by court on 22 October.\u0022  The case study also notes that Mr. Mansoor ul-Haq \u0022paid U.S. $6.2792 million as first installment of his Plea-Bargained money through safe deposits of Fatima Trust, which is owned members of his family through an off shore company, Messer. Moylegrove, registered in the Isle of Jersey.\u0022  Mr. Mansoor ul-Haq had been charged with receiving illegal commissions and kick-backs. The total plea amount was $7.5 million. Remaining sum was to be paid within 15 months.  (Source: Case study #16, accessed at http:\/\/www.nab.gov.pk\/Downloads\/Case_studies\/mansoorulhaq.pdf; on U.S. assistance, see In re: Letter of Request from the Government of Pakistan for Assistance in the Investigation of Adm. (R) Mansur ul Haq, Case No. 1:01-cv-00164-SS (W.D. Tex.), Motion by United States for order pursuant to Title 28, U.S.C. 1782 filed on March 9, 2001 and Order granting motion for order pursuant to Title 28, U.S.C. 1782, filed on March 19, 2001.)","Disposition of Criminal Case(s)":"According to a case study posted on the website of Pakistan\u0027s National Accountability Bureau, Mr. Mansoor ul-Haq had been charged with corruption related offenses and entered into a settlement agreement with authorities.  (Source: Case study #16, accessed at http:\/\/www.nab.gov.pk\/Downloads\/Case_studies\/mansoorulhaq.pdf, last accessed on May 9, 2011.)","Jurisdiction of Origin: Investigative Agency":"National Accountability Bureau","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"National Accountability Bureau","Jurisdiction of Origin: Courts Involved":"Accountability Court, Riwalpindi","Jurisdiction of Asset Recovery: Investigative Agency":"National Accountability Bureau","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"National Accountability Bureau (Pakistan); U.S. Attorney for the Western District of Texas [Letter of Request from Pakistan]","Jurisdiction of Asset Recovery: Courts Involved":"Accountability Court, Riwalpindi (Pakistan); U.S. District Court for the Western District of Texas [Letter of Request from Pakistan]","Documents":"","Sources ":"Case study #16, \u0022Mansoor ul-Haq\u0022 by the National Accountability Bureau of Pakistan and posted at its website: http:\/\/www.nab.gov.pk\/Downloads\/Case_studies\/mansoorulhaq.pdf; \nIn re:  Letter of Request from the Government of Pakistan for Assistance in the Investigation of Adm. (R) Mansur ul Haq, Case No. 1:01-cv-00164-SS (W.D. Tex. 2001), Motion by United States for Order pursuant to Title 28, U.S.C. 1782 filed on March 9, 2001 and Order granting motion for order pursuant to Title 28, U.S.C. 1782, filed on March 19, 2001; \nBBC News, \u0022Former head of Pakistan navy disciplined,\u0022 January 31, 2002, posted at http:\/\/news.bbc.co.uk\/2\/hi\/south_asia\/1792779.stm.\n"},{"Case ID":"ARW-122","Case Title (Name of Public Official or Entity Allegedly Involved)":"Manuel Antonio Noriega","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Panama","Position of Public Official(s) (yrs in office)":"Commander, Panama Defense Forces (1983-1989)","Jurisdiction of Asset Recovery":"France","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.18, Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture  ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified, but Panama was Partie Civile in the French prosecution","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"N\/A","Case Summary":"On July 7, 2010, Mr. Noriega was convicted in Paris of money laundering of criminal drug proceeds received while he was commander of the Panama Defense Forces.  He was ordered to forfeit 2.2 million Euros (U.S.$2.8 million) that had been frozen in his French bank accounts.  Reuters reported that the court also ordered EUR 1 million (approx. U.S. $1,026,000) to be paid in damages to Panama.  Mr. Noriega had originally been convicted in absentia in 1999 in France, but retried after completion of his sentence in U.S. and extradition to France.  Mr. Noriega had unsuccessfully contested his extradition from the United States.  Panama had been a \u0022partie civile\u0022 (civil party) in the criminal case. (Source: Administration des Douanes et Droits Indirects c\/ NORIEGA, Republique francaise, Au nom du Peuple francais, Tribunal de Grande Instance de Paris, 11eme chambre\/1, No d\u0027affaire : 8935669013 Jugement du : 7 juillet 2010 no : 14.)","Disposition of Criminal Case(s)":"According to the July 7, 2010 decision by a Paris trial court, Mr. Noriega was convicted money laundering of criminal drug proceeds received while he was commander of the Panama Defense Forces. (Source: Administration des Douanes et Droits Indirects c\/ NORIEGA, Republique francaise, Au nom du Peuple francais, Tribunal de Grande Instance de Paris, 11eme chambre\/1, No d\u0027affaire : 8935669013 Jugement du : 7 juillet 2010 no : 14.)   According to the U.S. 11th Circuit Court of Appeals, Mr. Noriega was also convicted in the U.S. on eight drug-related counts.  (Source: US v. Noriega, Nos. 92-4687, 96-4471 (11th Cir.), Judgment dated July 7, 1997.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Public Prosecutor","Jurisdiction of Asset Recovery: Courts Involved":"Tribunal de Grande Instance de Paris, 11th Chamber","Documents":"","Sources ":"Administration des Douanes et Droits Indirects c\/ NORIEGA, Republique francaise, Au nom du Peuple francais, Tribunal de Grande Instance de Paris, 11eme chambre\/1, No d\u0027affaire : 8935669013 Jugement du : 7 juillet 2010 no : 14; David Jolly, \u0022French court sentences Noriega to 7 years,\u0022 New York Times, July 7, 2010. See also, U.S. v. Noriega, et al, Case No. 1:88-cr-00079-WMH (S.D. Fla), please note that many documents are missing from docket; U.S. v. Noriega, 746 F. Supp. 1511 (11th Circuit Court, affirming conviction and denying new trial, decision dated July 7, 1997.)\n"},{"Case ID":"ARW-125","Case Title (Name of Public Official or Entity Allegedly Involved)":"Maria Carolina Nolasco (also referred to as Carolina Nolasco) \/ Brazil - New York Money Transmitters Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Brazil","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"2007","UNCAC Offenses Implicated":"Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Non-Conviction Based Confiscation ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Close cooperation between U.S. and Brazilian authorities; underlying case triggered by New York County District Attorney\u0027s Office investigation into black market money transmitters. (Source: Decennial Report of the District Attorney, County of New York, 2000-2009, \u0022Merchant\u0027s Bank\/Valley National Bank, at 131.)   ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"As described in a report highlighting its work from 2000-2009, \u0022The District Attorney\u0027s Office, as part of a 2002 investigation into unlicensed money transmissions through New York, discovered that more than 60 people, all Brazilian citizens and all foreign-based money transmitters, were operating unlicensed money transmission businesses in New York County. The 60 Brazilians accomplished their crimes using accounts at Merchant\u0027s Bank \/ Valley National Bank in Manhattan, and then transmitted the funds to other accounts which were designated by their customers. In order to facilitate this criminal activity, the individuals \u0022employed\u0022 Carolina Nolasco, a corrupt employee of Valley National Bank, via bribery payments to manage their accounts and attend to their business interests in New York. The corporate defendants were chiefly offshore shell corporations that were used by the individual defendants.\u0022 (Source: Decennial Report of the District Attorney, County of New York, 2000-2009, \u0022Merchant\u0027s Bank\/Valley National Bank, at 131.)   Maria Carolina Nolasco was arrested in 2002 and, in U.S. District Court for the District of New Jersey, pleaded guilty to money laundering.  She also agreed to forfeit over $21 million held in 39 bank accounts held at Merchants Bank, where she had worked.  The funds were then turned over to the New York County District Attorney\u0027s office (which had initiated the investigation) for civil asset forfeiture.  The NY County District Attorney\u0027s office, in turn, transferred the funds to the custody of the Department of Justice, which filed a civil asset forfeiture action in the U.S. District Court for the District of Columbia for the funds which Brazil was seeking return.  (Sources: U.S. v. Nolasco, Case No. 04-cr-617 (D.N.J.); Morgenthau v. Avion Resources Ltd., et al, 898 N.E.2d 929 (NY 2008); Brief for the United States in Opposition, in Harber Corporation, et al v. U.S., U.S. SCt, 09-1389.  Unable to locate the name and documents of the District of Columbia civil forfeiture case.","Disposition of Criminal Case(s)":"According to a letter by the United States Attorney for the District of New Jersey that was filed in U.S. District Court for the District of New Jersey on October 4, 2004, Ms. Nolasco pleaded guilty to charges of operating a money transmitting business without a license.  (Source:  US v. Nolasco, Case No.  2:04-cr-617-JAG (D.N.J.), Letter by United States Attorney for the District of New Jersey filed on October 4, 2004.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Immigration and Customs Enforcement; Internal Revenue Service, Criminal Division; Drug Enforcement Administration","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"New York County District Attorney\u0027s Office; US Attorney for the District of New Jersey; US Department of Justice","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of New Jersey","Documents":"","Sources ":"U.S. v. Nolasco, Case No. 04-cr-617 (D.N.J.), Plea agreement filed on October 4, 2004, Consent Order for Preliminary Forfeiture, filed on December 17, 2004, Amended Order Amending Preliminary Order of Forfeiture, filed on June 8, 2006; \nMorgenthau v. Avion Resources Ltd., et al, 898 N.E.2d 929 (NY 2008); \nBrief for the United States in Opposition, in Harber Corporation, et al v. U.S., SCt, 09-1389.  (District of Columbia Civil Asset Forfeiture Case -- Case name and information - unable to obtain.); \nDecennial Report of the District Attorney, County of New York, 2000-2009, \u0022Merchant\u0027s Bank\/Valley National Bank, at 131, accessed at http:\/\/manhattanda.org\/whatsnew\/inthenews\/2009-12-30.pdf.\n"},{"Case ID":"ARW-126","Case Title (Name of Public Official or Entity Allegedly Involved)":"Michael Misick","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Turks and Caicos","Position of Public Official(s) (yrs in office)":"Prime Minister (2006-2009); Chief Minister (2003-2006); Legislative Council (1991-?)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\n\n\t\t\tBeginning in 2010, along with the criminal investigation, civil recovery efforts by law firm of Edwards Angell Palmer \u0026 Dodge were taking place in the Turks and Caicos. \u00a0(Sources: Quarterly Statement and Annual Review from the Governor [Gordon Wetherell], dated September 9, 2010; Attorney General v. Salt Cay Devco Limited, Salt Cay Estates Limited, Salt Cay Golf Club Limited, No. CL-5\/2010, Supreme Court of the Turks and Caicos Islands, filed April 23, 2010. \u00a0See also, The Turks and Caicos Islands, Government Information Service Press Release, \u0022Special Prosecutor Helen Garlick Introduced to TCI,\u0022 posted at http:\/\/www.tcgov.tc\/info--ID--500.html.) \u00a0According to the Turks and Caicos Sun, the publication had obtained documents which stated: \u0022on June 23rd, 2011, Chief Justice His Lordship Gordon Ward made the order to freeze all of Misick\u2019s assets, including bank accounts here and overseas, his personal residence in Providenciales, parcels of land throughout the Turks and Caicos Islands, two condominiums, a cinema in Providenciales [ \u00a0] and several credit cards.\u0022 \u00a0 (Source: Hayden Boyce, Sun Publisher and Editor-in- Chief, \u0022Michael Misick\u0027s Assets Frozen World-wide,\u0022 Turks and Caicos Sun, posted July 4, 2011.)\n\n\t\t\t\u00a0\n\n\t\t\tAccording to secondary sources, Mr. MIsick\u0027s trial is ongoing as of June 2016, when he was also granted permission to travel to the Dominican Republic for medical services. (Source: Caribbean News Now, \u0022\u0022Corruption-accused former Turks and Caicos premier to travel for medical attention,\u0022 June 6, 2016.)\n\n\t\t\t\u00a0\n\n\t\t\tIn a related case, according to a press release issued jointly by the Turks and Caicos Attorney General, Director of Public Prosecutions and the Special Investigation and Prosecution Team, Richard Padgett pleaded guilty on May 31, 2013 to bribery and conspiracy. \u00a0The TCI Government also announced that it had settled all civil claims and proceedings against Mr. Padgett and his companies, including \u201ccivil claims arising from the Third Turtle Development referred to in the Report of the Commission of Inquiry, and a separate civil claim arising in relation to Crown Land on East Caicos acquired by a company controlled by Richard Padgett. \u00a0Under the settlement, Mr Padgett has transferred to TCIG land which has been valued at approximately US$7m, and has made a cash contribution of $75,000 to the costs of investigating the claims. The land transferred to TCIG includes about 540 acres of former Crown Land on East Caicos (although some of this land is charged to a bank for about US$1.5m), and two parcels at North West Point and Richmond Commons on Providenciales totalling about 10 acres.\u201d \u00a0(Source: \u0022TCI criminal and civil case update,, issued jointly by the Turks and Caicos Attorney General, Director of Public Prosecutions and the Special Investigation and Prosecution Team, gov.uk, May 31, 2013, accessed at https:\/\/www.gov.uk\/government\/world-location-news\/tci-criminal-and-civil...).\u00a0\n\n\t\t\t\u00a0\n\n\n\u00a0","Disposition of Criminal Case(s)":"According to a January 2014 statement by the Governor\u0027s Office of Turks and Caicos, \u0022Mr Misick faces charges of conspiracy to receive bribes, conspiracy to defraud government, and money laundering related to his time in office.report by the Governor of Turks and Caicos.\u0022  (Source: Governor\u0027s Office Waterloo Grand Turk, \u0022Former Premier of the TCI, Michael Misick, was released on conditional bail by the TCI Supreme Court today, Monday, 13 January 2014.); As of June 2016, his trial was ongoing. (Source: Caribbean News Now, \u0022Corruption-accused former Turks and Caicos premier to travel for medical attention,\u0022 June 16, 2016.)","Jurisdiction of Origin: Investigative Agency":"Special Investigation and Prosecution Team, Special Prosecutor; Edwards Angell Palmer \u0026 Dodge law firm (civil asset recovery)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Special Investigation and Prosecution Team, Special Prosecutor; Edwards Angell Palmer \u0026 Dodge law firm (civil asset recovery)","Jurisdiction of Origin: Courts Involved":"Supreme Court of the Turks and Caicos Islands (against the Salt Cay developers)","Jurisdiction of Asset Recovery: Investigative Agency":"Special Investigation and Prosecution Team, Special Prosecutor; Edwards Angell Palmer \u0026 Dodge law firm (civil asset recovery)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Special Investigation and Prosecution Team, Special Prosecutor ; Edwards Angell Palmer \u0026 Dodge law firm (civil asset recovery)","Jurisdiction of Asset Recovery: Courts Involved":"Supreme Court of the Turks and Caicos Islands (against the Salt Cay developers)","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_AG_v_Salt_Cay_Apr_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Governor_Wetherell_4th_Quarterly_Statement_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Special_Prosecutor_Introduced_Aug_27_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_The Sun_worldwide-freeze-order-posted-Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Misick_UK_SIPT_Update_Oct_4_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_AG_v_Salt_Cay_Apr_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Governor_Wetherell_4th_Quarterly_Statement_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Special_Prosecutor_Introduced_Aug_27_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_The Sun_worldwide-freeze-order-posted-Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Misick_The%20Sun_worldwide-freeze-order-posted-Jul_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_AG_v_Salt_Cay_Apr_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Governor_Wetherell_4th_Quarterly_Statement_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Special_Prosecutor_Introduced_Aug_27_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_The Sun_worldwide-freeze-order-posted-Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Misick_Padgett_UKGOV_PR_May_23_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_AG_v_Salt_Cay_Apr_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Governor_Wetherell_4th_Quarterly_Statement_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Special_Prosecutor_Introduced_Aug_27_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_The Sun_worldwide-freeze-order-posted-Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Misick_Padgett_UKGOV_PR_May_31_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_AG_v_Salt_Cay_Apr_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Governor_Wetherell_4th_Quarterly_Statement_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Special_Prosecutor_Introduced_Aug_27_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_The Sun_worldwide-freeze-order-posted-Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Misick_Charges_Bail_TCI_Gov_Statement_Jan_14_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_AG_v_Salt_Cay_Apr_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Governor_Wetherell_4th_Quarterly_Statement_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Special_Prosecutor_Introduced_Aug_27_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_The Sun_worldwide-freeze-order-posted-Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Misick_TCI_Govt_Statement_Extradition_Jan_7_2014.pdf","Sources ":"\n\tGovernor\u0027s Office Waterloo Grand Turk, \u0022Former Premier of the TCI, Michael Misick, was released on conditional bail by the TCI Supreme Court today, Monday, 13 January 2014, at https:\/\/www.gov.uk\/government\/world-location-news\/former-turks-and-caico...\n\n\t\u00a0\n\n\tGovernment of the Turks and Caicos Islands, \u0022Premier Ewing Welcomes the Return of Michael Misick,\u0022 January 7, 2014, at http:\/\/www.gov.tc\/pressoffice\/?q=latest-news\/premier-ewing-welcomes-retu...\n\n\t\u00a0\n\n\tQuarterly Statement and Annual Review from the Governor [Gordon Wetherell], dated September 9, 2010; Attorney General v. Salt Cay Devco Limited, Salt Cay Estates Limited, Salt Cay Golf Club Limited, No. CL-5\/2010, Supreme Court of the Turks and Caicos Islands, filed April 23, 2010. \u00a0See also, The Turks and Caicos Islands, Government Information Service Press Release, \u0022Special Prosecutor Helen Garlick Introduced to TCI,\u0022 posted at http:\/\/www.tcgov.tc\/info--ID--500.html; Hayden Boyce, Sun Publisher and Editor-in- Chief, \u0022Michael Misick\u0027s Assets Frozen World-wide,\u0022 Turks and Caicos Sun, posted July 4, 2011, accessed at http:\/\/www.suntci.com\/index.php?p=story\u0026id=1793.\n\n\t\u00a0\n\n\tGov.UK, \u0022TCI criminal and civil case update: Issued jointly by the Turks and Caicos Attorney General, Director of Public Prosecutions and the Special Investigation and Prosecution Team,\u0022 May 31, 2013, accessed at https:\/\/www.gov.uk\/government\/world-location-news\/tci-criminal-and-civil...\n\n\t\u00a0\n\n\tGov.UK, \u0022Civil recovery retrieves $19.5m and 2,500 acres with more to come.\u0022 May 23, 2013 accessed at https:\/\/www.gov.uk\/government\/world-location-news\/civil-recovery-retriev...\n"},{"Case ID":"ARW-127","Case Title (Name of Public Official or Entity Allegedly Involved)":"Mohamed Suharto","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Indonesia","Position of Public Official(s) (yrs in office)":"President (1967-1998)","Jurisdiction of Asset Recovery":"Indonesia","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"1998","Asset Recovery End":"2010","UNCAC Offenses Implicated":"Art.17, Art.19","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Civil suit","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"On Appeal","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$307,000,000","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unspecified","Case Summary":"The Government of Indonesia had brought a civil suit against the Suharto family, charging that they misused the Supersemar Foundations\u0027 funds.  Instead of using the funds for its intended purpose of providing scholarships for poor children, the Soehartos were found to have funnelled foundation\u0027s funds to businesses and banks owned by associates of the former president.  According to the Jakarta Post, the Supreme Court announced in a press conference on December 31, 2010 that the Supersemar suit had retrieved Rp. 2.8 trillion (US$307,440,000) for the government.  (Source:  The Jakarta Post, \u0022Supreme Court retrieves Rp 9.43t in 2010,\u0022 December 31, 2010, accessed at http:\/\/www.thejakartapost.com\/news\/2010\/12\/31\/supreme-court-retrieves-rp....)","Disposition of Criminal Case(s)":"According to his January 28, 2008 obituary, Mr. Suharto \u0022managed to escape criminal prosecution for embezzling millions of dollars, possibly billions, by having himself declared mentally incapable to stand trial.\u0022 (Source: Marilyn Berger, \u0022Suharto Dies at 86; Indonesian Dictator Brought Order and Bloodshed,\u0022 New York Times, January 28, 2008.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Origin: Courts Involved":"South Jakarta District Court; High Court; Supreme Court","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"South Jakarta District Court; High Court; Supreme Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Suharto_Obituary_NYTimes_Jan_28_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Suharto_Supersemar_Atty_Genl_Dec_25_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Suharto_Supersemar_Atty_Genl_Oct_16_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Suharto_Supersemar_SCt_Jakarta_Post_Dec_31_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Suharto_Supersemar_Fdn_Jakarta_Post_May_16_2013.pdf","Sources ":"The Jakarta Post, \u0022Supreme Court retrieves Rp 9.43t in 2010,\u0022 December 31, 2010, accessed at http:\/\/www.thejakartapost.com\/news\/2010\/12\/31\/supreme-court-retrieves-rp... Official Website of the Attorney General of the Republic of Indonesia, \u0022Perkara Perdata Yayasan Supersemar\u0022 [Civil fraud case of Supersemar Foundation], October 16, 2009 and \u0022Perkara Gugatan Perdata Pemerintah RITerhadap Mantan Presiden RI HM.Soeharto\/ Yayasan Supersemar\u0022 [Government Civil Suit against former President Soeharto and Supersemar Foundation], December 25, 2007, accessed respectively at http:\/\/www.kejaksaan.go.id\/unit_kejaksaan.php?idu=25\u0026idsu=19\u0026id=1487 and http:\/\/www.kejaksaan.go.id\/unit_kejaksaan.php?idu=25\u0026idsu=19\u0026id=32. [Court decision numbers: The South Jakarta District Court (904\/Pdt.G\/2007\/PN.Jak.Sel) and the Jakarta High Court (465\/PDT\/2008\/PT.DKI)]; Marilyn Berger, \u0022Suharto Dies at 86; Indonesian Dictator Brought Order and Bloodshed,\u0022 New York Times, January 28, 2008, accessed at http:\/\/www.nytimes.com\/2008\/01\/28\/world\/asia\/28suharto.html?scp=2\u0026sq=suh... Jakarta Post, \u0022Soeharto\u0027s foundation told to pay damages,\u0022 May 16, 2013, at http:\/\/www.thejakartapost.com\/news\/2013\/05\/16\/soeharto-s-foundation-told...\n"},{"Case ID":"ARW-128","Case Title (Name of Public Official or Entity Allegedly Involved)":"Moussa Traore","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mali","Position of Public Official(s) (yrs in office)":"President (1979-1991)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1991","Asset Recovery End":"1997","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Unspecified","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"According to Anne Lugon-Moulin, Mali \u0022asked Switzerland if it was willing to pay for the fees of a Swiss lawyer who could represent the interests of the Malian State.  This request was accepted and funded by the [Swiss Agency for Development and Co-operation], which had been operating in Mali for many years....  It was the first time that Switzerland had repatriated assets to an African State, and was also an example of an innovative collaboration between the Federal Department of Justice and the Foreign Affairs Department.\u0022 (Source: Anne Lugon-Moulin, \u0022Asset recovery: concrete challenges for development assistance,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008)).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$2,400,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"Switzerland noted that the Government of Mali spent the funds on rural development programs.","Case Summary":"According to the Swiss Ministry of Foreign Affairs, $2.4 million in assets were returned to Mali.  Switzerland also paid the fees of the Mali lawyer. (Source: Swiss Ministry of Foreign Affairs, September 30, 2009.)  The 1991 Mutual Legal Assistance Treaty request by the Malian government had asked if Switzerland would be willing to pay for a Swiss lawyer who could represent the interests of the Malian State. The request was accepted and funded by the Swiss Agency for Development and Co-operation (SDC).  The Konare government spent the money on rural development programs.  (Source: Anne Lugon-Moulin, \u0022Asset recovery: concrete challenges for development assistance,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (2008)).","Disposition of Criminal Case(s)":"According to the BBC timeline of Mali\u0027s history, Mr. Traore was pardoned in 2002. (Source:  BBC, Timeline: Mali, accessed at http:\/\/news.bbc.co.uk\/2\/hi\/africa\/country_profiles\/1022844.stm, on May 10, 2011.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"","Sources ":"Swiss Ministry of Foreign Affairs, September 30, 2009; \nAnne Lugon-Moulin, \u0022Asset recovery: concrete challenges for development assistance,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008); \nBBC, Timeline: Mali, accessed at http:\/\/news.bbc.co.uk\/2\/hi\/africa\/country_profiles\/1022844.stm, on May 10, 2011.\n"},{"Case ID":"ARW-141","Case Title (Name of Public Official or Entity Allegedly Involved)":"Munari and Rovelli Settlements \/ Vittorio Metta (Judge) \/ IMI Bank Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Italy","Position of Public Official(s) (yrs in office)":"Court of Appeals Judge (Metta, inclusive 1990)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2007","Asset Recovery End":"2007","UNCAC Offenses Implicated":"Art.15, Art.17, Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Cooperation by the U.S. and Italian authorities and sharing of information which enabled the U.S. to link successfully the assets to the defendants although the underlying criminal offenses had taken place over a decade prior to the filing of the complaint for civil asset forfeiture. (Source: Researcher interview, U.S. Immigration and Customs and Enforcement, December 2010.) ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$122,000,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In November 2007, the United States District Court for the Southern District of Florida issued a Final Judgment of Forfeiture against a number of bank and securities accounts, as proceeds, property traceable to proceeds and property involved in foreign public corruption offenses, fraud against a foreign bank, U.S. money laundering offenses, and violations of 18 U.S.C. section 2314 (transportation of stolen goods, moneys, etc.)  The judgment followed settlement agreements by the U.S. and (1) Pier Francesco Munari and Concejo de Capital Hanne, CCH, S.A. and (2) Oscar Rovelli, Angela Rovelli and Primarosa Battistella in which the individuals agreed to forfeit their interests in the properties to the United States in order that the United States could return the properties to Italy for the resolution of pending Italian legal proceedings against them.  According to the U.S. Government complaint, the money laundering scheme involved shell entities or their financial accounts being \u0022set-up in numerous foreign countries, including, but not limited to, the United States, British Virgin Islands, the Cayman Islands, Guernsey, Jersey, Switzerland, Luxembourg, Liechtenstein, Singapore, the Cook Islands, and Costa Rica. Eventually, portions of the fraudulently obtained IMI monies held by these MUNARI controlled entities found their way into financial accounts located in the United States.\u0022  The U.S. returned $122 million to Italy to an escrow account established by an Italian court which had ordered restitution for the victim bank.   (Sources: U.S. v. Proceeds of Crime Transferred to Certain Domestic Financial Accounts, Case No. 07-21791-civ-UU (S.D. Fla.), Verified Complaint for Forfeiture In Rem filed on July 17, 2007 and Final Judgment of Forfeiture filed November 21, 2007); U.S. Department of Justice Press Release, \u0022Money Laundering Forfeiture Complaint Filed against $110 million in Proceeds from Italian Public Corruption Offenses,\u0022 July 16, 2007; Researcher phone interview with investigator, U.S. Immigration and Customs and Enforcement, December 2010.)","Disposition of Criminal Case(s)":"According to the U.S. civil forfeiture complaint, in May 2006, the Italian Supreme Court affirmed Mr. Metta\u0027s conviction for \u0022bribery in judicial acts.\u0022  (Source: U.S. v. Proceeds of Crime Transferred to Certain Domestic Financial Accounts, Case No. 07-21791-civ-UU (S.D. Fla.), Verified Complaint for Forfeiture in Rem (filed July 17, 2007).","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"Supreme Court; Court of Appeal (Rome); Italian Tribunal (Rome)","Jurisdiction of Asset Recovery: Investigative Agency":"Immigration and Customs Enforcement, Office of Investigations in Miami; Department of Justice Criminal Division\u2019s Office of International Affairs and the Justice Department\u2019s Attach\u00e9 in Rome;  Immigration and Customs Enforcement Attach\u00e9 in Rome.","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section;  U.S. Attorney\u2019s Offices for the Southern District of Florida, Asset Forfeiture Division; U.S. Attorney\u0027s Offices for Southern District of California, District of New Jersey and Southern District of New York (ex-parte restraint orders)","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of Florida","Documents":"","Sources ":"U.S. v. Proceeds of Crime Transferred to Certain Domestic Financial Accounts, Case No. 07-21791-civ-UU (S.D. Fla.), Verified Complaint for Forfeiture in Rem (filed July 17, 2007) and Final Judgment of Forfeiture (filed November 21, 2007); \nU.S. Department of Justice Press Release, \u0022Money Laundering Forfeiture Complaint Filed against $110 million in Proceeds from Italian Public Corruption Offenses,\u0022 July 16, 2007; Researcher interview, U.S. Immigration and Customs and Enforcement, December 2010.\n"},{"Case ID":"ARW-144","Case Title (Name of Public Official or Entity Allegedly Involved)":"Omar Bongo","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Gabon","Position of Public Official(s) (yrs in office)":"President (1967-2009)","Jurisdiction of Asset Recovery":"France","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2007","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Ongoing Case, but Transparency International stated that this is the first time French courts allowed such a complaint by nongovernmental organizations to proceed. Source: Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision: The complaint filed by Transparency International France is ruled admissible,\u0022 November 9, 2010.","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"Three non-governmental organizations had filed their \u0022Biens Mal Acquis\u0022 (Improperly acquired property) complaint against Omar Bongo, Denis Sassou Nguesso and Teodoro Obiang and their relatives.  (Source: Supreme Court of France, Case No. 6092, decision of November 9, 2010, L\u0027association Transparence Intenrational France, partie civile, reversing High Court of Paris, section 2, judgment of October 29, 2009.)  With regard to Mr. Bongo and his relatives, the complaint alleged that they had acquired real estate, including thirty-nine properties, seventeen of which are registered in his name.  According to Transparency International, most of the properties are located in Paris\u0027 upscale 16th district; seventy identified bank accounts, eleven of which are registered in name of Omar Bongo, and a fleet of automobiles comprising at least nine vehicles for a total estimated value of EUR 1,493,443.   (Source: Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision, The complaint by Transparence International France is ruled admissible,\u0022 November 9, 2010.)\nAccording to the August 18, 2015 message by President Bongo, on the occasion of the 55th anniversary of the independence of Gabon, he had decided to offer the Gabonese people all income from part of his inheritance to assist in the education and training of the Gabonese youth, the residence of Omar Bongo Ondimba in the capital will be sold to the state to build a university and two Paris properties will be sold to the state and earmarked for the promotion of culture and diplomatic influences of the country. (Source:  Republique Gabonaise, Direction de la communication Presidentielle, August 18, 2015)","Disposition of Criminal Case(s)":"In November 2010, the French Supreme Court held that the criminal complaint filed earlier by Transparency International and other non-governmental organizations against Mr. Bongo may proceed. (Source: Supreme Court of France, Case No. 6092, decision of November 9, 2010, L\u0027association Transparence Intenrational France, partie civile, reversing High Court of Paris, section 2, judgment of October 29, 2009.)","Jurisdiction of Origin: Investigative Agency":"NA","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Investigating Magistrate","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Public Prosecutor","Jurisdiction of Asset Recovery: Courts Involved":"Supreme Court, High Court (Paris)","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bongo_France_SCt_Judgment_Nov_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bongo_France_TransparencyIntl_Sherpa_Press_Release.docx\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bongo_Statement_Aug2015.pdf","Sources ":"\n\tSupreme Court of France, Case No. 6092, decision of November 9, 2010, L\u0027association Transparence International France, partie civile, reversing High Court of Paris, section 2, judgment of October 29, 2009. See also Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision, The complaint by Transparence International France is ruled admissible,\u0022 November 9, 2010, posted at http:\/\/www.transparency.org\/news_room\/latest_news\/press_releases_nc\/2010...\n\n\t\u00a0\n\n\tRepublique Gabonaise, Direction de la communication Presidentielle, August 18, 2015, at www.preidence-gabon.ga\/presse)\n"},{"Case ID":"ARW-145","Case Title (Name of Public Official or Entity Allegedly Involved)":"Omar Bongo \/ Lobbyist Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Gabon","Position of Public Official(s) (yrs in office)":"President (1967-2009)","Jurisdiction of Asset Recovery":"Malta","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2010","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In the aftermath of the February 4, 2010 U.S. Senate Permanent Subcommittee on Investigations hearing and investigation report on Mr. Bongo, Malta press reported that Maltese authorities were investigating alleged transfer of funds by Mr. Bongo\u0027s Washington lobbyist Jeffrey Birrell to that country.  (Source: Malta Today, \u0022Late Gabon President Omar Bongo had [EUR] 7 million Malta bank account,\u0022 May 2, 2010.)  The U.S. Senate Permanent Subcommittee on Investigations Press Release stated that in 2006, $18 million in funds from Gabon were wired to the U.S. corporate bank accounts of a U.S. lobbyist who then distributed the funds within the United States and across the globe as directed by President Bongo in connection with two projects to support his regime, buying U.S.-made armored cars and C-130 military cargo planes.  Among the funds the lobbyist distributed was $9.2 million which he wire transferred to an account for President Omar Bongo - not in Gabon - but in the country of Malta.  (Source: United States Senate, Permanent Subcommittee on Investigations, Committee on Homeland Security and Governmental Affairs, Majority and Minority Staff Report, \u0022Keeping Foreign Corruption Out of the United States: Four Case Histories,\u0022 released in conjunction with the Permanent Subcommittee on Investigations February 4, 2010 Hearing.)","Disposition of Criminal Case(s)":"In November 2010, the French Supreme Court held that the criminal complaint filed earlier by Transparency International and other non-governmental organizations against Mr. Bongo may proceed. (Source: Supreme Court of France, Case No. 6092, decision of November 9, 2010, L\u0027association Transparence Intenrational France, partie civile, reversing High Court of Paris, section 2, judgment of October 29, 2009.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"United States Senate, Permanent Subcommittee on Investigations, Committee on Homeland Security and Governmental Affairs, Majority and Minority Staff Report, \u0022Keeping Foreign Corruption Out of the United States: Four Case Histories,\u0022 released in conjunction with the Permanent Subcommittee on Investigations February 4, 2010 Hearing, posted at http:\/\/hsgac.senate.gov\/public\/index.cfm?FuseAction=Hearings.Hearing\u0026Hea... links to witness testimonies also at same; \nMalta Today, \u0022Late Gabon President Omar Bongo had [EUR] 7 million Malta bank account,\u0022 May 2, 2010.\n"},{"Case ID":"ARW-148","Case Title (Name of Public Official or Entity Allegedly Involved)":"Paulo Maluf (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Brazil","Position of Public Official(s) (yrs in office)":"Governor and Mayor of Sao Paulo (Governor,1979-1983; Mayor, 1993-1996); Legislator (as of 2007)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In April 2014, a New York Supreme Court Appellate Division panel unanimously refused to overturn a lower court decision not to grant Mr. Maluf\u0027s request to have the indictment filed against him dismissed.  (Sources:  Matter of Maluf v Vance 2014 NY Slip Op 02546 Decided on April 15, 2014 Appellate Division, First Department and Mark Thompson, \u0022Brazilian Pol Can\u0027t Shake Indictment in New York,\u0022 Courthouse News Service, April 22, 2014.)  The appellate court held that: \u0022The extraordinary remedy of prohibition is not available to petitioners, who assert that the underlying criminal action violates their statutory and constitutional rights to a speedy trial and their right to due process, or, in the alternative, that the indictment should be dismissed either in furtherance of justice pursuant to CPL 210.40(1) or under principles of international comity. These claims allege errors of law for which petitioners have adequate alternative remedies, including filing pretrial motions in the underlying criminal action and challenging any conviction on appeal [citation omitted]. That petitioners would have to voluntarily leave their home country to appear for arraignment since Brazil will not extradite its own citizens before availing themselves of such remedies does not render them inadequate [citation omitted] Moreover, petitioners have failed to meet their burden of demonstrating a \u0022clear legal right\u0022 to any of the relief sought [ ].\u0022  (Source: Matter of Maluf v Vance 2014 NY Slip Op 02546 Decided on April 15, 2014 Appellate Division, First Department, published at http:\/\/law.justia.com\/cases\/new-york\/appellate-division-first-department....)\nIn April 2012, the New York County Supreme Court had declined to grant Mr. Maluf\u0027s request to have the indictment filed against him dismissed and to have an Interpol arrest warrant lifted. (Source: Matter of Maluf v. Vance, 2012 NY Slip Op 50743(U), April 24, 2012.)  In March 2007, Mr. Maluf, his family members and his associates were indicted by the New York County District Attorney\u0027s Office, which charged them with conspiracy, grand larceny and criminal possession of stolen property.  The indictment alleged that, \u0022The object of the conspiracy was to steal money from the City of Sao Paulo, Brazil, to possess the money in Brazil, New York and elsewhere, and to conceal the existence of the conspiracy and the location of the stolen money. To do this, the conspirators perpetrated an over-invoicing and kick-back scheme involving the municipal construction of an arterial highway in Sao Paulo known as the Avenida Agua Espraiada project. In the course of the conspiracy, stolen proceeds were transferred to a bank account in New York County and, from New York County, to a bank account located in the Bailiwick of Jersey in the Channel Islands. The conspirators also used the bank account in New York County to return stolen proceeds to Brazil, to buy personal items, and to pay for expenses related to Brazilian political campaigns.  During the period from on or about January 1993 to on or about December 1996, PAULO MALUF was Mayor of Sao Paulo. During this period and thereafter, PAULO MALUF directed the over-invoicing scheme, received kick-backs from the scheme amounting to millions of dollars, used secret bank accounts in New York County and the Bailiwick of Jersey to hide and utilize the stolen funds, and was the conspiracy\u2019s principal beneficiary. (Source: The People of the State of New York v. Paulo Maluf, Flavio Maluf, Simeao Damasceno de Oliveira, Joel Guedes Fernandes and Vivaldo Alves, Indictment filed on March 8, 2007, New York State Supreme Court, County of New York.)   Then-District Attorney for New York County, Mr. Robert Morgenthau, wrote that Mr. Maluf\u0027s indictment was among the spin-offs of his office\u0027s investigation into the unlicensed money transmitter, Beacon Hill Service Corporation.  Mr. Morgenthau wrote that $140 million had passed through Mr. Maluf\u0027s principal account at Safra National Bank in Manhattan.  (Source: Robert Morgenthau, \u0022Tax Evasion Nation,\u0022 American Interest, September-October 2008, last accessed on October 1, 2010 at http:\/\/www.the-american-interest.com\/article-bd.cfm?piece=465.)","Disposition of Criminal Case(s)":"According to the March 8, 2007 press release by the New York County District Attorney\u0027s Office, Mr. Maluf was indicted in New York for his alleged conspiracy in embezzlement of public funds and concealment of such funds, and that charges were also pending against him in Brazil. \u00a0(Source: The People of the State of New York v. Paulo Maluf, Flavio Maluf, Simeao Damasceno de Oliveira, Joel Guedes Fernandes and Vivaldo Alves, Indictment filed on March 8, 2007 in New York state Supreme Court, County of New York and New York County District Attorney\u0027s Office, News Release on the Paulo Maluf case, March 8, 2007.) \u00a0According to Agence France Presse, on November 4, 2013, Mr. Maluf\u0027s conviction on \u0022administrative corruption\u0022 was upheld by a Brazilian court. (Source: Agence France Presse, \u0022Graft sentence upheld for ex-Sao Paulo ex-mayor,\u0022 November 4, 2013.)","Jurisdiction of Origin: Investigative Agency":"Ministry of Justice; Federal Police","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General of the State of Sao Paulo, Prosecutor General of the Republic of Brazil","Jurisdiction of Origin: Courts Involved":"Superior Tribunal of Justice","Jurisdiction of Asset Recovery: Investigative Agency":"New York County District Attorney\u0027s Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"New York County District Attorney\u0027s Office","Jurisdiction of Asset Recovery: Courts Involved":"Supreme Court of the State of New York, County of New York, Criminal Term; New York Supreme Court, Appellate Division, First Department","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_New_York_Indictment_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_NY_Indictment_Press_Release_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Swiss_Dept_Justice_Oct_14_2002.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_US_Morgenthau_Tax_Evasion_American_Interest_SepOct_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_Graft_sentence_upheld_Agence_France_Presse_Nov_4_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_New_York_Indictment_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_NY_Indictment_Press_Release_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Swiss_Dept_Justice_Oct_14_2002.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_US_Morgenthau_Tax_Evasion_American_Interest_SepOct_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_US_NY_Appeal_Court_Decision_Apr_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_New_York_Indictment_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_NY_Indictment_Press_Release_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Swiss_Dept_Justice_Oct_14_2002.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_US_Morgenthau_Tax_Evasion_American_Interest_SepOct_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_US_NY_Appeal_Courthouse%20News%20Service_Apr_22_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_New_York_Indictment_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_NY_Indictment_Press_Release_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Swiss_Dept_Justice_Oct_14_2002.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_US_Morgenthau_Tax_Evasion_American_Interest_SepOct_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_Interpol_wanted_Feb_6_2015_1.pdf","Sources ":"\n\tMatter of Maluf v Vance 2014 NY Slip Op 02546 Decided on April 15, 2014 Appellate Division, First Department (also at 2014 WL 1419459); Mark Thompson, \u0022Brazilian Pol Can\u0027t Shake Indictment in New York,\u0022 Courthouse News Service, April 22, 2014, at http:\/\/www.courthousenews.com\/2014\/04\/22\/67222.htm\n\n\t\u00a0\n\n\tMatter of Maluf v. Vance, 2012 NY Slip Op 50743(U), April 24, 2012, accessed at http:\/\/law.justia.com\/cases\/new-york\/other-courts\/2012\/2012-ny-slip-op-5...\n\n\t\u00a0\n\n\tThe People of the State of New York v. Paulo Maluf, Flavio Maluf, Simeao Damasceno de Oliveira, Joel Guedes Fernandes and Vivaldo Alves, Indictment filed on March 8, 2007 in New York State Supreme Court, County of New York, accessed at http:\/\/manhattanda.org\/whatsnew\/press\/2007-03-08%20Maluf%20Indictment%20...\n\n\t\u00a0\n\n\tNew York County District Attorney\u0027s Office, News Release on the Paulo Maluf Case, March 8, 2007, accessed at http:\/\/www.manhattanda.org\/whatsnew\/press\/2007-03-08.shtml 1\/;\u00a0\n\n\t\u00a0\n\n\tRobert Morgenthau, \u0022Tax Evasion Nation,\u0022 American Interest, September-October 2008, accessed at http:\/\/www.the-american-interest.com\/article-bd.cfm?piece=465;\n\n\t\u00a0\n\n\tSee also, Swiss Federal Department of Police and Justice Press Release, \u0022Strengthening co-operation in the fight against crime \/ Brazilian delegation visits Bern,\u0022 October 14, 2002, accessed at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2002\/2002....\n\n\t\u00a0\n\n\tAgence France Presse, \u0022Graft sentence upheld for ex-Sao Paulo ex-mayor,\u0022 November 4, 2013, at http:\/\/www.globalpost.com\/dispatch\/news\/afp\/131104\/graft-sentence-upheld...\n"},{"Case ID":"ARW-149","Case Title (Name of Public Official or Entity Allegedly Involved)":"Paulo Maluf (Jersey)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Brazil","Position of Public Official(s) (yrs in office)":"Governor and Mayor of Sao Paulo (Governor,1979-1983; Mayor, 1993-1996); Legislator (as of 2007)","Jurisdiction of Asset Recovery":"Jersey","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"Letter of Request","Basis for Intl Cooperation":"Criminal Justice (International Co-operation) (Jersey) Law 2001","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"plus unspecified amount in accrued interest","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tIn April 2013, in upholding the lower court\u0027s judgment in a private civil action brought by Brazilian authorities, the Jersey Appeals Court summarised the decision as follows: \u0022After trial the Royal Court (H.W.B. Page, Q.C. and Jurats) concluded that the claim succeeded and, in November 2012, found and held:-\n\n\t(i) \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0That the second respondent had been the victim of a fraud substantially as alleged;\n\n\t(ii) \u00a0 \u00a0 \u00a0 \u00a0 \u00a0That Paulo Maluf was to some extent a party to that fraud, receiving some fifteen secret payments;\n\n\t(iii) \u00a0 \u00a0 \u00a0 \u00a0 That Flavio Maluf, knowing of the nature of such payments arranged for a large proportion of those funds to be transferred out of Brazil and into the bank account known as Chanani with Safra International Bank of New York, an account controlled by Paulo Maluf and beneficially owned by either or both of him and his son;\n\n\t(iv) \u00a0 \u00a0 \u00a0 \u00a0 That those latter payments were traceable into the bank accounts of the first and second appellants with Deutsche Bank in Jersey;\n\n\t(v) \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 That the knowledge of the Malufs that such payments were the proceeds of a fraud on the present respondents was attributable to each of the defendants;\n\n\t(vi) \u00a0 \u00a0 \u00a0 \u00a0 That each of the present appellants was, accordingly, liable to the present respondents as constructive trustee;\n\n\t(vii) \u00a0 \u00a0 \u00a0 \u00a0That the knowledge of the Malufs that the present appellants had no entitlement to such payments was attributable to each of the present appellants, giving rise to liability on the basis of unjust enrichment; and\n\n\t(viii) \u00a0 \u00a0 \u00a0That the present respondents had a proprietary claim to specified monies from funds currently held by Deutsche Bank in accounts in the name of \u00a0the present appellants.\u0022 \u00a0(Source: Brazil v. Durant. [2013] JCA 071, at para 4.) \u00a0The Federal Republic of Brazil and the State of Sao Paolo had brought a civil suit in the Isle of Jersey against frozen assets held in the names of two companies that are alleged to be beneficially owned by Mr. Maluf and\/or his son. \u00a0(Source: Republic of Brazil v. Durant, 2012 JRC 094.) \u00a0 As the Jersey Royal Court noted, the action is a claim by Brazil \u0022to certain funds, of the order of US$10.5 million plus interet, held in bank accounts in Jersey in the name of the defendants, Durant International Corporation (\u0022Durant\u0022) and\/or Kildare Finance Limited (\u0022Kildare\u0022) and subject of a freezing order granted by the Royal Court on 13th March, 2009.\u0022 \u00a0The funds were alleged to have flowed through the \u0022Chanani\u0022 account at Safra Bank of New York. (Source: Republic of Brazil v Durant, 2011 JRC 091.) \u00a0The Jersey courts hade granted Norwich Pharmacal disclosure orders in the Durant Intl, et al and Citibank et al cases. \u00a0(Sources: Durant Intl. Corp. v. Att. Gen., 2006 JLR 31 (19 Jan 2006) and 2006 JLR 112 (17 Mar 2006); Brazil v. Citibank, 2006 JLR 478 (1 Nov 2006); Macdoel Invs v. Brazil, 2007 JLR 201 (19 Mar 2007)).\u00a0\n\n\t\u00a0\n\n\tIn 2015, in an important judgment upholding the concept of backwards tracing of assets, the UK Privy Council rejected an appeal by Durant International that of the US$10.5 million determined to be proceeds of bribes, the total amount that should be traced to the bribery should be limited to US$7.7 million. (Source: The Federal Republic of Brazil and another v. Durant International Corporation and another, [2015] UKPC 35.)\n\n\t\u00a0\n\n\tAccording to the New York County District Attorney\u0027s Office\u0027s March 2007 indictment against Mr. Maluf and his family members and associates, $26 million have been frozen in Jersey; U.S. and Brazillian authorities are seeking to forfeit these funds. (Sources: The People of the State of New York v. Paulo Maluf, Flavio Maluf, Simeao Damasceno de Oliveira, Joel Guedes Fernandes and Vivaldo Alves, Indictment filed on March 8, 2007 in New York state Supreme Court, County of New York and New York County District Attorney\u0027s Office, News Release on the Paulo Maluf case, March 8, 2007; \u00a0\u0022Promotoria quer repatriar R $303 milhoes de empresa de Maluf,\u0022 Estadao.com.br, August 3, 2009; Swiss Federal Department of Police and Justice Press Release, \u0022Strengthening co-operation in the fight against crime \/ Brazilian delegation visits Bern,\u0022 October 14, 2002, accessed at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2002\/2002....) \u00a0 \u00a0According to a secondary source, the return of MacDoel funds are said to have been under negotiation. (Source: \u00a0Marcelo Godoy and Fausto Macedo, \u0022Acordo de Maluf traria US$13 mi a cofres da Prefeturia de Sao Paulo,\u0022 Estado.com.br, August 25, 2011.)","Disposition of Criminal Case(s)":"According to the March 8, 2007 press release by the New York County District Attorney\u0027s Office, Mr. Maluf was indicted in New York for his alleged conspiracy in embezzlement of public funds and concealment of such funds, and that charges were also pending against him in Brazil. (Source: The People of the State of New York v. Paulo Maluf, Flavio Maluf, Simeao Damasceno de Oliveira, Joel Guedes Fernandes and Vivaldo Alves, Indictment filed on March 8, 2007 in New York state Supreme Court, County of New York and New York County District Attorney\u0027s Office, News Release on the Paulo Maluf case, March 8, 2007.) According to Agence France Presse, on November 4, 2013, Mr. Maluf\u0027s conviction on \u0022administrative corruption\u0022 was upheld by a Brazilian court. (Source: Agence France Presse, \u0022Graft sentence upheld for ex-Sao Paulo ex-mayor,\u0022 November 4, 2013.)","Jurisdiction of Origin: Investigative Agency":"Brazilian Financial Intelligence Unit; Ministry of Justice; Federal Police","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General of the State of Sao Paulo, Prosecutor General of the Republic of Brazil","Jurisdiction of Origin: Courts Involved":"Superior Tribunal of Justice","Jurisdiction of Asset Recovery: Investigative Agency":"Jersey Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"BakerPlatt (Attorney Stephen Baker, for the Jersey Attorney General); Advocate P.D. James for the Federal Republic of Brazil;","Jurisdiction of Asset Recovery: Courts Involved":"Court of Appeal; Royal Court (Samedi Division)","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Interpol_Wanted_May_6_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Citibank_2006_JLR_478.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Civil_Actions_Estadao.com_Aug_3_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Durant_Intl_2006_JLR_31.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Durant_Intl_2006_JLR_112.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Macdoel_2007_JLR_201.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_New_York_Indictment_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_NY_Indictment_Press_Release_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Swiss_Dept_Justice_Oct_14_2002.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Republic_of_Brazil-v-Durant_2011_JLR_091, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_MacDoel_Negotiations_Estadao.com.br_Aug_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_Brazil%20v%20Durant_2013_JCA_71_Apr_11_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Interpol_Wanted_May_6_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Citibank_2006_JLR_478.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Civil_Actions_Estadao.com_Aug_3_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Durant_Intl_2006_JLR_31.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Durant_Intl_2006_JLR_112.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Macdoel_2007_JLR_201.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_New_York_Indictment_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_NY_Indictment_Press_Release_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Swiss_Dept_Justice_Oct_14_2002.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Republic_of_Brazil-v-Durant_2011_JLR_091, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_MacDoel_Negotiations_Estadao.com.br_Aug_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_Brazil-v-Durant_2013_JRC_019A_24-Jan-2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Interpol_Wanted_May_6_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Citibank_2006_JLR_478.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Civil_Actions_Estadao.com_Aug_3_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Durant_Intl_2006_JLR_31.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Durant_Intl_2006_JLR_112.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Macdoel_2007_JLR_201.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_New_York_Indictment_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_NY_Indictment_Press_Release_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Swiss_Dept_Justice_Oct_14_2002.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Republic_of_Brazil-v-Durant_2011_JLR_091, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_MacDoel_Negotiations_Estadao.com.br_Aug_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_Interpol_wanted_Feb_6_2015_0.pdf","Sources ":"\n\tRepublic of Brazil v. Durant, [2015] UKPC 35 (August 3, 2015), at https:\/\/www.jcpc.uk\/cases\/docs\/jcpc-2013-0069-judgment.pdf; [2013] JCA 071 (April 11, 2013), at http:\/\/www.jerseylaw.je\/Judgments\/UnreportedJudgments\/Documents\/Display.... \u00a0[2013] JRC 019A (January 24, 2013), at http:\/\/www.jerseylaw.je\/Judgments\/UnreportedJudgments\/Documents\/Display.... and \u00a0[2012] JRC 211 (November 16, 2012), at http:\/\/www.jerseylaw.je\/Judgments\/UnreportedJudgments\/Documents\/Display.... \u00a0\n\n\t\u00a0\n\n\tSee also, Brazil v. Durant, [2012] JCA 151 (August 22, 2012) and \u00a0[2012] JCA 094 (May 11, 2012);\u00a0\n\n\tDurant Intl. Corp. v. Att. Gen., 2006 JLR 31 (19 Jan 2006); 2006 JLR 112 (17 Mar 2006) and 2011 JLR 091 (April 27, 2011);\u00a0\n\n\tBrazil v. Citibank, 2006 JLR 478 (1 Nov 2006);\u00a0\n\n\tMacdoel Invs v. Brazil, 2007 JLR 201 (19 Mar 2007). \u00a0\n\n\t\u00a0\n\n\tSee also, The People of the State of New York v. Paulo Maluf, Flavio Maluf, Simeao Damasceno de Oliveira, Joel Guedes Fernandes and Vivaldo Alves, Indictment filed on March 8, 2007 in New York state Supreme Court, County of New York, accessed at http:\/\/manhattanda.org\/whatsnew\/press\/2007-03-08%20Maluf%20Indictment%20... \u00a0New York County District Attorney\u0027s Office, News Release on the Paulo Maluf case, March 8, 2007, accessed at http:\/\/www.manhattanda.org\/whatsnew\/press\/2007-03-08.shtml 1\/;\u00a0\n\n\t\u00a0\n\n\t\u0022Promotoria quer repatriar R $303 milhoes de empresa de Maluf,\u0022 Estadao.com.br, August 3, 2009. \u00a0Swiss Federal Department of Police and Justice Press Release, \u0022Strengthening co-operation in the fight against crime \/ Brazilian delegation visits Bern,\u0022 October 14, 2002, accessed at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2002\/2002... \u00a0Paulo Maluf, Interpol Wanted List, at Interpol website: \u00a0http:\/\/www.interpol.int\/public\/data\/wanted\/notices\/data\/2009\/08\/2009_136... (last accessed on February 6, 2015); \u00a0Marcelo Godoy and Fausto Macedo, \u0022Acordo de Maluf traria US$13 mi a cofres da Prefeturia de Sao Paulo,\u0022 Estado.com.br, August 25, 2011, accessed at http:\/\/www.estadao.com.br\/noticias\/impresso,acordo-de-maluf-traria-us-13... Agence France Presse, \u0022Graft sentence upheld for ex-Sao Paulo ex-mayor,\u0022 November 4, 2013, at http:\/\/www.globalpost.com\/dispatch\/news\/afp\/131104\/graft-sentence-upheld...\n"},{"Case ID":"ARW-150","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pavel Borodin","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Russian Federation","Position of Public Official(s) (yrs in office)":"State Secretary of the Union of Russia and Belarus (inclusive 2000-2001);  Chief of the Administrative Directorate of the Russian Federation (?-2000)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2000","Asset Recovery End":"2002","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"European Convention on Mutual Legal Assistance in Criminal Matters (Switzerland - Requesting State; Russia - Requested State)","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"[fine ordered but unknown if paid]","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a December 19, 2000 Press Release by the Swiss Federal Department of Justice and Police, the Swiss authorities requested and received from the Russian Federation, mutual legal assistance in the investigation of Mr. Borodin\u0027s case. (Source: Swiss Federal Department of Justice and Police Press Release, Bundesanwaltschaft stellt Rechtshilfe der Schweiz an Russland im Strafverfahren  ein,\u0022 December 19, 2000, accessed at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/de\/home\/dokumentation\/mi\/2000\/2000....) According to a Swiss Federal Office of Justice Press Release of February 5, 2001, Switzerland sought Mr. Borodin\u0027s extradition from the U.S., stating that \u0022The request is based on two arrest warrants issued on 10 January 2000 and on 24 January 2001, respectively, by the Geneva Examining Magistrates, who are conducting a criminal proceeding against Borodin on account of money laundering and participation in a criminal organisation.\u0022 (Source: Swiss Federal Department of Justice and Police Press Release, \u0022Switzerland asks the US to extradite Borodin,\u0022 February 5, 2001.) According to the St. Petersburg Times, in March 2002, a judgment was entered in Switzerland against Mr. Borodin on a money laundering charge and he was fined $177,000. The article reported Mr. Borodin\u0027s attorneys as stating that he would not appeal the decision because he did not \u0022recognize the court\u0027s jurisdiction.\u0022 (Source: Robin Munro, \u0022Convicted Borodin Will Defy Swiss Courts,\u0022 St. Petersburg Times, March 19, 2002). According to the article, Mr. Borodin\u0027s case dates back to 2000, when Swiss authorities accused him of receiving $30 million in kickbacks from two Swiss companies (Mabetex and Mercata) involved in the renovation of the Kremlin, and funneling the proceeds through entities owned by him or his family members. The Swiss issued an international arrest warrant, and in 2001, he was arrested as he sought to enter the U.S. and subsequently extradited to Switzerland. (Source: Pavel Borodin (petitioner) v. Ashcroft (respondent), Case No. 01-civ-1433 (E.D.NY), Memorandum and Order March 21, 2001 (denying Mr. Borodin petition seeking release pending extradition hearing; also details allegations of Mr. Borodin\u0027s misuse of corporate vehicles made by the Swiss authorities as part of their formal extradition request.) According to the BBC, Mr. Borodin was briefly detained in Switzerland but returned to Russia after posting bail of $3 million. The BBC stated that the Russian news agency, Interfax, quoted the deputy chief of the special investigations department of the Russian Prosecutor-General\u0027s Office, Ruslan Tamayev, as saying there was \u0022no case\u0022 against Mr. Borodin. (Source: BBC News, \u0022Moscow aide flies home on bail,\u0022 April 13, 2001, accessed at http:\/\/news.bbc.co.uk\/2\/hi\/europe\/1275813.stm.) ","Disposition of Criminal Case(s)":"According to the St. Petersburg Times, on March 19, 2002, a judgment was entered in Switzerland against Mr. Borodin on a money laundering charge and he was fined $177,000.  The article reported Mr. Borodin\u0027s attorneys as stating that he would not appeal the decision because he did not \u0022recognize the court\u0027s jurisdiction.\u0022  (Source: Robin Munro, \u0022Convicted Borodin Will Defy Swiss Courts,\u0022 St. Petersburg Times, March 19, 2002).","Jurisdiction of Origin: Investigative Agency":"Prosecutor General\u0027s Office, Moscow","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Geneva Canton Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"[Public Prosecutor, Geneva, Switzerland, criminal prosecution] U.S. Attorney for the Southern District of New York (extradition)","Jurisdiction of Asset Recovery: Courts Involved":"Switzerland: Unspecified; U.S. District Court for the Southern District of New York (extradition)","Documents":"","Sources ":"Swiss Federal Department of Justice and Police Press Release, Bundesanwaltschaft stellt Rechtshilfe der Schweiz an Russland im Strafverfahren  ein,\u0022 December 19, 2000, accessed at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/de\/home\/dokumentation\/mi\/2000\/2000... Swiss Federal Department of Justice and Police Press Release, \u0022Switzerland asks the US to extradite Borodin,\u0022 February 5, 2001, accessed at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2001\/ref_.... The St. Petersburg Times, \u0022Convicted Borodin Will Defy Swiss Court,\u0022 March 19, 2002; BBC News, \u0022Moscow aide flies home on bail,\u0022 April 12, 2001; BBC News, \u0022Yeltsin aide held in U.S. jail,\u0022 January 19, 2001. See also, Pavel Borodin (petitioner) v. Ashcroft (respondent), Case No. 01-civ-1433 (E.D.N.Y.), Memorandum and Order filed on March 21, 2001 (denying Borodin petition seeking release pending extradition hearing). \n"},{"Case ID":"ARW-151","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pavel I. Lazarenko (Antigua and Barbuda)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Member of Parliament (1998); Prime Minister (1996-1997); First Vice Prime Minister (1995-1996); various government and political positions, Dnepropetrovsk region (1992-1995)","Jurisdiction of Asset Recovery":"Antigua and Barbuda","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.18, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdictions","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tSee related entry - Pavel Lazarenko (US Civil Asset Forfeiture Case). \u00a0According to the November 2010 judgment by the High Court of Justice of Antigua and Barbuda in Claim No: ANUHCV 2010\/0298 Between: \u00a0The Liquidators of Eurofed Bank Limited (in Liquidation) and The Supervisory Authority, \u0022On 21 st September 2010 Harris,J. ordered that a Restraining Order of the United States District Court for the District of Columbia be registered in the High Court of Justice of Antigua and Barbuda and given effect with respect to all funds or property restrained thereby which are held or controlled by Scotia Bank, High Street, S1. John\u0027s, Antigua and the Joint Liquidators of Eurofed Bank (In Liquidation). On 12th October 2010 the Learned Judge gave his reasons for decision in a written judgment delivered on that day by the Registrar of the High Court. [ ] By Notice of Application filed on 20th October 2010 the Liquidators of Eurofed Bank Limited (In Liquidation) made application to the Court for leave to appeal against the aforesaid judgment of Harris, J. and for stay of execution, enforcement and all further proceedings on the decision and orders of Harris, J. dated 12th October 2010 and on the registered United States District Court Restraining Order dated 8th July 2005 pending the hearing of the appeal. the Court takes the view that the Intended Appellants may well have a very difficult task to convince the Court of Appeal to overrule the decision of Harris, J. in this matter but they do have a realistic prospect of doing so.\u0022 \u00a0The Court granted leave to the liquidators of Eurofed Bank to appeal. \u00a0(Source: \u00a0 CLAIM NO: ANUHCV 2010\/0298 Between: The Liquidators of Eurofed Bank LImited (in \u00a0liquidation), Intended Appellants and and The Supervisory Authority, High Court of Antigua and Barbuda, Judgment of November 12, 2010, accessed at the website of the Eastern Caribbean Supreme Court at http:\/\/www.eccourts.org\/judgments\/decisions\/2010\/LiquidatorsofEurofedBan....). \u00a0In 2011, the Restraining Order was upheld by the Court of Appeal. (Source: The Liquidators of Eurofed Bank Limited and The Supervisory Authority, HCVAP 2010\/051, November 21, 2011.)\n\n\t\u00a0","Disposition of Criminal Case(s)":"According to the U.S. Department of Justice Press Release dated November 19, 2009, Mr. Lazarenko was sentenced to 97 months in prison, subsequent to his conviction on eight counts of money laundering.  (Source: U.S. Department of Justice, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison,\u0022 November 19, 2009.) According to  BBC News, Mr. Lazarenko was convicted in Switzerland, in June 2000, on money laundering charges. (Sources:  BBC News, \u0022The case against Lazarenko,\u0022  August 25, 2006.  See also, Swiss court decisions: BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court).","Jurisdiction of Origin: Investigative Agency":"Prosecutor General","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Antigua and Barbuda","Documents":"","Sources ":"\n\tCLAIM NO: ANUHCV 2010\/0298 Between: The Liquidators of Eurofed Bank LImited (in \u00a0liquidation), Intended Appellants and and The Supervisory Authority, High Court of Antigua and Barbuda, Judgment of November 12, 2010, accessed at the website of the Eastern Caribbean Supreme Court at http:\/\/www.eccourts.org\/judgments\/decisions\/2010\/LiquidatorsofEurofedBan... The Liquidators of Eurofed Bank Limited and The Supervisory Authority, HCVAP 2010\/051, November 21, 2011, at https:\/\/www.eccourts.org\/the-liquidators-of-eurofed-bank-ltd-v-the-super...\n\n\t\u00a0\n"},{"Case ID":"ARW-152","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pavel I. Lazarenko \/ Northern California Criminal Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Member of Parliament (1998); Prime Minister (1996-1997); First Vice Prime Minister (1995-1996); various government and political positions, Dnepropetrovsk region (1992-1995)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.18, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Criminal Fine  ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Investigatory cooperation but exact mechanism unknown","Contributing Factors in Asset Recovery":"Close cooperation among investigators and prosecutors of Ukraine, Switzerland, United States and Antigua","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"criminal fine ($9 million), criminal forfeiture ($20 million)","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In November 2009, Mr. Lazarenko was sentenced to 97 months in prison and ordered to pay a $9 million fine and forfeit $22,851,000 and various specified assets resulting from his money laundering convictions.  (Source: Department of Justice Press Release, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison \/ Fined $9 Million for Role in Laundering $30 Million of Extortion Proceeds,\u0022 November 19, 2009.)  The Amended Judgment of February 4, 2010 had ordered Mr. Lazarenko to also pay restitution of $19,473,309 to his co-conspirator\/victim Peter Kiritchenko; this was later reversed by the Ninth Circuit which held that as a general rule, a participant in a crime cannot recover restitution. (Sources: U.S. v. Lazarenko, Case No. 3:00-cr-00284-CRB (N.D. Cal.), Amended Judgment of February 4, 2010, reversed appeal, U.S. (Plaintiff-Appellee), Kiritchenko (Intervenor) v. Lazarenko (Defendant-Appellant), Case No. 08-10185, (9th Cir.). The U.S. Government had opposed the payment of restitution to Mr. Kiritchenko.)  Some of the forfeited assets included Mr. Lazarenko\u0027s assets held in the European Federal Credit Bank in Antigua.  As the Ninth Circuit Court of Appeals noted, Mr. Lazarenko\u0027s \u0022activities raised prosecutorial eyebrows in both the United States and Antigua.  Antiguan officials ordered the liquidation of Eurofed\u0027, and the High Court of Antigua appointed several persons as \u0027Liquidators\u0027 of Eurofed to assist in the collection and distribution of Eurofed\u0027s assets to its rightful, law-abiding owners.\u0022  The Liquidators asserted ownership specifically to the approproximately $2.5 million in funds and Ukrainian bonds on deposit with Bank of America, in a correspondent account of Eurofed.  In January 2011, the Ninth Circuit Court reversed the lower court\u0027s ruling on grounds of ers judicata, and remanded with instructions that the district court vacate the forfeiture order with regard to the funds and Ukrainian bonds held in Bank of America and to return those assets to the Liquidators.  (Source: U.S. v. Liquidators of European Federal Credit Bank, U.S. and Liquidators of European Federal Credit Bank v. Lazarenko, and U.S. v. Lazarenko, Case Nos. 09-10116, 09-10161, 09-10183 (9th Cir.), January 4, 2011.)  On April 4, 2011, the US District Court for the Northern District of California issued the order for return of those assets to the liquidators of EuroFed Bank. (Source: US v. Lazrenko, Case No. 3:00-cr-00284 (N.D. Cal.), Amended Final Order of Forfeiture on Remand filed April 4, 2011.)","Disposition of Criminal Case(s)":"According to the U.S. Department of Justice Press Release dated November 19, 2009, Mr. Lazarenko was sentenced to 97 months in prison, following his conviction on eight counts of money laundering.  (Source: U.S. Department of Justice, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison,\u0022 November 19, 2009.) According to  BBC News, Mr. Lazarenko was convicted in Switzerland, in June 2000, on money laundering charges. (Sources:  BBC News, \u0022The case against Lazarenko,\u0022  August 25, 2006.  See also, Swiss court decisions: BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court).","Jurisdiction of Origin: Investigative Agency":"Prosecutor General","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, Federal Bureau of Investigation, Eurasian Organized Crime Squad (San Francisco); Internal Revenue Service, Criminal Investigations","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney\u0027s Office for the Northern District of California; U.S. Department of Justice, Criminal Division, Organized Crime \u0026 Racketeering Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Northern District of California, Ninth Circuit Court of Appeals, U.S. Supreme Court, U.S. District Court for the District of Columbia","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Lazarenko_US_NDCAL_Indictment_May_18_2000.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Lazarenko_US_NDCAL_Amended_Judgment_Feb_4_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Lazarenko_US_NDCAL_Catch_Oligarch_Oct_4_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Lazarenko_US_NDCAL_Eurofed_Liquidators_Courthouse_News_Jan_5_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Lazarenko_US_NDCAL_Eurofed_Liquidators_Jan_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Lazarenko_US_NDCAL_Kiritchenko_Restitution_Order_Vacate_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Lazarenko_US_NDCAL_Sentence_DOJ_PR_Nov_19_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Lazarenko_NDCAL_Amended_Judgment_Forfeiture_Apr_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Lazarenko_NDCAL_Amended_Judgment_Forfeiture_Apr_4_2011.pdf","Sources ":"U.S. v. Lazarenko, Case No. 3:00-cr-00284-CRB (N.D. Cal.), Indictment filed on May 18, 2000; Amended Judgment filed on February 4, 2010; and Amended Final Order of Forfeiture Filed on April 4, 2011. U.S. v. Lazarenko, 564 F. 3d 1026 (9th Cir. 2009); U.S. (Plaintiff-Appellee), Kiritchenko (Intervenor) v. Lazarenko (Defendant-Appellant), Case No. 08-10185, (9th Cir. 2010); Department of Justice Press Release, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison \/ Fined $9 Million for Role in Laundering $30 Million of Extortion Proceeds,\u0022 November 19, 2009. Jason Felch, San Francisco Magazine, \u0022To Catch an Oligarch\u0022 posted at website of the Center for Investigative Reporting at http:\/\/www.centerforinvestigativereporting.org\/articles\/tocatchanoligarch. Eurofed Liquidators: U.S. v. Liquidators of European Federal Credit Bank, U.S. and Liquidators of European Federal Credit Bank v. Lazarenko, and U.S. v. Lazarenko, Case Nos. 09-10116, 09-10161, 09-10183 (9th Cir.), January 4, 2011; Jonny Bonner, \u0022Feds Lose Claim to Assets of Ex-Ukrainian Minister,\u0022 Courthouse News Service, January 5, 2011, accessed at http:\/\/www.courthousenews.com\/2011\/01\/05\/33090.htm.\n"},{"Case ID":"ARW-153","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pavel Lazarenko (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Member of Parliament (1998); Prime Minister (1996-1997); First Vice Prime Minister (1995-1996); various government and political positions, Dnepropetrovsk region (1992-1995)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"2001","UNCAC Offenses Implicated":"Art.15, Art.17, Art.18, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Investigatory cooperation but exact mechanism unknown","Contributing Factors in Asset Recovery":"Close cooperation among investigators of Ukraine, Switzerland, U.S. and Antigua","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In 2000, Mr. Lazarenko was convicted in absentia on money laundering charges.  (Sources:  BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court; see also BBC News, \u0022The case against Pavlo Lazarenko,\u0022 August 25, 2006, accessed at http:\/\/news.bbc.co.uk\/2\/hi\/europe\/4780743.stm.)","Disposition of Criminal Case(s)":"According to the U.S. Department of Justice Press Release dated November 19, 2009, Mr. Lazarenko was sentenced to 97 months in prison, subsequent to his conviction on eight counts of money laundering.  (Source: U.S. Department of Justice, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison,\u0022 November 19, 2009.) According to  BBC News, Mr. Lazarenko was convicted in Switzerland, in June 2000, on money laundering charges. (Sources:  BBC News, \u0022The case against Lazarenko,\u0022  August 25, 2006.  See also, Swiss court decisions: BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court).","Jurisdiction of Origin: Investigative Agency":"Prosecutor General","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Investigating Magistrate","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Asset Recovery: Courts Involved":"Administrative Law Court, Geneva","Documents":"","Sources ":"BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court (decisions can be downloaded from www.bger.ch). Jason Felch, \u0022To Catch an Oligarch,\u0022 San Francisco Magazine, October 4, 2004, posted on http:\/\/www.centerforinvestigativereporting.org\/articles\/tocatchanoligarch; BBC News, \u0022The case against Pavlo Lazarenko,\u0022 August 25, 2006, accessed at http:\/\/news.bbc.co.uk\/2\/hi\/europe\/4780743.stm.\n"},{"Case ID":"ARW-154","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pavel Lazarenko (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Member of Parliament (1998); Prime Minister (1996-1997); First Vice Prime Minister (1995-1996); various government and political positions, Dnepropetrovsk region (1992-1995)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.18, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Unspecified","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the Swiss Ministry of Foreign Affairs, $5.4 million remain frozen.  (Source: Swiss Ministry of Foreign Affairs, September 30, 2009).","Disposition of Criminal Case(s)":"According to the U.S. Department of Justice Press Release dated November 19, 2009, Mr. Lazarenko was sentenced to 97 months in prison, subsequent to his conviction on eight counts of money laundering.  (Source: U.S. Department of Justice, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison,\u0022 November 19, 2009.) According to  BBC News, Mr. Lazarenko was convicted in Switzerland, in June 2000, on money laundering charges. (Sources:  BBC News, \u0022The case against Lazarenko,\u0022  August 25, 2006.  See also, Swiss court decisions: BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court).","Jurisdiction of Origin: Investigative Agency":"Prosecutor General","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Origin: Courts Involved":"Unknown","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"","Sources ":"Swiss Ministry of Foreign Affairs, September 30, 2009.\n"},{"Case ID":"ARW-155","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pavel Lazarenko (United States Civil Asset Forfeiture Case)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Member of Parliament (1998); Prime Minister (1996-1997); First Vice Prime Minister (1995-1996); various government and political positions, Dnepropetrovsk region (1992-1995)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2005","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.18, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Investigatory cooperation but exact mechanism unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"As of June 2016, the case was ongoing against approximately $271 million and additional unspecified amounts held in accounts in financial institutions in Guernsey, Antigua and Barbuda, Switzerland, Liechtenstein and Lithuania. (Source: U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Court Docket Report as of June 20, 2016.)\nOn May 14, 2004, the U.S. filed a civil asset forfeiture suit, seeking to forfeit more than $250 million which the government alleged were illegal proceeds of criminal activities by Mr. Lazarenko and his associates.  The U.S. government also alleged that the assets were obtained through the abuse of public office and illegally transported and\/or laundered through the abuse of financial institutions in the United States, and were located in in foreign bank accounts in Guernsey, Antigua \u0026 Barbuda, Switzerland, Lithuania and Liechtenstein.(Source: U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Verified Claim for Forfeiture In Rem filed on May 14, 2004 and First Amended Verified Claim for Forfeiture In Rem filed on June 30, 2005.)   On May 20, 2004, a Restraining Order was issued against the defendant accounts.  (Source: U.S. v. All Assets Held in Julis Baer, et al, Case No. 1:04-cv-00798-PLF (D.D.C.), which stipulated that \u0022terms of Order shall remain in full force and effect until the judgment rendered in the case or further Order of the court.\u0022)  Actions against some of the assets were terminated in June 2005.","Disposition of Criminal Case(s)":"According to the U.S. Department of Justice Press Release dated November 19, 2009, Mr. Lazarenko was sentenced to 97 months in prison, subsequent to his conviction on eight counts of money laundering.  (Source: U.S. Department of Justice, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison,\u0022 November 19, 2009.) According to  BBC News, Mr. Lazarenko was convicted in Switzerland, in June 2000, on money laundering charges. (Sources:  BBC News, \u0022The case against Lazarenko,\u0022  August 25, 2006.  See also, Swiss court decisions: BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court).","Jurisdiction of Origin: Investigative Agency":"Prosecutor General","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation; Internal Revenue Service, Criminal Investigations","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Columbia","Documents":"","Sources ":"U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Verified Claim for Forfeiture In Rem filed on May 14, 2004;  First Amended Verified Claim for Forfeiture In Rem filed on June 30, 2005 and Notice of Errata for First Amended Verified Claim for Forfeiture In Rem filed on January 21, 2011; Restraining Order filed on May 20, 2004; Court Docket Report as of June 20, 2016.\n"},{"Case ID":"ARW-156","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pertamina (PT Pertambangan Minyak dan Gas Bumi Negara) \/ Haji Achmad Thahir Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Indonesia","Position of Public Official(s) (yrs in office)":"General Assistant to the President Director of Pertamina (Haji Achmad Thahir, 1968-1976)","Jurisdiction of Asset Recovery":"Singapore","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1977","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"The private civil action was triggered subsequent to Mr. Thahir\u0027s death, by competing claims to the deposited funds between his wife and children from his first marriage.","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$81,757,260.74","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"As described in the Stolen Asset Recovery (StAR) Initiative\u0027s Asset Recovery Handbook (December 2010), \u0022Pertamina - an Indonesian state-owned enterprise whose principal business was the exploration, processing, and marketing of oil and natural gas - sought to recover bribes paid to Pertamina executive Haji Achmad Thahir by contractors hoping for better contractual terms and preferential treatment.  The bribes were deposited by the executive into [the Sumitomo Bank branch] in Singapore.  Pertamina learned about the bank accounts (owned jointly by Thahir and his wife Kertika Ratna thahir) in Singapore after the death of the executive and brought an action in Singapore claiming to be entitied to the funds.  The court of first instance ruled that the bribes and all earned interest were held by the executive as a constructive trustee.\u0022 (Source:  Asset Recovery Handbook, at 160-62, citing Singapore High Court decision in Kartika Ratna Thahir v. PT Pertambangan Minyak dan Gas Bumi Negara (Pertamina) [1994] 3 SLR 257, hereinafter cited as \u0022Pertamina decision.\u0022)  The Court of Appeal of Singapore wrote in its 1994 Pertamina decision that, \u0022This appeal arises from the decision of Lai Kew Chai J on an originating summons taken out by the Sumitomo Bank Ltd for interpleader reliefs in the face of competing claims to 19 separate and discrete deposits with the Asian Currency Unit (ACU) of the Singapore branch of the bank.\u0022  The Court wrote, \u0022Gen Haji Achmad Thahir (Gen Thahir) was employed by Pertamina and at the material time was the general assistant to the then president director of Pertamina, Gen Ibnu Sutowo (Gen Sutowo). Gen Thahir was appointed to the office with effect from 14 October 1968 and at all material times his total salary was about US$9,000 a year. He held that position until 23 July 1976 when he died.\u0022  The Singapore High Court stated that \u0022as of 27 March 1992 the total of the said ACU deposits including the interest, which had accrued during the intervening period, was US$81,757,260.74.\u0022  (Source: Sumitomo Bank Ltd v Kartika Ratna Thahir and others and another matter [1992] SGHC 301.)","Disposition of Criminal Case(s)":"None (The private civil action was triggered subsequent to Mr. Thahir\u0027s death, by competing claims to the deposited funds between his wife and children from his first marriage.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Pertamina (PT Pertambangan Minyak dan Gas Bumi Negara)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Wong Meng Meng \u0026 Pnrs (David\r\nHunt QC, Wong Meng Meng and Alvin Yeo) for Pertamina","Jurisdiction of Asset Recovery: Courts Involved":"High Court, Court of Appeal","Documents":"","Sources ":"Sumitomo Bank Ltd v Kartika Ratna Thahir and others and another matter [1992] SGHC 301, High Court, Suit No. OS 308\/1976, Decision dated December 3, 1992, accessed at http:\/\/lwb.lawnet.com.sg\/legal\/lgl\/rss\/landmark\/%5B1992%5D_SGHC_301.html; Kartika Ratna Thahir v PT Pertambangan Minyak dan Gas Bumi Negara (Pertamina) [1994] 3 SLR 257; [1994] SGCA 105, Court of Appeal, Suit No: CA 204\/1992, Decision dated August 25, 1994, accessed at http:\/\/www.singaporelaw.sg\/rss\/judg\/10401.html; Jean-Pierre Brun, Larissa Gray, Clive Scott, and Kevin M. Stephenson, \u0022Asset Recovery Handbook: A Guide for Practitioners,\u0022 Stolen Asset Recovery (StAR) Initiative (Washington, D.C., December 2010).\n"},{"Case ID":"ARW-157","Case Title (Name of Public Official or Entity Allegedly Involved)":"Propinoduto (Principal - Agent) \/ Rodrigo Silveirinha Correa Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Brazil","Position of Public Official(s) (yrs in office)":"Deputy Head of Tax Collection Office, Tax Officials (1990s, exact years unspecified)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.19","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"On Appeal","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$0","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unspecified","Case Summary":"According to the 2011 U.S. Department of State, Bureau for International Narcotics and Law Enforcement Affairs\u0027 International Narcotics Control Strategy Report, $30 million was repatriated from Switzerland to Brazil in the Propinoduto case. (Source: U.S. Department of State, Bureau for International Narcotics and Law Enforcement Affairs\u0027 International Narcotics Control Strategy Report, Vol. I (March 2011), at 154.) According to a Brazillian Justice Ministry statement, on November 26, 2009, the Brazilian Justice Minister announced that Switzerland had agreed to return $30 million to Brazil, and the only remaining issue was what tools of repatriation (bilateral convention or Merida treaty) but hoped to have money in Brazilian treasury by 2010. (Source: Noticias, Lavagem de Dinheiro, Ministerio da Justica, Brasil, \u0022Brasil consegue repatriacao de cerca de U.S. $30 milhoes na Suica,\u0022 November 26, 2009.) According to the press announcement, the investigation of the \u0022Propinoduto\u0022 case began about 2003 and culminated in the conviction of several people who allegedly received kickbacks from companies in exchange for tax benefits. The Brazilian government opened investigations after detecting suspicious deposits in Swiss banks belonging to tax officials assigned to the Tax Administration of Rio de Janeiro. The money will be returned to the coffers of the Union, with the possibility of it being passed on to the government of Rio de Janeiro, according to the Ministry announcement.","Disposition of Criminal Case(s)":"According to the International Centre for Asset Recovery\u0027s Case Study on Mr. Correa\u0027s case, he was convicted in Brazil of criminal charges related to the Propinoduto case. (Source: \u0022Rodrigo Silveirinha Correa\u0022 Case Study, at http:\/\/www.assetrecovery.org\/kc\/node\/bb4181b0-f78b-11dd-aec1-9dfae7b42ba1.1.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"State Prosecutor, State of Rio de Janeiro","Jurisdiction of Origin: Courts Involved":"Superior Court of Justice, 6th Chamber","Jurisdiction of Asset Recovery: Investigative Agency":"Ministry of Justice, Department of Asset Recovery and International Legal Cooperation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Noticias, Lavagem de Dinheiro, Ministerio da Justica, Brasil, \u0022Brasil consegue repatriacao de cerca de U.S. $30 milhoes na Suica,\u0022 last accessed October 1, 2010 at http:\/\/portal.mj.gov.br\/data\/Pages\/MJ7FABCBFCITEMID8A1481F26CDD463488D2B... U.S. Department of State, Bureau for International Narcotics and Law Enforcement Affairs\u0027 International Narcotics Control Strategy Report, Vol. I (March 2011), at 154, accessed at http:\/\/www.state.gov\/documents\/organization\/156575.pdf. Gabriella Broggi, \u00225 Swiss bankers convicted in Brazil money case,\u0022 Associated Press, Sept. 18, 2008, in \u0022Rodrigo Silveirinha Correa\u0022 Case Study by International Centre for Asset Recovery\u0027, at http:\/\/www.assetrecovery.org\/kc\/node\/bb4181b0-f78b-11dd-aec1-9dfae7b42ba1.1.\n"},{"Case ID":"ARW-158","Case Title (Name of Public Official or Entity Allegedly Involved)":"Raul Salinas (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mexico","Position of Public Official(s) (yrs in office)":"Brother of President Carlos Salinas (1988-1994)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1995","Asset Recovery End":"2008","UNCAC Offenses Implicated":"Art.15, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"According to the Swiss Federal Office of Justice Press Release, \u0022The Mexican authorities demonstrated, with the support of bank documents and other papers, how public funds amounting at the time to around USD 66 million had been misappropriated and moved to domestic banks. The Swiss authorities had already reconstructed the trail of the funds outside Mexico. On the basis of the Swiss and Mexican proceedings, the clearly criminal origin of these assets was thus demonstrated, thereby fulfilling the requirements for their early handover. The parties concerned have not opposed the handover of these assets, totalling USD 74 million (including interest), to Mexico.\u0022 (Source: Swiss Federal Department of Justice and Police Press Release, \u0022Salinas assets handed over to Mexico, Federal Examining Magistrate concludes 12-year proceedings,\u0022 June 18, 2008.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$74,000,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"On June 18, 2008, the Swiss Federal Department of Justice and Police announced that Switzerland would return $74 million to Mexico in assets related to Mr. Salinas\u0027 case.  According to the Swiss government press release, in 1995, Switzerland had initiated criminal proceedings for money laundering, and in 2002 turned over their investigative files to Mexico.  As of 2002, some $110 million were frozen in Switzerland.  Some $74 million (including accrued interest) were deemed to be of criminal origin and returned.   The press release noted that \u0022Other assets, which are not of criminal origin, have been unfrozen.\u0022  The Federal Examining Magistrate has also ordered the CHF 2.2 million ($2,110,010) be transferred to the federal treasury and CHF 1.1 million ( $1,055,000) to the treasury of the Canton of Geneva, both to cover costs of the Swiss authorities\u0027 \u0022wide ranging activities since 1995.\u0022  (Source: Swiss Federal Department of Justice and Police Press Release, \u0022Salinas assets handed over to Mexico, Federal Examining Magistrate concludes 12-year proceedings,\u0022 June 18, 2008.)  On June 18, 2008, the Mexican Prosecutor General\u0027s office also announced the return of assets from Switzerland and indicated that the funds would be returned to the Mexican Treasury to be used for the benefit of the people of Mexico.  (Source:  Procuraduria General de la Republica, Sala de Prensa 501\/08, \u0022PGR Achieves the Repayment of more than 74 million dollars,\u0022 June 18, 2008.)","Disposition of Criminal Case(s)":"According to the New York Times, Mr. Salinas was convicted in January 1999 in Mexico of murder. (Source: Julia Preston, \u0022Raul Salinas Guilty in Killing And Is Sentenced to Fifty Years,\u0022 New York Times, January 22, 1999.) \u00a0According to a December 16, 2014 media release by the Mexican Prosecutor General\u0027s Office, Mr. Salinas was acquitted of unjust enrichment by the Third Criminal Court of the Federal District. (Source: \u00a0Procuraduria General de la Republica, Resumen de Medios Electronicos, December 16, 2014.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Chief Public Prosecutor\u0027s Office","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Examining Magistrate","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Federal Office of Justice; [name of Mexico\u0027s civil attorney not known]","Jurisdiction of Asset Recovery: Courts Involved":"Federal Supreme Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Salinas_GAO_Testimony_1999.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Salinas_Mexico_Murder_Conviction_NYT_Jan_22_1999.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Salinas_Switzerland_Assets_Handover_Dept_Justice_PR_Jun_18_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Salinas_Mexico_PGR_resumenmat16dic2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Salinas_GAO_Testimony_1999.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Salinas_Mexico_Murder_Conviction_NYT_Jan_22_1999.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Salinas_Switzerland_Assets_Handover_Dept_Justice_PR_Jun_18_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Salinas_Swiss_Return_Mexico_Procuradur%C3%ADa%20General%20de%20la%20Rep%C3%BAblica_PR_2007.pdf","Sources ":"\n\tSwiss Federal Department of Justice and Police Press Release, \u0022Salinas assets handed over to Mexico, Federal Examining Magistrate concludes 12-year proceedings,\u0022 June 18, 2008, last accessed on October 4, 2010 at http:\/\/www.ejpd.admin.ch\/ejpd\/en\/home\/dokumentation\/mi\/2008\/ref_2008-06-...\n\n\t\u00a0\n\n\tProcuraduria General de la Republica, Sala de Prensa 501\/08, \u0022PGR Achieves the Repayment of more than 74 million dollars,\u0022 June 18, 2008, at http:\/\/www.pgr.gob.mx\/prensa\/2007\/press08\/Jun\/pr50108.shtm;\n\n\t\u00a0\n\n\tProcuraduria General de la Republica, Resumen de Medios Electronicos, December 16, 2014, at http:\/\/www.pgr.gob.mx\/prensa\/sintesis\/resumenmat16dic2014.pdf;\n\n\t\u00a0\n\n\tJulia Preston, \u0022Raul Salinas Guilty in Killing And Is Sentenced to Fifty Years,\u0022 New York Times, January 22, 1999, accessed at http:\/\/www.nytimes.com\/1999\/01\/22\/world\/raul-salinas-guilty-in-killing-a... \u0022Private Banking: Raul Salinas, Citibank, and Alleged Money Laundering,\u0022 Statement for the Record of Robert H. Hast, Acting Assistant Comptroller General for Investigations, Office of Special InvestigationsTestimony, Before the Permanent Subcommittee on Investigations, Committee on Governmental Affairs, U.S. Senate, November 9, 1999, accessed at http:\/\/www.gao.gov\/archive\/2000\/os00003t.pdf.\n\n\t\u00a0\n"},{"Case ID":"ARW-161","Case Title (Name of Public Official or Entity Allegedly Involved)":"Raul Salinas (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mexico","Position of Public Official(s) (yrs in office)":"Brother of President Carlos Salinas (1988-1994)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"2009","UNCAC Offenses Implicated":"Art.15, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified ","Contributing Factors in Asset Recovery":"Global settlement agreement","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"Unspecified amount","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a 1998 Report by the U.S. General Accounting Office (currently known as Government Accountability Office), Mr. Salinas\u0027 shell company Trocca held investment accounts in Citibank UK.  (Source:  U.S. General Accounting Office, Report to the Ranking Minority Member, Permanent Subcommittee on Investigations, Committee on Governmental Affairs, U.S. Senate, \u0022Private Banking: Raul Salinas, Citibank and Alleged Money Laundering,\u0022 GAO\/OSI-99-1 (October 1998).  According to a UK official knowledgeable about the case, $20 million in London accounts had been restrained.  After a worldwide settlement was reached, United Kingdom discharged the restraint orders and in early 2009, the funds were forwarded to Switzerland.  Civil lawyers acting on behalf of the Mexican government had a role in the funds transfer. (Source: Researcher interview with United Kingdom official, November 2010.)","Disposition of Criminal Case(s)":"According to the New York Times, Mr. Salinas was convicted in January 1999 in Mexico of murder. (Source: Julia Preston, \u0022Raul Salinas Guilty in Killing And Is Sentenced to Fifty Years,\u0022 New York Times, January 22, 1999.)  According to a December 16, 2014 media release by the Mexican Prosecutor General\u0027s Office, Mr. Salinas was acquitted of unjust enrichment by the Third Criminal Court of the Federal District. (Source:  Procuraduria General de la Republica, Resumen de Medios Electronicos, December 16, 2014.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Chief Public Prosecutor\u0027s Office","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Scotland Yard","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Raul_Salinas_UK_GAO_Rept_Oct_1998.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Salinas_GAO_Testimony_1999.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Salinas_Mexico_Murder_Conviction_NYT_Jan_22_1999.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Salinas_US_Senate_Report_Scotland_Yard.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Salinas_Mexico_PGR_resumenmat16dic2014_0.pdf","Sources ":"\n\tU.S. General Accounting Office [currently known as Government Accountability Office], Report to the Ranking Minority Member, Permanent Subcommittee on Investigations, Committee on Governmental Affairs, U.S. Senate, \u0022Private Banking: Raul Salinas, Citibank and Alleged Money Laundering,\u0022 GAO\/OSI-99-1 (October 1998) and \u0022Private Banking: Raul Salinas, Citibank, and Alleged Money Laundering,\u0022 Statement for the Record of Robert H. Hast, Acting Assistant Comptroller General for Investigations, Office of Special Investigations, Testimony Before the Permanent Subcommittee on Investigations, Committee on Governmental Affairs, U.S. Senate, November 9, 1999, accessed at http:\/\/www.gao.gov\/archive\/2000\/os00003t.pdf; Researcher interview with United Kingdom official, November 2010. \u00a0See also \u00222\/2\/96 document prepared by Scotland Yard on transactions in Salinas\u0027 accounts,\u0022 in Hearings before the Permanent Subcommittee on Investigations of the Committeee on Governmental Affairs, United States Senate, on \u0022Private Banking and Money Laundering: A Case Study of Opportunities and Vulnerabilities,\u0022 S. Hrg. 106-428, November 9 and 10, 1999 at 352-53; Julia Preston, \u0022Raul Salinas Guilty in Killing And Is Sentenced to Fifty Years,\u0022 New York Times, January 22, 1999, accessed at http:\/\/www.nytimes.com\/1999\/01\/22\/world\/raul-salinas-guilty-in-killing-a...\n\n\t\u00a0\n\n\tProcuraduria General de la Republica, Resumen de Medios Electronicos, December 16, 2014, at http:\/\/www.pgr.gob.mx\/prensa\/sintesis\/resumenmat16dic2014.pdf;\n"},{"Case ID":"ARW-163","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha (Bahamas)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"Bahamas","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Letter of Request","Basis for Intl Cooperation":"Criminal Justice (International Co-operation) Act","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In March 2012, the Supreme Court of the Bahamas rejected an application by Ibrahim Ali Amin to remove the restraint on funds held in a numbered account of March Finance SA at the Private Investment Bank in Nassau, Bahamas.  The Court referenced an affidavit by the Swiss Attorney General\u0027s Office which stated that the Swiss Investigating Judge\u0027s Conviction Order of the Republic and Canton of Geneva, dated November 19, 2009, in criminal case P\/12983\/199 versus Mr. Abba Abacha determined that the name Ibrahim Ali Amin was a fake name used to open the account.   The Bahamas Supreme Court stated that this is not refuted, and held that the account should remain frozen until the proceedings against Abacha have been concluded and application for confiscation is made. (Source: The Attorney General vs. General Sani Abacha and others, Bahamas Supreme Court, March 19, 2012.)\n According to the UK\u0027s Anti-Corruption Forum, \u0022Yves Aeschlimann, a magistrate in Geneva, found Abba Abacha, son of General Sani Abacha, the late Nigerian dictator, guilty of corruption, sentenced him to a suspended prison term and ordered confiscation of $350m (EUR 235m, GBP 210m) in funds held in Luxembourg and the Bahamas. The funds had already been frozen by the investigation.\u0022 (Source: UK Anti-Corruption Forum, November 2009 Newsletter).","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate.  (Source:  Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C... According to BBC News, in September 2011, the Swiss supreme court ordered the retrial of Mr. Abba Abacha, son of former President Abacha, on the basis that he had been unable to obtain a visa to attend his trial.  (Source:  BBC News, \u0022Swiss court orders retrial of Nigeria\u0027s Abba Abacha,\u0022 September 20, 2011.)","Jurisdiction of Origin: Investigative Agency":"Special Panel established to investigate Abacha looting","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"Supreme Court, Common Law \u0026 Equity Division","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bahamas_Anti-Corruption_Newsletter_Nov_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Switzerland_Retrial_Son_BBC_News_Sep_20_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Switzerland_Retrial_Son_BBC_News_Sep_20_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bahamas_Anti-Corruption_Newsletter_Nov_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Switzerland_Retrial_Son_BBC_News_Sep_20_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Bahamas_Acct_Freeze_SCt_Judgment_2012.pdf","Sources ":"The Attorney General vs. General Sani Abacha and others, Bahamas Supreme Court Judgment, March 19, 2012, at http:\/\/www.supremecourt.org.bs\/download\/073533800.pdf;\nUK Anti-corruption Forum, November 2009 newsletter, at http:\/\/www.anticorruptionforum.org.uk\/acf\/forum_newsletters\/nov09\/nov09.... BBC News, \u0022Swiss court orders retrial of Nigeria\u0027s Abba Abacha,\u0022 September 20, 2011, accessed at http:\/\/www.bbc.co.uk\/news\/world-africa-14992084\n"},{"Case ID":"ARW-164","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha (Luxembourg)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President","Jurisdiction of Asset Recovery":"Luxembourg","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2000","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Letter of Request","Basis for Intl Cooperation":"Letter of Request","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"On Appeal","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to Attorney Enrico Monfrini, on February 20, 2000, a Letter Rogatory was sent to Luxembourg and within one month, Luxembourg froze $630 million in eight accounts at the M.M. Warburg \u0026 Co Luxembourg S.A.  (Source: Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets [Peter Lang, 2008]).  According to the Swiss Ministry of Foreign Affairs, as of September 30, 2009, $400 million was frozen in Luxembourg and asset recovery effort was ongoing.  According to the UK Anti-Corruption Forum November 2009 newsletter. Yves Aeschlimann, the Investigating Magistrate overseeing the Swiss criminal case, found Abba Abacha (son of late President Sani Abacha) guilty of corruption, sentenced him to a suspended prison term and ordered confiscation of $350m (EUR 235m, GBP 210m) in funds held in Luxembourg and the Bahamas. The funds had already been frozen by the investigation. As of October 2013, the case is ongoing.","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate.  (Source:  Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....  According to BBC News, in September 2011, the Swiss supreme court ordered the retrial of Mr. Abba Abacha, son of former President Abacha, on the basis that he had been unable to obtain a visa to attend his trial.  (Source:  BBC News, \u0022Swiss court orders retrial of Nigeria\u0027s Abba Abacha,\u0022 September 20, 2011.)","Jurisdiction of Origin: Investigative Agency":"Special Panel established to investigate Abacha looting","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Monfrini Crettol \u0026 Partners (Attorneys Enrico Monfrini and Yves Klein)","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Luxembourg_UK_Anticorruption_Newsletter_Nov_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Monfrini_Article_2008.pdf Abacha_Switzerland_Retrial_Son_BBC_News_Sep_20_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Switzerland_Retrial_Son_BBC_News_Sep_20_2011_0.pdf","Sources ":"Swiss Ministry of Foreign Affairs, September 30, 2009; \nEnrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), and also available at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C... \nUK Anti-corruption Forum, November 2009 newsletter, at http:\/\/www.anticorruptionforum.org.uk\/acf\/forum_newsletters\/nov09\/nov09.... \nBBC News, \u0022Swiss court orders retrial of Nigeria\u0027s Abba Abacha,\u0022 September 20, 2011, accessed at http:\/\/www.bbc.co.uk\/news\/world-africa-14992084\n"},{"Case ID":"ARW-165","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha \/ Abubakar Bagudu","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (Abacha,1993-1998) \/ Associate (Bagudu)","Jurisdiction of Asset Recovery":"Jersey","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"2003","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"\u0022The Abacha case is a clear example of the benefit of international cooperation to which the Island is committed. Given the nature of business in Jersey, the investigation of serious financial crime inevitably involves liaison with other jurisdictions, both to provide assistance to other countries, and to obtain assistance from them. The Serious Crime Group continues to assist other countries in fighting crime and uses its close links with other nations to obtain evidence to combat crime in the Island.\u0022 (Source: Attorney General\u0027s Annual Review 2003). ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Part of worldwide settlement, with recovered funds to be used to fund projects in the health, education, water, electricity and road sectors; monitoring responsbility held by the World Bank.  (Source:  \u0022Utilization of Repatriated Abacha Loot, Results of the Field Monitoring Exercise,\u0022 Report Prepared by the World Bank with Cooperation from the Federal Ministry of Finance (December 2006)).","Case Summary":"Jersey Attorney General\u0027s Annual Review for 2003, the report noted that \u00222003 saw Jersey\u2019s long running investigation into Nigerian corruption approach its climax. Working closely with the present Nigerian authorities, the U.S. authorities and countries across Western Europe, Serious Crime Group lawyers played a direct and crucial role in the repatriation of some U.S.$160 million of money embezzled from the people of Nigeria and channelled through Jersey by the late Nigerian dictator Sani Abacha, and his henchmen. Further repatriations of stolen funds are expected to follow in the months ahead.\u0022 (Source: Attorney General\u0027s Annual Review 2003, at 6-7, accessed at http:\/\/www.gov.je\/SiteCollectionDocuments\/Government%20and%20administrat....) According to Attorney Enrico Monfrini, the Jersey authorities had informally frozen the $160 million. In 2003, Abubakar Bagudu, an associate of Mr. Abacha, was arrested and extradited from Houston, Texas at the request of Jersey. Mr. Bagudu settled with the Nigerian government, agreeing to return the $160 million in exchange for deportation to Nigeria. (Source: Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008)).","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate.  (Source:  Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"Special Panel established to investigate Abacha looting","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Attorney General\u0027s Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Jersey: Attorney General\u0027s Office, Serious Crime Group; United States: United States Attorney for the Southern District of Texas; Civil: Edwards Angell Palmer \u0026 Dodge (Attorneys James Maton and Tim Daniel); Monfrini Crettol \u0026 Partners (Attorneys Enrico Monfrini and Yves Klein)","Jurisdiction of Asset Recovery: Courts Involved":"Jersey Royal Court; United States: U.S. District Court for the Southern District of Texas","Documents":"","Sources ":"Government of Jersey, Attorney General\u0027s Annual Review 2003, accessed at http:\/\/www.gov.je\/SiteCollectionDocuments\/Government%20and%20administrat... and at ICC FraudNet, notable cases: http:\/\/www.icc-ccs.org\/home\/resources\/118-leading-cases\/697-abacha-case; Jersey Financial Services Commission Press Release, \u0022Abacha Investigation,\u0022 March 1, 2004 posted at http:\/\/www.jerseyfsc.org\/the_commission\/general_information\/press_releas... (notes investigation and return of assets, although not the amount returned); Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), and also available at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C... Tim Daniel, \u0022General Abacha - A Nation\u0027s Thief,\u0022 Case Study published in Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational (Bali, Indonesia, September 2007), published by the ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific (2008); Harvey Rice, \u0022Businessman will return to Nigeria to face charges \/ Accused of bilking nation\u0027s treasury,\u0022 The Houston Chronicle, November 21, 2003, accessed at http:\/\/www.chron.com\/CDA\/archives\/archive.mpl?id=2003_3709885.\n"},{"Case ID":"ARW-166","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha \/ Raj Arjandas Bhojwani Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (Abacha,1993-1998) \/ Businessman and contractor for Nigerian government (Bhojwani)","Jurisdiction of Asset Recovery":"Jersey","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"2013","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Letter of Request","Basis for Intl Cooperation":"Criminal Justice (International Co-operation) Jersey Law 2001 [Letter of Request sent by Nigeria\u0027s civil attorney, Mr. Monfrini to Nigeria to seek evidence]","Contributing Factors in Asset Recovery":"Ongoing cooperation and existing sharing agreement (Source:  Federal Ministry of Justice, \u0022FG assures speedy prosecution of criminal and civil cases; reveals more Abacha loots are being recovered,\u0022 undated statement posted June 30, 2013.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"","Case Summary":"\n\tAccording to a statement posted on the website of Nigeria\u0027s Federal Ministry of Justice, the Minister of Justice stated that GBP 22.5 million confiscated in Jersey were repatriated to Nigeria. (Source: \u00a0Federal Ministry of Justice, \u0022FG assures speedy prosecution of criminal and civil cases; reveals more Abacha loots are being recovered,\u0022 undated statement posted June 30, 2013.)\n\n\t\u00a0\n\n\tIn 2010, Mr. Bhojwani was convicted in Jersey and concealing $40 million of his illicit proceeds in bank account in the jurisdiction. \u00a0According to the February 23, 2010 Judgment by the Jersey Royal Court (Samedi Division), the Prosecution alleged that in 1996 and 1997, Mr. Bhojwani \u0022negotiated with officials serving as part of the military dictatorship of General Abacha, who was at the time the de facto President of Nigeria. \u00a0The contracts were for the supply of vehicles to the military, and it is alleged that the contracts were at a significantly inflated price such that an ollegal surplus of about US $130 milllion came into the applicant\u0027s bank accounts in Jersey. \u00a0It is alleged that the surplus was transferred by the applicant to bank accounts in other countries linked to the Abacha regime.\u0022 \u00a0 \u00a0According to the judgment, the Attorney General of Jersey indicated that \u0027In the event that Mr. Bhojwani is convicted in Jersey and the assets that represent the proceeds of his crime are lawfully confiscated then I will of course consider the possibility of a legal agreement to share assets.\u0022 \u00a0The investigation was initiated by a letter of request, sent in 2002, by Nigeria\u0027s private attorney, Mr. Enrico Monfrini to Jersey authorities. (Source: AG v. Bhojwani, 2010 JRC 042, Judgment dated February 23, 2010.) \u00a0His conviction was affirmed by the Jersey Appeals Court in February 2011; the Appeals Court also upheld the assessment of GBP 65,000 in prosecution costs against Mr. Bhojwani, calling the sum modest for a complex case. \u00a0(Sources: \u00a0Raj Arjandas Bhojwani v. The Attorney General, Jersey Court of Appeals, 2011 JCA 034 and 2011 JCA 035, both dated February 10, 2011.) \u00a0 In June 2011, the Government of Jersey stated that, \u0022It is now anticipated that discussions will take place with the government of Nigeria regarding the repatriation of some of the confiscated funds which are held in Jersey. Approximately US$170 million connected with the Abacha investigations has already been returned by Jersey to the Nigerian authorities as part of previous asset sharing agreements.\u0022 (Source: States of Jersey, \u0022Funds confiscated from money launderer,\u0022 June 7, 2011.)","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate.  (Source:  Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....  According to the Royal Court of the Isle of Jersey, Mr. Bhojwani was convicted of two counts of converting the proceeds of criminal conduct and one count of removing the proceeds of criminal conduct, contrary to art. 34(1)(b) of the Proceeds of Crime (Jersey) Law 1999.  (Source: Attorney General v. Bhojwani, 2010 JLR Note 34 (June 25, 2010), accessed at http:\/\/www.jerseylaw.je\/Judgments\/JerseyLawReports\/Display.aspx?url=cases\\JLR2010\\JLR10N034.htm.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Attorney General\u0027s Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General; N.M. Santos Costa (for the Attorney General of Nigeria)","Jurisdiction of Asset Recovery: Courts Involved":"Royal Court (Samedi Division)","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Jersey_Bhojwani_2010_JLR_Note_34 .pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Jersey_Bhojwani_2010_JRC_042_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bhojwani_v_Atty_Genl_2011_JCA_034, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bhojwani_v_Atty_Genl_2011_JCA_035, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bhojwani_Jersey_Confiscation_BBC_Jun_8_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Bhojwani_Jersey_Confiscation_PR_Jun_7_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Jersey_Bhojwani_2010_JLR_Note_34 .pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Jersey_Bhojwani_2010_JRC_042_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bhojwani_v_Atty_Genl_2011_JCA_034, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bhojwani_v_Atty_Genl_2011_JCA_035, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bhojwani_Jersey_Confiscation_BBC_Jun_8_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Bhojwani_Repatriation_Nigeria_Min_Justice_Jun_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Jersey_Bhojwani_2010_JLR_Note_34 .pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Jersey_Bhojwani_2010_JRC_042_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bhojwani_v_Atty_Genl_2011_JCA_034, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bhojwani_v_Atty_Genl_2011_JCA_035, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bhojwani_Jersey_Confiscation_BBC_Jun_8_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Bhojwani_v_Atty_Genl_2011_JCA_034.pdf","Sources ":"\n\tFederal Ministry of Justice, \u0022FG assures speedy prosecution of criminal and civil cases; reveals more Abacha loots are being recovered,\u0022 undated statement posted June 30, 2013, at http:\/\/www.nigeria.gov.ng\/2012-10-29-11-09-25\/news\/429-fg-assures-speedy...\n\n\t\u00a0\n\n\tAttorney General v. Raj Arjandas Bhojwani, 2010 JRC 042, Judgment dated February 23, 2010, and Attorney General v. Bhojwani, 2010 JLR Note 34 (June 25, 2010),; Raj Arjandas Bhojwani v. The Attorney General, Jersey Court of Appeals, 2011 JCA 034 and 2011 JCA 035, both dated February 10, 2011. \u00a0All judgements can be accessed at: http:\/\/www.jerseylaw.je\/judgments\/jerseylawreports\/JLRHomePage.aspx; States of Jersey, \u0022Funds confiscated from money launderer,\u0022 June 7, 2011, at http:\/\/www.gov.je\/News\/2011\/Pages\/BhowaniConfiscation.aspx. \u00a0See also, BBC News, \u0022Man in money launder scam with dictator to pay [GBP] 26.5m,\u0022 June 8, 2011, accessed at http:\/\/www.bbc.co.uk\/news\/world-europe-jersey-13699045\n"},{"Case ID":"ARW-167","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha \/ Swiss Mutual Legal Assistance Treaty Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1998","Asset Recovery End":"2007","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"MLAT","Contributing Factors in Asset Recovery":"\u0022Thanks to the thorough investigation in the Geneva domestic criminal proceedings, the criminal origin of the funds was clearly demonstrated.\u0022  (Source: Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets [Peter Lang, 2008]).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$723,000,000","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Part of worldwide settlement with recovered funds to be used to fund projects in the health, education, water, electricity and road sectors; monitoring responsibility held by the World Bank.  (Source:  \u0022Utilization of Repatriated Abacha Loot, Results of the Field Monitoring Exercise,\u0022 Report Prepared by the World Bank with Cooperation from the Federal Ministry of Finance (December 2006)).","Case Summary":"According to the Swiss Ministry of Foreign Affairs, $700 million were returned to Nigeria. \u00a0(Source: Swiss Ministry of Foreign Affairs, September 30, 2009; see also, The Federal Authorities of the Swiss Confederation, \u0022Out-of-court settlement in the Abacha case - Nigeria to receive more than a billion USD; The countries concerned cooperate in the implementation of the settlement,\u0022 April 17, 2002.) \u00a0In 2001, the Abacha family and associates reached an agreement with the Nigerian government to release $1.3 billion frozen in Switzerland, Liechtenstein and Luxembourg in exchange for being able to keep $100 million. According to Attorney Enrico Monfrini (lawyer for Nigeria), \u0022Thanks to the thorough investigation in the Geneva domestic criminal proceedings, the criminal origin of the funds was clearly demonstrated...On 19 August 2004, the Federal Office of Justice agreed to transmit to Nigeria all the assets in Switzerland beneficially owned by the Abacha family, waiving the condition of a prior judicial forfeiture decision in Nigeria,\u0022 \u00a0This decision was upheld for the most part by the Swiss Supreme Court in February 2005. \u00a0The Abacha family did not \u0022attempt to reverse the presumption by proving that the balance of the attached funds was not of criminal origin.\u0022 \u00a0(Source: Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets [Peter Lang, 2008]; See also, Chronology and related court documents in the Abacha case in ICC FraduNet, at http:\/\/www.icc-ccs.org\/home\/resources\/118-leading-cases\/697-abacha-case).\nUpdate (December 2017): According to the MOU between Nigeria, Switzerland, and the World Bank, signed in December 2017, Switzerland had returned $723 million to Nigeria by 2005. Based on this, the total amount of retruned assets for this case entry was updated from $700 million to $723 million. Also see ARW-250.\u00a0","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate. (Source: Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"Special Panel established to investigate Abacha looting","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Office of Justice","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Monfrini Crettol \u0026 Partners (Attorneys Enrico Monfrini and Yves Klein) - asset recovery","Jurisdiction of Asset Recovery: Courts Involved":"Geneva Canton Courts","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Switzerland_127_II_198_Jun_5_2001.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Switzerland_Accounts_Frozen_Federal_Office_Justice_PR_Oct_14_1999.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Switzerland_Anti-Corruption_Newsletter_Nov_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Switzerland_Assets_Handed_Over_Federal_Office_Justice_Feb_16_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Switzerland_Monfrini_Art_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Settlement_Switzerland_Press_Rel_Apr_17_2002.pdf","Sources ":"Swiss Ministry of Foreign Affairs, September 30, 2009; The Federal Authorities of the Swiss Confederation, \u0022Out-of-court settlement in the Abacha case - Nigeria to receive more than a billion USD; The countries concerned cooperate in the implementation of the settlement,\u0022 April 17, 2002, at http:\/\/www.admin.ch\/aktuell\/00089\/index.html?lang=en\u0026msg-id=23391.\n\u00a0\nSwiss Federal Office of Justice Press Releases: \u0022Abacha assets to be handed over to Nigeria, Switzerland doesn\u0027t provide refuge for funds of criminal origin,\u0022 February 16, 2005; \u0022Abacha\u0027s accounts frozen as provisional measure,\u0022 October 14, 1999, and others at http:\/\/www.ejpd.admin.ch\/ejpd\/en;\n\u00a0\nEnrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Bern: Peter Lang AG, 2008) and at also available at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C.... \u00a0Among the Swiss court decisions cited by Mr. Monfrini are: \u00a0ATF 1A.157\/2001 and 1A.158\/2001 (December 7, 2001); ATF 1A.49-54\/2002 (April 23 2003), ATF 115 1b 517; ATF 123 II 134; ATF 123 II 268; ATF 123 II 595; ATF 1A.215\/2004 (February 7, 2005). \u00a0See also, 127 II 198, extract from Judgment of Cour de droit public [Court of Public Law], June 5, 2001, in the case of Abacha and Bagudu, Chambre d\u0027accusacion du canton de Geneva (administrative appeal) [challenge of right to inspect files on bank records pursuant to MLAT request by Nigeria].\n\u00a0\nChronology and related court documents in the Abacha case can be accessed at ICC FraduNet, at http:\/\/www.icc-ccs.org\/home\/resources\/118-leading-cases\/697-abacha-case.\u00a0\n"},{"Case ID":"ARW-34","Case Title (Name of Public Official or Entity Allegedly Involved)":"Charles Taylor \/ Guus Kouwenhoven","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Liberia","Position of Public Official(s) (yrs in office)":"President (Taylor, 1997-2003) \/ Head of the Oriental Timber Corporation (Kouwenhoven, 2000-2003)","Jurisdiction of Asset Recovery":"Netherlands","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2003","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\u0022Guus Kouwenhoven was de-listed from the travel ban and assets freeze lists by the Committee in December 2008. However, the Panel notes that in April 2010 the Supreme Court of the Netherlands overturned a 2008 ruling by the Court of Appeal which cleared businessman Guus Kouwenhoven of charges of involvement in illegal arms deals and war crimes during the civil war in Liberia from 2000 to 2003.  The Court of Appeal will now have to re-examine the case and make a new judgement. The Panel recalls that Kouwenhoven was head of the Oriental Timber Corporation during the regime of President Charles Taylor.\u0022  (Source:  Court Press Release, April 20, 2010, accessed at http:\/\/www.rechtspraak.nl\/Gerechten\/HogeRaad\/Actualiteiten. See also, summary of Mr. Kouwenhoven\u0027s case and court decisions at the Hague Justice Portal, accessed at http:\/\/www.haguejusticeportal.net\/index.php?id=6412.)","Disposition of Criminal Case(s)":"According to the Special Court for the Sierra Leone, in September 2013, Mr. Taylor\u0027s appeal was denied. \u00a0(Source: \u00a0Special Court for the Sierra Leone, In the Appeals Chamber, Judgment of September 23, 2013, accessed at http:\/\/www.sc-sl.org\/LinkClick.aspx?fileticket=t14fjFP4jJ8%3D\u0026tabid=5).\u00a0","Jurisdiction of Origin: Investigative Agency":"United Nations Special Court for the Sierra Leone","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"United Nations Special Court for the Sierra Leone","Jurisdiction of Origin: Courts Involved":"United Nations Special Court for the Sierra Leone","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Asset Recovery: Courts Involved":"Court of Appeal; Supreme Court; District Court of the Hague","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Netherlands_Global_Witness_GVH_SCt_ Apr_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Netherlands_Hoge Raad_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Special_Court_Sierra_Leone_May_3_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taylor_Appeal_Judgment_Sep_23_2013_0.pdf","Sources ":"The Special Court for the Sierra Leone, Web Homepage, accessed on May 3, 2011, at http:\/\/www.sc-sl.org\/; Judgment, Chamber of Appeals, September 23, 2013, accessed at http:\/\/www.sc-sl.org\/LinkClick.aspx?fileticket=t14fjFP4jJ8%3D\u0026tabid=53; Court press release, April 20, 2010, available at http:\/\/www.rechtspraak.nl\/Gerechten\/ HogeRaad\/Actualiteiten. See also, Global Witness, \u0022Global Witness welcomes Dutch court decision to retry timber baron Guus Kouwenhoven for crimes committed during Liberian war,\u0022 April 21, 2010, accessed at http:\/\/www.globalwitness.org\/library\/global-witness-welcomes-dutch-court... See also, \u0022Guus Kouwenhoven,\u0022 The Hague Justice Portal, http:\/\/www.haguejusticeportal.net\/index.php?id=6412 (last accessed on July 18, 2012).\n"},{"Case ID":"ARW-36","Case Title (Name of Public Official or Entity Allegedly Involved)":"Charles Taylor \/ Two Unnamed Associates","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Liberia","Position of Public Official(s) (yrs in office)":"President (Taylor, 1997-2003) \/ Unknown (Two Unnamed Associates)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2003","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Letter of Request","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"[Unknown Status of Recovery]","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"$1,468,320","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"According to a July 23, 2003 press release by the Swiss Federal Department of Justice, \u0022Around 2 million Swiss francs has been frozen in accounts held by two persons associated with the Liberian president Charles Taylor. No accounts held directly by President Taylor have been found, however.\u0022 The press release also noted that \u0022The Federal Office of Justice (FOJ) has delegated enactment of the legal assistance application from the Special Court for Sierra Leone to the Office of the Attorney General of Switzerland.\u0022 The Federal Office of Justice had issued a prior statement stating that acting on a June 19, 2003 request by the Special Court for Sierre Leone, that it had ordered that any accounts of Liberian President Charles Taylor and further persons be blocked as a provisional measure. (Source: Federal Department of Justice and Police, \u00222 million frozen in Taylor case,\u0022 press release dated July 23, 2003, posted at http:\/\/www.bj.admin.ch\/bj\/en\/home\/dokumentation\/medieninformationen\/2003...).","Disposition of Criminal Case(s)":"According to the Special Court for the Sierra Leone, in September 2013, Mr. Taylor\u0027s appeal was denied. (Source: Special Court for the Sierra Leone, In the Appeals Chamber, Judgment of September 23, 2013, accessed at http:\/\/www.sc-sl.org\/LinkClick.aspx?fileticket=t14fjFP4jJ8%3D\u0026tabid=5). Unknown as to the unnamed associates.","Jurisdiction of Origin: Investigative Agency":"United Nations Special Court for the Sierra Leone","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"United Nations Special Court for the Sierra Leone","Jurisdiction of Origin: Courts Involved":"United Nations Special Court for the Sierra Leone","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Office of Justice","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Office of the Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Special_Court_Sierra_Leone_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Switzerland_EJPD_PR_Jul_23_2003.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Switzerland_EJPD_PR_Jun_23_2003.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taylor_Appeal_Judgment_Sep_23_2013.pdf","Sources ":"Swiss Federal Office of Justice, \u00222 million frozen in Taylor case,\u0022 Press Release dated July 23, 2003, posted at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2003\/ref_... Swiss Federal Office of Justice, \u0022Taylor\u0027s accounts blocked as provisional measure,\u0022 Press Release dated June 23, 2003, at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2003\/ref_.... \u00a0The Special Court for the Sierra Leone Website Homepage, accessed on May 3, 2011, at http:\/\/www.sc-sl.org\/; Judgment, Chamber of Appeals, September 23, 2013, accessed at http:\/\/www.sc-sl.org\/LinkClick.aspx?fileticket=t14fjFP4jJ8%3D\u0026tabid=53\n"},{"Case ID":"ARW-37","Case Title (Name of Public Official or Entity Allegedly Involved)":"Charles Taylor \/ Viktor Bout \/ Richard Chichakli","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Liberia","Position of Public Official(s) (yrs in office)":"President (Taylor, 1997-2003) \/ Close Associate (Bout)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2010","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"\n\tIn February 2010, the U.S. District Court for the Southern District of New York court unsealed a 9-count indictment against Mr. Bout and his chief financial manager Richard Ammar Chichakli. \u00a0The indictment included forfeiture allegations for more than $1.7 million alleged to have been laundered through New York banks to other banks in the U.S. and noted that the U.S. Department of Treasury had blocked the U.S. accounts of Bout-associated companies in violations of US sanctions against the former Taylore regime. Both men are on the UN Security Council Resolution 1521 asset freeze list. (Source: Indictment in U.S. v. Bout and Chichakli, Case No. 1:09-cr-1002 (S.D.N.Y.), unsealed February 17, 2010 and Press Release by U.S. Attorney\u0027s Office for the Southern District of New York on same date; Superseding Indictment filed on October 25, 2013 against Richard Chichakli). \u00a0On November \u00a016, Mr. Bout was extradited from Thailand to the U.S. (Source: Seth Mydans, \u0022Thailand Extradites Russian Arms Suspect to the U.S.,\u0022 New York Times, November 16, 2010.) \u00a0In April 2012, Mr. Bout was convicted and sentenced in another case against him in the U.S. District Court for the \u00a0Southern District of New York on terrorism-related charges; he appealed the conviction to the U.S. Court of Appeals, Second Circuit. (Source: U.S. v. Bout, Case No. 1:08-cr-00365 (S.D.N.Y.), Judgment in a Criminal Case filed April 9, 2012. US Appeals Court case no. 12-1487).\n\n\t\u00a0","Disposition of Criminal Case(s)":"In April 2012, Mr. Bout was sentenced on terrorism-related charges in the U.S. District Court for the Southern District of New York; he has appealed the conviction to the US Court of Appeals. \u00a0(US v. Bout, Case No. 1:08-cr-00365 (S.D.N.Y.) \u00a0According to the U.S. Government\u0027s indictment, Mr. Bout (and Mr. Chichakli) also faces money laundering, wire fraud and conspiracy charges in a separate case pertaining to violations of US Sanctions against the former Taylor regime before the U.S. District Court for the Southern District of New York. (US v. Bout and Chichakli, Case No. 1:09-cr-01002 (S.D.N.Y.), Indictment unsealed on February 17, 2010).","Jurisdiction of Origin: Investigative Agency":"United Nations Special Court for Sierra Leone","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"United Nations Special Court for Sierra Leone","Jurisdiction of Origin: Courts Involved":"United Nations Special Court for Sierra Leone","Jurisdiction of Asset Recovery: Investigative Agency":"Drug Enforcement Agency; Assistance provided by Department of Justice, Office of International Affairs and Department of State; INTERPOL","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Southern District of New York","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_Case_108-cr-00365_SDNY_Court_Docket_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_Extradition_NYT_Nov_16_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_Indictment_Feb_17_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_Indictment_PR_Feb_17_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_ML_DktRpt_May3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_ML_DktRpt_Pulled_Dec_3_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_Terrorism_DktRpt_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bout_SDNY_Arms_Conviction_WSJ_CC_Nov_2_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bout_SDNY_Arms_Conviction_WSJ_CC_Nov_2_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_Case_108-cr-00365_SDNY_Court_Docket_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_Extradition_NYT_Nov_16_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_Indictment_Feb_17_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_Indictment_PR_Feb_17_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_ML_DktRpt_May3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_ML_DktRpt_Pulled_Dec_3_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_Terrorism_DktRpt_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bout_SDNY_Arms_Conviction_WSJ_CC_Nov_2_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bout_SDNY_Sanctions_Chichakli_Supersede_Indict_Oct_25_2013.pdf","Sources ":"U.S. v. Bout and Chichakli, Case No. 1:09-cr-1002 (S.D.N.Y.), Indictment unsealed on February 17, 2010 and Superseding Indictment (Chichakli) filed October 25, 2013); \u00a0United States Attorney\u0027s Office for the Southern District of New York Press Release, \u0022U.S. Announces New Indictment against International Arms Dealer Viktor Bout and American Co-Conspirator for \u00a0Money Laundering, Wire Fraud and Conspiracy,\u0022 February 17, 2010. \u00a0See also, US v. Bout, Case No. 1:08-cr-00365 (S.D.N.Y.), Judgment in a Criminal Case filed April 6, 2012; Notice of appeal filed April 7, 2012. \u00a0Seth Mydans, \u0022Thailand Extradites Russian Arms Suspect to U.S.,\u0022 New York Times, November 16, 2010; Samuel Rubenfeld, \u0022Viktor Bout Convicted In Arms-Dealing Case,\u0022 Wall Street Journal Corruption Currents, November 2, 2011, accessed at http:\/\/blogs.wsj.com\/corruption-currents\/2011\/11\/02\/viktor-bout-convicte...\n"},{"Case ID":"ARW-38","Case Title (Name of Public Official or Entity Allegedly Involved)":"Charles Warwick Reid","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"","Position of Public Official(s) (yrs in office)":"Deputy Crown Prosecutor (1975-1989)","Jurisdiction of Asset Recovery":"New Zealand","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1986","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.15, Art.20","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Cooperation by Hong Kong and New Zealand","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"At his 1990 sentencing in Hong Kong, Charles Warwick Reid was ordered to pay HK $12.4 million (the value of his unexplainable assets).  However, the funds in his Singaporean bank account had disappeared, and Mr. Reid never paid the fine.  The Attorney General of Hong Kong pursued a civil case on behalf of the Crown in New Zealand to seize the three properties Mr. Reid owned in New Zealand. In 1993, the Privy Council in London held that the properties were held in constructive trust for the Crown.  (Source: Attorney General for Hong Kong v. Reid, 1993 UKPC 2 [November 1, 1993]).  A week after his release from Hong Kong and return to New Zealand, however, he was re-arrested on another bribery charge and again forced to forfeit properties that represented the proceeds of his corrupt activities. The High Court of Auckland ordered the seizure of Mr. Reid\u0027s assets, which included his family home in Tauranga, the Bay BodyFit Gymnasium, and his family trust funds.  In a deal reached with Crown lawyers in 1997, Charles Warwick Reid dropped his appeal against the ruling, and the Reids were allowed to rent their former home at market rates for a period of six years, until their youngest child turned sixteen. (Source: AFP, \u0022Ex-HK Prosecutor Warwick Reid gives up fight to keep assets,\u0022 October 17, 1997.)","Disposition of Criminal Case(s)":"According to a judgment by the Hong Kong Court of Appeals, Mr. Reid pleaded guilty to violation of section 10(1)(b) of the Prevention of Bribery Ordinance and, in July 1990, he was sentenced by the Hong Kong High Court to an 8-year prison term. (Source: In the Matter of an Application for Leave to Apply for Judicial review and in the Matter of Charles Warwick Reid, Case No. CACV 149\/2003, Judgement dated January 12, 1994.)","Jurisdiction of Origin: Investigative Agency":"Independent Commission Against Corruption; [Philippines Immigration officers, 1990 - illegal entry]","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General ","Jurisdiction of Origin: Courts Involved":"Magistrates Court, High Court","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Herbert Smith, London Agents for Russell McVeagh McKenzie Bartleet \u0026 Co (for Attorney General of Hong Kong, Privy Council)","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Auckland, Court of Appeal of New Zealand, United Kingdom Privy Council","Documents":"","Sources ":"AG for Hong Kong v. Reid, 1993 UKPC 2 (01 November 1993) (on appeal from the Court of Appeal of New Zealand, Civil Appeal No. 44 of 1992) (available through www.bailii.org) and Index of Reference including Reasons for Judgment of the Court of Appeal of New Zealand (December 19, 1991) and Judgment of Court of Appeal of New Zealand (March 18, 1992); In the Matter of an Application for Leave to Apply for Judicial Review and in the Matter of Charles Warwick Reid, Case No. CACV 149\/1993, Judgement dated January 12, 1994, accessed at http:\/\/legalref.judiciary.gov.hk\/lrs\/common\/ju\/judgment.jsp; See also, \u0022Senior Government Counsel Bribery Case,\u0022 as part of the landmark cases section of the Hong Kong Independent Commission Against Corruption website, at http:\/\/www.icac.org.hk\/new_icac\/eng\/cases\/ddpp\/dcont_01.htm.\n"},{"Case ID":"ARW-42","Case Title (Name of Public Official or Entity Allegedly Involved)":"Chinese National #1 (unnamed)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"China","Position of Public Official(s) (yrs in office)":"Unknown","Jurisdiction of Asset Recovery":"Australia","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Other ","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Australia - China law enforcement cooperation and establishment of Australia\u0027s Equitable Sharing Program (Source: \u0022Equitable Sharing Program,\u0022 on the website of the Australian Government, Attorney-General\u0027s Department, Overview of the Proceeds of Crime Act 2002, accessed at http:\/\/www.ag.gov.au\/agd\/WWW\/ncphome.nsf\/Page\/POCA_funding_for_Non-Government_Agencies.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$2,561,820","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"Citing obligation under the United Nations Convention Against Corruption to share profits of crime where assistance in the recovery of those profits contributes to legal enforcement cooperation, the Australian government made the following payment under its equitable sharing program: AUD $3,372,807.49 to the Chinese Government for money recovered in Australia by the Australian Federal Police, regarding a matter involving a Chinese national, who was wanted in China for embezzlement and fraud offenses. (Source: \u0022Equitable Sharing Program,\u0022 on the website of the Australian Government, Attorney-General\u0027s Department, Overview of the Proceeds of Crime Act 2002, accessed at http:\/\/www.ag.gov.au\/agd\/WWW\/ncphome.nsf\/Page\/POCA_funding_for_Non-Gover....)","Disposition of Criminal Case(s)":"According to the website of Australia\u0027s Attorney General on the Equitable Sharing Program under the Proceeds of Crime Act, the Chinese national was \u0022wanted in China for embezzlement and fraud charges.\u0022 (Source: http:\/\/www.ag.gov.au\/agd\/WWW\/ncphome.nsf\/Page\/POCA_funding_for_Non-Gover..., last accessed on May 3, 2011.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Australian Federal Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"http:\/\/\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Australia_ATTY_GENL_ESP_May_3_2011.pdf","Sources ":"\u0022Equitable Sharing Program,\u0022 on the website of the Australian Government, Attorney-General\u0027s Department, Overview of the Proceeds of Crime Act 2002, accessed at http:\/\/www.ag.gov.au\/agd\/WWW\/ncphome.nsf\/Page\/POCA_funding_for_Non-Gover....\n"},{"Case ID":"ARW-43","Case Title (Name of Public Official or Entity Allegedly Involved)":"Chinese National #2 (unnamed)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"China","Position of Public Official(s) (yrs in office)":"Unknown","Jurisdiction of Asset Recovery":"Australia","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"","UNCAC Offenses Implicated":"Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Other ","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Australia - China law enforcement cooperation and establishment of Australia\u0027s Equitable Sharing Program (Source: \u0022Equitable Sharing Program,\u0022 on the website of the Australian Government, Attorney-General\u0027s Department, Overview of the Proceeds of Crime Act 2002, accessed at http:\/\/www.ag.gov.au\/agd\/WWW\/ncphome.nsf\/Page\/POCA_funding_for_Non-Government_Agencies.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$3,873,950","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"Citing obligation under the United Nations Convention Against Corruption to share profits of crime where assistance in the recovery of those profits contributes to legal enforcement cooperation, the Australian government made the following payment under its equitable sharing program: AUD $4,160,259.81 to the Chinese Government for money recovered in Australia by the Australian Federal Police, regarding a matter involving a Chinese national, who was wanted in China for money laundering offenses. (Source: \u0022Equitable Sharing Program,\u0022 on the website of the Australian Government, Attorney-General\u0027s Department, Overview of the Proceeds of Crime Act 2002, accessed at http:\/\/www.ag.gov.au\/agd\/WWW\/ncphome.nsf\/Page\/POCA_funding_for_Non-Gover....)","Disposition of Criminal Case(s)":"According to the website of the Australia\u0027s Attorney General on the Equitable Sharing Program under the Proceeds of Crime Act, the Chinese government assisted in \u0022the investigation and prosecution of a Chinese national for money laundering offences.\u0022 (Source: http:\/\/www.ag.gov.au\/agd\/WWW\/ncphome.nsf\/Page\/POCA_funding_for_Non-Gover..., last accessed on May 3, 2011.)","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Australian Federal Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"http:\/\/\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Australia_ATTY_GENL_ESP_May_3_2011_0.pdf","Sources ":"\u0022Equitable Sharing Program,\u0022 on the website of the Australian Government, Attorney-General\u0027s Department, Overview of the Proceeds of Crime Act 2002, accessed at http:\/\/www.ag.gov.au\/agd\/WWW\/ncphome.nsf\/Page\/POCA_funding_for_Non-Gover....\n"},{"Case ID":"ARW-44","Case Title (Name of Public Official or Entity Allegedly Involved)":"CODELCO \/ Juan Pablo Davila","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Chile","Position of Public Official(s) (yrs in office)":"Chief commodities futures trader, CODELCO (1989-1994)","Jurisdiction of Asset Recovery":"Cayman Islands","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1995","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Early warning to bank putting it on notice that it may hold proceeds from fraud which encouraged it to report the funds in order not to risk liability as constructive trustee under Cayman laws. (Source: Website of the Government of Cayman Islands \u0022Forfeiting Proceeds of Corruption,\u0022 last accessed on February 28, 2011, at http:\/\/www.gov.ky\/portal\/page?_pageid=1142,1687439\u0026_dad=portal\u0026_schema=PORTAL).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to the 2002 decision by the Grand Court of the Cayman Islands, as part of his sentence in Chile, Mr. Davila was ordered to pay US$186,183,060 in damages to Codelco.  (Source:   Corporacion Nacional del Cobre de Chile v. Interglobal Incorporated and Avendano Sabugao, 2002 CILR 298 (May 23, 2002))  According to the official website of the Government of Cayman Islands, \u0022In the matter of Re Codelco an early warning to the bank putting it on notice that it may hold accounts which contained the proceeds of official corruption visited on a large scale upon the State-owned copper producing enterprise of the State of Chile, caused the bank voluntarily to freeze the accounts. In responding as it did, the bank\u0027s primary early concern was to avoid its own civil liability as a constructive trustee; but this allowed the Chilean Government time to get discovery orders against the bank for disclosure of information about the accounts and ultimately to freeze the accounts and recover the proceeds. This resulted also in information being disclosed for use in proceedings in other jurisdictions to recover other assets and by the U.S. Commodity Futures Trading Commission [CFTC] in proceedings taken against some of the co-conspirators, employees of a large futures brokerage firm and who were regulated by the CFTC.\u0022 (Source: Website of the Government of Cayman Islands, \u0022Forfeiting Proceeds of Corruption,\u0022 last accessed on October 18, 2010 at http:\/\/www.gov.ky\/portal\/page?_pageid=1142,1687439\u0026_dad=portal\u0026_schema=P...).","Disposition of Criminal Case(s)":"According to a 2002 decision by the Cayman Islands Grand Court, \u0022Following criminal proceedings in Chile, Davila was found guilty of, inter alia, fraud against the state and the crime of presentation of false documents in a criminal proceeding. The latter relates to his production of the fabricated Drexel Burnham documentation. Davila was sentenced to a total of eight years\u0027 imprisonment.\u0022","Jurisdiction of Origin: Investigative Agency":"[Congressional and criminal proceedings in Chile]","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Consejo de Defensa de Estado","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General; Ritchie \u0026 Duckworth (G.F. Ritchie, Charles Adams, representing CODELCO)","Jurisdiction of Asset Recovery: Courts Involved":"Grand Court","Documents":"","Sources ":"Corporacion Nacional del Cobre de Chile v. Interglobal Incorporated and Avendano Sabugao, 2002 CILR 298, Judgment dated May 23, 2002, accessed at http:\/\/www.caymanjudicial-legalinfo.com.ky\/judgments\/Cayman-Islands-Law-... \nDeutsch-Sudamerikanische Bank A.G. v. Corporacion Nacionale del Cobre de Chile and Attorney General, 1996 CILR 1, Judgment dated December 9th, 1995, accessed at http:\/\/www.caymanjudicial-legalinfo.ky\/Judgments\/Cayman-Islands-Law-Repo....  \nSee also Website of the Government of Cayman Islands \u0022Forfeiting Proceeds of Corruption,\u0022 last accessed on February 28, 2011, at http:\/\/www.gov.ky\/portal\/page?_pageid=1142,1687439\u0026_dad=portal\u0026_schema=P...\n"},{"Case ID":"ARW-45","Case Title (Name of Public Official or Entity Allegedly Involved)":"Daniel Arap Moi \/ Anglo-Leasing Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kenya","Position of Public Official(s) (yrs in office)":"President (1978-2002)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"2004","UNCAC Offenses Implicated":"Art.17, Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Other","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"According to a Kenyan government audit report, during the investigation by the Kenya Anti-Corruption Commission  into Anglo Leasing, some of the credit supplier companies involved voluntarily refunded the full amounts relating to their contracts without prompting or explanation:  (Source: \u0022Special Audit on Procurement of Passport Issuing Equipment By the Department of Immigration, Office of the Vice-President and Ministry of Home Affairs.\u0022 Report of the The Public Accounts Committee to the Kenyan National Assembly, Ninth Parliament - Fifth Session. March 2006. page 16ff.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$13,248,234","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to a Kenyan government audit report, during the investigation by the Kenya Anti-Corruption Commission (led by John Githongo) into Anglo Leasing, some of the credit supplier companies involved voluntarily refunded the full amounts relating to their contracts without prompting or explanation:  Leyland Export Ltd. returned $910,000 (from the Export Lease Purchase project); Anglo Leasing \u0026 Finance Ltd. returned $4,744,444 (from the Forensic Science Laboraties project) and EUR 956,700 (from the Immigration ISDCS project); Infotalent Ltd. returned EUR 5,287,164 (from the Kenyan Police Law and Order (E Cops) project).  The $4.7 million from Anglo Leasing was remitted by the Schroder and Co Bank AG of Zurich on behalf of its client, but Mr. Githongo commented that no one in the government knew who actually had sent the money.  (Source: \u0022Special Audit on Procurement of Passport Issuing Equipment By the Department of Immigration, Office of the Vice-President and Ministry of Home Affairs.\u0022 Report of the The Public Accounts Committee to the Kenyan National Assembly, Ninth Parliament - Fifth Session. March 2006. page 16ff.)","Disposition of Criminal Case(s)":"None","Jurisdiction of Origin: Investigative Agency":"Kenya Anti-Corruption Commission; Kenya National Assembly, Public Accounts Committee","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"High Court; Court of Appeal of Kenya at Nairobi","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"","Sources ":"Special Audit on Procurement of Passport Issuing Equipment By the Department of Immigration, Office of the Vice-President and Ministry of Home Affairs,\u0022 Report of the The Public Accounts Committee to the Kenyan National Assembly, Ninth Parliament - Fifth Session. March 2006, at 16ff, accessed at website of Transparency International Kenya, http:\/\/www.tikenya.org\/documents\/pac_report06.pdf; \nProfile of Daniel Toroitich arap Moi from the Official Website of State House, Kenya, accessed at http:\/\/www.statehousekenya.go.ke\/presidents\/moi\/profile.htm.\n"},{"Case ID":"ARW-46","Case Title (Name of Public Official or Entity Allegedly Involved)":"Daniel Arap Moi \/ Anglo-Leasing Case \/ First Mercantile Securities Corporation","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kenya","Position of Public Official(s) (yrs in office)":"President (1978-2002)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction; Domestic Criminal Investigation","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"Unknown Amounts Frozen","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"NA","Agreement for Returned Assets - Description":"NA","Case Summary":"In June 2014, the Office of the Attorney General of Switzerland announced that \u0022as part of its own criminal investigation into the Anglo Leasing case, [the OAG] has requested support from the Kenyan judicial authorities to obtain evidence of a possible predicate offence to money laundering.\nCompanies based in Switzerland are suspected of being involved in the Kenyan Anglo Leasing scandal and related assets are believed to have been moved to Switzerland. This is the starting point for the OAG\u0027s criminal proceedings against three suspects, which began in April 2009 following a report from the Money Laundering Reporting Office (MROS).\nSince then, the OAG has successfully identified and frozen several bank accounts in Switzerland. Financial transfers were assessed and the results of the comprehensive cash flow analysis of cross-border links led the OAG to request mutual legal assistance from various states. England, Scotland and Jersey have already provided the OAG with a considerable amount of useful information.\nThe OAG is now requesting Kenya for active mutual legal assistance in order to obtain evidence of the predicate offence committed outside Switzerland. The suspected predicate offence to money laundering is the alleged bribery of Kenyan public officials in return for the award of lucrative government contracts. The OAG has requested the transmission of evidence obtained in the course of the Kenyan criminal proceedings in the Anglo Leasing scandal. Assistance from the Kenyan judicial authorities is therefore essential and their contribution will be decisive to the success of the Swiss criminal investigation.\nThe OAG has previously granted mutual legal assistance to Kenya, providing the Kenya Anti-Corruption Commission with documents on Swiss links to the Anglo Leasing affair and on the associated funds that were identified in Switzerland (See OAG press release dated 20.09.2012: https:\/\/www.news.admin.ch\/message\/index.html?long=de\u0026msg-id=46040).\u0022 (Source: Switzerland, Office of the Attorney General Media Releases:  \u0022Anglo Leasing affair: Office of the Attorney General of Switzerland requests Kenya for mutual legal assistance,\u0022 June 20, 2014.)\nOn July 16, 2010, in the matter between the Kenya Anti-Corruption Commission and First Mercantile Securities Corporation, the Court of Appeal of Kenya at Nairobi set aside a ruling by the lower court which had permitted First Mercantile to have set aside the request for mutual legal assistance made by the anti-corruption agency to the Swiss authorities in connection with its investigation into the Anglo-Leasing scandal.  (Source: Between Kenya Anti-Corruption Commission and First Mercantile Securities Corporation, In H.C. Misc. C.C. No. 695 of 2007, Civil Appeal 194 of 2008, July 16, 2010).   As explained in the court\u0027s judgment, on July 22, 2002, the Government of Kenya entered into an US$811,787,000 agreement with First Mercantile Securities Corporation.  The Postal Corporation of Kenya had wanted to purchase telecommunications equipment from an American company, but neither the Government of Kenya or the Postal Corporation could immediately pay the $811 million in lump sum.  The court then writes \u0022But for some unexplained reason\u0022 instead of the Postal Corporation, the Government of Kenya entered into a contract with First Mercantile to finance the purchase.  The 2002 contract required the Government to make installment payments to First Mercantile.  In 2003, the Anti-Corruption and Economic Crimes Act came into force and established the Kenya Anti-Corruption Commission.  According to the Court, the Government of Kenya made payments to First Mercantile up to June 14, 2004, leaving an outstanding balance of US $5,936,910.09, when \u0022For some reason or reasons which we need not concern ourselves with the in the judgment, GOK [Government of Kenya] thereafter refused to pay any further instalments. We only need to point out that this agreement is one of those now notoriously referred to in Kenya as the Anglo-Leasing Scandal.  when it stopped the payments.\u0022  In December 2005, First Mercantile sued the Kenyan government for unpaid sums.  In May 2007, the Director of the Kenyan Anti-Corruption Commission sent a letter of request to the Federal Office of Justice and Police Section of Mutual Assistance in Criminal Matters, which stated that the Commission \u0022is investigating in the present case serious criminal offences which include breach of laws, procedures and regulations, corrupt transactions with agents, in which Government of Kenya officials acting on false and or fradulent information, awarded a contract for US$12.8 million.  About US$6.8 million was paid out to First Mercantile Securities Corporation, Tortala, Succursale de Geneva, a subsidiary of First Mercantile Securities Corporation, British Virgin Islands...to Swiss Bank Accounts which is the reason for the present request for MLA is make to Swiss Authorities.\u0022  A month after the request was made, the company filed suit in June 2007, in the High Court in Nairobi to seek an order to prohibit the Anti-Corruption Commission\u0027s mutual legal assistance request and to stay enforcement of the letter of request for assistance.  The High Court granted leave which also operated as a stay on the assistance request.   The Court of Appeals reversed, writing, in part, that the Anti-Corruption Commission is independent of the Government of Kenya and that it \u0022can investigate GOK [Government of Kenya] officials if they are suspected to have been involved in corrupt practices or to have committed economic crimes.\u0022  Moreover, it was up to the Swiss government to  agree to the request or not.  The Court stated that one of the grounds presented by the Commission as the basis for its mutual legal assistance request was that Kenya was a signatory to the United Nations Convention on Corruption.  The Court wrote, \u0022We have already held that the Appellant [Anti-Corruption Commission] was entitled to issue the LMA [Letter for Mutual Assistance]  under section 12(3) of its creating statute and we see no reason to go into the question on principles of international law.\u0022 (Source: Id.)","Disposition of Criminal Case(s)":"None","Jurisdiction of Origin: Investigative Agency":"Kenya Anti-Corruption Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Kenya Anti-Corruption Commission","Jurisdiction of Origin: Courts Involved":"High Court of Nairobi; Court of Appeal of Kenya at Nairobi","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Office of Justice and Police, Section of Mutual Assistance in Criminal Matters","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Office of the Attorney General of Switzerland","Jurisdiction of Asset Recovery: Courts Involved":"NA","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Moi_Profile_Statehousekenya_Gov_Apr_29_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Moi_Special_Audit_Security_Projects_Mar_2006.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Anglo_Leasing_Switzerland_OAG_MLA_Request_to_Kenya_Jun_20_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Moi_Profile_Statehousekenya_Gov_Apr_29_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Moi_Special_Audit_Security_Projects_Mar_2006.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Anglo_Leasing_Switzerland_Dossiers_to_Kenya_Sep_20_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Moi_Profile_Statehousekenya_Gov_Apr_29_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Moi_Special_Audit_Security_Projects_Mar_2006.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Anglo_Leasing_Special_Audit_Security_Projects_Mar_2006.pdf","Sources ":"Between Kenya Anti-Corruption Commission and First Mercantile Securities Corporation, In H.C. Misc. C.C. No. 695 of 2007, Civil Appeal 194 of 2008, Court of Appeal of Kenya at Nairobi (July 16, 2010), accessed at http:\/\/kenyalaw.org\/Downloads_FreeCases\/76031.pdf; Profile of Daniel Toroitich arap Moi from the Official Website of State House, Kenya, accessed at http:\/\/www.statehousekenya.go.ke\/presidents\/moi\/profile.htm.\nSwitzerland, Office of the Attorney General Media Releases:  \u0022Anglo Leasing affair: Office of the Attorney General of Switzerland requests Kenya for mutual legal assistance,\u0022 June 20, 2014, at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=53434 and \u0022Further legal assistance dossiers handed over to Kenya,\u0022 September 20, 2012, at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026long=de\u0026msg-id=46040\n"},{"Case ID":"ARW-47","Case Title (Name of Public Official or Entity Allegedly Involved)":"Daniel Arap Moi \/ World Duty Free Company Limited","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kenya","Position of Public Official(s) (yrs in office)":"President (1978-2002)","Jurisdiction of Asset Recovery":"International Centre for Settlement of Investment Disputes, Washington, D.C.","Jurisdiction of Asset Description":"Location of Recovery Effort","Asset Recovery Start":"1998","Asset Recovery End":"2006","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Other ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"The Article 9(2)(c) of the Agreement of 27th April 1989 provided that any arbitration shall apply English law while Article 10(A) provided that the Agreement shall be governed by Kenyan law.  The Tribunal noted that the provisions were \u0022perhaps awkwardly worded.  for present purposes, however, no practical difficulty arises from their apparent inconsistency,\u0022 in voiding the contract under both English and Kenyan laws and public policy.  (Award of September 25, 2006, at 49).  The Tribunal also held that \u0022Mr. Ali\u0027s payment was received corruptly by the Kenyan head of state; it was a covert bribe; and accordingly its receipt is not legally to be imputed to Kenya itself.\u0022 (Award of September 25, 2006, at 54).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"Avoidance of monetary damages in commercial arbitration case filed against Government of Kenya","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to the December 2010 Asset Recovery Handbook by the Stolen Asset Recovery Initiative, \u0022In 1989, Kenya initially entered into an agreement with World Duty Free Company (WDF) for construction, maintenance, and operation of duty-free complexes at Nairobi and Mombasa international airports.  In obtaining the contract, WDF paid bribes to the former Kenyan president, Daniel arap Moi. Subsequently, in 1998, WDF was placed under receivership by the High Court in Kenya; and a formal judgment and decree was made in 2001, transferring beneficial ownership to the receiver.  In disputing the order before the ICSID, WDF claimed that Kenya had unlawfully destroyed its contractual rights through the receivership order. The government of Kenya argued that WDF\u0027s procurement of the agreement through bribes was a breach of English and Kenyan laws applicable to the contract, as well as breach of international public policy, and that the government was lawfully entitled to avoid contract obligations.\u0022 (Source:  Asset Recovery Handbook (Stolen Asset Recovery Initiative, December 2010) at 167).  The Arbitration Tribunal noted that \u0022former President of Kenya, Mr. Daniel arap Moi, was not a party to these arbitration proceedings and was not legally represented in these proceedings.  He was not heard as a witness... The Tribunal decided on the dispute submitted to it on the evidence adduced and the submissions made by the parties to the case.\u0022  (Source: In the Proceeding Between World Duty Free Company Limited and The Republic of Kenya, ICSID Case No. ARB\/00\/7, Award of September 25, 2006.)   World Duty Free Company Limited, a company incorporated in the Isle of Man, had requested the arbitration on June 16, 2000.  The request was registered by the ICSID purusant to Article 36(3) of the ICSID Convention on the Settlement of Investment Disputes between States and Nationals of Other States.   World Duty Free was managed by Mr. Nasir Ibrahim Ali; in 1991, the Al-Ghurair family which had owned WDF sold its shares and as a result, Mr. Ali held in his own name 10% of the World Duty Free shares and 90% of the stock was registered in the name of Dinky International SA, whose shareholders were Mr. Ali at 90% and rest owned by his wife.  Mr. Ali\u0027s $2 million payment to then President Moi is described in his written statement to the Tribunal (Award of September 25, 2006, at 37-38.)  The Tribunal wrote, \u0022It remains nonetheless a highly disturbing feature in this case that the corrupt recipient of the Claimant\u0027s bribe was more than an officer of the State but its most senior officer, the Kenyan President; and that it is Kenya which is here advancing as a complete defence to the Claimant\u0027s [World Duty Free\u0027s] claims the illegalities of its own former President.  Moreover, on the evidence before this Tribunal, the bribe was apparently solicited by the Kenyan President and not wholly initiated by the Claimant.  Although the Kenyan President has now left office and is no longer immune from suit under the Kenyan Constitution, it appears that no attempt has been made by Kenya to prosecute him for corruption or to recover the bribe in civil proceedings.\u0022 (Award of September 25, 2006, at 59.)","Disposition of Criminal Case(s)":"None","Jurisdiction of Origin: Investigative Agency":"Kenyan Anti-Corruption Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Kenyan Anti-Corruption Commission","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Government of Kenya represented at proceedings by: Attorney General of Kenya, Counsel from law firm of Freshfields Bruckhaus Deringer, Director of Public Prosecutions, Senior Assistant Commissioner Police of Kenya","Jurisdiction of Asset Recovery: Courts Involved":"International Centre for Settlement of Investment Disputes (Washington, D.C.)","Documents":"","Sources ":"World Duty-Free Company Limited v. The Republic of Kenya, ICSID Case No. ARB\/00\/7, Award of September 25, 2006, accessed at http:\/\/ita.law.uvic.ca\/documents\/WDFv.KenyaAward.pdf;  \nJean-Pierre Brun, Larissa Gray, Clive Scott and Kevin M. Stephenson, Asset Recovery Handbook: A Guide for Practitioners (Stolen Asset Recovery Initiative, December 2010), \u0022Box 8.5: World Duty Free Company Limited v. The Republic of Kenya,\u0022 at 167.  \nSee also, \u0022World Duty Free v The Republic of Kenya: a Unique Precedent?,\u0022 Summary of Chatham House International Law Discussion Group meeting, March 28, 2007, with main speaker Constantine Partasides, Partner, International Arbitration Group, Freshfields Bruckhaus Deringer who represented Government of Kenya in the arbitration proceedings, accessed at http:\/\/www.chathamhouse.org.uk\/files\/9129_il280307.pdf; \nProfile of Daniel Toroitich arap Moi from the Official Website of State House, Kenya, accessed at http:\/\/www.statehousekenya.go.ke\/presidents\/moi\/profile.htm.\n"},{"Case ID":"ARW-49","Case Title (Name of Public Official or Entity Allegedly Involved)":"Denis Sassou Nguesso","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Congo, Republic of","Position of Public Official(s) (yrs in office)":"President (1979-1992 and 1997-present)","Jurisdiction of Asset Recovery":"France","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2007","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"[Ongoing Case, but Transparency International stated that this is the first time French courts allowed such a complaint by nongovernmental organizations to proceed. Source: Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision: The complaint filed by Transparency International France is ruled admissible,\u0022 November 9, 2010.]","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"In November 2010, the French Supreme Court held that the complaint filed by Transparency International France  and SHERPA against Mr. Sassou Nguesso may proceed.  The organizations had filed their \u0022Biens Mal Acquis\u0022 (Improperly acquired property) complaint against Omar Bongo, Denis Sassou Nguesso and Teodoro Obiang and their relatives.  With regard to Mr. Sassou Nguesso and his relatives, the complaint alleged that they had acquired real estate, including 18 properties, one hundred and twelve bank accounts and fleet of automobiles including at least one vehicle estimated to be worth EUR 172,321.  (Source: Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision, The complaint by Transparence International France is ruled admissible,\u0022 November 9, 2010.)","Disposition of Criminal Case(s)":"In November 2010, the French Supreme Court held that the complaint (\u0022Biens Mal Acquis\u0022\/Improperly Acquired Property) filed by Transparency International France and SHERPA against Mr. Sassou Nguesso may proceed.  (Sources: Supreme Court of France, Case No. 6092, decision of November 9, 2010, L\u0027association Transparence International France, partie civile, reversing High Court of Paris, section 2, judgment of October 29, 2009; Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision, The complaint by Transparence International France is ruled admissible,\u0022 November 9, 2010.)","Jurisdiction of Origin: Investigative Agency":"NA","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Transparency International France, SHERPA (civil complaint)","Jurisdiction of Asset Recovery: Courts Involved":"La Cour de Cassation, Chambre Criminelle (Supreme Court)","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sassou_Nguesso_France_SCt_Nov_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sassou_Nguesso_Transparency_Intl_PR_Nov_9_2010.docx, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sassou_Nguesso_US_DOS_Congo_Profile_Dec_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Sassou_Nguesso_France_%20Mediapart_Oct_11_2013.pdf","Sources ":"Supreme Court of France, Case No. 6092, decision of November 9, 2010, L\u0027association Transparence International France, partie civile, reversing High Court of Paris, section 2, judgment of October 29, 2009. See also Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision, The complaint by Transparence International France is ruled admissible,\u0022 November 9, 2010, posted at http:\/\/www.transparency.org\/news_room\/latest_news\/press_releases_nc\/2010... US Department of State, Background Note: Republic of the Congo (December 2010), accessed at http:\/\/www.state.gov\/r\/pa\/ei\/bgn\/2825.htm; Mediapart, \u0022A Paris, le shopping de la corruption du clan Sassou Nguesso,\u0022 October 11, 2013, at http:\/\/www.mediapart.fr\/journal\/international\/101013\/paris-le-shopping-d...\n"},{"Case ID":"ARW-50","Case Title (Name of Public Official or Entity Allegedly Involved)":"Diepreye Alamieyeseigha (Cyprus)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Governor (1999-2005)","Jurisdiction of Asset Recovery":"Cyprus","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Nigeria\u0027s lawyers in the civil case carried out the enforcement of the judgment in Cyprus. (Source: StAR Case Study, attached PDF)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"Nigeria brought a civil suit against Santolina Investment Corporation, an entity that was the purported owner of properties purchased with Mr. Alamieyeseigha\u0027s criminal proceeds and in relation to approximately GBP 1 million on deposit in Cyprus (as of the date of EWHC judgment in related case on December 1, 2007, equivalent of U.S. $2,062,470). According to a case study by the Stolen Asset Recovery (StAR) Initiative, a July 2008 judgment by a United Kingdom court led to the confiscation of assets in the United Kingdom, Cyprus and Denmark. Nigeria\u0027s lawyers in the civil case carried out the enforcement of the judgment in Cyprus. (Source: StAR Case Study, accessed at http:\/\/www1.worldbank.org\/publicsector\/star_site\/documents\/Case_Studies_....)","Disposition of Criminal Case(s)":"According to the December 3, 2007 UK High Court decision in Nigeria v. Santolina Investment Corp and Ors, Mr. Alamieyeseigha entered a guilty plea in Nigeria\u0027s High Court to six counts of making false declaration of assets. According to the same judgment, Mr. Alamieyeseigha was arrested at Heathrow Airport in September 2005 by officers of the Metropolitan Police and initially remanded but later granted bail. In breach of his bail requirements, he left UK and returned to Nigeria in November 2005. (Source: Nigeria v. Santolina Investment Corp and Ors, [2007] EWHC 3053 (Q.B.)) \u00a0In March 2013, he was pardoned in Nigeria. (Source: \u00a0BBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013.)","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Courts Involved":"Federal High Court (Lagos)","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Edwards Angell Palmer \u0026 Dodge LLP (James Maton, Tim Daniel)","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC_3053 (QB).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Case_Study.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_Pardon_BBC_News_Mar_13_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC_3053 (QB).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Case_Study.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_StAR_Case_Study_0.pdf","Sources ":"\n\tStolen Asset Recovery (StAR) Initiative Case Study, \u0022Diepreye Alamieyeseigha\u0022 (attached PDF); Republic of Nigeria v. Santolina \u0026 Ors, [2007] EWHC 3053 (QB), Judgment dated December 3, 2007.\n\n\t\u00a0\n\n\tBBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013, at http:\/\/www.bbc.com\/news\/world-africa-21769047.\n"},{"Case ID":"ARW-51","Case Title (Name of Public Official or Entity Allegedly Involved)":"Diepreye Alamieyeseigha (Denmark)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Governor (1999-2005)","Jurisdiction of Asset Recovery":"Denmark","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2007","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.15, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Nigeria\u0027s lawyers in the civil case carried out the enforcement of the judgment in Denmark. (Source: StAR Case Study, attached PDF)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"Nigeria brought a civil suit against Santolina Investment Corporation, an entity that was the purported owner of properties purchased with Mr. Alamieyeseigha\u0027s criminal proceeds and in relation to approximately GBP 1 million on deposit in Cyprus (as of the date of EWHC judgment in related case on December 1, 2007, equivalent of U.S. $2,062,470). According to a case study by the Stolen Asset Recovery (StAR) Initiative, a July 2008 judgment by a United Kingdom court led to the confiscation of assets in the United Kingdom, Cyprus and Denmark. Nigeria\u0027s lawyers in the civil case carried out the enforcement of the judgment in Denmark. (Source: StAR Case Study, accessed at http:\/\/www1.worldbank.org\/publicsector\/star_site\/documents\/Case_Studies_....)","Disposition of Criminal Case(s)":"According to the December 3, 2007 UK High Court decision in Nigeria v. Santolina Investment Corp and Ors, Mr. Alamieyeseigha entered a guilty plea in Nigeria\u0027s High Court to six counts of making false declaration of assets. According to the same judgment, Mr. Alamieyeseigha was arrested at Heathrow Airport in September 2005 by officers of the Metropolitan Police and initially remanded but later granted bail. In breach of his bail requirements, he left UK and returned to Nigeria in November 2005. (Source: Nigeria v. Santolina Investment Corp and Ors, [2007] EWHC 3053 (Q.B.)) \u00a0In March 2013, he was pardoned in Nigeria. (Source: \u00a0BBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013.)","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Courts Involved":"Federal High Court (Lagos)","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Edwards Angell Palmer \u0026 Dodge LLP (James Maton, Tim Daniel)","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC_3053 (QB).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Case_Study.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_Pardon_BBC_News_Mar_13_2013_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC_3053 (QB).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Case_Study.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_StAR_Case_Study.pdf","Sources ":"\n\tStolen Asset Recovery (StAR) Initiative Case Study, \u0022Diepreye Alamieyeseigha,\u0022 (attached PDF); Republic of Nigeria v. Santolina \u0026 Ors, [2007] EWHC 3053 (QB), Judgment dated December 3, 2007.\n\n\t\u00a0\n\n\tBBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013, at http:\/\/www.bbc.com\/news\/world-africa-21769047.\n"},{"Case ID":"ARW-52","Case Title (Name of Public Official or Entity Allegedly Involved)":"Diepreye Alamieyeseigha (South Africa)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Governor (1999-2005)","Jurisdiction of Asset Recovery":"South Africa","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2005","Asset Recovery End":"2007","UNCAC Offenses Implicated":"Art.15, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"The use by South Africa\u0027s Asset Forfeiture Unit of non-conviction based confiscation proceedings allowed the authorities to seize property by demonstration of the illegal origin of the funds used to acquire it, but before the criminal prosecution concluded in Nigeria. (Source: StAR Case Study, \u0022Diepreye Alamieyeseigha\u0022).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"In February 2006, the Asset Forfeiture Unit of the National Prosecuting Authority of South Africa secured a court order to freeze a residential property belonging to Mr. Alamieyeseigha on the Cape Town waterfront. An application to freeze, first the rental income from the apartment and later his interest in the apartments themselves, was successful. United Kingdom\u0027s High Court also notes that (Mr. Alamieyeseigha\u0027s corporate vehicle) Santolina Investment Corporation\u0027s bank statements from the \u0022principal Royal Bank of Scotland account where a sum of GBP949,000 was paid out, apparently to acquire a property.\u0022 (Sources: Stolen Asset Recovery (StAR) Initiative Case Study, \u0022Diepreye Alamieyeseigha.\u0022 Republic of Nigeria v. Santolina \u0026 Ors., [2007] EWHC 3053 (QB), Judgment dated December 3, 2007). Funds were returned to Nigeria following the sale of the property in January 2007.\u00a0 According to an article by attorneys Tim Daniel and James Maton, who had represented Nigeria in the UK civil proceedings, \u0022Nigeria successfully intervened in the proceeding seeking an order for the return of the proceeds of sale.\u0022\u00a0 (Source: James Maton and Tim Daniel, \u0022The Kleptocrat\u0027s Portfolio Decisions,\u0022 in Draining Development? Controlling Flows of Illicit Funds from Developing Countries, Peter Reuter, ed., (The World Bank, 2012) at 433-434.)","Disposition of Criminal Case(s)":"According to the December 3, 2007 UK High Court decision in Nigeria v. Santolina Investment Corp and Ors, Mr. Alamieyeseigha entered a guilty plea in Nigeria\u0027s High Court to six counts of making false declaration of assets. According to the same judgment, Mr. Alamieyeseigha was arrested at Heathrow Airport in September 2005 by officers of the Metropolitan Police and initially remanded but later granted bail. In breach of his bail requirements, he left UK and returned to Nigeria in November 2005. (Source: Nigeria v. Santolina Investment Corp and Ors, [2007] EWHC 3053 (Q.B.)) \u00a0In March 2013, he was pardoned in Nigeria. (Source: \u00a0BBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013.)","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Courts Involved":"Federal High Court (Lagos)","Jurisdiction of Asset Recovery: Investigative Agency":"The National Prosecuting Authority of South Africa, Asset Forfeiture Unit","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"The National Prosecuting Authority of South Africa, Asset Forfeiture Unit; Edwards Angell Palmer \u0026 Dodge LLP (James Maton, Tim Daniel)","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC_3053 (QB).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Case_Study.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_Pardon_BBC_News_Mar_13_2013_1.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC_3053 (QB).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Case_Study.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_StAR_Case_Study_1.pdf","Sources ":"\n\tRepublic of Nigeria v. Santolina \u0026 Ors., [2007] EWHC 3053 (QB), Judgment dated December 3, 2007; Stolen Asset Recovery (StAR) Initiative Case Study, \u0022Diepreye Alamieyeseigha\u0022 (attached PDF).\u00a0\n\n\t\u00a0\n\n\tJames Maton and Tim Daniel, \u0022The Kleptocrat\u0027s Portfolio Decisions,\u0022 in Draining Development? Controlling Flows of Illicit Funds from Developing Countries, Peter Reuter, ed., (The World Bank, 2012) at 433-434.\n\n\t\u00a0\n\n\tBBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013, at http:\/\/www.bbc.com\/news\/world-africa-21769047.\n"},{"Case ID":"ARW-54","Case Title (Name of Public Official or Entity Allegedly Involved)":"Diepreye Alamieyeseigha (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Governor (1999-2005)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2005","Asset Recovery End":"2010","UNCAC Offenses Implicated":"Art.15, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Administrative Confiscation; Private Civil Action; Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Effective cooperation between Nigerian and United Kingdom authorities (Nigeria\u0027s Economic and Financial Crimes Commission, United Kingdom\u0027s London Metropolitan Police (Source: Stolen Asset Recovery (StAR) initiative Case Study, \u0022Diepreye Alamieyeseigha\u0022; United Kingdom court\u0027s denial of Mr. Alamieyeseigha\u0027s petition of immunity as state governor, a ruling upheld by the High Court (Source: R on the application of Diepreye Solomon Peter Alamieyeseigha v. CPS [2005] EWHC 2704 (Admin).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to a case study by the Stolen Asset Recovery Initiative, the recovery in the case consisted of (1) $1.5 million in cash seized at the time of arrest and (2) $2.7 million held in bank accounts [Royal Bank of Scotland PLC, Santolina Investment Corporation account in excess of GBP 1.8 million] and London real estate worth $15 million [4 properties registered under Solomon \u0026 Peters Ltd. as sole proprietor]. In May 2006, a London court ordered confiscation of the seized cash pursuant to the Proceeds of Crime Act, after Mr. Alamieyeseigha skipped bail and returned to Nigeria; bank accounts and London real estate were confiscated pursuant to a December 2007 United Kingdom High Court summary judgment; and a July 2008 judgment left to confiscation of remaining assets in the United Kingdom, Denmark and Cyprus. Pursuant to his July 2007 plea in Nigerian High Court, he was sentenced to a two-year prison term and his assets in Nigeria were ordered seized. (Source: StAR Case Study, \u0022Diepreye Alamieyeseigha\u0022).","Disposition of Criminal Case(s)":"According to the December 3, 2007 UK High Court decision in Nigeria v. Santolina Investment Corp and Ors, Mr. Alamieyeseigha entered a guilty plea in Nigeria\u0027s High Court to six counts of making false declaration of assets. \u00a0According to the same judgment, Mr. Alamieyeseigha was arrested at Heathrow Airport in September 2005 by officers of the Metropolitan Police and initially remanded but later granted bail. \u00a0In breach of his bail requirements, he left UK and returned to Nigeria in November 2005. \u00a0(Source: Nigeria v. Santolina Investment Corp and Ors, [2007] EWHC 3053 (Q.B.)) \u00a0In March 2013, he was pardoned in Nigeria. (Source: \u00a0BBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013.)","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Courts Involved":"Federal High Court (Lagos)","Jurisdiction of Asset Recovery: Investigative Agency":"London Metropolitan Police, Proceeds of Corruption Unit","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service; Edwards Angell Palmer \u0026 Dodge LLP (James Maton, Tim Daniel)","Jurisdiction of Asset Recovery: Courts Involved":"England and Wales High Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2005_EWHC_2704 (Admin).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC 437 (Ch).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC_3053 (QB).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Case_Study.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Handbook.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Transparency_Intl_UK_Recovering_Looted_Gains_June_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_Pardon_BBC_News_Mar_13_2013_2.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2005_EWHC_2704 (Admin).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC 437 (Ch).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC_3053 (QB).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Case_Study.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Handbook.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Transparency_Intl_UK_Recovering_Looted_Gains_June_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_StAR_Case_Study_2.pdf","Sources ":"\n\tJean-Pierre Brun, Larissa Gray, Clive Scott, and Kevin M. Stephenson, Asset Recovery Handbook: A Guide for Practitioners, (StAR Initiative, December 2010), \u00221.3.3 Case of Diepreye Alamieyeseigha,\u0022 at 17-18, \u00a0accessed at \u00a0http:\/\/star.worldbank.org\/star\/publication\/asset-recovery-handbook; R on the application of Diepreye Solomon Peter Alamieyeseigha v. CPS [2005] EWHC 2704 (Admin) [UK High Court ruling upholding the Crown Court\u0027s denial of Alamieyeseigha petition on immunity]; Federal Republic of Nigeria v. Santolina Investment Corporation and Others [2007] EWHC 437 (Ch) and [2007] EWHC 3053 (QB). See also Transparency International UK, \u0022Combating Money Laundering and Recovering Looted Gains: Raising the UK\u0027s Game,\u0022 June 2009.\u00a0\n\n\t\u00a0\n\n\tBBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013, at http:\/\/www.bbc.com\/news\/world-africa-21769047.\n"},{"Case ID":"ARW-55","Case Title (Name of Public Official or Entity Allegedly Involved)":"Diepreye Alamieyeseigha (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Governor (1999-2005)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Both actions brought through the US Department of Justice\u0027s Kleptocracy Asset Recovery Initiative","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"Value of Massachusetts account and estimated value of Maryland house","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"\n\tThe United States obtained Default Judgments in Maryland (house valued at over $700,000) and in Massachusetts against approximately $400,000 in a Fidelity investment account. (Sources: US v. Real Property titled in the name of Solomon \u0026 Peters, located at 504 Pleasant Drive..., Case No. 8:11-cv-00662-RWT (D. Md.), Default Judgment of May 24, 2013; US v. The Contents of Account Number Z44-343021, Case No. 1:11-cv-10606-RWZ (D. Mass.), Order Final Judgment and Forfeiture filed June 13, 2012). \u00a0The forfeiture actions had been brought under the Justice Department\u0027s Kleptocracy Asset Recovery Initiative. \u00a0(Source: \u00a0U.S. Department of Justice, \u0022Assistant Attorney General Lanny A. Bruer of the Criminal Divison Speaks at the Franz-Hermann Bruner Memorial Lecture at the World Bank,\u0022 May 25, 2011.) \u00a0\u00a0\n\n\t\u00a0\n\n\tAccording to the complaint in the case, the residence\u0027s owner of record is Solomon \u0026 Peters, Ltd. a now defunct company incorporated in the British Virgin Islands. (Source: US v. Real Property titled in the name of Solomon \u0026 Peters, located at 504 Pleasant Drive..., Case No. 8:11-cv-00662-RWT (D. Md.), Verified Complaint for Forfeiture filed March 11, 2011.)\n\n\t\u00a0\n\n\tAccording to a June 13, 2012 Order for Final Judgment and Forfeiture issued by the US federal court in Massachusetts, \u0022The contents of account number Z44-343021 held at Fidelity Brokerage Services, LLC., Boston, Massachusetts, in the name of Nicholas Aiyegbemi d\/b\/a\/ Inadinov and Co. OAO, which account is believed to contain approximately $386,080, and all assets traceable thereto,\u0022 were forfeited to the United States after all those parties with potential claims to the funds were notified but did not respond. \u00a0(Source: US v. The Contents of Account Number Z44-343021, Case No. 1:11-cv-10606-RWZ (D. Mass.), Order Final Judgment and Forfeiture filed June 13, 2012; \u00a0Verified Complaint for Forfeiture In Rem filed April 8, 2011.)\u00a0\u00a0","Disposition of Criminal Case(s)":"According to the December 3, 2007 UK High Court decision in Nigeria v. Santolina Investment Corp and Ors, Mr. Alamieyeseigha entered a guilty plea in Nigeria\u0027s High Court to six counts of making false declaration of assets. \u00a0According to the same judgment, Mr. Alamieyeseigha was arrested at Heathrow Airport in September 2005 by officers of the Metropolitan Police and initially remanded but later granted bail. \u00a0In breach of his bail requirements, he left UK and returned to Nigeria in November 2005. \u00a0(Source: Nigeria v. Santolina Investment Corp and Ors, [2007] EWHC 3053 (Q.B.)) \u00a0In March 2013, he was pardoned in Nigeria. (Source: \u00a0BBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013.)","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Courts Involved":"Federal High Court (Lagos)","Jurisdiction of Asset Recovery: Investigative Agency":"Homeland Security Investigation\u2019s Asset Identification \u0026 Removal Group (AIRG) in Baltimore, Immigration and Customs Enforcement","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section; United States Attorney\u0027s Office for the District of Maryland","Jurisdiction of Asset Recovery: Courts Involved":"District Court for the District of Maryland; District Court for the District of Massachusetts","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_US_DOJ_Lanny_Breuer_Speech_at_World_Bank_May_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_MD_Complaint_8-11-cv-00662-RWT_March_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_MD_Court_Docket_Report_Oct_26_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_Mass_Complaint_1-11-cv-10606-RWZ_April_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_Mass_Docket_Report_Oct_26_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_MD_Forfeit_DOJ_PR_May_31_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_US_DOJ_Lanny_Breuer_Speech_at_World_Bank_May_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_MD_Complaint_8-11-cv-00662-RWT_March_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_MD_Court_Docket_Report_Oct_26_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_Mass_Complaint_1-11-cv-10606-RWZ_April_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_Mass_Docket_Report_Oct_26_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_US_MD_Decree_Forfeiture_May_24_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_US_DOJ_Lanny_Breuer_Speech_at_World_Bank_May_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_MD_Complaint_8-11-cv-00662-RWT_March_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_MD_Court_Docket_Report_Oct_26_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_Mass_Complaint_1-11-cv-10606-RWZ_April_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_Mass_Docket_Report_Oct_26_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_Pardon_BBC_News_Mar_13_2013_3.pdf","Sources ":"\n\n\t\tUS Department of Justice press release, \u0022Rockville, Md., Property Purchased with Nigerian Corruption Proceeds Forfeited Through Justice Department\u2019s Kleptocracy Initiative,\u0022 May 31, 2013, at http:\/\/www.justice.gov\/opa\/pr\/2013\/May\/13-crm-628.html; U.S. Department of Justice, \u0022Assistant Attorney General Lanny A. Bruer of the Criminal Divison Speaks at the Franz-Hermann Bruner Memorial Lecture at the World Bank,\u0022 May 25, 2011, accessed at http:\/\/www.justice.gov\/criminal\/pr\/speeches\/2011\/crm-speech-110525.html;\u00a0\n\n\t\t\u00a0\n\n\t\tUS v. Real Property titled in the name of Solomon \u0026 Peters, located at 504 Pleasant Drive..., Case No. 8:11-cv-00662-RWT (D. Md.), Verified Complaint for Forfeiture filed March 11, 2011; \u00a0Default judgment of May 24, 2013;\u00a0\n\n\t\t\u00a0\n\n\t\tUS v. The Contents of Account Number Z44-343021, Case No. 1:11-cv-10606-RWZ (D. Mass.), Verified Complaint for Forfeiture In Rem filed April 8, 2011 and Order of Final Judgment and Forfeiture, filed June 13, 2012. \u00a0\n\n\t\t\u00a0\n\n\t\tBBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013, at http:\/\/www.bbc.com\/news\/world-africa-21769047.\n\n\u00a0\n"},{"Case ID":"ARW-57","Case Title (Name of Public Official or Entity Allegedly Involved)":"Edemar Cid Ferreira\/ Banco Santos, S.A. Art Repatriation Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Brazil","Position of Public Official(s) (yrs in office)":"Founder and Former President of Banco Santos (unspecified-2006)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2007","Asset Recovery End":"","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT; Letter of Request","Basis for Intl Cooperation":"Treaty between the United States and Brazil on Mutual Legal Assistance in Criminal Matters; Letter of Request (INTERPOL)","Contributing Factors in Asset Recovery":"The U.S. Attorney for the Southern District of New York thanked the Brazilian authorities for their assistance with the investigation.    (Source: U.S. Attorney for the Southern District of New York Press Release, \u0022Manhattan U.S. Attorney Returns Two Paintings Linked to Bank Fraud to Brazilian Government,\u0022 September 21, 2010.)","Status of Asset Recovery ":"Completed (in part) and Ongoing (in part)","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$4,000,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to the September 21, 2010 press release by the U.S. Attorney for the Southern District of New York, two paintings appraised at more than $4 million were repatriated to Brazil. \u00a0The paintings had once belonged to Mr. Ferrerira, and as part of the investigations into his case, the 6th Federal Criminal Court Specialized in Crimes Against the National Financial System and Money Laundering of Sao Paulo\/SP also ordered the search, seizure and confiscation of assets that Mr. Ferrerira, his associates and members of his family acquired with unlawfully obtained funds from Banco Santos. \u00a0The assets included the artwork which had been smuggled into the United States. \u00a0In 2007, Sao Paulo sought INTERPOL\u0027s assistance, and INTERPOL and the Government of Brazil sought the assistance by the United States. \u00a0The U.S. Immigration and Customs Enforcement located and seized the artworks, and in 2008, the U.S. filed the civil asset forfeiture complaint. \u00a0 Two artworks -- Liechtenstein\u0027s \u0022Modern Painting with Yellow Interweave\u0022 and Joaquin Torres-Garcia\u0027s \u0022Figures dans une structure\u0022 -- were forfeited to the U.S. on August 16, 2010 and July 16, 2010, respectively. \u00a0Other artworks -- Jean Michel Basquiat\u0027s \u0022Hannibal\u0022 valued at about $8 million and a sculpture known as the \u0022Roman Togatus\u0022 -- have also been forfeited to the U.S. An appeal is pending. (Source: US v. The painting known as \u0022Hannibal\u0022 et al, Case No. 1:08-cv-01511-RJS (S.D.N.Y.), Order of Forfeiture filed May 10, 2013 and Order filed September 17, 2013.) \u00a0The Default Judgment as to the Liechtenstein (US v. The Painting Known as \u0022Hannibal,\u0022 et al, Case No. 1:08-cv-01511-RJS (S.D.N.Y.), filed August 16, 2010.) \u00a0In May 2014, the US Immigration and Customs Enforcement (ICE) announced the repatriation of the Poliakoff painting to Brazil. (Source: ICE, \u0022ICE returns masterpiece linked to bank fraud to Brazilian government,\u0022 May 9, 2014.)\u00a0","Disposition of Criminal Case(s)":"According to the February 13, 2008 Verified Complaint filed in U.S. District Court for the Southern District of New York, Mr. Ferreira was sentenced in December 2006 by the 6th Federal Criminal Court Specialized in Crimes Against the National Financial System and Money Laundering of Sao Paulo\/SP to 21 years\u0027 imprisonment for crimes against the national financial system and money laundering,  (Source: US v. The Painting Known as \u0022Hannibal\u0022 by Jean-Michel Basquiat, Case No. 1:08-cv-01511-RJS (S.D.N.Y.), Verified Complaint filed on February 13, 2008.)","Jurisdiction of Origin: Investigative Agency":"Federal Police","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"State Prosecutor   ","Jurisdiction of Origin: Courts Involved":"6th Federal Criminal Court Specialized in Crimes Against the National Financial System and Money Laundering of Sao Paulo\/SP","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Immigration and Customs Enforcement, Cultural Property Art and Antiquities Unit; INTERPOL","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Southern District of New York, Asset Forfeiture Unit","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_SDNY_PR_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_Two_Paintings_Returned_SDNY_PR_Sept_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferreira_SDNY_Complaint_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Liechtenstein_Painting_SDNY_Default_Judgment_Aug_16_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/US-v_Broadening_Info_Second_Circuit_Appeal_Case_Summary_Nov_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ferreira_Liechenstein_Painting_Default_Judgment_Aug_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_SDNY_PR_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_Two_Paintings_Returned_SDNY_PR_Sept_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferreira_SDNY_Complaint_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Liechtenstein_Painting_SDNY_Default_Judgment_Aug_16_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/US-v_Broadening_Info_Second_Circuit_Appeal_Case_Summary_Nov_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/US-v_Broadening_Info_Second_Circuit_Appeal_Case_Summary_Nov_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_SDNY_PR_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_Two_Paintings_Returned_SDNY_PR_Sept_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferreira_SDNY_Complaint_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Liechtenstein_Painting_SDNY_Default_Judgment_Aug_16_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/US-v_Broadening_Info_Second_Circuit_Appeal_Case_Summary_Nov_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ferreira_US_Forfeiture_Order_May_10_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_SDNY_PR_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_Two_Paintings_Returned_SDNY_PR_Sept_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferreira_SDNY_Complaint_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Liechtenstein_Painting_SDNY_Default_Judgment_Aug_16_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/US-v_Broadening_Info_Second_Circuit_Appeal_Case_Summary_Nov_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ferreira_US_Forfeit_Order_Case_Close_Sep_17_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_SDNY_PR_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_Two_Paintings_Returned_SDNY_PR_Sept_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferreira_SDNY_Complaint_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Liechtenstein_Painting_SDNY_Default_Judgment_Aug_16_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/US-v_Broadening_Info_Second_Circuit_Appeal_Case_Summary_Nov_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ferreira_ICE_Painting_Return_Brazil_May_9_2014.pdf","Sources ":"\n\tU.S. Attorney for the Southern District of New York Press Releases, \u0022Manhattan U.S. Attorney Returns Two Paintings Linked to Bank Fraud to Brazilian Government,\u0022 September 21, 2010, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/September10\/brazilrepatria... and \u0022United States Files Action to Forfeit Basquiat Painting \u0022Hannibal\u0022 Valued at $8 million,\u0022 February 13, 2008. \u00a0U.S. v. The Painting Known as \u0022Hannibal,\u0022 Case No. 1:08-cv-01511-RJS (SDNY), Verified Complaint filed on February 13, 2008; \u00a0Default Judgment filed August 16, 2010 (accessed at http:\/\/www.bancosantos.com.br\/Ceremony%20Obras%20de%20Arte%2020102109.pdf), Order of Forfeiture filed May 10, 2013 and Order filed September 17, 2013; US v. Broadening-Info Enterprises, Inc., Docket No. 10-5204 (2nd Cir.), Case Summary as of November 2, 2011.\n\n\tUS Immigration and Customs Enforcement, \u0022ICE returns masterpiece linked to bank fraud to Brazilian government,\u0022 May 9, 2014, at http:\/\/www.ice.gov\/news\/releases\/1405\/140509newyork.htm\n"},{"Case ID":"ARW-60","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ferdinand and Imelda Marcos (WestLB account)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"President (F. Marcos,1965-1986); First Lady, Governor of Metro Manila and Minister of Human Settlements (I. Marcos. Governor and Minister from 1978-1986)","Jurisdiction of Asset Recovery":"Singapore","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1998","Asset Recovery End":"2014","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"\n\tIn February 2014, $29 million that had been held in the WestLB account were returned to the Philippines; the monies had been part of the asset return from the Marcos Swiss accounts. \u00a0(Source: \u00a0\u0022Philippines seize {GBP] 17.6m from Marcos accounts,\u0022 The Guardian\/Associated Press, February 12, 2014). \u00a0The return follows a December 2013 decision by the Singapore Appeals Court in favor of the Government of the Philippines\u0027 claim to the funds over that of Marcos era human rights victims and the Marcos-associated Liechtenstein foundations under whose names the Swiss accounts were originally held. \u00a0 (Source: \u00a0The Republic of the Philippines v. Maler Foundation and others and other appeals, [2013] SGCA 66, 30 December 2013).\u00a0\n\n\t\u00a0\n\n\tIn August 2012, the Singapore High Court dismissed claims by the Government of the Philippines, Marcos-associated foundations and the Marcos-era human rights victims to funds being held at the WestLB Bank. \u00a0The High Court held that the Philippine National Bank (PNB) held title to the funds. \u00a0(Source: \u00a0WestLB AG v. Philippine National Bank and others, [2012] SGHC 162 (August 10, 2012); The Philippines Presidential Commission on Good Goverment noted that other parties to the action had appealed and on \u0022All parties to the appeal were heard by the Singapore Court of Appeal on 7 February 2013; the Court subsequently appointed an amicus curiae to help resolve a number of issues under consideration.\u0022 \u00a0(Source: PCGG Annual Report 2012, at 11.). \u00a0\n\n\t\u00a0\n\n\tBetween April 1998 and July 1998, Switzerland had released the Marcos-related assets it had frozen to the PNB to hold as escrow agent. \u00a0The PNB, in turn, deposited some of the funds at West LB AG in Singapore. \u00a0The Marcos-era human rights victims filed claim to enforce the judgment for recovery that they had obtained in the Hawaiian courts. \u00a0On January 30, 2004, West LB filed for interpleader relief. \u00a0In December 2006, Singapore High Court dismissed others\u0027 claims to the funds. (Source: \u00a0WestLB AG v. Philippines National Bank [2007] 1 SLR 967). \u00a0However, in March 2008, the Singapore Court of Appeals overturned the lower court\u0027s decision. \u00a0(Source: Republic of the Philippines v. Maler Foundation and others, Civil Appeal 7 of 2007, decision dated March 24, 2008.) \u00a0In its 2012 decision, the High Court stated that \u0022While this court sympathises with the HRVs\u2019 [Human Rights Victims\u0027] plight during the rule of Ferdinand E Marcos, it must act in a principled manner when dealing with such questions of law and is bound by the enunciated principles to reject the HRVs\u2019 claim. This result is of course unfortunate, since, as confirmed by the chairman of the PCGG [Presidential Commission on Good Government] during cross-examination, no compensation of the HRVs has taken place out of the sum in excess of US$600m which has been recovered by the Republic from the Marcos Estate. However, some comfort may be drawn from the testimony of the chairman of PCGG confirming that legislation for the compensation of the HRVs is being debated. There is thus some hope that the HRVs will soon receive the redress they long await.\u0022 \u00a0(Source: \u00a0WestLB AG v. Philippine National Bank and others, [2012] SGHC 162 (August 10, 2012)). \u00a0\n\n\t\u00a0","Disposition of Criminal Case(s)":"A trial in the U.S. District Court for the Southern District of New York on criminal racketeering and fraud charges concluded in an acquittal for Mrs. Marcos.  Mr. Marcos had also been indicted in the case, but the court had deemed him too ill to stand trial. (Sources: US v. Tantoco, et al, Case No. 1-87-cr-598-JFK (S.D.N.Y.), Docket Report accessed on January 2, 2011 and Indictment of October 22, 1988, obtained from US National Archives; Craig Wolff, \u0022The Marcos Verdict; Marcos Is Cleared of All Charges In Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990.)  On April 21, 2010, the GMA News reported that \u0022According to records of the Philippine anti-graft court Sandiganbayan as of 2005, Mrs. Marcos continues to face 11 criminal charges and 25 civil cases.\u0022  (Source: Sohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....)","Jurisdiction of Origin: Investigative Agency":"Presidential Commission on Good Government","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Presidential Commission on Good Government","Jurisdiction of Origin: Courts Involved":"Sandiganbayan; Supreme Court of the Republic of the Philippines","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Kohn Swift \u0026 Graf PC (Attorney Robert A. Swift) [Interpleader Proceedings, representing human rights victims]","Jurisdiction of Asset Recovery: Courts Involved":"High Court; Court of Appeals; Supreme Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_Appeals_Court_Maler_Foundation_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_Recovery_GMANEWS_June_29_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_WestLB_1_SLR_2007.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/PCGG_Annual_Report_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_Appeals_Court_Maler_Foundation_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_Recovery_GMANEWS_June_29_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_WestLB_1_SLR_2007.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Singapore_WestLB%20AG%20v%20Phil_Natl_Bank_Aug_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_Appeals_Court_Maler_Foundation_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_Recovery_GMANEWS_June_29_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_WestLB_1_SLR_2007.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Singapore_WestLB_Appeals_Ct_Decision_2013_SGCA_66.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_Appeals_Court_Maler_Foundation_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_Recovery_GMANEWS_June_29_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_WestLB_1_SLR_2007.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Singapore_WestLB_AR_Guardian_Feb_12_2014.pdf","Sources ":"\n\tThe Republic of the Philippines v. Maler Foundation and others and other appeals, [2013] SGCA 66, 30 December 2013, accessed at file:\/\/\/C:\/Users\/j.w\/Downloads\/[2013]%20SGCA%2066%20(1).pdf; \u0022Philippines seize {GBP] 17.6m from Marcos accounts,\u0022 The Guardian\/Associated Press, February 12, 2014;WestLB AG v. Philippine National Bank and others, [2012] SGHC 162 (August 10, 2012); \u00a0WestLB AG v. Philippines National Bank [2007] 1 SLR 967; \u00a0Republic of the Philippines v. Maler Foundation and others, Civil Appeal 7 of 2007, Singapore Court of Appeals decision dated March 24, 2008, copy of actual decision accessed at http:\/\/claimants1081.files.wordpress.com\/2008\/03\/singapore-ct-appeals-de...); Presidential Commission on Good Government Annual Report 2012\n\n\t\u00a0\n\n\tGMA News, \u0022Time Short for RP to Track Marcos Money - PCGG Execs,\u0022 June 29 , 2010 accessed at http:\/\/www.gmanews.tv\/story\/194745\/time-short-for-rp-to-track-marcos-mon... Sophia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....\n"},{"Case ID":"ARW-61","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ferdinand and Imelda Marcos (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"President (F. Marcos,1965-1986); First Lady, Governor of Metro Manila and Minister of Human Settlements (I. Marcos. Governor and Minister from 1978-1986)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1986","Asset Recovery End":"2004","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"International Mutual Assistance in Criminal Matters","Contributing Factors in Asset Recovery":"First case under the Federal Act on International Mutual Assistance in Criminal Matters (IMAC) enacted in January 1983 (Source: Stolen Asset Recovery Initiative Case Study, \u0022Ferdinand Marcos\u0022; Voluntary reporting of Marcos assets by Swiss banks immediately after the Marcoses fled the Philippines which led to automatic freezing of the reported funds; International Mutual Assistance in Criminal Matters (Switzerland) (Source: Jovito R. Salonga, Presidential Plunder: The Quest for the Marcos Ill-Gotten Wealth (Regina Publishing, 2000).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$683,000,000","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Monies returned from Switzerland were to be used for the Agrarian Reform Fund and to establish a  human rights victims fund; Responsibility for monitoring was placed with the Committee on Audit of the Republic of the Philippines.  (Source: Republic of the Philippines, Commission on Audit, Management Services Report No. 2006-01, \u0022Utilization of the Forfeited Swiss Deposits for the Implementation of the Comprehensive Agrarian Reform Program (CARP)).","Case Summary":"\n\tIn 2004, Switzerland released $683 million in funds to the Philippines Treasury, following a July 2003 Philippine Supreme Court decision ordering forfeiture of the Marcos Swiss deposits. \u00a0The $683 million represents sum of the $356 million frozen and accumulated interest. (Source: Merceditas Gutierrez Ombudsman, Republic of the Philippines, \u0022Ferdinand E. Marcos (Philippines): A Case Study,\u0022 in ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational (Bali, 5-7 September 2007.) \u00a0As stated in the Swiss Federal Office of Justice Press Release of August 5, 2003, \u0022The Marcos case began in 1986 when the Federal Council ordered bank accounts to be frozen. In 1990, the Swiss Federal Supreme Court approved the handover to the Phillippines of bank documents relating to the Marcos family, but ruled that the actual return of assets would be conditional upon a final and absolute judgment by a Phillippine court. In 1997, the Court established that the majority of the Marcos foundation assets were of criminal origin and permitted their transfer to a escrow account in Manila, even though no Phillippine court ruling had yet been issued. \u00a0The Swiss Federal Supreme Court set two conditions for this advance transfer, however. The Phillippines had to provide an assurance that the confiscation or repayment of the assets in question would be handled through judicial proceedings that complied with the principles of the International Civil and Political Rights Pact, and the Phillippine government also had to undertake to brief the Swiss authorities regularly on the judicial confiscation and repayment proceedings, as well as on the precautions and procedures pertaining to compensation for victims of violations of human rights under the Marcos regime. \/ \u00a0No further decision required from Swiss authorities \/ Once the Federal Office of Justice (at the time: the Federal Office of Police Matters) had declared the guarantee given by the Phillippines to be satisfactory and the Swiss Federal Supreme Court had dismissed appeals against the ruling, the assets could be transferred in 1998 to a escrow account with the Phillippine National Bank in Manila. Following the confiscation ruling of the Phillippine Supreme Court on 15 July 2003, which confirmed the view of the Swiss Federal Supreme Court with regard to the criminal origin of the monies seized, the Phillippine government may now dispose of the assets, worth some USD 683 million. No further decisions are due on the part of the Swiss authorities. The Phillippine parliament is currently debating legislation under which the Marcos assets would be used for land reform and to compensate the victims of human rights violations.\u0022 (Source: Federal Office of Justice Press Release, \u0022Philippines given access to over USD 683 million \/ Confiscation ruling closes Marcos case,\u0022 August 5, 2003.)\n\n\t\u00a0\n\n\tFollowing the August 2012 Singapore Court decision (and in New York in the Arelma Deposit case), the PCGG stated, \u0022Considering these positive de- velopments in 2012, the Commission decided to remit a portion of the [Contingency\/Litigation Fund \u2013 specifically US$10 mil-lion or PhP422.83 million \u2013 to the Bureau of the Treasury. (Source: PCGG Annual Report 2012)\n\n\t\u00a0\n\n\tIn February 2013, the Human Rights Victims Reparations and Recognition Act was approved, \u00a0creating an independent Human Rights Victims\u0027 Claims Board to administer a compensation fund of P10 billion (US$230.8 million) for Marcos era human rights victims. \u00a0(Source: \u00a0Republic Act 10368, AN ACT PROVIDING FOR REPARATION AND RECOGNITION OF VICTIMS OF HUMAN RIGHTS VIOLATIONS DURING THE MARCOS REGIME, DOCUMENTATION OF SAID VIOLATIONS, APPROPRIATING FUNDS THEREFOR AND FOR OTHER PURPOSES, at http:\/\/www.gov.ph\/downloads\/2013\/02feb\/20130225-RA-10368-BSA.pdf). \u00a0In November 2014, the Philippines legislature passed Joint Resolution 16, extending to May 2015 the deadline for victims to file claims. \u00a0(Source: Senate of the Philippines, \u0022Bill passed to give martial law victims more time to file claims; ethnic origin to be included in national census,\u0022 November 18, 2014, at https:\/\/www.senate.gov.ph\/press_release\/2014\/1118_prib1.asp).","Disposition of Criminal Case(s)":"A trial in the U.S. District Court for the Southern District of New York on criminal racketeering and fraud charges concluded in an acquittal for Mrs. Marcos.  Mr. Marcos had also been indicted in the case, but the court had deemed him too ill to stand trial. (Sources: US v. Tantoco, et al, Case No. 1-87-cr-598-JFK (S.D.N.Y.), Docket Report accessed on January 2, 2011 and Indictment of October 22, 1988, obtained from US National Archives; Craig Wolff, \u0022The Marcos Verdict; Marcos Is Cleared of All Charges In Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990.)  On April 21, 2010, the GMA News reported that \u0022According to records of the Philippine anti-graft court Sandiganbayan as of 2005, Mrs. Marcos continues to face 11 criminal charges and 25 civil cases.\u0022  (Source: Sohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....)","Jurisdiction of Origin: Investigative Agency":"Presidential Commission on Good Government","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Presidential Commission on Good Government","Jurisdiction of Origin: Courts Involved":"Sandiganbayan; Supreme Court of the Republic of the Philippines","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Office of Justice","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Federal Supreme Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Ombudsman_Case_Study_ADB_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_BGER_125_II_411.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_Sandiganbayan_Jul_15_2003.rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_StAR_Briones_Case_Study.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_US683M_EJPD_PR_Aug_5_2003.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/PCGG_Annual_Report_2012_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Ombudsman_Case_Study_ADB_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_BGER_125_II_411.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_Sandiganbayan_Jul_15_2003.rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_StAR_Briones_Case_Study.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_US683M_EJPD_PR_Aug_5_2003.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Phil_Reparations_Act_20130225-RA-10368-BSA.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Ombudsman_Case_Study_ADB_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_BGER_125_II_411.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_Sandiganbayan_Jul_15_2003.rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_StAR_Briones_Case_Study.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_US683M_EJPD_PR_Aug_5_2003.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Phil_Joint_Resln_16_Nov_2014.pdf","Sources ":"\n\tMerceditas Gutierrez, Ombudsman, Republic of the Philippines, \u0022Ferdinand E. Marcos (Philippines): A Case Study,\u0022 in ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational (Bali, 5-7 September 2007), accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf; Swiss federal court decisions, including 125 II 411 (1999 decision on Marcos case and request for judicial assistance by Philippines), as contained in assetrecovery.org case study on Marcos; Swiss Federal Office of Justice Press Releases including, \u0022Philippines given access to over USD 683 million,\u0022 August 5, 2003, at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2003\/ref_... Republic of the Philippines v. Sandiganbayan, Ferdinand E. Marcos, and others, Republic of the Phillippines Supreme Court. G.R. No. 152154, Judgment of July 15, 2003 (Supreme Court of the Republic of Philippines decisions can be accessed at: http:\/\/www.worldlii.org\/ph\/); please see also case study by Professor Leonor Briones, in \u0022Stolen Asset Recovery (StAR) Initiative: Challenges, Opportunities, and Action Plan,\u0022 at 21; Jovito R. Salonga, Presidential Plunder: the Quest for the Marcos Ill-Gotten Wealth (U.P. Center for Leadership, Citizenship and Democracy \u0026 Regina Publishing Co. 2000); PCGG Annual Report 2012;\u00a0\n\n\t\u00a0\n\n\tPhilippines Republic Act 10368, Human Rights Victims Reparation and Recognition Act, at http:\/\/www.gov.ph\/downloads\/2013\/02feb\/20130225-RA-10368-BSA.pdf; Senate of the Philippines, \u0022Bill passed to give martial law victims more time to file claims; ethnic origin to be included in national census,\u0022 November 18, 2014, at https:\/\/www.senate.gov.ph\/press_release\/2014\/1118_prib1.asp;\n\n\t\u00a0\n\n\tSophia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....\n"},{"Case ID":"ARW-62","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ferdinand and Imelda Marcos \/ Accounts in names of associates","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"President (F. Marcos,1965-1986); First Lady, Governor of Metro Manila and Minister of Human Settlements (I. Marcos. Governor and Minister from 1978-1986) \/ Associates (Names Unknown)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2003","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Unspecified","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"International Mutual Assistance in Criminal Matters","Contributing Factors in Asset Recovery":"[Unknown Status]","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"$15,000,000 (as of 2003)","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"The Swiss Federal Office of Justice press release of August 5, 2003 included this mention: \u0022The Office of the District Attorney IV for Canton of Zurich subsequently released assets worth approximately USD 30 million because the Phillippine authorities were unable to provide evidence that they were still pursuing criminal proceedings against the individuals concerned. Around USD 10 million remain frozen in Switzerland. The Phillippine judicial authorities will therefore have to issue a ruling on the confiscation of USD 15.5 million in the names of persons associated with the Marcos case.\u0022 (Source: Swiss Federal Office of Justice Press Release, \u0022Philippines given access to over USD 683 million, Confiscation ruling closes Marcos case,\u0022 August 5, 2003.)","Disposition of Criminal Case(s)":"A trial in the U.S. District Court for the Southern District of New York on criminal racketeering and fraud charges concluded in an acquittal for Mrs. Marcos.  Mr. Marcos had also been indicted in the case, but the court had deemed him too ill to stand trial. (Sources: US v. Tantoco, et al, Case No. 1-87-cr-598-JFK (S.D.N.Y.), Docket Report accessed on January 2, 2011 and Indictment of October 22, 1988, obtained from US National Archives; Craig Wolff, \u0022The Marcos Verdict; Marcos Is Cleared of All Charges In Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990.)  On April 21, 2010, the GMA News reported that \u0022According to records of the Philippine anti-graft court Sandiganbayan as of 2005, Mrs. Marcos continues to face 11 criminal charges and 25 civil cases.\u0022  (Source: Sohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....)","Jurisdiction of Origin: Investigative Agency":"Presidential Commission on Good Government","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Presidential Commission on Good Government","Jurisdiction of Origin: Courts Involved":"Sandiganbayan, Supreme Court of the Republic of the Philippines","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"District Attorney IV for Canton of Zurich","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"","Sources ":"Swiss Federal Office of Justice Press Release, \u0022Philippines given access to over USD 683 million, Confiscation ruling closes Marcos case,\u0022 August 5, 2003; Sophia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....\n"},{"Case ID":"ARW-63","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ferdinand Marcos and Imelda Marcos (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"President (F.Marcos,1965-1986); First Lady, Governor of Metro Manila and Minister of Human Settlements (I. Marcos. Governor and Minister from 1978-1986)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1986","Asset Recovery End":"2006","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation; Private Civil Action; Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"The Mutual Legal Assistance Treaty in Criminal Matters","Contributing Factors in Asset Recovery":"Pro Bono lawyers in New York, New Jersey, California, District of Columbia, Texas and elsewhere (Philippine treasury was bankrupt and the Presidential Commission on Good Government had limited financial resources to pay overseas lawyers).  In New York, an unprecedented granting of a temporary injunction request by local courts although no underlying case had yet been filed in the Philippines; additional criminal and civil suits filed against Marcos associates also resulted in their cooperation and agreements to forfeit properties and return cash held overseas.  (Source: Jovito R. Salonga, Presidential Plunder: the Quest for the Marcos Ill-Gotten Wealth (U.P. Center for Leadership, Citizenship and Democracy \u0026 Regina Publishing Co. 2000)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to a 2007 case study by Merceditas Gutierrez, Ombudsman of the Republic of Philippines, from 1986 to 2006, the total value of the assets recovered in the U.S. is less than $50 million.  They include: (1) in New Jersey, funds in a bank account and two residences at Princeton Pike and Cherry Hill used by Marcos children (amount not given); (2) administrative settlement relating to four New York buildings (40 Wall Street, Crown Building, Herald Center, and at 200 Madison Avenue); (3) settlement agreements that led to recovery of properties such as the Olympic Tower Apartment, Pendleton Drive property, the Cedars, Summit Drive Beverly Hills, Lindenmere estate and the Makiki Heights property; (4) seizure of various jewelry, art, and other valuables; and (5) funds in Sanwa Bank and shares in California Overseas Bank and Redwood Bank.  (Sources: Merceditas Gutierrez, \u0022Ferdinand E. Marcos (Philippines): A Case Study,\u0022 in the Asian Development Bank, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific: Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational (Bali, September 5-7, 2007); for the New Jersey recovery:  Jovito R. Salonga, Presidential Plunder: the Quest for the Marcos Ill-Gotten Wealth (U.P. Center for Leadership, Citizenship and Democracy \u0026 Regina Publishing Co. 2000).  The Philippines\u0027 Presidential Commission on Good Government\u0027s January 2011 reported listed among assets recovered, Ms. Marcos\u0027 Hawaii jewelry collection, estimated in value PhP 112,500,000 (approx. US$2.5 million).  (Source: The Presidential Commission on Good Government, 100 Day Report and Plan of Action, \u0022LIST OF SURRENDERED\/RECOVERED ASSETS, as of 17 January 2011.\u0022","Disposition of Criminal Case(s)":"A trial in the U.S. District Court for the Southern District of New York on criminal racketeering and fraud charges concluded in an acquittal for Mrs. Marcos.  Mr. Marcos had also been indicted in the case, but the court had deemed him too ill to stand trial. (Sources: US v. Tantoco, et al, Case No. 1-87-cr-598-JFK (S.D.N.Y.), Docket Report accessed on January 2, 2011 and Indictment of October 22, 1988, obtained from US National Archives; Craig Wolff, \u0022The Marcos Verdict; Marcos Is Cleared of All Charges In Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990.)  On April 21, 2010, the GMA News reported that \u0022According to records of the Philippine anti-graft court Sandiganbayan as of 2005, Mrs. Marcos continues to face 11 criminal charges and 25 civil cases.\u0022  (Source: Sohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....)","Jurisdiction of Origin: Investigative Agency":"Presidential Commission on Good Government","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Presidential Commission on Good Government","Jurisdiction of Origin: Courts Involved":"Sandiganbayan, Supreme Court of the Republic of the Philippines","Jurisdiction of Asset Recovery: Investigative Agency":"Numerous","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Center for Constitutional Rights; numerous other pro bono attorneys","Jurisdiction of Asset Recovery: Courts Involved":"Supreme Court; U.S. District Court for the Central District of California;  U.S. District Court for Hawaii; U.S. District Court for the Southern District of New York; New Jersey court (exact venue not known).","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Ombudsman_Case_Study_ADB_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_SDNY_Indictment_1_of_3.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_SDNY_Indictment_2_of_3.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_SDNY_Indictment_3_of_3.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Chaikin_Tracking_Proceeds.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_NY_Buildings_2nd_Cir_806_ f.2d_344 (1986).pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_SDNY_Cleared_NYT_Jul_3_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_PCGG_-100-day-report-and-plan-of-action1\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_PCGG_-100-day-report-and-plan-of-action1.pdf","Sources ":"Merceditas Gutierrez, \u0022Ferdinand E. Marcos (Philippines): A Case Study,\u0022 in the Asian Development Bank, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific: Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational (Bali, September 5-7, 2007), accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf. New Jersey recovery is discussed in Jovito R. Salonga, Presidential Plunder: the Quest for the Marcos Ill-Gotten Wealth (U.P. Center for Leadership, Citizenship and Democracy \u0026 Regina Publishing Co. 2000). Republic of the Philippines v. Marcos, et al, Case No. 86-cv-3859-MRP (C.D. Cal) and Central Bank of the Philippines v. Marcos, et al, Case No. 86-cv-0213 (Hawaii) and Settlement Agreement and Partial Release of Claim, as cited in Dr. David Chaikin, \u0022Tracking the Proceeds of Organised Crime - The Marcos Case,\u0022 presented at the Transnational Crime Conference (Canberra, March 9-10, 2000), accessed at http:\/\/www.aic.gov.au\/events\/aic%20upcoming%20events\/2000\/~\/media\/confer.... U.S. v. Tantoco, et al, Case No. 1:87-cr-00598-JFK (S.D.N.Y.), copy of Indictment obtained from the U.S. National Archives; Craig Wolff, \u0022The Marcos Verdict; Marcos Cleared of All Charges in Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990. Civil Litigation re: New York properties: U.S. v. Marcos, et al, 806 F.2d 344 (2nd Cir. 1986); Sohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica... The Presidential Commission on Good Government, 100 Day Report and Plan of Action, \u0022LIST OF SURRENDERED\/RECOVERED ASSETS, as of 17 January 2011,\u0022 accessed at http:\/\/pcgg.gov.ph\/100-day-report-and-plan-of-action\/\n"},{"Case ID":"ARW-64","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ferdinand Marcos and Imelda Marcos \/ Arelma Deposit Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"President (F. Marcos,1965-1986); First Lady, Governor of Metro Manila and Minister of Human Settlements (I. Marcos. Governor and Minister from 1978-1986)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1990","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"$40,000,000 (approximate)","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"According to a decision by the U.S. Supreme Court, in 1972, Ferdinand Marcos formed the Arelma S.A. entity under the laws of Panama and around the same time, opened an account under its name at the brokerage firm of Merrill, Lynch, Pierce, Fenner \u0026 Smith, Inc. in New York and deposited $2 million.\u00a0\u00a0 A class action by the Marcos\u0027 human rights victims resulted in a nearly $2 billion judgment for the \u0022Pimentel class,\u0022 which claimed a right to enforce its judgment by attaching the Arelma assets.  (The cases brought by the human rights victims have been consolidated and is now referred to as \u0022Estate of Ferdinand E. Marcos Human Rights Litigation.\u0022)  The ownership in Arelma was represented by two bearer share certificates that are held in escrow by the Philippine National Bank (PNB), after being transferred there in 1990 by an order of the Swiss Federal Supreme Court. (Source:  In the Supreme Court of the United States, Brief for the United States as Amicus Curiae in Estate of Roger Roxas et al v. Pimentel, et. al. and Republic of the Philippines v. Pimentel, et. al. Nos. 06-1039 and 06-1042).  The Philippines claimed ownership of the Arelma deposit of approximately $35 million based on its custody of the Arelma shares, but citing claims to the funds by the Marcos\u0027 human rights victims, Merrill Lynch filed an interpleader motion to request the courts to settle ownership of the funds.  Litigation is ongoing in the United States, as of early March 2011.  In April 2012, the Philippines Supreme Court upheld a previous ruling by the\u00a0Sandiganbayan  anti-graft court,\u00a0forfeiting the Arelma assets to the Republic of Philippines.\u00a0 The Supreme Court denied petitions filed by\u00a0Mrs. Marcos and her son who had challenged the Sandiganbayan\u0027s decision.\u00a0 (Source:  Republic of the Philippines Supreme Court, Ferdinand R. Marcos, Jr. v. Republic of the Philippines, G.R. No. 189434\u00a0and Imelda Romualdez-Marcos v. Republic of Philippines, G.R. No. 189505,\u00a0Decision, April 25, 2012; reaffirmed in Decision of March 12, 2014.) \u00a0In June 2012, the New York Court of Appeals upheld the\u00a0New York State Appellate Court decision a year earlier which held that the case of Swezey (representing the class of human rights victims) v. Merrill Lynch, et al,  cannot proceed without the participation of the Republic of Philippines, making reference to the\u00a0Philippines\u0027 Supreme Court\u00a0ruling that the Arelma assets belonged to the People of the Philippines and should be returned to them.\u00a0(Sources: Swezey v. Merrill Lynch, Pierce, Fenner, et al, National Bank of Philippines, et al (Intervenor),\u00a0\u00a0New York Court of Appeals, No. 88 (June 26, 2012); \u00a02011 NY Slip Op 05208 [appellate court decision].)\u00a0 The New York Court of Appeals decision noted that the Arelma assets, now approximately $40 million, were transferred,\u00a0pursuant to a court order, by Merrill Lynch to the custody of the New York City\u0027s Commissioner of Finance. (Swezey v. Merrill Lynch, Pierce, Fenner, et al, National Bank of Philippines, et al (Intervenor),\u00a0 New York Court of Appeals, No. 88 (June 26, 2012), at fn 6.)","Disposition of Criminal Case(s)":"A trial in the U.S. District Court for the Southern District of New York on criminal racketeering and fraud charges concluded in an acquittal for Mrs. Marcos.  Mr. Marcos had also been indicted in the case, but the court had deemed him too ill to stand trial. (Sources: US v. Tantoco, et al, Case No. 1-87-cr-598-JFK (S.D.N.Y.), Docket Report accessed on January 2, 2011 and Indictment of October 22, 1988, obtained from US National Archives; Craig Wolff, \u0022The Marcos Verdict; Marcos Is Cleared of All Charges In Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990.)  On April 21, 2010, the GMA News reported that \u0022According to records of the Philippine anti-graft court Sandiganbayan as of 2005, Mrs. Marcos continues to face 11 criminal charges and 25 civil cases.\u0022  (Source: Sohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....)","Jurisdiction of Origin: Investigative Agency":"Presidential Commission on Good Government","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Presidential Commission on Good Government","Jurisdiction of Origin: Courts Involved":"Sandiganbayan, Supreme Court of the Republic of the Philippines","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Kohn Swift \u0026 Graf PC (Attorney Robert A. Swift, on behalf of Human Rights Victims)","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Hawaii; Ninth Circuit Court of Appeals; Supreme Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_AP_Feb_24_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Judgment_Civil_Jan_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Judgment_Contempt_Jan_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Notice_Appeal_Feb_24_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_NYT_Mar_1_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Order_Atty_Fees_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Order_Distribution_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Order_Finders_Fee_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Texas_Del_Prado_Complaint_Apr_8_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Texas_Del_Prado_Order_Settlement_Nov_16_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Texas_Fifth_Circuit_Apr_5_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_NY_Appellate_Court_Decision_Jun_16_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Arelma_Deposit_NYS_Appellate_Decision_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_AP_Feb_24_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Judgment_Civil_Jan_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Judgment_Contempt_Jan_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Notice_Appeal_Feb_24_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_NYT_Mar_1_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Order_Atty_Fees_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Order_Distribution_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Order_Finders_Fee_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Texas_Del_Prado_Complaint_Apr_8_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Texas_Del_Prado_Order_Settlement_Nov_16_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Texas_Fifth_Circuit_Apr_5_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_NY_Appellate_Court_Decision_Jun_16_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Arelma_Phil_Supreme_Ct_Decision_Apr_25_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_AP_Feb_24_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Judgment_Civil_Jan_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Judgment_Contempt_Jan_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Notice_Appeal_Feb_24_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_NYT_Mar_1_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Order_Atty_Fees_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Order_Distribution_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Order_Finders_Fee_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Texas_Del_Prado_Complaint_Apr_8_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Texas_Del_Prado_Order_Settlement_Nov_16_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Texas_Fifth_Circuit_Apr_5_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_NY_Appellate_Court_Decision_Jun_16_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Arelma_Phil_Supreme_Ct_Decision_Mar_12_2014.pdf","Sources ":"\u00a0Republic of the Philippines, et al v. Pimentel, et al, 128 S.Ct. 2180 (2008) and subsequent decisions in Merrill Lynch, Fenner \u0026 Smith v. ENC Corp., 535 F.3d 1010; 2008 U.S. App. LEXIS 16468 (9th Cir. 2008); Appeal after remand at, Remanded by Merrill Lynch, Pierce, Fenner \u0026 Smith v. Arelma 2009 U.S. App. LEXIS 25051 (9th Cir., Nov. 13, 2009) at http:\/\/claimants1081.wordpress.com\/arelma-case\/; \u00a0Republic of the Philippines Supreme Court, Ferdinand R. Marcos, Jr. v. Republic of the Philippines, G.R. No. 189434 and Imelda Romualdez-Marcos v. Republic of Philippines, G.R. No. 189505, Decision, April 25, 2012, accessed at http:\/\/sc.judiciary.gov.ph\/jurisprudence\/2012\/april2012\/189434.htm and March 12, 2014 decision at http:\/\/sc.judiciary.gov.ph\/pdf\/web\/viewer.html?file=\/jurisprudence\/2014\/... See also Dr. Jaime S. Bautista, \u0022Recovery of the Marcos Assets,\u0022 accessed at http:\/\/www.unafei.or.jp\/english\/pdf\/PDF_ThirdGGSeminar\/Third_GGSeminar_P... Swezey v. Merrill Lynch, Pierce, Fenner, et al, National Bank of Philippines, et al (Intervenor), \u00a0New York Court of Appeals, No. 88 (June 26, 2012). \u00a0Swezey v. Merrill Lynch, Pierce, Fenner, et al, National Bank of Philippines, et al (Intervenor), \u00a02011 NY Slip Op 05208, accessed at http:\/\/iapps.courts.state.ny.us\/lawReporting\/Search (and also available at http:\/\/law.justia.com\/cases\/new-york\/appellate-division-first-department....)\n"},{"Case ID":"ARW-65","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ferdinand Marcos and Imelda Marcos \/ Estate of Ferdinand E. Marcos Human Rights Litigation","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"President (F. Marcos,1965-1986); First Lady, Governor of Metro Manila and Minister of Human Settlements (I. Marcos. Governor and Minister from 1978-1986)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1986","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"Letter of Request","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Much of the $7.5 million recovered by the Marcos\u0027 era human rights victims resulted from the settlement of the Texas case, in which judicial assistance was provided by the Philippines and Hong Kong.  (Source: In Re: Estate of Ferdinand E. Marcos Human Rights Litigation, Case No. 1:03-cv-11111-MLR (MDL-00840-MLR) (D. Hawaii). The U.S. Fifth Circuit Court of Appeals also  held that the Full Faith and Credit clause of the U.S. Constitution requires a state to give a judgment on a judgment rendered by a different state court equal dignity to a judgment rendered by its own state court.  (Source: Del Prado v. B N Development Company, Inc. et al, Case No. 09-10581 (5th Cir. 2010), citing Roche v. McDonald, 275 U.S. 449 (1928). ","Status of Asset Recovery ":"Completed (in part) and Ongoing (in part)","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$7,526,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"See also related entry, \u0022Ferdinand Marcos and Imelda Marcos \/ Vilma Bautista New York Art Case \/ Human Rights victims\u0027 Settlement.\u0022 \nIn January 2011, the U.S. District Court for the District of Hawaii authorized the distribution of $1,000 to each of the 7,526 eligible members of the class action brought by victims of the Marcos era human rights violations. The Court held that $10,261,000 were available in the Class Settlement Fund (comprised of $286,000 from pre-2010 executions and $9,975,000 net from the Texas class action settlement, Del Prado v. BN Development Company Inc et al, Case No. 4:05-cv-00234-Y; and included the following Colorado actions: De Leon v. Imelda R. Marcos et al., No. 09-CV-2216, and 135 Randomly Selected Class Claimants and the Plaintiff Class as Designated in the Judgment of February 3, 1995 v. Denman Investment Corporation, Inc. et al, No. 05-CV-702). The Court ordered the funds to be distributed as follows: $7,526,000 to 7,526 eligible class members, the vast majority of whom reside in the Philippines; $50,000 advanced to the attorneys for the cost of distribution; $1,402,288 in plaintiff\u0027s attorney fees and $847,952 in reimbursable costs for their work for the past 25 years; $300,000 to Alan Meeker in finders fee for locating the Marcos-related properties in Texas and Colorado; $10,000 to Jerry Pimentel as the next of kin to deceased Mariano Pimentel for Mariano Pimentel\u0027s services as a class representative in the Texas and Colorado actions; $5,000 to Ferdinand De Leon, for services as class representative. The order is in partial satisfaction of a 1995 judgment for $2 billion that was awarded to the human rights victims, who registered the judgment in Illinois, and in turn, in Texas. In 2010, a federal court in Northern District of Texas approved a settlement agreement between the human rights victims and seven companies that held legal ownership to properties in Texas and Colorado that the claimants had alleged were beneficially owned by the Marcoses. Hong Kong provided judicial assistance in the Texas case. On January 25, 2011, Judge Manuel Real also handed down a Judgment of Contempt against Imelda R. Marcos, Ferdinand E. Marcos and the Estate of Ferdinand E. Marcos in the amount of $353,600,000. The Court held that it had jurisdiction over a contempt order of May 26, 1995 which provided a daily sanction of $100,000 against the Marcoses for refusing to furnish information and using the frozen assets of the estate, and that a total of 3,536 days had elapsed since the Contempt Order. On February 24, the Marcoses\u0027 attorneys filed an appeal against the Judgment of Contempt. (Source: In Re: Estate of Ferdinand E. Marcos Human Rights Litigation, Case No. 1:03-cv-11111-MLR (MDL-00840-MLR) (D. Hawaii), Order Authorizing Distribution to Eligible Class Members from the Settlement Fund, Order for Interim Award of Attorneys Fees and Reimbursement of Expenses, and Order for Finders Fee and Incentive Fee, all issued on January 13, 2011; Judgment of Contempt and Judgment in a Civil Case, both filed on January 25, 2011; Notice of Appeal, filed on February 24, 2011.)","Disposition of Criminal Case(s)":"A trial in the U.S. District Court for the Southern District of New York on criminal racketeering and fraud charges concluded in an acquittal for Mrs. Marcos.  Mr. Marcos had also been indicted in the case, but the court had deemed him too ill to stand trial. (Sources: US v. Tantoco, et al, Case No. 1-87-cr-598-JFK (S.D.N.Y.), Docket Report accessed on January 2, 2011 and Indictment of October 22, 1988, obtained from US National Archives; Craig Wolff, \u0022The Marcos Verdict; Marcos Is Cleared of All Charges In Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990.)  On April 21, 2010, the GMA News reported that \u0022According to records of the Philippine anti-graft court Sandiganbayan as of 2005, Mrs. Marcos continues to face 11 criminal charges and 25 civil cases.\u0022  (Source: Sohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....)","Jurisdiction of Origin: Investigative Agency":"Presidential Commission on Good Government","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Presidential Commission on Good Government","Jurisdiction of Origin: Courts Involved":"Sandiganbayan; Supreme Court of the Republic of Philippines","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Kohn Swift \u0026 Graf PC (Attorney Robert A. Swift); Attorney Sherry P. Broder, Liaison Counsel; and Others [for Human Rights Victims Class];  Kabayashi, Sugita \u0026 Goda (Attorneys Lex R. Smith, Joseph A. Stewart, Maria Y. Yang) [for Estate of Ferdinand E. Marcos]","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Hawaii and Ninth Circuit Court of Appeals; U.S. District Court for the Northern District of Texas and Fifth Circuit Court of Appeals; U.S. District Court for the District of Colorado","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_9th_Circuit_Decision_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_535_F3d_1010_2008_Leagle.com, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Sandiganbayan_Business_World_Jan_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_US_Supreme_Court_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Bautista.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Sandiganbayan_GMANews_Aug_31_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_New_Sandiganbayan_GMANEWS_Jun_17_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_Hawaii_Judgment_Civil_Jan_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_9th_Circuit_Decision_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_535_F3d_1010_2008_Leagle.com, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Sandiganbayan_Business_World_Jan_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_US_Supreme_Court_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Bautista.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Sandiganbayan_GMANews_Aug_31_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_New_Sandiganbayan_GMANEWS_Jun_17_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_Hawaii_Judgment_Contempt_Jan_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_9th_Circuit_Decision_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_535_F3d_1010_2008_Leagle.com, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Sandiganbayan_Business_World_Jan_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_US_Supreme_Court_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Bautista.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Sandiganbayan_GMANews_Aug_31_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_New_Sandiganbayan_GMANEWS_Jun_17_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_Hawaii_Order_Distribution_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_9th_Circuit_Decision_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_535_F3d_1010_2008_Leagle.com, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Sandiganbayan_Business_World_Jan_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_US_Supreme_Court_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Bautista.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Sandiganbayan_GMANews_Aug_31_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_New_Sandiganbayan_GMANEWS_Jun_17_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_Hawaii_Order_Atty_Fees_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_9th_Circuit_Decision_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_535_F3d_1010_2008_Leagle.com, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Sandiganbayan_Business_World_Jan_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_US_Supreme_Court_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Bautista.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Sandiganbayan_GMANews_Aug_31_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_New_Sandiganbayan_GMANEWS_Jun_17_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_Hawaii_Order_Finders_Fee_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_9th_Circuit_Decision_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_535_F3d_1010_2008_Leagle.com, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Sandiganbayan_Business_World_Jan_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_US_Supreme_Court_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Bautista.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Sandiganbayan_GMANews_Aug_31_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_New_Sandiganbayan_GMANEWS_Jun_17_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_Texas_Del_Prado_Order_Settlement_Nov_16_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_9th_Circuit_Decision_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_535_F3d_1010_2008_Leagle.com, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Sandiganbayan_Business_World_Jan_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_US_Supreme_Court_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Bautista.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Sandiganbayan_GMANews_Aug_31_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_New_Sandiganbayan_GMANEWS_Jun_17_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_Texas_Del_Prado_Second_Complaint_Aug_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_9th_Circuit_Decision_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_535_F3d_1010_2008_Leagle.com, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Sandiganbayan_Business_World_Jan_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_US_Supreme_Court_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Bautista.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Sandiganbayan_GMANews_Aug_31_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_New_Sandiganbayan_GMANEWS_Jun_17_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_Texas_Del_Prado_Complaint_Apr_8_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_9th_Circuit_Decision_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_535_F3d_1010_2008_Leagle.com, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Sandiganbayan_Business_World_Jan_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_US_Supreme_Court_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Bautista.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Sandiganbayan_GMANews_Aug_31_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_New_Sandiganbayan_GMANEWS_Jun_17_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_Hawaii_NYT_Mar_1_2011_0.pdf","Sources ":"In Re: Estate of Ferdinand E. Marcos Human Rights Litigation, Case No. 1:03-cv-11111-MLR (MDL-00840-MLR) (D. Hawaii), Order Authorizing Distribution to Eligible Class Members from the Settlement Fund, Order for Interim Award of Attorneys Fees and Reimbursement of Expenses, and Order for Finders Fee and Incentive Fee, all issued on January 13, 2011; Judgment of Contempt and Judgment in a Civil Case, both filed on January 25, 2011; Notice of Appeal, filed on February 24, 2011. See also, Del Prado v. B N Development Company Inc et al, Case No. 4:05-cv-00234-Y, Complaint filed on April 8, 2005 and Second Amended Complaint filed on August 9, 2010; Order Granting Motion for Final Approval of Settlement, November 16, 2010; Del Prado v. B N Development Company, Inc. et al, Case No. 09-10581 (5th Cir. 2010), Opinion filed on April 5, 2010. See also, Seth Mydans, \u0022First Payments Are Made to Victims of Marcos Rule,\u0022 New York Times, March 1, 2011; Teresa Cerojano, \u0022Marcos victims in Philippines to get compensation,\u0022 Associated Press, February 24, 2011. Colorado actions included in the Texas settlement agreement are: De Leon v. Imelda R. Marcos et al., No. 09-CV-2216, and 135 Randomly Selected Class Claimants and the Plaintiff Class as Designated in the Judgment of February 3, 1995 v. Denman Investment Corporation, Inc. et al, No. 05-CV-702 (D. Col.); Sohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....\n"},{"Case ID":"ARW-66","Case Title (Name of Public Official or Entity Allegedly Involved)":"Fexngxia Sun","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"China","Position of Public Official(s) (yrs in office)":"Employee of Jiangsu Nuclear Power Corporation (State Owned Enterprise) (inclusive 1999-2000)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2010","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Unspecified","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"MLAT between the United States and Switzerland","Contributing Factors in Asset Recovery":"[Unknown Status]","Status of Asset Recovery ":"Unknown","Stage in Asset Recovery Chain":"Unknown [no confirmation that U.S. warrant of arrest in rem has been executed]","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"In 2009, the U.S.-based Control Components Inc. pleaded guilty to violation of the Travel Act in relation to improper payments to foreign officials.  Fexngxia Sun is one of the Chinese officials who allegedly received bribes from Control Components.  In April 2010, the U.S. filed a complaint against assets held by Fexngxia Sun in account no. 257-572688 at Union Bank of Switzerland, including $100,600 and proceeds thereof. In May 2010, a Warrant of Arrest in rem was issued by the U.S. District Court for the District of Columbia.  (Sources: U.S. v. All assets held in the name of Fexngxia Sun, account no. 257-572688 at Union Bank of Switzerland AG, Case No. 1:10-cv-00637-RBW (D.D.C.), Verified Complaint for Forfeiture In Rem, filed on April 23, 2010 and Warrant of Arrest In Rem dated May 18, 2010.)  According to the Court Docket Report, the case was terminated on August 31, 2011. (Source: Sources: U.S. v. All assets held in the name of Fexngxia Sun, account no. 257-572688 at Union Bank of Switzerland AG, Case No. 1:10-cv-00637-RBW (D.D.C.), Court Docket Report retrieved on November 2, 2011.)","Disposition of Criminal Case(s)":"Unknown as to Fexngxia Sun.  For details on completed and ongoing criminal proceedings in the U.S. against Control Component Inc. and related individuals, please see U.S. Department of Justice website at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/control-components.html.","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sun_Switzerland_Forfeiture_Complaint_Apr_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sun_Switzerland_Warrant_Arrest_May_18_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sun_DDC_Court_Docket_Rept_Nov_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Sun_DDC_Court_Dkt_Rept_Nov_2011.pdf","Sources ":"U.S. v. All assets held in the name of Fexngxia Sun, account no. 257-572688 at Union Bank of Switzerland AG, Case No. 1:10-cv-00637-RBW (D.D.C.), Verified Complaint for Forfeiture In Rem, filed on April 23, 2010 and Warrant of Arrest In Rem dated May 18, 2010 (last document filed in the Court Docket), Court Docket Report retrieved on November 2, 2011).  \nInformation on criminal proceedings against Control Components Inc. can be found at U.S. Department of Justice website: http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/control-components.html.\n"},{"Case ID":"ARW-67","Case Title (Name of Public Official or Entity Allegedly Involved)":"Fexngxia Sun","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"China","Position of Public Official(s) (yrs in office)":"Employee of Jiangsu Nuclear Power Corporation (State Owned Enterprise) (inclusive 1999-2000)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2010","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"[Unknown status]","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"In 2009, the U.S.-based Control Components Inc. pleaded guilty to violation of the Travel Act in relation to improper payments to foreign officials.  Fexngxia Sun is one of the Chinese officials who allegedly received bribes from Control Components.  In April 2010, the U.S. filed a complaint against assets held by Fexngxia Sun in account no. 257-572688 at Union Bank of Switzerland, including $100,600 and proceeds thereof. In May 2010, a Warrant of Arrest in rem was issued by the U.S. District Court for the District of Columbia. (Sources: U.S. v. All assets held in the name of Fexngxia Sun, account no. 257-572688 at Union Bank of Switzerland AG, Case No. 1:10-cv-00637-RBW (D.D.C.), Verified Complaint for Forfeiture In Rem, filed on April 23, 2010 and Warrant of Arrest In Rem dated May 18, 2010.)  According to the Court Docket Report, the case was terminated on August 31, 2011. (Source: U.S. v. All assets held in the name of Fexngxia Sun, account no. 257-572688 at Union Bank of Switzerland AG, Case No. 1:10-cv-00637-RBW (D.D.C.), Court Docket Report retrieved on November 2, 2011.)","Disposition of Criminal Case(s)":"Unknown as to Fexngxia Sun.  For details on completed and ongoing criminal proceedings in the U.S. against Control Component Inc. and related individuals, please see U.S. Department of Justice website at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/control-components.html.","Jurisdiction of Origin: Investigative Agency":"N\/A","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Columbia","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sun_US_Forfeiture_Complaint_Apr_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sun_US_Warrant_Arrest_May_18-2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sun_DDC_Court_Docket_Rept_Nov_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Sun_DDC_Court_Dkt_Rept_Nov_2011_0.pdf","Sources ":"U.S. v. All assets held in the name of Fexngxia Sun, account no. 257-572688 at Union Bank of Switzerland AG, Case No. 1:10-cv-00637-RBW (D.D.C.), Verified Complaint for Forfeiture In Rem, filed on April 23, 2010 and Warrant of Arrest In Rem dated May 18, 2010 (last document filed in the Court Docket Report); Court Docket Report retrieved on November 2, 2011.  \nInformation on criminal proceedings against Control Components Inc. can be found at U.S. Department of Justice website: http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/control-components.html.\n"},{"Case ID":"ARW-68","Case Title (Name of Public Official or Entity Allegedly Involved)":"Frederick Jacob Titus Chiluba","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Zambia","Position of Public Official(s) (yrs in office)":"President (1991-2002)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"As summarized in a 2009 report by Transparency International UK, \u0022Civil proceedings were brought by Zambia in the High Court against Dr. Chiluba and nineteen of his alleged associates. The case in the London civil courts concerned three separate claims:  The Zamtrop Conspiracy...The MOFED Claim...[which] ultimately failed...[and] The BK Conspiracy....On May 4, 2007, Zambia obtained judgment against Dr. Chiluba and some of his co-defendants for about U.S. $46 million.  Judgment was obtained against Dr. Chiluba\u0027s lawyer Iqbal Meer....However, on 31 July 2008 Mr  Meer successfully appealed the judgment against him, persuading the Court of Appeal that he had not known or suspected the dishonesty of his clients.\u0022  (Sources: Transparency International UK, \u0022Combating Money Laundering and Recovering Looted Gains: Raising the UK\u0027s Game, June 2009; AG of Zambia v Meer Care \u0026 Desai and others [2007] EWHC 952 (Ch) and [2007] EWHC 1540 (Ch).  See also, AG of Zambia v. Meer Care \u0026 Desai and others [2008] EWCA Civ 1007 (31 July 2008), paragraph 6 descriptionof the Zamtrop account and paragraph 8 description of the BK conspiracy.)","Disposition of Criminal Case(s)":"According to the New York Times, Mr. Chiluba was acquitted on August 18, 2009 by a court in Lusaka, Zambia. (Source: Celia W. Dugger, \u0022Former President of Zambia Is Acquitted,\u0022 New York Times, August 18, 2009.)","Jurisdiction of Origin: Investigative Agency":"Task Force on Corruption (established 2002)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General of Zambia","Jurisdiction of Origin: Courts Involved":"[Lusaka, Zambia]","Jurisdiction of Asset Recovery: Investigative Agency":"Serious Fraud Office; Office for the Supervision of Solicitors; Grant Thornton (asset tracing, on behalf of Zambia and some of the defendants)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"DLA Piper UK LLP (Michael Sullivan Q.C. and Hannah Brown) (representing Government of Zambia)","Jurisdiction of Asset Recovery: Courts Involved":"England and Wales High Court; Court of Appeal","Documents":"","Sources ":"AG of Zambia v. Meer Care and Desai and others [2008] EWCA Civ. 1007, [2007] EWHC 952 (Ch) and other decisions in the case, available at www.bailii.org (British and Irish Legal Information Institute); \nTransparency International UK report, \u0022Combating Money Laundering and Recovering Looted Gains: Raising the UK\u0027s Game,\u0022 (June 2009) which can be downloaded at http:\/\/www.transparency.org.uk\/publications, box on right, \u0022Recommended Reading.\u0022  \nSee also, Faustin M. Kabewe and Aaron Chungu v. the United Kingdom, 2967\/08 [2010]  ECHR 251 (2 February 2010), at http:\/\/bailii.org\/eu\/cases\/ECHR\/2010\/251.html.  \nCelia W. Dugger, \u0022Former President of Zambia Is Acquitted,\u0022 New York Times, August 18, 2009, accessed at http:\/\/www.nytimes.com\/2009\/08\/18\/world\/africa\/18zambia.html.\n"},{"Case ID":"ARW-70","Case Title (Name of Public Official or Entity Allegedly Involved)":"Haiti Teleco \/ Jean Rene Duperval","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Haiti","Position of Public Official(s) (yrs in office)":"Director of International Affairs, Haiti Teleco (2003-2004)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"As part of his sentencing, Mr. Duperval was ordered to forfeit $497,331 in proceeds of crime. (Source: U.S. v. Esquenazi, et al,  Case No. 1:09-cr-21010-MGC (S.D. Fla.), Superseding Indictment filed July 12, 2011; Order of Forfeiture, May 21, 2012.)   According to the US Government\u0027s Forfeiture motion, \u0022The evidence at trial also showed that he laundered the $497,331 in the United States through the bank accounts of two South Florida companies, Crossover Records and Telecom Consulting Services, owned by his siblings.\u0022  (Source: US v. Duperval, Case No. 1:09-cr-21010 (S.D.Fla.), United States\u0027 Motion for Entry of Forfeiture Money Judgment at Sentencing and Incorporated Memorandum of Law, filed May 18, 2012.)","Disposition of Criminal Case(s)":"According to a US Department of Justice Press Release, in May 2012, \u0022Jean Rene Duperval, a former director of international relations for Telecommunications D\u2019Haiti S.A.M. (Haiti Teleco), a Haitian state-owned telecommunications company, was sentenced today to nine years in prison for his role in a scheme to launder bribes paid to him by two Miami-based telecommunications companies.\u0022 (Source: US Department of Justice press release, \u0022Former Haitian Government Official Sentenced to Nine Years in Prison for Role in Scheme to Launder Bribes,\u0022\nMay 21, 2012.)","Jurisdiction of Origin: Investigative Agency":"Haiti\u0027s financial intelligence unit, the Unite Centrale de Renseignements Financiers (UCREF), the Bureau des Affaires Financieres et Economiques (BAFE), which is a specialized component of the Haitian National Police, and the Ministry of Justice and Public Security","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Internal Revenue Service, Criminal Investigations -  Miami Field Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney\u0027s Office for the Southern District of Florida","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of Florida","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duperval_US_SDFLA_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duperval_US_SDFLA_Indictment_Dec_8_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Duperval_Joseph_Order_Set_Trial_Date_SDFLA_Sep_1_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Joseph_Superseding_Indictment_July_12_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Superseding_Indictment_DOJ_PR_Jul_13_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Haiti_Teleco_Duperval_Govt_Mtn_Forfeiture_May_18_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duperval_US_SDFLA_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duperval_US_SDFLA_Indictment_Dec_8_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Duperval_Joseph_Order_Set_Trial_Date_SDFLA_Sep_1_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Joseph_Superseding_Indictment_July_12_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Superseding_Indictment_DOJ_PR_Jul_13_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Haiti_Teleco_Duperval_Judgment_May_22_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duperval_US_SDFLA_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duperval_US_SDFLA_Indictment_Dec_8_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Duperval_Joseph_Order_Set_Trial_Date_SDFLA_Sep_1_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Joseph_Superseding_Indictment_July_12_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Superseding_Indictment_DOJ_PR_Jul_13_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Haiti_Teleco_Duperval_Order_Forfeiture_May_21_2012.pdf","Sources ":"U.S. v. Esquenazi, et al,  Case No. 1:09-cr-21010-MGC (S.D. Fla.), Superseding Indictment filed July 12, 2011; Judgment, May 21, 2012; Order of Forfeiture, May 21, 2012, all accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/esquenazij.html;\nUS Department of Justice Press Release, \u0022Former Haitian Government Official Sentenced to Nine Years in Prison for Role in Scheme to Launder Bribes,\u0022 May 21, 2012, accessed at  http:\/\/www.justice.gov\/opa\/pr\/2012\/May\/12-crm-656.html;\nUS v. Duperval, Case No. 1:09-cr-21010 (S.D.Fla.), United States\u0027 Motion for Entry of Forfeiture Money Judgment at Sentencing and Incorporated Memorandum of Law, filed May 18, 2012, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/esquenazij\/2012-05-18-d....\n"},{"Case ID":"ARW-72","Case Title (Name of Public Official or Entity Allegedly Involved)":"Haiti Teleco \/ Robert Antoine \/ Joel Esquenazi \/ Carlos Rodriguez \/ Juan Diaz","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Haiti","Position of Public Official(s) (yrs in office)":"Director of International Affairs, Haiti Teleco (2001-2003)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Criminal Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Antonio Perez (Controller of the Bribe Giver company) pleaded guilty in April 2009 and named Mr. Antoine as a recipient of the bribes.  Assistance provided by a number of Government of Haiti\u0027s investigative agencies was acknowledged by the U.S. Department of Justice. Source: U.S. Department of Justice Press Release, \u0022Ex funcionario gubernamental de Haiti sentenciado a prision por su papel en conspiracion de lavado de dinero relacionada con ardid de soborno en el extranjero,\u0022 June 2, 2010, posted at http:\/\/www.justice.gov\/opa\/pr\/2010\/June\/10-crm-639-spanish.html.); Close and specific collaboration among the U.S. authorities and Haitian authorities such as the financial intelligence unit, national police and the Ministry of Justice and Public Security (Source: StAR Asset Recovery Handbook (December 2010), \u0022Box 9.5 Important Role of the Jurisdiction Harmed by Corruption -- A Case Example from Haiti,\u0022 at 183.)  ","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"$1,852,209.39 in restitution was ordered as part of Mr. Antoine\u0027s judgment in a criminal case heard in U.S. District Court for the Southern District of Florida.  A discussion between the U.S. and Haitian authorities regarding the sharing of the proceeds is ongoing, as of December 2010. (Source: StAR Asset Recovery Handbook (December 2010), \u0022Box 9.5 Important Role of the Jurisdiction Harmed by Corruption -- A Case Example from Haiti,\u0022 at 183.  The judgment in Mr. Antoine\u0027s case noted \u0022see victims list\u0022 but this was not available through Pacer.)  In its press release, the U.S. Department of Justice acknowledged the assistance by various agencies of the Government of Haiti in the investigation. (Sources: U.S. v. Joel Esquenazi, Carlos Rodriguez, Robert Antoine, Jean Rene Duperval and Marguerite Grandison, Case No. 09-CR-21010-JEM (S.D. Fla.), Indictment filed December 4, 2009; U.S. v. Robert Antoine, et al, Case No. 1:09-21010-CR-MARTINEZ-3 (S.D. Fla.), Order of Forfeiture filed on June 2, 2010; U.S. v. Robert Antoine, Case No. 1:09-21010-CR-MARTINEZ-3 (S.D. Fla.), Judgment in a Criminal Case, filed on June 9, 2010.)  On November 3, 2011, Mr. Esquenazi and Mr. Rodriguez were sentenced to pay $2.2 million in restitution (joint and several liability with one another and with their other co-defendants Antoine Perez and Jean Fourcand) in the same case.  (US v. Esquenazi and U.S. v. Rodriguez, Case No. 09-cr-21020-JEM (S.D. Fla.), Amended Judgment in a Criminal Case filed November 3, 2011.)  On August 4, 2010, Juan Diaz, a defendant in a related case, was also ordered to pay restitution in the amount of $73,824.20 to the Government of Haiti.  (US v. Diaz, Case No. 09-cr-20346-JEM (S.D. Fla.), Judgment in a criminal case and sentencing hearing transcript, both filed August 5, 2010.)","Disposition of Criminal Case(s)":"According to the U.S. Department of Justice press release, Mr. Antoine pleaded guilty on March 12, 2010, to conspiracy to commit money laundering.   (Source: U.S. Department of Justice Press Release, \u0022 Former Haitian Government Official Sentenced to Prison for His Role in Money Laundering Conspiracy Related to Foreign Bribery Scheme,\u0022 June 2, 2010.)","Jurisdiction of Origin: Investigative Agency":"Haiti\u2019s financial intelligence unit, the Unite Centrale de Renseignements Financiers (UCREF), the Bureau des Affaires Financieres et Economiques (BAFE), which is a specialized component of the Haitian National Police, and the Ministry of Justice and Public Security","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Internal Revenue Service, Criminal Investigations - Miami Field Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Southern District of Florida; Department of Justice, Criminal Division, Fraud Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of Florida","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_StAR_Handbook_Haiti_Teleco.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Factual_Agreement_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Forfeiture_Order_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Indictment_Dec_4_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Sentencing_DOJ_PR_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Judgment_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Sentencing_Hearing_Transcript_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Esquenazi_Amended_Judgment_Nov_3_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Rodriguez_Amended_Judgment_Nov_3_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Diaz_DOJ_Factual_Agreement_May_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_StAR_Handbook_Haiti_Teleco.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Factual_Agreement_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Forfeiture_Order_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Indictment_Dec_4_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Sentencing_DOJ_PR_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Judgment_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Sentencing_Hearing_Transcript_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Esquenazi_Amended_Judgment_Nov_3_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Rodriguez_Amended_Judgment_Nov_3_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Haiti_Teleco_Diaz_Judgment_Aug_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_StAR_Handbook_Haiti_Teleco.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Factual_Agreement_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Forfeiture_Order_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Indictment_Dec_4_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Sentencing_DOJ_PR_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Judgment_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Sentencing_Hearing_Transcript_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Esquenazi_Amended_Judgment_Nov_3_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Rodriguez_Amended_Judgment_Nov_3_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Haiti_Teleco_Diaz_Sentencing_Hearing_Transcript_Aug_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_StAR_Handbook_Haiti_Teleco.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Factual_Agreement_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Forfeiture_Order_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Indictment_Dec_4_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Sentencing_DOJ_PR_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Judgment_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Sentencing_Hearing_Transcript_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Esquenazi_Amended_Judgment_Nov_3_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Rodriguez_Amended_Judgment_Nov_3_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Haiti_Teleco_Esquenazi_Amended_Judgment_Nov_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_StAR_Handbook_Haiti_Teleco.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Factual_Agreement_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Forfeiture_Order_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Indictment_Dec_4_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Sentencing_DOJ_PR_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Judgment_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Sentencing_Hearing_Transcript_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Esquenazi_Amended_Judgment_Nov_3_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Rodriguez_Amended_Judgment_Nov_3_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Haiti_Teleco_Rodriguez_Amended_Judgment_Nov_3_2011.pdf","Sources ":"U.S. v. Joel Esquenazi, Carlos Rodriguez, Robert Antoine, Jean Rene Duperval and Marguerite Grandison, Case No. 09-CR-21010-JEM (S.D. Fla.), Indictment filed December 4, 2009 and Factual Agreement filed March 12, 2010; U.S. v. Robert Antoine, et al, Case No. 1:09-21010-CR-MARTINEZ-3 (S.D. Fla.), Order of Forfeiture filed on June 2, 2010; U.S. v. Robert Antoine, Case No. 1:09-21010-CR-MARTINEZ-3 (S.D. Fla.), Judgment in a Criminal Case, filed on June 9, 2010; U.S. Department of Justice Press Release, \u0022 Former Haitian Government Official Sentenced to Prison for His Role in Money Laundering Conspiracy Related to Foreign Bribery Scheme,\u0022 June 2, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/June\/10-crm-639.html.  See also, StAR Asset Recovery Handbook (December 2010), \u0022Box 9.5 Important Role of the Jurisdiction Harmed by Corruption - A Case Example from Haiti,\u0022 at 183; US v. Esquenazi and U.S. v. Rodriguez, Case No. 09-cr-21020-JEM (S.D. Fla.), Amended Judgment in a Criminal Case filed November 3, 2011; US v. Diaz, Case No. 09-cr-20346-JEM (S.D. Fla.), Judgment in a criminal case and sentencing hearing transcript, both filed August 5, 2010.\n"},{"Case ID":"ARW-75","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hendra Rahardja","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Indonesia","Position of Public Official(s) (yrs in office)":"President \/ CEO of PT Bank Harapan Sentosa (?-1997)","Jurisdiction of Asset Recovery":"Australia","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1991","Asset Recovery End":"2008","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation; Other ","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"The Australian court decision noted that the Government of Hong Kong had provided evidence pursuant to Australia\u0027s Mutual Legal Assistance Treaty request (Source: CDPP - In the matter of S.19 of the Proceeds of Crime Act 2002; In the matter of Funds in a bank account; In the matter of Sunshine Worldwide Holdings Limited and South East Group Limited, 62 NSWLR 400 [2005])","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$493,647 ([Australia Attorney General - Euitable Sharing Program; compared to $3 million reported in Jakarta Post article that was posted at Indonesian Embassy Ottawa website; please see sources]","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to the March 1, 2005 Judgment by Australia\u0027s New South Wales Supreme Court, \u0022It was contended that the crimes of the deceased Rahardja produced a total loss to the Central Bank of Indonesia of A$390 million of which some A$38.5 million came to Australia.\u0022 (Source: CDPP - In the Matter of S.19 of the Proceeds of Crime Act 2002; In the Matter of Funds in a Bank Account; In the Matter of Sunshine Worldwide Holdings Limited and South East Group Limited [2005] NSWSC 117.) According to a January 23, 2008 Jakarta Post article posted on the website of the Indonesian Embassy in Ottawa and citing an official of the Indonesian Justice and Human Rights Ministry, $3 million was returned from Australia. Australia was said to also be helping repatriate another $3 million from Hong Kong. Hendra Rahardja had fled to Australia, and was convicted in absentia in 2002 by Indonesia for misuse of Bank of Indonesia liquidity support funds. Indonesia had ordered him to pay $280 million in indemnities. An Australian court decision in 2008 cited a 2003 affidavit by the Australian Federal Police investigator, who contended that some $26 million in Hendra Rahardja\u0027s criminal proceeds were found to have come to Australia. [Source: CDPP - In the matter of S.19 of the Proceeds of Crime Act 2002; In the matter of Funds in a bank account; In the matter of Sunshine Worldwide Holdings Limited and South East Group Limited, 62 NSWLR 400 (2005), at para 29.] The website of the Attorney General of Australia noted that as part of Australia\u0027s Equitable Sharing Program established under United Nations Convention Against Corruption (UNCAC) provisions as well as Australia\u0027s Proceeds of Crime Act, $493,647.07 was provided to the Indonesian Government for assistance in the Hendra Rahardja matter. (Source: http:\/\/www.ag.gov.au\/agd\/WWW\/ncphome.nsf\/Page\/POCA_funding_for_Non-Gover...)","Disposition of Criminal Case(s)":"According to the March 1, 2005 Judgment by Australia\u0027s New South Wales Supreme Court, \u0022The deceased [Hendra Rahardja]  had been convicted in Indonesia on 18 March 2002 in absentia of charges relating to this matter and was sentenced to life imprisonment and fined 30 million rupiah.\u0022  (Source: CDPP - In the Matter of S.19 of the Proceeds of Crime Act 2002; In the Matter of Funds in a Bank Account; In the Matter of Sunshine Worldwide Holdings Limited and South East Group Limited [2005] NSWSC 117.)","Jurisdiction of Origin: Investigative Agency":"Department of Justice of the Republic of Indonesia [extradition]","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Australian Federal Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Commonwealth Director of Public Prosecutions; Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"New South Wales Supreme Court [civil asset recovery]; Federal Court of Australia, New South Wales District Registry [extradition proceedings]","Documents":"","Sources ":"CDPP - In the matter of S.19 of the Proceeds of Crime Act 2002; In the matter of Funds in a bank account; In the matter of Sunshine Worldwide Holdings Limited and South East Group Limited, 62 NSWLR 400 [2005]; \nAbdul Khalik, \u0022Indonesia Recovers $3 million Bank Bosses Stashed in Australia,\u0022 Jakarta Post, January 23, 2008, posted on the website of the Indonesian Embassy, Ottawa, at http:\/\/www.indonesia-ottawa.org\/information\/details.php?type=news_copy\u0026i... \nWorking Group Report, Australia\/ Indonesia Working Group on Legal Cooperation (Denpasar, 26-27 June 2006), accessed at \u0022http:\/\/www.ag.gov.au\/www\/agd\/rwpattach.nsf\/VAP\/(CFD7369FCAE9B8F32F341DBE097801FF)~9WGLC+REPORT+Final1.doc\/$file\/9WGLC+REPORT+Final1.doc - - Cached\u0022; \nEmbassy of the Republic of Indonesia Canberra, \u0022Press Release on the Death of Hendra Rahardja,\u0022 No. 58\/Pen\/I\/03, January 27, 2003.\n"},{"Case ID":"ARW-76","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hendra Rahardja (Hong Kong SAR, China)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Indonesia","Position of Public Official(s) (yrs in office)":"President \/ CEO of PT Bank Harapan Sentosa (?-1997)","Jurisdiction of Asset Recovery":"Hong Kong SAR, China","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"[Unknown Status of Recovery]","Status of Asset Recovery ":"Unknown","Stage in Asset Recovery Chain":"Unknown","Assets Frozen (USD)":"$3,000,000 (secondary source)","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unknown","Case Summary":"According to the March 1, 2005 Judgment by Australia\u0027s New South Wales Supreme Court, \u0022It was contended that the crimes of the deceased Rahardja produced a total loss to the Central Bank of Indonesia of A$390 million of which some A$38.5 million came to Australia.\u0022  (Source: CDPP - In the Matter of S.19 of the Proceeds of Crime Act 2002; In the Matter of Funds in a Bank Account; In the Matter of Sunshine Worldwide Holdings Limited and South East Group Limited [2005] NSWSC 117.)  According to the International Centre for Asset Recovery, in February 2009, an official of the \u0022Hong Kong Ministry of Justice would confirm only that USD 3 million was frozen in Hong Kong, despite press reports of larger amounts concealed in that jurisdiction.\u0022  (Source: http:\/\/www.assetrecovery.org\/kc\/node\/88a69af9-f1fe-11dd-acdc-479fc5e02d5a.)  At the time of Hendra Rahardja\u0027s case in Indonesia, Hong Kong and Indonesia did not have a bilateral Mutual Legal Assistance Treaty (they signed one in 2008).  The lack of an MLAT betwen the two jurisdictions cited as one of the reasons Australia was acting as intermediary between the two jurisdictions.  (Source:  Working Group Report, Australia\/ Indonesia Working Group on Legal Cooperation (Denpasar, 26-27 June 2006), at 5: \u0022In particular, the group discussed recent developments in the Hendra Rahardja case, including Australia\u2019s recent mutual assistance request to Hong Kong requesting a portion of the assets identified and restrained in Hong Kong be returned to Indonesia.)","Disposition of Criminal Case(s)":"According to the March 1, 2005 Judgment by Australia\u0027s New South Wales Supreme Court, \u0022The deceased had been convicted in Indonesia on 18 March 2002 in absentia of charges relating to this matter and was sentenced to life imprisonment and fined 30 million rupiah.\u0022  (Source: CDPP - In the Matter of S.19 of the Proceeds of Crime Act 2002; In the Matter of Funds in a Bank Account; In the Matter of Sunshine Worldwide Holdings Limited and South East Group Limited [2005] NSWSC 117.)","Jurisdiction of Origin: Investigative Agency":"Unspecfied","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"","Sources ":"CDPP - In the matter of S.19 of the Proceeds of Crime Act 2002; In the matter of Funds in a bank account; In the matter of Sunshine Worldwide Holdings Limited and South East Group Limited, 62 NSWLR 400 [2005] (notes Hong Kong government\u0027s assistance to Australian investigation), accessed at the website of New South Wales Government LawLink: http:\/\/www.lawlink.nsw.gov.au\/scjudgments\/2005nswsc.nsf\/0000000000000000... \nWorking Group Report, Australia\/ Indonesia Working Group on Legal Cooperation (Denpasar, 26-27 June 2006), accessed at \u0022http:\/\/www.ag.gov.au\/www\/agd\/rwpattach.nsf\/VAP\/(CFD7369FCAE9B8F32F341DBE097801FF)~9WGLC+REPORT+Final1.doc\/$file\/9WGLC+REPORT+Final1.doc - - Cached\u0022;\nInternational Centre for Asset Recovery, \u0022Hendra Rahardja Case Study,\u0022 at http:\/\/www.assetrecovery.org\/kc\/node\/88a69af9-f1fe-11dd-acdc-479fc5e02d5a.\n"},{"Case ID":"ARW-77","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hosni Mubarak (various jurisdictions)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Egypt","Position of Public Official(s) (yrs in office)":"President (1981-2011)","Jurisdiction of Asset Recovery":"Various, unnamed jurisdictions","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Not Identified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"Unspecified","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"According to the note verbale dated 7 October 2011 from the Permanent Mission of Egypt to the United Nations (Vienna) addressed to the United Nations Office on Drugs and Crime, Corruption and Economic Crime Branch, \u0022Given the large number of cases reported to the Prosecutor-General\u2019s office in the aftermath of Egypt\u2019s 25 January 2011 revolution, the office has opened an investigation into thousands of reports against officials in the former regime for obtaining financial gain from corruption for themselves or others. A large number of those officials have been brought to stand criminal trial, notably the former Head of State, his two sons and many former ministers. Because of the complex ties those persons had and the great power they wielded by virtue of their former prominent public functions, they were able to transfer vast sums of money gained from crimes of corruption out of the country, which impeded its development. The Prosecutor-General\u2019s office thus promptly submitted requests for mutual legal assistance to various countries of the world, based on the provisions of the Convention, enquiring whether the said indicted persons had transferred funds and, if so, requesting the freezing and seizure of those funds and their return to Egypt. However, many substantive and procedural difficulties have been encountered in executing those requests, inter alia, those described [in the note verbale and accompanying annex.]\u0022  (Source: Note verbale dated 7 October 2011 from the Permanent Mission of Egypt to the United Nations (Vienna) addressed to the United Nations Office on Drugs and Crime, Corruption and Economic Crime Branch, Submitted to the United Nations Conference of the States Parties to the United Nations Convention against Corruption.)","Disposition of Criminal Case(s)":"According to the New York Times and other sources, in May 2014, Mr. Mubarak was convicted on charge of embezzlement and sentenced to three years\u0027 imprisonment. (Source: \u00a0David Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014.)","Jurisdiction of Origin: Investigative Agency":"Prosecutor-General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor-General\u0027s Office","Jurisdiction of Origin: Courts Involved":"Cairo Appeals Court","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"http:\/\/\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_UNCAC_COSP_Note_2011.pdf, http:\/\/\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_Embezzlement_Verdict_NYTimes_May_21_2014_3.pdf","Sources ":"\n\tNote verbale dated 7 October 2011 from the Permanent Mission of Egypt to the United Nations (Vienna) addressed to the United Nations Office on Drugs and Crime, Corruption and Economic Crime Branch, Submitted to the United Nations Conference of the States Parties to the United Nations Convention against Corruption, accessed at http:\/\/www.unodc.org\/documents\/treaties\/UNCAC\/COSP\/session4\/V1186327e.pdf;\n\n\t\u00a0\n\n\tDavid Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014, at http:\/\/www.nytimes.com\/2014\/05\/22\/world\/middleeast\/hosni-mubarak-trial.html\n"},{"Case ID":"ARW-78","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hosni Mubarak (European Union)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Egypt","Position of Public Official(s) (yrs in office)":"President (1981-2011)","Jurisdiction of Asset Recovery":"European Union","Jurisdiction of Asset Description":"Location of Recovery Effort","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"\n\tOn November 26, 2012, the Council of the European Union announced that it had taken steps to facilitate the return of misappropriated funds to the Egyptian authorities: \u00a0\u0022The new legislative framework authorises EU member states to release frozen assets on the basis of judicial decisions recognized in EU member states. Once the necessary judicial steps have been taken, this should enable the release and return to the Egyptian and Tunisian authorities of funds frozen under EU sanctions against the former Mubarak and Ben Ali regimes. In addition, the amended legislation will facilitate the exchange of information between EU member states and the relevant authorities in Tunisia and Egypt so as to assist in the recovery of misappropriated funds. [ \u00a0] \u00a0Since January 2011, [ \u00a0] \u00a09 persons responsible for the misappropriation of Egyptian state funds, including former President Hosni Mubarak, have had their assets in the EU frozen since March 2011.\u0022 \u00a0(Source: Council of the European Union, Press Statement, 16078\/12, November 26, 2012.)\u00a0\n\n\t\u00a0\n\n\tThe European Union had originally issued Council Regulation - (EU) No 270\/2011 of 21 March 2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Egypt, including freeze on assets belonging to Mr. Mubarak and others - in March 2011. (Source: Council Regulation (EU) No 270\/2011 of 21 March 2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Egypt.) \u00a0 The Council Decision has been renewed on several occasions, including most recently with the Council Decision 2016\/411 of March 18, 2016, extending the period of restrictive measures until March 22, 2017. (Source: Official Journal of the European Union, at http:\/\/eur-lex.europa.eu\/legal-content\/EN\/TXT\/HTML\/?uri=CELEX:32016D0411...)","Disposition of Criminal Case(s)":"According to the New York Times and other sources, in May 2014, Mr. Mubarak was convicted on charge of embezzlement and sentenced to three years\u0027 imprisonment. (Source: \u00a0David Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014.)","Jurisdiction of Origin: Investigative Agency":"Prosecutor-General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor-General\u0027s Office","Jurisdiction of Origin: Courts Involved":"Cairo Appeals Court","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Asset Recovery: Courts Involved":"NA","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_European_Union_Regulation_No_270_2011_Mar_21_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Trial_Postponed_to_December_BBC_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_EU_Council_AR_Statement_Nov_26_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_European_Union_Regulation_No_270_2011_Mar_21_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Trial_Postponed_to_December_BBC_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_Embezzlement_Verdict_NYTimes_May_21_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_European_Union_Regulation_No_270_2011_Mar_21_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Trial_Postponed_to_December_BBC_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_EU%20Council%20Decision_2016_411_March%202016.pdf","Sources ":"\n\n\t\tCouncil of the European Union, Press Statement, 16078\/12, November 26, 2012, at http:\/\/www.consilium.europa.eu\/\/uedocs\/cms_data\/docs\/pressdata\/EN\/foraff...\n\n\t\t\u00a0\n\n\t\tCouncil Regulation (EU) No 270\/2011\n\n\t\tof 21 March 2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Egypt, accessed at http:\/\/eur-lex.europa.eu\/LexUriServ\/LexUriServ.do?uri=OJ:L:2011:076:0004... \u00a0Council Decision 2016\/411 of 18 March 2016, at http:\/\/eur-lex.europa.eu\/legal-content\/EN\/TXT\/HTML\/?uri=CELEX:32016D0411...\n\n\t\t\u00a0\n\n\t\tDavid Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014, at http:\/\/www.nytimes.com\/2014\/05\/22\/world\/middleeast\/hosni-mubarak-trial.html\n\n\u00a0\n"},{"Case ID":"ARW-79","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hosni Mubarak (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Egypt","Position of Public Official(s) (yrs in office)":"President (1981-2011)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty ","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"\n\tIn the November 2014 speech by the President of the Swiss Confederation to the Arab Forum on Asset Recovery (AFAR III), Mr. Didier Burkhalter stated that, \u0022Our aim is therefore to verify the origin of the USD 650 million frozen in the Egyptian context [ \u00a0] in order to be able to return them should their illicit origin be established.\u0022 \u00a0(Source: \u0022Progress and challenges of asset recovery: a shared effort and responsibility,\u0022 November 1, 2014, at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=55048)\n\n\t\u00a0\n\n\tIn January 2014, the Swiss Office of the Attorney General announced that it would seek Egypt\u0027s assistance, stating: \u0022During the past couple of months, the Office of the Attorney General has thoroughly analysed the case of Egypt and reviewed it in depth. Priority has been accorded to establishing the facts, the relationships between the persons under investigation - all Egyptian nationals associated with former president Mubarak - and to analysing bank accounts and flows of financial assets.\n\n\t\u00a0\n\n\tWhat is decisive in Switzerland\u0027s criminal investigation, as in all cases of money laundering, is the question of whether the predicate offences can be shown to have been committed outside of Switzerland. The cooperation of the Egyptian judicial authorities is vital since the alleged criminal acts or predicate offences to money laundering took place almost exclusively in Egypt. Consequently, the Office of the Attorney General will be contacting the competent Egyptian authorities in the next couple of days and actively requesting legal assistance as provided for under the Swiss Act on Mutual Assistance in Criminal Matters (IMAC) and the Swiss Criminal Procedure Code (CrimPC).\u0022 \u00a0(Source: Swiss Office of Attorney General, \u0022Arab Spring: Swiss Attorney General to request legal assistance from Egypt,\u0022 January 31, 2014.)\n\n\t\u00a0\n\n\tAccording to the May 11, 2011 statement by the Swiss Federal Department of Foreign Affairs, CHF 410 million (US$428,373,000) in assets held by Egyptian individuals belonging to the former Mubarak government had been frozen in Switzerland. \u00a0The statement noted: \u0022The freezing of these assets does not demonstrate their legal or illegal origin. Thus, it is now up to the Egyptian judicial authorities to determine, through criminal proceedings, whether these assets were illicitly acquired. \u00a0Switzerland hopes to be able to quickly return to the Egyptian people all frozen assets whose origin is proved by the Egyptian authorities to be illegal. It is ready to cooperate with the Egyptian authorities on international mutual legal assistance.\u0022 (Source: Swiss Federal Department of Foreign Affairs, \u0022Swiss delegation of experts in Cairo,\u0022 May 11, 2011.) \u00a0On February 11, 2011, the Swiss Government announced that it had passed a special ordinance blocking any assets in Switzerland of the former President Mubarak and parties close to him. \u00a0The special ordinance (revised February 16) remains valid for three years. (Source: \u00a0Federal Department of Foreign Affairs Media Release, \u0022Federal Council orders freezing of any assets of Egypt\u0027s former President Hosni Mubarak in Switzerland,\u0022 February 11, 2011, provides links to the special ordinances.) \u00a0According to the Swiss Federal Department of Foreign Affairs, \u0022The ordinance on freezing assets, which was originally limited to three years, was extended at the beginning of 2014 for a further three years to allow more time for criminal investigations in Egypt into the origins of the funds.\u0022 (Source: \u0022Freezing of assets,\u0022 at https:\/\/www.eda.admin.ch\/eda\/en\/fdfa\/foreign-policy\/financial-centre-eco...)\n\n\t\u00a0","Disposition of Criminal Case(s)":"According to the New York Times and other sources, in May 2014, Mr. Mubarak was convicted on charge of embezzlement and sentenced to three years\u0027 imprisonment. (Source: \u00a0David Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014.)","Jurisdiction of Origin: Investigative Agency":"Prosecutor-General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor-General\u0027s Office","Jurisdiction of Origin: Courts Involved":"Cairo Appeals Court","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Federal Prosecutors Office; Office of Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_Annex_final.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Swiss_Admin_PR_Feb_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Swiss_Asset_Frozen_Amount_Washingtonpost_May_2_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Funds_Located_NYT_Feb_18_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_Feb_16_2011_Amendement.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_vom2_Feb_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Trial_Postponed_to_December_BBC_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_Swiss_OAG_Release_Jan_31_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_Annex_final.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Swiss_Admin_PR_Feb_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Swiss_Asset_Frozen_Amount_Washingtonpost_May_2_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Funds_Located_NYT_Feb_18_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_Feb_16_2011_Amendement.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_vom2_Feb_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Trial_Postponed_to_December_BBC_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_Embezzlement_Verdict_NYTimes_May_21_2014_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_Annex_final.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Swiss_Admin_PR_Feb_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Swiss_Asset_Frozen_Amount_Washingtonpost_May_2_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Funds_Located_NYT_Feb_18_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_Feb_16_2011_Amendement.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_vom2_Feb_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Trial_Postponed_to_December_BBC_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_Swiss_Ordinance_Extend_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_Annex_final.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Swiss_Admin_PR_Feb_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Swiss_Asset_Frozen_Amount_Washingtonpost_May_2_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Funds_Located_NYT_Feb_18_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_Feb_16_2011_Amendement.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_vom2_Feb_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Trial_Postponed_to_December_BBC_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_Swiss_Pres_AFARIII_Speech_Nov_2014.pdf","Sources ":"\n\tSpeech by the President of the Swiss Confederation, Mr. Didier Burkhalter, at the Arab Forum on Asset Recovery (AFAR III), November 1, 2014, \u0022Progress and challenges of asset recovery: a shared effort and responsibility,\u0022 \u00a0at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=55048;\n\n\t\u00a0\n\n\tSwiss Office of Attorney General, \u0022Arab Spring: Swiss Attorney General to request legal assistance from Egypt,\u0022 January 31, 2014, at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=51874;\n\n\t\u00a0\n\n\tVerordnung uber Massnahmen gegen gewisse Personen aus der Arabischen Republik Agypten, vom 2. February 11, 2011 and revised on February 16, 2011, and accessed at official website of the Swiss Federal Confederation government website: http:\/\/www.admin.ch\/dokumentation\/gesetz\/00068\/index.html?lang=de\u0026unters... \u00a0\u0022Freezing of assets,\u0022 at https:\/\/www.eda.admin.ch\/eda\/en\/fdfa\/foreign-policy\/financial-centre-eco... (last accessed February 6, 2015)\n\n\t\u00a0\n\n\tFederal Department of Foreign Affairs Media Release, \u0022Federal Council orders freezing of any assets of Egypt\u0027s former President Hosni Mubarak in Switzerland,\u0022 February 11, 2011.\u00a0\n\n\t\u00a0\n\n\tSwiss Federal Department of Foreign Affairs, \u0022Swiss delegation of experts in Cairo,\u0022 May 11, 2011, accessed at http:\/\/www.eda.admin.ch\/eda\/en\/home\/recent\/media\/single.html?id=39108\n\n\t\u00a0\n\n\tDavid Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014, at http:\/\/www.nytimes.com\/2014\/05\/22\/world\/middleeast\/hosni-mubarak-trial.html\n\n\t\u00a0\n\n\tSwissinfo.ch, \u0022Federal Court rules in favour of Egypt,\u0022 May 10, 2012, at \u00a0http:\/\/www.swissinfo.ch\/eng\/politics\/foreign_affairs\/Federal_Court_rules... \u0022Swiss mulls restitution of Mubarak\u0027s funds to Egypt,\u0022 September 4, 2013, at http:\/\/www.swissinfo.ch\/eng\/politics\/Swiss_mull_restitution_of_Mubarak_f...\n"},{"Case ID":"ARW-81","Case Title (Name of Public Official or Entity Allegedly Involved)":"IBM \/ Banco de la Nacion Officials (Alfredo Adaco, Mario Dadone, Genaro Contartese, Hugo Gaggero)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Argentina","Position of Public Official(s) (yrs in office)":"Officials of State Owned Enterprise","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1994","Asset Recovery End":"2010, Ongoing","UNCAC Offenses Implicated":"Art.16, Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Settlement agreement by defendants ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"","Case Summary":"In June 1999, Switzerland returned $4.5 million in suspected bribe funds to Argentina.  (Source: Swiss Ministry of Foreign Affairs, September 30, 2009).  According to a 2010 report by the Argentina\u0027s Ministry of Justice Office of Anticorruption report, total of $18,286,683 were recovered in the related cases.  (Source: Republic of Argentina, Ministerio de Justicia, Seguridad y Derechos Humanos, Oficina anticorrupcion, \u0022Recupero de Activos en Casos de Corrupcion,\u0022 2010, at 37-38.)","Disposition of Criminal Case(s)":"According to a report by the Argentina\u0027s Ministry of Justice, the defendants in the case pleaded guilty. (Source: epublic of Argentina, Ministerio de Justicia, Seguridad y Derechos Humanos, Oficina anticorrupcion, \u0022Recupero de Activos en Casos de Corrupcion,\u0022 2010, at http:\/\/www.anticorrupcion.gov.ar\/documentos\/Recupero%20de%20Activos%20-%....)  For information on IBM\u0027s U.S. cases, please see Shearman \u0026 Sterling law firm\u0027s Foreign Corruption Practices Act database at http:\/\/fcpa.shearman.com\/index.php.","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Ministerio Publico Procuracion General de la Nacion","Jurisdiction of Origin: Courts Involved":"C\u00e1mara de Casaci\u00f3n penal.","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Switzerland_ACCA_2001.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Banco_Nacion_Status_Lanacion_Mar_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Transparency_Intl_Progress_Report_on_OECD_Convention_Enforcement_July2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Banco_Nacion_Argentina_Plea_Agreement\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/IBM_Banco_Nacion_Status_Lanacion_Mar_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Switzerland_ACCA_2001.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Banco_Nacion_Status_Lanacion_Mar_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Transparency_Intl_Progress_Report_on_OECD_Convention_Enforcement_July2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Banco_Nacion_Argentina_Plea_Agreement\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/IBM_Banco_Nacion_Argentina_Plea_Agreement.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Switzerland_ACCA_2001.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Banco_Nacion_Status_Lanacion_Mar_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Transparency_Intl_Progress_Report_on_OECD_Convention_Enforcement_July2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Banco_Nacion_Argentina_Plea_Agreement\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Transparency_Intl_Progress_Report_on_OECD_Convention_Enforcement_July2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Switzerland_ACCA_2001.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Banco_Nacion_Status_Lanacion_Mar_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Transparency_Intl_Progress_Report_on_OECD_Convention_Enforcement_July2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Banco_Nacion_Argentina_Plea_Agreement\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Recupero%20de%20Activos%20-%20form%20red.pdf","Sources ":"Swiss Ministry of Foreign Affairs, September 30, 2009; American Corporate Counsel Association, 2001 Annual Meeting report, \u0022605 Current Challenges to Complying with the Foreign Corrupt Practices Act,\u0022 at 18-19, last accessed on October 12, 2010 at http:\/\/www.acc.com\/vl\/public\/ProgramMaterial\/loader.cfm?csModule=securit... \u00a0Phone interview with Argentine Attorney (November 2010). \u00a0See also, La Nacion, \u0022Jueces y personajes que se repiten,\u0022 March 9, 2011, accessed at http:\/\/www.lanacion.com.ar\/1355847-jueces-y-personajes-que-se-repiten; Transparency International, Progress Report 2011, Enforcement of the OECD Anti-Bribery Convention, \u0022Argentina,\u0022 at 14-15, accessed at http:\/\/www.transparency.org\/publications\/publications\/conventions\/oecd_r... and plea agreement between government of Argentina and Banco de la Nacion defendants, accessed at http:\/\/www.mpf.gov.ar\/biblioteca\/newsletter\/n176\/ibm-acta-acuerdo-defini... Republic of Argentina, Ministerio de Justicia, Seguridad y Derechos Humanos, Oficina anticorrupcion, \u0022Recupero de Activos en Casos de Corrupcion,\u0022 2010, at http:\/\/www.anticorrupcion.gov.ar\/documentos\/Recupero%20de%20Activos%20-%....\n"},{"Case ID":"ARW-82","Case Title (Name of Public Official or Entity Allegedly Involved)":"IBM \/ Banco de la Nacion Officials (Alfredo Adaco, Mario Dadone, Genaro Contartese, Hugo Gaggero)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Argentina","Position of Public Official(s) (yrs in office)":"Officials of State Owned Enterprise","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"1997","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Other","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Unspecified (Commercial settlement)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"This case concerns the bribery paid in 1994 by IBM\u0027s Argentine subsidiary to Banco de la Nacion officials to secure a contract with the bank.  After litigation, IBM agreed to reimburse Banco de la Nacion $34 million in losses.  (Source: \u0022Argentina: IBM to Reimburse U.S. $34 mil to Banco Nacion,\u0022 South American Business Information, November 10, 1997, cited in Wlimer, Cutler and Pickering, \u0022Foreign Corrupt Practices Act Updates IBM Consents to Civil Penalty and SEC Cease and Desist Order Based on Argentine Bribe Scandal,\u0022 January 12, 2001.)  According to an Argentine attorney knowledgeable about the case, this is the first case in Argentina of a plea agreement in a criminal action involving public officials and corruption.   In 2009, the officials agreed to the plea deal, but once it was approved by the court, they appealed it as their final sentence, on statute of limitations grounds.  As of November 17, 2010, nearly 16 years after the bribery, the case was on appeal in the Argentine Supreme Court.","Disposition of Criminal Case(s)":"According to an Argentine attorney familiar with the case of Banco de la Nacion officials, as of November 2010, their appeal was pending before the Argentine Supreme Court. (Source: StAR researcher phone interview, November 2010).  For information on IBM\u0027s U.S. cases, please see Shearman \u0026 Sterling law firm\u0027s Foreign Corruption Practices Act database at http:\/\/fcpa.shearman.com\/index.php.","Jurisdiction of Origin: Investigative Agency":"Unspecified (Commercial settlement)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Ministerio Publico Procuracion General de la Nacion","Jurisdiction of Origin: Courts Involved":"C\u00e1mara de Casaci\u00f3n penal.","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Department of Justice, Securities and Exchange Commission","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Department of Justice, Securities and Exchange Commission","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Columbia","Documents":"","Sources ":"Securities and Exchange Commission v. International Business Machines Corp., 1:00-cv-030400 (D.D.C. Dec. 21, 2000), Case Digest at Shearman and Sterling FCPA Website, at http:\/\/fcpa.shearman.com\/?mode=form\u0026id=132; \nIn the Matter of International Business Machines Corp., Administrative Proceeding File No. 3-13097, Rel. No. 34-43761 (Dec. 21, 2000), posted at http:\/\/www.sec.gov\/litigation\/admin\/34-43761.htm; \nWilmer, Cutler \u0026 Pickering, \u0022Foreign Corrupt Practices Act Updates IBM Consents to Civil Penalty and SEC Cease and Desist Order Based on Argentine Bribe Scandal,\u0022 January 12, 2001, accessed at http:\/\/www.wilmerhale.com\/files\/Publication\/506aff4a-d418-4046-9dad-18c6... \nResearcher phone interview with Argentine attorney (November 2010).\n"},{"Case ID":"ARW-87","Case Title (Name of Public Official or Entity Allegedly Involved)":"Jean Claude \u0022Baby Doc\u0022 Duvalier (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Haiti","Position of Public Official(s) (yrs in office)":"President (1971-1986)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1986","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"International Mutual Assistance on Criminal Matters (ended January 2010)","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"On Appeal","Assets Frozen (USD)":"$6,556,090","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\n\t\tAccording to a Federal Administrative Court (FAC) press release, on September 23, 2013, the FAC ruled against Mr. Duvalier and co-complainants and upheld the freezing of their assets ordered by the Federal Council in 2002. In its decision of September 24, 2013, the FAC also upheld the asset forfeiture proceedings launched by the Federal Department of Finance (FDF) on behalf of the Swiss Confederation on April 29, 2011. \u00a0The press release stated, \u0022In its decision of 24 September 2013, the FAC confirmed that these asset forfeiture proceedings were valid because the assets in question had been obtained illicitly. Specifically, the FAC felt that Jean- Claude Duvalier and his entourage did not demonstrate that the increase in their assets had resulted from activities unrelated to their role as public officials. Moreover, the level of corruption of the Haitian state was notoriously high during the period in which they had held public office. It was therefore concluded that the conditions determining the illicit origin of the assets in question were met.\u0022 \u00a0These assets have been frozen since 2002. \u00a0Both decisions may be subject to appeal before the Federal Supreme Court, but barring an appeal, the way is now clear for the restitution procedure of these seized assets to be launched (Source: Federal Administrative Court press release, \u0022FAC confirms freezing and forfeiture of Duvalier assets\u0022, September 25, 2013; See also text of decision: \u0022Extrait de l\u0027arr\u00eat de la Cour III \u00a0dans la cause D\u00e9partement f\u00e9d\u00e9ral des finances contre Fondation Brouilly, Jean-Claude Duvalier, hoirie de feue Simone Ovide Duvalier, compos\u00e9e de Jean-Claude Duvalier, Nicole Duvalier, Marie-Denise Duvalier et Simone Duvalier, et Mich\u00e8le Benett-Duvalier C\u20122528\/2011 du 24 septembre 2013,\u0022 BVGE 2013\/40).\u00a0\n\n\t\t\u00a0\n\n\t\tAccording to the Swiss Federal Department of Foreign Affairs, the funds were frozen by a 2010 Federal Council decision of, which followed the January 2010 \u00a0judgment by the Federal Court \u0022which put an end to the mutual legal assistance between Haiti and Switzerland, this freezing order has avoided a return of the assets to the Duvalier family. The freezing remained in force until the entry into force of the Act on the Restitution of Illicit Asset (LRAI). This law was accepted by Parliament in the autumn session 2010 and is entered into force on 1 February 2011. The Duvalier assets have then been frozen on the basis of article 14 RIAA. The Confederation took legal action before the Federal Administrative Court to enable frozen assets to be forfeited in April 2011, further to the decision of the Federal Council to ask the Federal Department of Finance (FDF) to initiate proceedings for the forfeiture of the Duvalier funds frozen in Switzerland. (Source: Swiss Federal Department of Foreign Affairs, \u0022Illicit assets of politically exposed persons (PEPs),\u0022 last modification March 20, 2012, at http:\/\/www.eda.admin.ch\/eda\/en\/home\/topics\/finec\/intcr\/poexp.html.)\u00a0\n\n\u00a0","Disposition of Criminal Case(s)":"\n\tOn October 4, 2014, Mr. Duvalier passed away. Prior to his death, the charges against him in Haiti had been voided on grounds of expiration of statute of limitations. \u00a0(Source: The Economist, \u0022Obituary: Baby Doc Duvalier,\u0022 October 11, 2014). \u00a0On January18, 2013, Haitian prosecutors charged Mr. Duvalier with corruption and embezzlement, and he was taken into police custody (Source: \u00a0New York Times, Jean-Cluade Duvalier, accessed at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/d\/jeanclaude_...) \u00a0According to an Amnesty International press release, after three failures to appear to court hearings, the latest on February 21, 2013, \u00a0the Court of Appeal had asked the Public Prosecutor to issue a warrant ordering the former president to appear before the court on February 28, 2013. \u00a0Mr. Duvalier had appeared in court on February 28, 2013 and entered a plea of not guilty. (Sources: Amnesty International press release, \u0022Haiti: Jean-Claude Duvalier\u2019s presence in Court brings hope to victims,\u0022 \u00a0March 1, 2013 accessed at http:\/\/www.amnesty.org\/en\/news\/haiti-jean-claude-duvalier-s-presence-cou... NBCnews.com, \u0022Ex-Haiti dictator \u0027Baby Doc\u0027 Duvalier faces corruption charges for first time since revolt,\u0022 February 28, 2013, accessed at \u00a0http:\/\/worldnews.nbcnews.com\/_news\/2013\/02\/28\/17136615-ex-haiti-dictator....\n\n\t\u00a0\n\n\tAccording to an April 2011 report by Human Rights Watch, criminal proceedings had been instituted in Haiti against Mr. Duvalier on charges of financial crimes, after he left Haiti in 1986. \u00a0These pending proceedings were reinstituted when Mr. Duvalier returned to Haiti in January 2011. \u00a0(Source: \u00a0Haiti\u0027s Rendezvous with History, \u0022The proceedings against Duvalier,\u0022 Human Rights Watch, April 14, 2011, accessed at http:\/\/www.hrw.org\/en\/node\/97889\/section\/4.)","Jurisdiction of Origin: Investigative Agency":"Investigating Judge (Juge d\u0027instruction)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"State Prosecutor (Commissaire du gouvernement) ","Jurisdiction of Origin: Courts Involved":"Unknown","Jurisdiction of Asset Recovery: Investigative Agency":"Le juge d\u0027instruction du canton de Geneve","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Office federal de la justice; Monfrini Crettol \u0026 Partners (Attorneys Enrico Monfrini and Yves Klein)","Jurisdiction of Asset Recovery: Courts Involved":"Chambre d\u0027accusation genevoise; Tribunal federal, Federal Administration Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Haiti_Charges_Filed_HRW_Apr_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_136 IV 4_Jan_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_Fed_Ct_Decision_Jan_2010_ICAR.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_Return_Illicit_Assets_Act.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_UN_News_Feb_13_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Duvalier_Swiss_Fed_Admin_Court_PR_25_Sep_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Haiti_Charges_Filed_HRW_Apr_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_136 IV 4_Jan_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_Fed_Ct_Decision_Jan_2010_ICAR.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_Return_Illicit_Assets_Act.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_UN_News_Feb_13_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Duvalier_Swiss_Fed_Admin_Court_Decision_Sept_2013_40.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Haiti_Charges_Filed_HRW_Apr_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_136 IV 4_Jan_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_Fed_Ct_Decision_Jan_2010_ICAR.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_Return_Illicit_Assets_Act.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_UN_News_Feb_13_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Duvalier_Obituary_Economist_Oct_11_2014.pdf","Sources ":"\n\n\t\tSwiss Federal Administrative Court Press Release, \u0022FAC confirms freezing and confiscation of Duvalier assets,\u0022 September 25, 2013; Swiss Federal Department Foreign Affairs, \u00a0\u0022Illicit assets of politically exposed persons (PEPs)\u0022;\u00a0\n\n\t\t\u00a0\n\n\t\tSwiss Federal Administrative Court, \u0022Extrait de l\u0027arr\u00eat de la Cour III \u00a0dans la cause D\u00e9partement f\u00e9d\u00e9ral des finances contre Fondation Brouilly, Jean-Claude Duvalier, hoirie de feue Simone Ovide Duvalier, compos\u00e9e de Jean-Claude Duvalier, Nicole Duvalier, Marie-Denise Duvalier et Simone Duvalier, et Mich\u00e8le Benett-Duvalier C\u20122528\/2011 du 24 septembre 2013,\u0022 BVGE 2013\/40, at http:\/\/www.bvger.ch\/?lang=en;\u00a0\n\n\t\t\u00a0\n\n\t\tSwiss federal court decision 136 IV 4 (January 12, 2010), accessed at http:\/\/www.bger.ch\/index\/juridiction\/jurisdiction-inherit-template\/juris... \u00a0\n\n\t\t\u00a0\n\n\t\tText of the Swiss \u0022Return of Illicit Assets Act,\u0022 accessed at website of the Swiss Federal Deapartment of Foreign Affairs, http:\/\/www.eda.admin.ch\/etc\/medialib\/downloads\/edazen\/topics\/finec\/intcr... \u00a0\n\n\t\t\u00a0\n\n\t\tHaiti\u0027s Rendezvous with History, \u0022The proceedings against Duvalier,\u0022 Human Rights Watch, April 14, 2011, accessed at http:\/\/www.hrw.org\/en\/node\/97889\/section\/4;\n\n\t\t\u00a0\n\n\t\tThe Economist, \u0022Obituary: Baby Doc Duvalier,\u0022 October 11, 2014, at http:\/\/www.economist.com\/news\/obituary\/21623568-jean-claude-baby-doc-duv...\n\n\u00a0\n"},{"Case ID":"ARW-88","Case Title (Name of Public Official or Entity Allegedly Involved)":"Jean Claude \u0022Baby Doc\u0022 Duvalier (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Haiti","Position of Public Official(s) (yrs in office)":"President (1971-1986)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Location of Recovery Effort","Asset Recovery Start":"1988","Asset Recovery End":"1990","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"A United Kingdom court granted a worldwide Mareva freezing order even though, as it noted, the Duvaliers were not in England and there was no evidence that they had assets in the UK.  However, the Court pointed out that the Duvaliers had used English solicitors in connection with dealings with the assets and all of the documentary evidence in relation to such dealings was therefore located in England which was adjudged a sufficient connection with England.  (Source: New Law Journal, \u0022Disarming litigation\r\nterrorists John Fordham explains how devastating freezing injunctions can be,\u0022 May 9, 2008 [Discussion of Republic of Haiti v Duvalier [1990] 1 QB 202, [1989] 1 All ER 456], accessed at http:\/\/www.venezlon.co.uk\/old\/pdf\/disarming_litigation.pdf; Republic of Haiti v Duvalier [1990] 1 QB 202, [1989] 1 All ER 456.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$0","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"On October 4, 2014, Mr. Duvalier passed away. Prior to his death, the charges against him in Haiti had been voided on grounds of expiration of statute of limitations. (Source: The Economist, \u0022Obituary: Baby Doc Duvalier,\u0022 October 11, 2014). On January18, 2013, Haitian prosecutors\u00a0charged Mr. Duvalier with corruption and embezzlement, and he was taken into police custody (Source: \u00a0New York Times,\u00a0Jean-Cluade Duvalier, accessed at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/d\/jeanclaude_...)\u00a0\u00a0According to an Amnesty International press release, after three failures to appear to court hearings, the latest on February 21, 2013, \u00a0the Court of Appeal asked the Public Prosecutor to\u00a0issue a warrant ordering the former president to appear before the court on February 28, 2013.\u00a0\u00a0Mr. Duvalier appeared in court on February 28, 2013 and entered a plea of not guilty. (Sources: Amnesty International press release, \u0022Haiti: Jean-Claude Duvalier\u2019s presence in Court brings hope to victims,\u0022 \u00a0March 1, 2013 accessed at http:\/\/www.amnesty.org\/en\/news\/haiti-jean-claude-duvalier-s-presence-cou... NBCnews.com, \u0022Ex-Haiti dictator \u0027Baby Doc\u0027 Duvalier faces corruption charges for first time since revolt,\u0022 February 28, 2013, accessed at \u00a0http:\/\/worldnews.nbcnews.com\/_news\/2013\/02\/28\/17136615-ex-haiti-dictator.... According to an April 2011 report by Human Rights Watch, criminal proceedings had been instituted in Haiti against Mr. Duvalier on charges of financial crimes, after he left Haiti in 1986. These pending proceedings were reinstituted when Mr. Duvalier returned to Haiti in January 2011. (Source: Haiti\u0027s Rendezvous with History, \u0022The proceedings against Duvalier,\u0022 Human Rights Watch, April 14, 2011, accessed at http:\/\/www.hrw.org\/en\/node\/97889\/section\/4.)","Disposition of Criminal Case(s)":"On January 18, 2013, Haitian prosecutors\u00a0charged Mr. Duvalier with corruption and embezzlement, and he was taken into police custody (Source: \u00a0New York Times,\u00a0Jean-Cluade Duvalier, accessed at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/d\/jeanclaude_...)\u00a0\u00a0According to an Amnesty International press release, after three failures to appear to court hearings, the latest on February 21, 2013, \u00a0the Court of Appeal asked the Public Prosecutor to\u00a0issue a warrant ordering the former president to appear before the court on February 28, 2013.\u00a0\u00a0Mr. Duvalier appeared in court on February 28, 2013 and entered a plea of not guilty. (Sources: Amnesty International press release, \u0022Haiti: Jean-Claude Duvalier\u2019s presence in Court brings hope to victims,\u0022 \u00a0March 1, 2013 accessed at http:\/\/www.amnesty.org\/en\/news\/haiti-jean-claude-duvalier-s-presence-cou... NBCnews.com, \u0022Ex-Haiti dictator \u0027Baby Doc\u0027 Duvalier faces corruption charges for first time since revolt,\u0022 February 28, 2013, accessed at \u00a0http:\/\/worldnews.nbcnews.com\/_news\/2013\/02\/28\/17136615-ex-haiti-dictator.... The trial is still ongoing.\u00a0 According to an April 2011 report by Human Rights Watch, criminal proceedings had been instituted in Haiti against Mr. Duvalier on charges of financial crimes, after he left Haiti in 1986. These pending proceedings were reinstituted when Mr. Duvalier returned to Haiti in January 2011. (Source: Haiti\u0027s Rendezvous with History, \u0022The proceedings against Duvalier,\u0022 Human Rights Watch, April 14, 2011, accessed at http:\/\/www.hrw.org\/en\/node\/97889\/section\/4.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Watson, Farley \u0026 Williams; Slaughter \u0026 May","Jurisdiction of Asset Recovery: Courts Involved":"Queens Bench","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Haiti_Charges_Filed_HRW_Apr_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_UK_1_QB_202_[1990].pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_UK_Mareva_New_Law_Journal_May_9_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Duvalier_Obituary_Economist_Oct_11_2014_0.pdf","Sources ":"Republic of Haiti and others v Duvalier and others, [1990] 1 QB 202 (Obtained from the U.S. Library of Congress); See also New Law Journal, \u0022Disarming litigation terrorists John Fordham explains how devastating freezing injunctions can be,\u0022May 9, 2008 (Discussion of Republic of Haiti v Duvalier [1990] 1 QB 202, [1989] 1 All ER 456); Haiti\u0027s Rendezvous with History, \u0022The proceedings against Duvalier,\u0022 Human Rights Watch, April 14, 2011, accessed at http:\/\/www.hrw.org\/en\/node\/97889\/section\/4; The Economist, \u0022Obituary: Baby Doc Duvalier,\u0022 October 11, 2014, at http:\/\/www.economist.com\/news\/obituary\/21623568-jean-claude-baby-doc-duv...\n"},{"Case ID":"ARW-90","Case Title (Name of Public Official or Entity Allegedly Involved)":"John H. O\u0027Halloran","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Trinidad and Tobago","Position of Public Official(s) (yrs in office)":"People\u0027s National Movement official (1956-1970), Chairman of the Trinidad and Tobago Racing Authority (inclusive 1980-1981)","Jurisdiction of Asset Recovery":"Canada","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1983","Asset Recovery End":"1991","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Unspecified","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In 1985, Mr. O\u0027Halloran went to Canada, where he died.  The Republic of Trinidad and Tobago, Trinidad and Tobago (B.W.I.A. International) Airways Corporation, Trinidad-Tesoro Petroleum Company Limited and Trinidad and Tobago Racing Authority brought a civil suit in Toronto, Canada to recover damages from Mr. O\u0027Halloran\u0027s estate.  On June 3, 1991, the Ontario Court of Justice issued a judgment ordering Mr. O\u0027Halloran\u0027s estate to pay the sum of $7.65 million to the Government of Trinidad and Tobago, Trinidad and Tobago (B.W.I.A. International) Airways Corporation, and the Trinidad and Tobago Racing Authority, as well as all of the plaintiffs\u0027 court costs. (Source: Republic of Trinidad and Tobago, Trinidad and Tobago (B.W.I.A. International) Airways Corporation, Trinidad-Tesoro Petroleum Company Limited, and Trinidad and Tobago Racing Authority v. John Frederick Cameron, Litigation Administrator for the Estate of John H. O\u0027Halloran, et al, Court file No. 29841\/88, Ontario Court of Justice (General Division) Judgment of June 3, 1991.)","Disposition of Criminal Case(s)":"According to the summary by the University of West Indies Library of Mr. O\u0027Halloran\u0027s papers, in 1983, Mr. O\u0027Halloran was charged by the Government of Trinidad and Tobago.with accepting bribes.  (Source: The University of the West Indies at St. Augustine, Trinidad and Tobago, The Alma Jordan Library, Special Collections, \u0022O\u0027Halloran Papers,\u0022 accessed at   http:\/\/www.mainlib.uwi.tt\/divisions\/wi\/collsp\/summaries\/ohalloran.htm.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"N\/A","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"McMillan Binch, Barristers \u0026 Solicitors (Attorneys William G. Horton and Paul G. MacDonald)","Jurisdiction of Asset Recovery: Courts Involved":"Ontario Court of Justice (General Division)","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_Canada_Ontario_Judgment_Jun_3_1991.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/O%27Halloran_Wallace_Company_FCPA_Traceinternational_Compendium.pdf","Sources ":"Republic of Trinidad and Tobago, Trinidad and Tobago (B.W.I.A. International) Airways Corporation, Trinidad-Tesoro Petroleum Company Limited, and Trinidad and Tobago Racing Authority v. John Frederick Cameron, Litigation Administrator for the Estate of John H. O\u0027Halloran, et al, Court file No. 29841\/88, Ontario Court of Justice (General Division) Judgment of June 3, 1991, obtained with the assistance of Toronto Region Court Services Division, Ontario Ministry of the Attorney General.  \nSee also, US v. Rodriguez (Sam P. Wallace Co.), Case No. 83-0044 (D.P.R.), Information filed March 11, 1983.\n"},{"Case ID":"ARW-91","Case Title (Name of Public Official or Entity Allegedly Involved)":"John O\u0027Halloran\/ Tesoro Petroleum Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Trinidad and Tobago","Position of Public Official(s) (yrs in office)":"People\u0027s National Movement official (1956-1970), Chairman of the Trinidad and Tobago Racing Authority (inclusive 1980-1981)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1989","Asset Recovery End":"1990","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Unknown","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"In July 1990, then-Attorney General of Trinidad and Tobago Selwyn Richardson obtained a settlement from Tesoro Petroleum for some $7.5 million in connection with the company\u0027s bribery case. The law firm of Wilmer Cutler in Washington, DC was counsel to the government.   (Source: Trinidad and Tobago, House of Representatives Parliamentary Proceedings, July 27, 1990.)","Disposition of Criminal Case(s)":"According to the summary by the University of West Indies Library of Mr. O\u0027Halloran\u0027s papers, in 1983, Mr. O\u0027Halloran was charged by the Government of Trinidad and Tobago.with accepting bribes.  (Source: The University of the West Indies at St. Augustine, Trinidad and Tobago, The Alma Jordan Library, Special Collections, \u0022O\u0027Halloran Papers,\u0022 accessed at   http:\/\/www.mainlib.uwi.tt\/divisions\/wi\/collsp\/summaries\/ohalloran.htm.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Wilmer Cutler law firm","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_SDNY_Docket_Rpt_TT v Tesoro_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Trinidad_Parliament_Tesoro_Jul_27_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Company_FCPA_Traceinternational_Compendium.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Judgment.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_SEC_Complaint.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Trace_Intl_Summary.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/O%27Halloran_Wallace_Company_FCPA_Traceinternational_Compendium_1.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_SDNY_Docket_Rpt_TT v Tesoro_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Trinidad_Parliament_Tesoro_Jul_27_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Company_FCPA_Traceinternational_Compendium.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Judgment.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_SEC_Complaint.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Trace_Intl_Summary.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/O%27Halloran_US_SDNY_Docket_Rpt_TT%20v%20Tesoro_1990_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_SDNY_Docket_Rpt_TT v Tesoro_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Trinidad_Parliament_Tesoro_Jul_27_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Company_FCPA_Traceinternational_Compendium.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Judgment.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_SEC_Complaint.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Trace_Intl_Summary.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/O%27Halloran_US_Trinidad_Parliament_Tesoro_Jul_27_1990_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_SDNY_Docket_Rpt_TT v Tesoro_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Trinidad_Parliament_Tesoro_Jul_27_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Company_FCPA_Traceinternational_Compendium.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Judgment.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_SEC_Complaint.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Trace_Intl_Summary.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/O%27Halloran_US_Wallace_Judgment.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_SDNY_Docket_Rpt_TT v Tesoro_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Trinidad_Parliament_Tesoro_Jul_27_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Company_FCPA_Traceinternational_Compendium.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Judgment.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_SEC_Complaint.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Trace_Intl_Summary.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/O%27Halloran_US_Wallace_SEC_Complaint.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_SDNY_Docket_Rpt_TT v Tesoro_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Trinidad_Parliament_Tesoro_Jul_27_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Company_FCPA_Traceinternational_Compendium.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Judgment.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_SEC_Complaint.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Trace_Intl_Summary.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/O%27Halloran_US_Wallace_Trace_Intl_Summary.pdf","Sources ":"Trinidad and Tobago, House of Representatives Parliamentary Proceedings, July 27, 1990; The Republic of Trinidad and Tobago v. Tesoro Petroleum Corporation, et al, 1:89-civ-01663-LLS (S.D.N.Y.) (filed March 10, 1989; settled and closed June 29, 1990), case files not available through Pacer but cause of action was civil Racketeer Influenced and Corrupt Organizations Act. See also, US v. Rodriguez (Sam P. Wallace Co.), Case No. 83-0044 (D.P.R.), Information filed March 11, 1983, accessed at Trace International Compendium.\n"},{"Case ID":"ARW-94","Case Title (Name of Public Official or Entity Allegedly Involved)":"Joshua Dariye \/ Joyce Oyebanjo","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Governor (Dariye, 1999-2006) \/ Associate (Oyebanjo)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"2007","UNCAC Offenses Implicated":"Art.17, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"The UK\u0027s Foreign \u0026 Commonwealth Office stated that the \u0022The return of [Dariye\/Oyebanjo -related] assets fulfils the UK\u0027s commitments under Chapter V of the United Nations Convention Against Corruption and is the result of continued co-operation with the Nigerian authorities.\u0022  (Source: UK Foreign and Commonwealth Office Press Release, \u0022UK Returns Stolen Funds to Nigeria,\u0022 April 24, 2009.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to evidence presented to the United Kingdom Parliament\u0027s International Development Committee by the UK Department for International Development, GBP 115,000 in the Joshua Dariye case and GBP 185,000 in Mr. Dariye\u0027s associate Joyce Oyebanjo\u0027s case have been returned to Nigeria. (Source: UK Parliament, International Development Committee, \u0022Supplementary written evidence submitted by The Department for International Development (DFID),\u0022 June 2012.)  Ms. Oyebanjo had been arrested by the London Metropolitan Police in 2004 and subsequently convicted of assisting Chief Dariye to retain the benefits of criminal conduct contrary to section 93A(1)(a) of the Criminal Justice Act 1988. (Sources: Nigeria v. Dariye, Claim no. HC 07-C00169 filed January 25, 2007 in the UK High Court of Justice Chancery Division; UK Foreign and Commonwealth Office Press Release, \u0022UK Returns Stolen Funds to Nigeria,\u0022 April 24, 2009; Transparency International UK, \u0022Combating Money Laundering and Recovering Looted Gains: Raising the UK\u0027s Game,\u0022 Appendix 1: Summaries of Recent Criminal and Civil Cases against Politically Exposed Persons in the UK, June 2009.)","Disposition of Criminal Case(s)":"According to the website of Nigeria\u0027s Economic and Financial Crimes Commission, Mr. Dariye\u0027s trial in Nigeria was contined to October 2010. (Source: Economic \u0026 Financial Crimes Commission, \u0022EFCC On-Going High Profile Cases,\u0022 2007-2010, posted at http:\/\/www.efccnigeria.org\/index.php?option=com_docman\u0026task=doc_view\u0026gid...).  According to the January 25, 2007 Particulars of Claim filed by the Government of Nigeria in its UK civil claim against Mr. Dariye, on September 2, 2004, Mr. Dariye was arrested and interviewed by the Metropolitan Police in London.  After he failed to answer Police bail on December 14, 2004 and returned to Nigeria, a warrant was issued for his arrest on charges of money laundering and obtaining services by deception. (Source:  Nigeria v. Dariye, Claim No. HC07-00169, High Court of Justice (Chancery Division).","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Courts Involved":"FTC Hgh Court - Gudu","Jurisdiction of Asset Recovery: Investigative Agency":"Metropolitan Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service","Jurisdiction of Asset Recovery: Courts Involved":"Southwark Crown Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Dariye_UK_FCO_Return_Apr_24_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Dariye_UK_FRN v Dariye\u0026Dariye_Approved Judgment_Mar_12_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Dariye_UK_FRN_v_Dariye_and_Dariye_2007_EWHC_0169_Jan_25_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Transparency_Intl_UK_Recovering_Looted_Gains_June_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Dariye_UK_FRN%20v%20Dariye%26Dariye_Approved%20Judgment_Mar_12_2007.pdf","Sources ":"UK Parliament, International Development Committee, \u0022Supplementary written evidence submitted by The Department for International Development (DFID),\u0022 June 2012, accessed at http:\/\/www.publications.parliament.uk\/pa\/cm201213\/cmselect\/cmintdev\/130\/... UK Foreign and Commonwealth Office Press Release, \u0022UK Returns Stolen Funds to Nigeria,\u0022 April 24, 2009, accessed at http:\/\/ukinnigeria.fco.gov.uk\/en\/news\/?view=PressR\u0026id=17622693 10\/; Nigeria v. Joshua Chibi Dariye and Valentina Dariye, Claim No: HC 07 C00169, filed January 25, 2007 in the High Court of Justice, Chancery Division; Transparency International UK, \u0022Combating Money Laundering and Recovering Looted Gains: Raising the UK\u0027s Game,\u0022 Appendix 1: Summaries of Recent Criminal and Civil Cases against Politically Exposed Persons in the UK (June 2009).\n"},{"Case ID":"ARW-95","Case Title (Name of Public Official or Entity Allegedly Involved)":"Juthamas Siriwan (Jersey)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Thailand","Position of Public Official(s) (yrs in office)":"Governor of Tourism (2002-2006)","Jurisdiction of Asset Recovery":"Jersey","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution (US)","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case (in U.S.)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Unknown","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"\n\tAs of May 22, 2016, the US criminal case was ongoing. \u00a0( U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Court Docket Report as of May 22, 2016.)\n\n\t\u00a0\n\n\tIn January 2009, United States authorities filed a criminal indictment against Ms.Siriwan and her daughter on charges of violating the Foreign Corrupt Practices Act; their indictment includes criminal forfeiture allegations against bank accounts located in Isle of Jersey (HSBC Bank International Limited, Acct #11108670 in amount of $411,434.80; Singapore (Citibank Bank, Acct #0259766-001 in the amount of $543,456.79 and Standard Chartered Bank, Acct #25-0-852573-6); United Kingdom (HSBC Bank PLC, Acct #22751518). \u00a0The indictment also noted that under Section 152 of Thailand\u0027s Penal Code, it is unlawful for any government official, having the duty of managing or looking after any activity, to take the interest for the benefit of herself or another person concerning such activity. (Source: U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Indictment filed January 28, 2009.) \u00a0According to Ms. Siriwan\u0027s Court Docket Report, on April 7, 2011, the U.S. District Court for the Central District granted the U.S. Government\u0027s ex-parte application seeking the extradition of Ms. Siriwan and her daughter\/co-defendant. \u00a0(Source: US v. Siriwan, 2:09-cr-00081 (C.D. Cal.), Court Docket Report.) \u00a0","Disposition of Criminal Case(s)":"\nAccording to the Joint Status Report and Indictment filed by Thai Special Prosecutor (Exh A in Thai and Exh B in English translation), Ms. Siriwan has been charged with violations of Thai laws pertaining to conduct of Thai officials and the Criminal Code pertaining to acceptance of bribery. The US criminal case against Ms. Siriwan is ongoing as of May 22, 2016. (Source: US v. Siriwan, Case No. 2:09-cr-81 (C.D. Cal), Joint Status Report of the Parties filed on October 13, 2015 and Exhibits A and B; Court Docket Report as of May 22, 2016.)\n\n\u00a0","Jurisdiction of Origin: Investigative Agency":"National Anti-Corruption Commission of Thailand; Attorney General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Special Prosecutor Office, Special Case Department 2","Jurisdiction of Origin: Courts Involved":"Criminal Court","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_USG_Supplemental_Resp_Jan_11_2013_1.pdf","Sources ":"U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), \u00a0Indictment filed January 28, 2009; \u00a0Joint Stipulation to Continue Hearing Date; and Order filed October 17, 2011; Government\u0027s Third Supplemental Brief in Opposition to Defendant\u0027s Motion to Dismiss and Exhibit A, filed January 11, 2013; Status Report by US and Exhibit A (Letter by Thailand\u0027s Office of the National Anti-Corruption Commission) filed March 10, 2014; Joint Status Report of the Parties and Exhibits A and B,filed October 13, 2015 and Court Docket Report as of May 22, 2016.)\n"},{"Case ID":"ARW-96","Case Title (Name of Public Official or Entity Allegedly Involved)":"Juthamas Siriwan (Singapore)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Thailand","Position of Public Official(s) (yrs in office)":"Governor of Tourism (2002-2006)","Jurisdiction of Asset Recovery":"Singapore","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture (US)","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case ","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Unknown","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tAs of May 22, 2016, the US criminal case was ongoing. \u00a0( U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Court Docket Report as of May 22, 2016.)\n\n\t\u00a0\n\n\tIn January 2009, United States authorities filed a criminal indictment against Ms.Siriwan and her daughter on charges of violating the Foreign Corrupt Practices Act; their indictment includes criminal forfeiture allegations against bank accounts located in Isle of Jersey (HSBC Bank International Limited, Acct #11108670 in amount of $411,434.80; Singapore (Citibank Bank, Acct #0259766-001 in the amount of $543,456.79 and Standard Chartered Bank, Acct #25-0-852573-6); United Kingdom (HSBC Bank PLC, Acct #22751518). \u00a0The indictment also noted that under Section 152 of Thailand\u0027s Penal Code, it is unlawful for any government official, having the duty of managing or looking after any activity, to take the interest for the benefit of herself or another person concerning such activity. (Source: U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Indictment filed January 28, 2009.)\u00a0\n\n\t\u00a0","Disposition of Criminal Case(s)":"According to the Joint Status Report and Indictment filed by Thai Special Prosecutor (Exh A in Thai and Exh B in English translation), Ms. Siriwan has been charged with violations of Thai laws pertaining to conduct of Thai officials and the Criminal Code pertaining to acceptance of bribery. The US criminal case against Ms. Siriwan is ongoing as of May 22, 2016. (Source: US v. Siriwan, Case No. 2:09-cr-81 (C.D. Cal), Joint Status Report of the Parties filed on October 13, 2015 and Exhibits A and B; Court Docket Report as of May 22, 2016.)","Jurisdiction of Origin: Investigative Agency":"National Anti-Corruption Commission of Thailand; Attorney General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Special Prosecutor Office, Special Case Department 2","Jurisdiction of Origin: Courts Involved":"Criminal Court","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_USG_Supplemental_Resp_Jan_11_2013_3.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_USG_Supp_Resp_Thai_Govt_Exhibit_A_Jan_11_2013_2.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_Status_Rept_Mar_10_2014_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_Status_Exhibit_A_Filed_Mar_10_2014_0.pdf","Sources ":"U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), \u00a0Indictment filed January 28, 2009; \u00a0Joint Stipulation to Continue Hearing Date; and Order filed October 17, 2011; Government\u0027s Third Supplemental Brief in Opposition to Defendant\u0027s Motion to Dismiss and Exhibit A, filed January 11, 2013; Status Report by US and Exhibit A (Letter by Thailand\u0027s Office of the National Anti-Corruption Commission) filed March 10, 2014; Joint Status Report of the Parties and Exhibits A and B,filed October 13, 2015 and Court Docket Report as of May 22, 2016.)\n"},{"Case ID":"ARW-97","Case Title (Name of Public Official or Entity Allegedly Involved)":"Juthamas Siriwan (Thailand)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Thailand","Position of Public Official(s) (yrs in office)":"Governor of Tourism (2002-2006)","Jurisdiction of Asset Recovery":"Thailand","Jurisdiction of Asset Description":"Undertaking Recovery Effort","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Ongoing Case   ","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\nAs of May 22, 2016, the US criminal case was ongoing. \u00a0( U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Court Docket Report as of May 22, 2016.)\n\n\n\tThe March 2014 letter by Thailand\u0027s Office of National Anti-Corruption Commission and December 14, 2012 letter (please see \u0022Disposition of Criminal Case\u0022) by the Thai Ministry of Foreign Affairs follow a March 2010 letter by Thailand\u0027s Office of the National Anti-Corruption Commission to the California court in the case of Gerald and Patricia Green (the convicted bribe givers) had stated that Thailand had initiated investigations into the alleged corrupt conduct of the former tourism government and other Thai nationals in the case. \u00a0(Sources: US v. Siriwan, Case No. 2:09-cr-81 (C.D. Cal), Status Report and Exhibit A filed March 10, 2014; U.S. v. Green, Case No. 2:08-cr-00059-GW (C.D. Cal.), Government\u0027s Supplemental Sentencing Memorandum for Defendants Gerald Green and Patricia Green and Exhibit E (Letter by the National Anti-Corruption Commission of Thailand regarding their investigation of the Juthamas Siriwan bribery case), both filed on March 12, 2010.) \u00a0","Disposition of Criminal Case(s)":"According to the Joint Status Report and Indictment filed by Thai Special Prosecutor (Exh A in Thai and Exh B in English translation), Ms. Siriwan has been charged with violations of Thai laws pertaining to conduct of Thai officials and the Criminal Code pertaining to acceptance of bribery. The US criminal case against Ms. Siriwan is ongoing as of May 22, 2016. (Source: US v. Siriwan, Case No. 2:09-cr-81 (C.D. Cal), Joint Status Report of the Parties filed on October 13, 2015 and Exhibits A and B; Court Docket Report as of May 22, 2016.)","Jurisdiction of Origin: Investigative Agency":"National Anti-Corruption Commission of Thailand; Attorney General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Special Prosecutor Office, Special Case Department 2","Jurisdiction of Origin: Courts Involved":"Criminal Court","Jurisdiction of Asset Recovery: Investigative Agency":"National Anti-Corruption Commission of Thailand","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Asset Recovery: Courts Involved":"Criminal Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_Thailand_NACC_Investig_Bangkok_Post_Aug_14_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_Thailand_NACC_Letter_Filed_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_Thailand_USG_Sentencing_Memo_Mar_12_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_USG_Supplemental_Resp_Jan_11_2013_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_Thailand_NACC_Investig_Bangkok_Post_Aug_14_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_Thailand_NACC_Letter_Filed_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_Thailand_USG_Sentencing_Memo_Mar_12_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_USG_Supp_Resp_Thai_Govt_Exhibit_A_Jan_11_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_Thailand_NACC_Investig_Bangkok_Post_Aug_14_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_Thailand_NACC_Letter_Filed_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_Thailand_USG_Sentencing_Memo_Mar_12_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_Status_Rept_Mar_10_2014_1.pdf","Sources ":"\n\n\t\tU.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), \u00a0Indictment filed January 28, 2009; \u00a0Joint Stipulation to Continue Hearing Date; and Order filed October 17, 2011; Government\u0027s Third Supplemental Brief in Opposition to Defendant\u0027s Motion to Dismiss and Exhibit A, filed January 11, 2013; Status Report by US and Exhibit A (Letter by Thailand\u0027s Office of the National Anti-Corruption Commission) filed March 10, 2014; Joint Status Report of the Parties and Exhibits A and B,filed October 13, 2015 and Court Docket Report as of May 22, 2016.)\n\n\t\tU.S. v. Green, Case No. 2:08-cr-00059-GW (C.D. Cal.), Government\u0027s Supplemental Sentencing Memorandum for Defendants Gerald Green and Patricia Green and Exhibit E (Letter by the National Anti-Corruption Commission of Thailand regarding their investigation of the Juthamas Siriwan bribery case), both filed on March 12, 2010.\n\n\t\t\u00a0\n\n\t\tSee also Bangkok Post, \u0022US wants Juthamas extradited,\u0022 August 4, 2012, at http:\/\/www.bangkokpost.com\/news\/local\/305892\/us-wants-juthamas-extradited\n\n\u00a0\n"},{"Case ID":"ARW-98","Case Title (Name of Public Official or Entity Allegedly Involved)":"Juthamas Siriwan (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Thailand","Position of Public Official(s) (yrs in office)":"Governor of Tourism (2002-2006)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2009","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.16, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture (U.S.)","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Unknown","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tAs of May 22, 2016, the US criminal case was ongoing. \u00a0( U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Court Docket Report as of May 22, 2016.)\u00a0\n\n\t\u00a0\n\n\tIn January 2009, United States authorities filed a criminal indictment against Ms. Siriwan and her daughter on charges of money laundering and transporting funds to support unlawful activity. The indictment included criminal forfeiture allegations against bank accounts located in Isle of Jersey (HSBC Bank International Limited, Acct #11108670 in amount of $411,434.80; Singapore (Citibank Bank, Acct #0259766-001 in the amount of $543,456.79 and Standard Chartered Bank, Acct #25-0-852573-6); United Kingdom (HSBC Bank PLC, Acct #22751518). \u00a0The indictment also noted that under Section 152 of Thailand\u0027s Penal Code, it is unlawful for any government official, having the duty of managing or looking after any activity, to take the interest for the benefit of herself or another person concerning such activity. (Source: U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Indictment filed January 28, 2009.) \u00a0Ms. Siriwan has filed a Motion to Dismiss the Indictment in January 2012. (Source: \u00a0U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Court Docket Report, entry for January 30, 2012.)\u00a0","Disposition of Criminal Case(s)":"According to the Joint Status Report and Indictment filed by Thai Special Prosecutor (Exh A in Thai and Exh B in English translation), Ms. Siriwan has been charged with violations of Thai laws pertaining to conduct of Thai officials and the Criminal Code pertaining to acceptance of bribery. The US criminal case against Ms. Siriwan is ongoing as of May 22, 2016. (Source: US v. Siriwan, Case No. 2:09-cr-81 (C.D. Cal), Joint Status Report of the Parties filed on October 13, 2015 and Exhibits A and B; Court Docket Report as of May 22, 2016.)","Jurisdiction of Origin: Investigative Agency":"National Anti-Corruption Commission of Thailand; Attorney General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Special Prosecutor Office, Special Case Department 2","Jurisdiction of Origin: Courts Involved":"Criminal Court","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"","Sources ":"\n\n\n\t\t\tU.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), \u00a0Indictment filed January 28, 2009; \u00a0Joint Stipulation to Continue Hearing Date; and Order filed October 17, 2011; Government\u0027s Third Supplemental Brief in Opposition to Defendant\u0027s Motion to Dismiss and Exhibit A, filed January 11, 2013; Status Report by US and Exhibit A (Letter by Thailand\u0027s Office of the National Anti-Corruption Commission) filed March 10, 2014; Joint Status Report of the Parties and Exhibits A and B,filed October 13, 2015 and Court Docket Report as of May 22, 2016.)\n\n\t\t\t\u00a0\n\n\t\t\tThe indictment can also be downloaded at the U.S. Department of Justice website: http:\/\/www.justice.gov\/criminal\/fraudsiriwan.html.\/fcpa\/cases\/.\n\n\t\t\t\u00a0\n\n\t\t\tSee also Bangkok Post, \u0022US wants Juthamas extradited,\u0022 August 4, 2012 "},{"Case ID":"ARW-162","Case Title (Name of Public Official or Entity Allegedly Involved)":"Samuel Gichuru \/ CB (Chris) Okemu","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kenya","Position of Public Official(s) (yrs in office)":"former Kenya Lighting and Power Company Chief Executive Officer, (Gichuru, 1984-2003; joined in 1974 as assistant company secretary) \/ Member of Parliament (Okemu)","Jurisdiction of Asset Recovery":"Jersey","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Criminal Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"Extradition Request by Jersey to Kenya","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"$34,343","Assets Adjudicated, Not Yet Returned (USD)":"$5,168,360","Assets Returned (USD)":"","Agreement for Returned Assets":"NA","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In February 2016, the Jersey Royal Court ordered the confiscation of amounts totalling US$9.8 million from the accounts of Windward Trading Limited. \u00a0The Court stated, \u0022The defendant company has pleaded guilty to four counts of money laundering offences involving a total of \u00a32,599,050 and US$2,971,743 respectively acquired or possessed by the defendant company between 29th July, 1999, and 19th October, 2001. The defendant company received and held the proceeds of criminal conduct perpetrated by its controlling mind and beneficial owner, Samuel Gichuru. The company knowingly enabled Gichuru to obtain substantial bribes paid to him while he held public office in Kenya. The company played a vital role without which corruption on a grand scale is impossible: money laundering.\u00a0\n2. Gichuru was the chief executive of Kenya\u2019s power utility, the Kenya Power \u0026 Lighting Company (\u201cKPLC\u201d) from November 1984 until February 2003. He accepted bribes from foreign businesses that contracted with that company during his term of office and hid them in Jersey.\u0022 The Court also stated that the confiscated assets totalling about $5.17 million \u0022will be transferred to the Criminal Offences Confiscation Fund with a view to their repatriation to Kenya, the victim of the offending.\u0022 (Source: Attorney General v. Windward Trading Limited, [2016] JRC 48A, February 24, 2016.)\u00a0\n\u00a0\nAccording to the April 25, 2008 Jersey Royal Court decision in an action between Samuel Gichuru and Walbrook Trustees (Jersey) Limited, et al (respondents) and Chief Officer of the States of Jersey Police (Party convened), Mr. Gichuru was the chief executive officer of the Kenya Lighting and Power Company, a majority state-owned entity. \u00a0 He stated that in Kenya public servants were not barred from running their own businesses until 2003 and he had wide-ranging commercial and business operations. \u00a0In 1981, Mr. Gichuru opened a bank account in Jersey. He also stated that the account was opened for the receipt of fees which he earned from business introductions and as a consultant. \u00a0In about 1986, he was advised by the Jersey office of Deloitte \u0026 Touche (forerunner to the respondents, \u0022Walbrook\u0022) that his needs would be better served by having a company. Accordingly in August 1986 Windward Trading Limited was incorporated in Jersey. Walbrook is the administrator of Windward and provides its directors and secretary. \u00a0Windward had bank accounts with HSBC Bank Plc and the Royal bank of Scotland International Limited, to which Walbrook provided signatories to the accounts. \u00a0The Court stated that Mr. Gichuru is the beneficial owner of Windward and the various Walbrook entities hold the shares as nominees for him. In May 2002, Walbrook filed a Suspicious Activity Report with the police and the police did not give consent to Walbrook making any payments and Walbrook refused to make any payments from Windward to Mr. Gichuru since then. \u00a0On August 21, 2003, a notice under the Investigation of Fraud (Jersey) Law 1990 was issued by the Attorney General demaning documents and information. In October 2003, Mr. Gichuru was informed that the Finnish authorities had sought information from the Jersey authorities about him and Windward. (Source: Between Samuel K. Gichuru and Walbrook, et al, 2008 JRC 068 (Jersey Royal Court, Samedi Division, April 25, 2008). \u00a0 August 17, 2011 post by the Kenyan Anti-Corruption Commission, \u0022Okemo and Gichuru are wanted in the Island of Jersey to face 53 charges over commissions paid by international and local companies for KPLC [Kenya Power and Lighting Company] business, mostly between 1999 and 2002, totaling 4,459,572 Sterling pounds, 786,853 Danish kronor and 3,207,360 US dollars (Kshs 902 million in total).\u0022 \u00a0Jersey is seeking their extradition from Kenya. \u00a0(Source: Kenyan Anti-Corruption Commission Current News 2011, posted August 17, 2011 (Carole Maina, \u0022KACC Told to Wait in Gichuru, Okemo Suit,\u0022 The Star, August 13, 2011). \u00a0See also, NTV Kenya coverage of August 2011 extradition proceedings at http:\/\/www.ntv.co.ke\/News\/Extradition+hearing\/-\/471778\/1213790\/-\/13oh4k7....)","Disposition of Criminal Case(s)":"According to an October 29, 2013 news article posted on the Kenyan Ethics and Anti Corruption Commission, it had commenced an investigation against Okemo and Gichuru. \u00a0(Source: \u0022 EACC Probes Okemo and Gichuru,\u0022 October 29, 2013.) \u00a0Windward Trading Limited - the account holder of the assets deemed to be proceeds of bribery payments received by Mr. Gichuru, entered a guilty plea in the Isle of Jersey to four counts of money laundering. The plea had been entered into by Zedra Trust Company Limited, which acquired the trust business of Barclays Wealth in January 2016 and as a result, provided two corporate directors to Windward Trading Limited. \u00a0(Source: Attorney General v. Windward Trading Limited, [2016] JRC 048A, February 24, 2016.)","Jurisdiction of Origin: Investigative Agency":"Kenyan Anti-Corruption Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions","Jurisdiction of Origin: Courts Involved":"High Court","Jurisdiction of Asset Recovery: Investigative Agency":"Attorney General\u0027s Office, Solicitor General","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General\u0027s Office, Solicitor General","Jurisdiction of Asset Recovery: Courts Involved":"Royal Court (Samedi Division)","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Jersey_Royal_Court_Walbrook_2008_JRC_068.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_KACC_Failed_Amnesty_Jul_29_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_KACC_Files_to_Join_Extradition_Suit_KAC_Whatsnew_Aug_10_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Okema_KACC_Post_KACC_told-to-wait_Aug_17_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Okema_NTV_Extradition_Hearing_Aug_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Gichuru_Okemo_EACC_Investigation_Commence_Oct_29_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Jersey_Royal_Court_Walbrook_2008_JRC_068.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_KACC_Failed_Amnesty_Jul_29_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_KACC_Files_to_Join_Extradition_Suit_KAC_Whatsnew_Aug_10_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Okema_KACC_Post_KACC_told-to-wait_Aug_17_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Okema_NTV_Extradition_Hearing_Aug_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Gichuru_KACC_Failed_Amnesty_Jul_29_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Jersey_Royal_Court_Walbrook_2008_JRC_068.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_KACC_Failed_Amnesty_Jul_29_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_KACC_Files_to_Join_Extradition_Suit_KAC_Whatsnew_Aug_10_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Okema_KACC_Post_KACC_told-to-wait_Aug_17_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Okema_NTV_Extradition_Hearing_Aug_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Gichuru_KACC_Files_to_Join_Extradition_Suit_KAC_Whatsnew_Aug_10_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Jersey_Royal_Court_Walbrook_2008_JRC_068.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_KACC_Failed_Amnesty_Jul_29_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_KACC_Files_to_Join_Extradition_Suit_KAC_Whatsnew_Aug_10_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Okema_KACC_Post_KACC_told-to-wait_Aug_17_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Okema_NTV_Extradition_Hearing_Aug_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Gichuru_Jersey_AG-v-Windward%20Trading%20Limited_2016_JRC_48A_24-Feb-2016.pdf","Sources ":"Attorney General v. Windward Trading Limited, [2016] JRC 48A, February 24, 2016, at https:\/\/www.jerseylaw.je\/judgments\/unreported\/Pages\/[2016]JRC048A.aspx;\n\u00a0\nKenya Ethics and Anti Corruption Commission, \u0022EACC Probes Okemo and Gichuru,\u0022 October 29, 2013,\u0022 at http:\/\/www.eacc.go.ke\/media.ASP?ID=501; Kenya Anti-Corruption Commission Press Release posted August 17, 2011 (Jillo Kadida, \u0022KACC files to join Okemo, Gichuru Extradition Suit,\u0022 The Star, August 10, 2011), accessed at http:\/\/www.kacc.go.ke\/pressreleases.ASP?ID=323;\u00a0\n\u00a0\nKenyan Ethics and Anti-Corruption Commission Current News 2011, posted August 17, 2011 (Carole Maina, \u0022KACC Told to Wait in Gichuru, Okemo Suit,\u0022 The Star, August 13, 2011), accessed at http:\/\/www.kacc.go.ke\/whatsnew.asp?id=324;\u00a0\n\u00a0\nKACC Current News - Year 2011, \u0022Amnesty to Avoid Prosecution,\u0022 etc. posted July 29, 2011, accessed at http:\/\/www.kacc.go.ke\/whatsnew.asp?id=307. \u00a0\n\u00a0\nSee also, NTV Kenya coverage of August 2011 extradition proceedings at http:\/\/www.ntv.co.ke\/News\/Extradition+hearing\/-\/471778\/1213790\/-\/13oh4k7...);\u00a0\n\u00a0\nBetween Samuel K. Gichuru and Walbrook, et al, 2008 JRC 068 (Jersey Royal Court, Samedi Division, April 25, 2008).\n"},{"Case ID":"ARW-170","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sanjaya Bahel \/ Nishan Kohli","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United Nations","Position of Public Official(s) (yrs in office)":"Chief of the Commodity Procurement Section, Procurement Division (1998-2003); Chief of the Commercial Activities Service in the UN Postal Administration (2003-2006): Bahel); Son of close friend of Bahel (Kohli)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2006","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16, Art.19","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution, Criminal Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"Cooperation by the United Nations Office of Investigative Oversight Services\/Procurement Task Force","Contributing Factors in Asset Recovery":"United Nations waiver of immunity of Mr. Bahel; cooperation in the investigation by the United Nations Office of Investigative Oversight Services\/Procurement Task Force (Sources:  United States v. Bahel, Docket No. 08-3327-cr (2nd Cir.), Judgment dated October 31, 2011; United States Attorney\u0027s Office for the Southern District of New York Press Release, \u0022United Nations Procurement Official Sentenced to 8 Years in Prison on Corruption Charges,\u0022 April 1, 2008.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$1,447,450.80","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the Press Release by the United States Attorney\u0027s Office for the Southern District of New York, on April 1, 2008, Mr. Bahel, \u0022former Chief of the Commodity Procurement Section within the Procurement Division of the United Nations (\u201cUN\u201d), was sentenced today in Manhattan federal court to 97 months in prison on his convictions for accepting hundreds of thousands of dollars\u2019 worth of benefits from a UN vendor in exchange for his assistance in awarding tens of millions of dollars\u2019 worth of UN contracts to the vendor.\u0022  (Source: United States Attorney\u0027s Office for the Southern District of New York Press Release, \u0022United Nations Procurement Official Sentenced to 8 Years in Prison on Corruption Charges,\u0022 April 1, 2008.)  Nishan Kohli was the son of a close friend of Mr. Bahel whose companies were involved in the corruption scheme.  As noted in the August 8, 2008 Stipulation and Order filed in US v. Nishan Kohli, on June 27, 2008, the US District Court ordered Mr. Bahel to pay restitution in the amount of $932,165.30 to the United Nations, of which $846,067.43 was to compensate the United Nations for the legal expenses that the UN incurred between February 2006 and June 2007, as a result of the US Government\u0027s investigation and prosecution of Mr. Bahel.  The UN also sought (and was granted) restitution from Mr. Kohli in the amount of $515,285.41, the amount the UN incurred between February 2006 and October 2006, prior to Mr. Kohli\u0027s cooperation with the US Government in its investigation and prosecution. (Source: US v. Nishan Kohli, Case No. 1:06-cr-00918-2-TPG (S.D.N.Y.), Stipulation and Order filed August 8, 2008 and Judgment in a Criminal Case filed August 26, 2008).","Disposition of Criminal Case(s)":"According to his Judgment in a Criminal Case, Mr. Bahel was convicted in 2008 following a jury trial, in the US District Court for the Southern District of New York, on six counts of fraud and bribery related charges.  (Source: US v. Sanjaya Bahel, Case No. 1:06-cr-00918-1TPG (S.D.N.Y.), Judgment in a Criminal Case filed June 30, 2008).  His conviction was upheld by the Second Circuit appeals court. (Source:  United States v. Bahel, Docket No. 08-3327-cr (2nd Cir.), Judgment dated October 31, 2011.)  According to his Judgment in a Criminal Case, Mr. Kohli pleaded guilty, in December 2006, to one count bribery concerning an organization receiving federal funds.  (Source: US v. Nishan Kohli, Case No. 1:06-cr-00918-2-TPG (S.D.N.Y.), Judgment in a Criminal Case filed August 26, 2008).","Jurisdiction of Origin: Investigative Agency":"United Nations Office of Investigative Oversight Services \/ Procurement Task Force","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation; United Nations Office of Investigative Oversight\r\nServices \/ Procurement Task Force","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney for the Southern District of New York","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the Southern District of New York","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bahel_SDNY_Docket_Report_Nov_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bahel_SDNY_Superseding_Indictment_Apr_11_2007.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bahel_SDNY_Judgment_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bahel_SDNY_Sentencing_Press_Release_Apr_1_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bahel_SDNY_Satisfaction_Judgement_Jul_18_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bahel_US_2nd_Circuit_Decision_Uphold_Conviction_Restitution_Oct_26_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kohli_SDNY_Judgment_Aug_26_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kohli_SDNY_Stipulation_Order_Restitution_Aug_8_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kohli_SDNY_Satisfaction_Judgement_Jun_8_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bahel_SDNY_Superseding_Indictment_Apr_11_2007.pdf","Sources ":"US v. Sanjaya Bahel, Case No. 1:06-cr-00918-1-TPG (S.D.N.Y.), Court Docket Report as of November 4, 2011; Superseding Indictment (S3) filed April 11, 2007; Judgment in a Criminal Case filed Judgment in a Criminal Case filed June 30, 2008; Satisfaction of Judgment filed July 18, 2011; United States v. Bahel, Docket No. 08-3327-cr (2nd Cir.), Judgment dated October 31, 2011. US v. Nishan Kohli, Case No. 1:06-cr-00918-2-TPG (S.D.N.Y.), Judgment in a Criminal Case filed August 26, 2008 and Stipulation and Order filed August 8, 2008; Satisfaction of Judgment filed June 8, 2009; United States Attorney\u0027s Office for the Southern District of New York Press Release, \u0022United Nations Procurement Official Sentenced to 8 Years in Prison on Corruption Charges,\u0022 April 1, 2008, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/April08\/bahelsentencingpr.pdf\n"},{"Case ID":"ARW-130","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (Austria)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"Austria","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"NA","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a March 1, 2011 statement by the National Bank of Austria, pursuant to European Union regulations, $1.2 billion in Libyan assets had been located and frozen in Austrian financial institutions; it was yet to be determined how much of those assets belonged to late-Mr. Qaddafi, his family and associates who fell under the EU sanctions regulations. (Source: Oesterreichische Nationalbank of Austria, Press Release \u0022\u00d6sterreich friert Verm\u00f6genswerte der Familie Gaddafi ein,\u0022 March 1, 2011.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"National Bank of Austria","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Oesterreichische Nationalbank of Austria, Press Release \u0022\u00d6sterreich friert Verm\u00f6genswerte der Familie Gaddafi ein,\u0022 March 1, 2011, accessed at http:\/\/www.oenb.at\/de\/presse_pub\/aussendungen\/2011\/2010q1\/pa_20110301_oe... New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_...\n"},{"Case ID":"ARW-129","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (Australia)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"Australia","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"United Nations Security Council Sanctions","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"$0","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"NA","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to Media Release by the Reserve Bank of Australia, on March 9, 2011, the Australian Government directed the Bank, \u0022to take steps under the Banking (Foreign Exchange) Regulations 1959 to implement autonomous targeted financial sanctions against certain key persons associated with the Qadhafi regime in Libya.\u0022  (Source: Reserve Bank of Australia Media Release No. 2011-05, \u0022Banking (Foreign Exchange) Regulations 1959 Sanctions Against Libya,\u0022 March 9, 2011.  On October 19, 2011, the Reserve Bank of Australia issued an updated Media List and \u0022Attachment A\u0022 sanctions list that included 35 persons and 12 entities.  (Sources: Reserve Bank of Australia Media Release No. 2011-23, \u0022Banking (Foreign Exchange) Regulations 1959 Sanctions Against Syria and Libya - Amendments to the Annexes,\u0022 October 19, 2011 and Attachment A.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Reserve Bank of Australia","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Reserve Bank of Australia Media Release No. 2011-23, \u0022Banking (Foreign Exchange) Regulations 1959 Sanctions Against Syria and Libya \u2013 Amendments to the Annexes,\u0022 October 19, 2011, accessed at http:\/\/www.rba.gov.au\/media-releases\/2011\/mr-11-23.html and Attachment A (Sanctions List), accessed at http:\/\/www.rba.gov.au\/media-releases\/2011\/mr-11-23-attach-a.html; Reserve Bank of Australia Media Release No. 2011-05, \u0022Banking (Foreign Exchange) Regulations 1959 Sanctions Against Libya,\u0022 March 9, 2011, accessed at http:\/\/www.rba.gov.au\/media-releases\/2011\/mr-11-05.html; New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_...\n"},{"Case ID":"ARW-131","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (Canada)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"Canada","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"United Nations Security Council sanctions","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a statement issued by the Canadian Foreign Minister, in September 2011, \u0022Canada has also secured from the United Nations Security Council\u0027s sanctions committee an exemption to unfreeze $2.2 billion worth of Libyan assets for humanitarian needs. \u0022These funds will help the Libyan people in the short and medium term; this money will help the new Libya get back on its feet.\u0022 (Source: Ministry of Foreign Affairs and International Trade, Statement by Minister Baird Updating Canada\u0027s Involvement in Libya, No. 262 - September 13, 2011, accessed at http:\/\/www.international.gc.ca\/media\/aff\/news-communiques\/2011\/262.aspx?....) \nAccording to the Press Release issued by the Canadian Prime Minister\u0027s Office, in September 2011, the Canadian government lifted Canada\u0027s unilteral sanctions that had been imposed on the Libyan government: \u0022These sanctions were passed under the Special Economic Measures Act and were in addition to the sanctions imposed by the United Nations in Security Council Resolutions 1970 and 1973. The sanctions imposed by the UN remain in effect until they are lifted by the United Nations Security Council.\u0022  (Source: Prime Minister of Canada Stephen Harper, Press Release, \u0022PM announces that Canada has lifted economic sanctions against Libya,\u0022 September 1, 2011, accessed at http:\/\/www.pm.gc.ca\/eng\/media.asp?category=1\u0026featureId=6\u0026pageId=26\u0026id=4315.)  The Prime Minister had announced the imposition of sanctions by Canada against the Qaddafi government, including asset freezes against Mr. Qaddafi and members of his family. (Source:  Government of Canada, \u0022Statement by the Prime Minister of Canada on Implementing Sanctions Against Libya,\u0022 February 27, 2011.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Qaddafi_Canada_Prime_Minister_Statement_Feb_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Qaddafi_NYT_Topic_Update_Oct_25_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Qaddafi_Canada_FA_Ministry_Statement_Sep_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Qaddafi_Canada_Prime_Minister_Statement_Feb_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Qaddafi_NYT_Topic_Update_Oct_25_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Qaddafi_Canada_PM_Lift_Sanctions_Sep_11_2011.pdf","Sources ":"Ministry of Foreign Affairs and International Trade, Statement by Minister Baird Updating Canada\u0027s Involvement in Libya, No. 262 - September 13, 2011, accessed at http:\/\/www.international.gc.ca\/media\/aff\/news-communiques\/2011\/262.aspx?... Prime Minister of Canada Stephen Harper, Press Release, \u0022PM announces that Canada has lifted economic sanctions against Libya,\u0022 September 1, 2011, accessed at http:\/\/www.pm.gc.ca\/eng\/media.asp?category=1\u0026featureId=6\u0026pageId=26\u0026id=4315; Government of Canada, \u0022Statement by the Prime Minister of Canada on Implementing Sanctions Against Libya,\u0022 Canada News Centre, February 27, 2011, accessed at http:\/\/news.gc.ca\/web\/article-eng.do?mthd=advSrch\u0026crtr.page=10\u0026nid=59286... New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_...\n"},{"Case ID":"ARW-132","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (European Union)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"European Union","Jurisdiction of Asset Description":"Undertaking Recovery Effort","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"United Nations Security Council sanctions","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the Official Journal of the European Union, on February 28, 2011, the European Union imposed sanctions and asset freezes against Mr. Qaddafi and related individuals and entities. The measure, European Council \u0022Decision 2011\/137\/CFSP concerning restrictive measures in view of the situation in Libya ( 1 ), implementing United Nations Security Council Resolution (UNSCR) 1970 (2011)\u0022 have subsequently been amended a number of times, including most recently on September 28, 2011.  (Sources: Official Journal of the European Union, \u0022COUNCIL REGULATION (EU) No 965\/2011 of 28 September 2011 amending Regulation (EU) No 204\/2011 concerning restrictive measures in view of the situation in Libya\u0022 and \u0022COUNCIL DECISION 2011\/137\/CFSP of 28 February 2011 concerning restrictive measures in view of the situation in Libya.\u0022)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Official Journal of the European Union, \u0022COUNCIL REGULATION (EU) No 965\/2011 of 28 September 2011 amending Regulation (EU) No 204\/2011 concerning restrictive measures in view of the situation in Libya,\u0022 accessed at http:\/\/eur-lex.europa.eu\/LexUriServ\/LexUriServ.do?uri=OJ:L:2011:253:0008... Official Journal of the European Union, \u0022COUNCIL DECISION 2011\/137\/CFSP of 28 February 2011 concerning restrictive measures in view of the situation in Libya,\u0022 accessed at http:\/\/eur-lex.europa.eu\/LexUriServ\/LexUriServ.do?uri=OJ:L:2011:058:0053... New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_...\n"},{"Case ID":"ARW-133","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (Germany)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"Germany","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"An article by the German Missions in the United States reported that at the September 2011 Libya Conference in Paris, Prime Minister Merkel stated \u0022Libyan assets blocked while Gaddafi was still in power are now to be unfrozen, among them one billion of the seven billion euros in Germany, which the United Nations has agreed to unfreeze, according to Merkel. These funds must now be used to rebuild the country.\u0022  (Source:  German Missions in the United States, \u0022Merkel Pledges Support at Libya Conference in Paris,\u0022 September 2, 2011.)  According to an article by Germany\u0027s Federal Foreign Office, pursuant to sanctions imposed by the European Union, Foreign Minister Westerwelle stated that \u0022Germany had acted swiftly to implement the sanctions. Libyan assets worth billions had been frozen in German banks.\u0022 (Source: Federal Foreign Office, \u0022Stepping up the pressure on the Libyan regime,\u0022 last updated March 14, 2011.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"German Missions in the United States, \u0022Merkel Pledges Support at Libya Conference in Paris,\u0022 September 2, 2011, accessed at http:\/\/www.germany.info\/Vertretung\/usa\/en\/__pr\/P__Wash\/2011\/09\/02__Libya... Federal Foreign Office, \u0022Stepping up the pressure on the Libyan regime,\u0022 last updated March 14, 2011, accessed at http:\/\/www.auswaertiges-amt.de\/EN\/Aussenpolitik\/Laender\/Aktuelle_Artikel... New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_...\n"},{"Case ID":"ARW-134","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (Sweden)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"Sweden","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a March 23, 2011 statement by Sweden\u0027s Finansinspektionen (Financial Supervisory Authority), pursuant to the European Union Sanctions Regulation concerning restrictive measures with regard to the situation in  Libya, Swedish financial institutions had reported to the Financial Authority that a total of more than 10 billion kronor had been frozen to date.  Citing confidentiality rules, the Financial Authority did not release additional information. (Source: Government of Sweded, Finansinpektionen, \u0022Frysta libyska tillg\u00e5ngar i Sverige,\u0022 March 23, 2011.)  According to the Wall Street Journal, Sweden froze nearly $1.6 billion in Libyan assets. (Source:  Wall Street Journal Corruption Currents Blog, \u0022Sweden Freezes Nearly $1.6 Billion In Libyan Assets,\u0022 March 23, 2011.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Government of Sweden Finansinspektionen, \u0022Frysta libyska tillg\u00e5ngar i Sverige,\u0022 March 23, 2011, accessed at http:\/\/www.fi.se\/Utredningar\/Skrivelser\/Listan\/Frysta-libyska-tillgangar... New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_... Wall Street Journal Corruption Currents Blog, \u0022Sweden Freezes Nearly $1.6 Billion In Libyan Assets,\u0022 March 23, 2011, accessed at http:\/\/blogs.wsj.com\/corruption-currents\/2011\/03\/23\/sweden-freezes-nearl...\n"},{"Case ID":"ARW-135","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tAccording to the Swiss Federal Department on Foreign Affairs, \u0022On February 21, the Federal Council decided with immediate effect to block any assets in Switzerland of Moammar Gaddafi and those who are closely associated to him. The Ordinance was established on the basis of Article 184, par. 3 of the Swiss Constitution. \u00a0On March 30, the Federal Council adopted a new ordinance to replace that which had been issued on 21 February. Emerging against the backdrop of the implementation of the financial sanctions decided by the UN Security Council with regard to Libya, this new ordinance is no longer based on Article 184, para. 3 of the Swiss Constitution, but rather on Art. 2 of the 22 March 2002 Federal Act on the Implementation of International Sanctions (Embargo Act).\u0022 (Source: Swiss Federal Department of Foreign Affairs, \u0022Freeze on assets,\u0022 last modification July 14, 2011, accessed at http:\/\/www.eda.admin.ch\/eda\/en\/home\/topics\/finec\/intcr\/poexp\/sperr.html - which provides links to relevant Swiss government media releases and ordinances.) \u00a0On May 2, 2011, the Washington Post reported that \u0022Financial regulators in Switzerland had identified in Swiss banks assets worth almost $416 million that may belong to the embattled Libyan leader or the government [ \u00a0] The announcement was made by Swiss President and Foreign Minister Micheline Calmy-Rey at a diplomatic meeting in the Tunisian capital Tunis and confirmed for the Washington Post by a Swiss foreign ministry spokesman.\u0022 (Source: James V. Grimaldi, \u0022Gaddafi, other leaders had almost $1 billion in Swiss banks,\u0022 Washington Post, May 6, 2011.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Swiss Federal Department of Foreign Affairs, \u0022Freeze on assets,\u0022 last modification July 14, 2011, accessed at http:\/\/www.eda.admin.ch\/eda\/en\/home\/topics\/finec\/intcr\/poexp\/sperr.html (provides links to relevant Swiss government media releases and ordinances); State Secretariat for Economic Affairs, Measures against Libya, at http:\/\/www.seco.admin.ch\/themen\/00513\/00620\/00622\/04634\/index.html?lang=fr New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_... James V. Grimaldi, \u0022Gaddafi, other leaders had almost $1 billion in Swiss banks,\u0022 Washington Post, May 2, 2011, accessed at http:\/\/www.washingtonpost.com\/world\/middle-east\/gaddafi-other-leaders-ha...\n"},{"Case ID":"ARW-136","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Other (International Sanctions); Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Completed (in part) and Ongoing (in part)","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the UK Foreign and Commonwealth Office, \u0022The Government has today taken action to freeze the assets of Colonel Muammar Abu Minyar al Qadhafi, members of his family and those acting on their behalf or at their direction.  The individuals subject to an asset freeze are: Colonel Muammar Abu Minyar al-Qadhafi, Aisha Muammar Qadhafi (daughter), Hannibal Muammar Qadhafi (son), Khamis Muammar Qadhafi (son). Mutassim Qadhafi (son) and Saif al-Islam Qadhafi (son).\u0022  (Source: UK Foreign and Commonwealth Office, \u0022Libya update: Political action taken by UK government,\u0022 February 27, 2011.) According to the United Kingdom\u0027s Foreign and Commonwealth Office, \u0022In response to specific requests and with UN agreement, the UK has also made available Libyan assets frozen under the UN sanctions regime.  1.86 billion Libyan dinar bank notes that were printed in the UK before the current crisis have been delivered to Libya to help the Libyan population meet their basic needs.\u0022 (Source: UK Foreign and Commonwealth Office,\u0022Libya,\u0022 accessed on October 31, 2011, at http:\/\/www.fco.gov.uk\/en\/global-issues\/mena\/libya\/.)  On August 26, 2011, the Guardian reported that the UK was seeking to unfreeze some of the GBP 12 billion frozen in the UK.  (Source: Jo Adetunji, \u0022Libyan assets to be unfrozen, including \u00a31bn worth of dinar banknotes, British diplomats seek to unblock \u00a312bn worth of assets held in UK, including notes printed for Gaddafi regime,\u0022 the Guardian, August 26, 2011.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Chancellor of the Exchequer; Department for  Business, Innovation and Skills (export controls)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"UK Foreign and Commonwealth Office, \u0022Libya update: Political action taken by UK government,\u0022 February 27, 2011 and copy of Order, accessed at http:\/\/www.fco.gov.uk\/en\/news\/latest-news\/?view=News\u0026id=557710282; UK Foreign and Commonwealth Office,\u0022Libya,\u0022 accessed on October 31, 2011, at http:\/\/www.fco.gov.uk\/en\/global-issues\/mena\/libya\/; Jo Adetunji, \u0022Libyan assets to be unfrozen, including \u00a31bn worth of dinar banknotes, British diplomats seek to unblock \u00a312bn worth of assets held in UK, including notes printed for Gaddafi regime,\u0022 the Guardian, August 26, 2011, accessed at http:\/\/www.guardian.co.uk\/world\/2011\/aug\/26\/libyan-assets-banknotes-free... New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_...\n"},{"Case ID":"ARW-140","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) - World Health Organization Recovery case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"Netherlands","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"United Nations Security Council sanctions","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Approval of the UN Sanctions Committee to unfreeze funds and provide to the World Health Organization (Source: The Netherlands, Ministry of Foreign Affairs, \u0022Netherlands unfreezes Libyan assets for medical supplies,\u0022 August 15, 2011.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Other","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"The UN Sanctions Committee approved the transfer of funds to the United Nations World Health Organization, for medical supplies to people in Benghazi and other areas of fighting","Case Summary":"According to a news release by The Netherlands\u0027 Ministry of Foreign Affairs, \u0022The Netherlands is freeing up \u20ac100 million of the Libyan regime\u2019s assets that are frozen in the Netherlands at the urgent request of the World Health Organization. The WHO will use the funds to distribute medical supplies, of which there is currently an acute shortage in Libya, among the Libyan population.  The Netherlands can release the money to the WHO because the UN sanctions committee has given its approval. The medical supplies will go to people in Benghazi and other rebel-held areas, areas where there is fighting, and areas still controlled by the Gaddafi regime. The Netherlands is the first country to provide this kind of financial assistance to Libya\u2019s stricken healthcare sector.  Minister of Foreign Affairs Uri Rosenthal has described the unfreezing of the assets as a good example of how sanctions should work. \u2018I always say that sanctions should cut off the regime without hurting the population. That is exactly what is happening now, with Gaddafi\u2019s frozen funds being used to save Libyan lives,\u2019 he said.\u0022 (Source: The Netherlands, Ministry of Foreign Affairs, \u0022Netherlands unfreezes Libyan assets for medical supplies,\u0022 August 15, 2011.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"The Netherlands, Ministry of Foreign Affairs, \u0022Netherlands unfreezes Libyan assets for medical supplies,\u0022 August 15, 2011, accessed at http:\/\/www.minbuza.nl\/en\/news\/2011\/08\/netherlands-unfreezes-libyan-asset... New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_...\n"},{"Case ID":"ARW-139","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) - Netherlands Asset Return","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"Netherlands","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"United Nations Security Council sanctions","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Transitional Financial Mechanism set up by the International Contact Group for Libya. The mechanism has safeguards in place to ensure responsible spending.  The funds will go towards humanitarian needs, such as food and medicines, and education and salaries. (Source: The Netherlands Ministry of Foreign Affairs, \u0022The Netherlands unfreezes 2 billion dollars\u2019 worth of Libyan assets,\u0022 September 12, 2011.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"According to a news article by the Netherlands Ministry of Foreign Affairs, \u0022The money, which came from the Libyan Central Bank, will be made available to the National Transitional Council (NTC) through the Transitional Financial Mechanism set up by the International Contact Group for Libya. The mechanism has safeguards in place to ensure responsible spending.  The funds will go towards humanitarian needs, such as food and medicines, and education and salaries.\u0022 (Source: The Netherlands Ministry of Foreign Affairs, \u0022The Netherlands unfreezes 2 billion dollars\u2019 worth of Libyan assets,\u0022 September 12, 2011.)","Case Summary":"According to a news article by The Netherlands Ministry of Foreign Affairs, on September 12, 2011, the Netherlands agreed to unfreeze US $2 billion in Libyan assets that had previously been blocked by the Dutch government.  (Source: The Netherlands Ministry of Foreign Affairs, \u0022The Netherlands unfreezes 2 billion dollars\u2019 worth of Libyan assets,\u0022 September 12, 2011.)  In August 2011, the (UK) Telegraph reported that the Netherlands had frozen some EUR 3.1 billion in Libyan assets. (Source: The Telegraph, \u0022Libya: Netherlands gives \u00a387 million of frozen assets to WHO, August 16, 2011.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"The Netherlands Ministry of Foreign Affairs, \u0022The Netherlands unfreezes 2 billion dollars\u2019 worth of Libyan assets,\u0022 September 12, 2011, accessed at http:\/\/www.minbuza.nl\/en\/news\/2011\/09\/the-netherlands-unfreezes-2-billio... New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_... The Telegraph, \u0022Libya: Netherlands gives \u00a387 million of frozen assets to WHO, August 16, 2011, accessed at http:\/\/www.telegraph.co.uk\/news\/worldnews\/africaandindianocean\/libya\/870...\n"},{"Case ID":"ARW-138","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"United Nations Security Council Resolutions 1970 and 1973","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"United Nations Security Council Resolutions 1970 and 1973","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"","Case Summary":"According to the December 16, 2011 Fact Sheet by the US Department of Treasury, \u0022In conjunction with action taken at the United Nations (UN), the U.S. Department of the Treasury today issued General License No. 11, unblocking more than $30 billion in assets of the Government of Libya. [ ]  As of today\u2019s action, the only Libyan government assets still blocked under U.S. law are funds of the LIA and its subsidiaries, including the Libyan Africa Investment Portfolio (LAIP).  Both the LIA and the LAIP remain listed at the UN.  The property and interests in property of certain members of the Qadhafi family, certain senior members of the Qadhafi regime, and certain entities in which they have an interest also remain blocked.\u0022 (Source: US Department of the Treasury, \u0022Fact Sheet: Lifting Sanctions on the Government of Libya,\u0022 December 16, 2011.) \nOn February 25, 2011, President Barack Obama had issued an Executive Order entitled \u0022Blocking Property and Prohibiting Certain Transactions Related to Libya.\u0022  President Obama based the Executive Order under powers granted to him under the International Emergency Economic Powers Act and the National Emergencies Act.  The Executive Order applied to Mr. Muammar Qadhafi, members of his government, members of his family and close associates.  (Source: The White House, Executive Order, Blocking Property and Prohibiting Certain Transactions Related to Libya, February 25, 2011).","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Department of the Treasury","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Qaddafi_US_Asset_Freeze_Executive_Order_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Qaddafi_US_Treasury_Dept_Statement_Sep_1_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Qaddafi_NYT_Topic_Update_Oct_25_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Qaddafi_US_Treasury_Lift_Sanctions_Govt_Libya_Dec_16_2011.pdf","Sources ":"US Department of the Treasury, \u0022Fact Sheet: Lifting Sanctions on the Government of Libya,\u0022 December 16, 2011, accessed at http:\/\/www.treasury.gov\/press-center\/press-releases\/Pages\/tg1387.aspx; The White House, Executive Order, Blocking Property and Prohibiting Certain Transactions Related to Libya, February 25, 2011, accessed at http:\/\/www.treasury.gov\/resource-center\/sanctions\/Programs\/Documents\/201... New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_...\n"},{"Case ID":"ARW-15","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ananias Tumukunde","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Uganda","Position of Public Official(s) (yrs in office)":"Science and Technology Advisor to President (inclusive 2008)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"2012","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution, Criminal Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"NA","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"First conviction in overseas corporate corruption case by the City of London Police Overseas Anti-Corruption Unit since its establishment in June 2006. ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$55,000","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unknown","Case Summary":"According to the Norton Rose law firm Case Study cited in the July 13, 2011 United Kingdom\u0027s UNCAC Self-Assessment Report, Mr. Tumukunde made contact with Niels Tobiasen, the Managing Director of CBRN Team Ltd., a security specialist, regarding the procurement of training and security equipment for the Ugandan army in the run-up to the Commonwealth Heads of Government Meeting, held in Kampala in 2007.  CBRN Team Ltd. signed a contract with Mr. Tumukunde worth GBP 210,000 for the equipment, but Tobiasen reportedly agreed and made five \u0027local payments\u0027 totalling around GBP 83,000 to Tumukunde and a Ugandan army officer, Rusoke Tagaswire, between 2007 and 2008.  The purported agency payments in fact were inducements that went directly into two bank accounts opened by Tumukunde and Tagaswire in the UK. The London Police received information of Tumukunde\u0027s plans to travel to the UK and Tumukunde was arrested by Scotland Yard at Heathrow Airport. (Tobiasen later pleaded guilty to making corrupt payments to Tobiasen. Source: City of London Police Statement, \u0022Guilty plea to bribery sets legal landmark,\u0022 July 27, 2010.)  On September 22, 2008, Tumukunde pleaded guilty, before His Honour Judge Wadsworth in the Southwark Crown Court to accepting corrupt payments and was sentenced to 12 months\u0027 imprisonment; he also signed a disclaimer releasing the GBP 52,800 [US $96,681.60] from his bank account into the custody of the City of London Police for restitution.  (Source: Norton Rose (law firm), \u0022Case Study: CBRN Team Ltd (non-FCPA).\u0022)   Written evidence presented by the UK\u0027s Department for International Development (DFID) to the Parliament\u0027s International Development Committee stated that GBP35,000 has been returned in the case involving Mr. Tumukunde. (Source: UK Parliament, International Development Committee, \u0022Supplementary written evidence submitted by The Department for International Development (DFID),\u0022 June 2012.)","Disposition of Criminal Case(s)":"According to the United Kingdom\u0027s UNCAC Self-Assessment Report of  July 13, 2011, Mr. Tumukunde pleaded guilty and was sentenced on 22 September 2008 by the Southwark Crown Court to 12 months imprisonment for receiving corrupt payments in relation to a contract with a British company (CBRN Team Ltd) for training and equipment for the Ugandan Army.  The UK Report noted that \u0022(Although charges under the Public Bodies Corrupt Practices Act 1889 could have been used, it was decided to prosecute for money laundering offences).\u0022  (Source: UK Self-Assessment Report, at 24.)","Jurisdiction of Origin: Investigative Agency":"NA","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"City of London Police, Overseas Anti-Corruption Unit","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service","Jurisdiction of Asset Recovery: Courts Involved":"Southwark Crown Court","Documents":"","Sources ":"UK Parliament, International Development Committee, \u0022Supplementary written evidence submitted by The Department for International Development (DFID),\u0022 June 2012, accessed at http:\/\/www.publications.parliament.uk\/pa\/cm201213\/cmselect\/cmintdev\/130\/... United Nations Office on Drugs and Crime, \u0022United Nations Convention against Corruption, United Kingdom Self-Assessment for United Nations Convention against Corruption - Chapters III and IV,\u0022 July 13, 2011, accessed at  http:\/\/www.unodc.org\/documents\/treaties\/UNCAC\/SA-Report\/UK_UNCAC_4.11.20...  \nNorton Rose (law firm), \u0022Case Study: CBRN Team Ltd (non-FCPA),\u0022 accessed at http:\/\/www.nortonrose.com\/expertise\/business-ethics-and-anti-corruption\/... \nCity of London Police Statement, \u0022Guilty plea to bribery sets legal landmark,\u0022 July 27, 2010, accessed at  http:\/\/www.cityoflondon.police.uk\/CityPolice\/Departments\/ECD\/anticorrupt....  \nSee also Paul Lewis and Rob Evans, \u0022Ugandan is jailed in UK bribery crackdown,\u0022 The Guardian, September 23, 2008, accessed at http:\/\/www.guardian.co.uk\/uk\/2008\/sep\/23\/ukcrime.law\/print\n"},{"Case ID":"ARW-83","Case Title (Name of Public Official or Entity Allegedly Involved)":"Instituto Nacional de Seguros (INS) and Instituto Costarricense de Electricidad (ICE) \/ Julian Messent","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Costa Rica","Position of Public Official(s) (yrs in office)":"Officials at State-Owned Entities","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2006","Asset Recovery End":"2012","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution, Criminal Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"\u0022Following elections in Costa Rica in 2002, officials in INS and ICE were replaced. Enquiries were made into the contract with PWS and questions\r\nwere raised about payments made under it. The Foreign and Commonwealth Office referred the case to the SFO in October 2005 and the case was\r\naccepted for investigation in August 2006.\u0022  (Source: UK Serious Fraud Office Press Release, \u0022Insurance Broker jailed for bribing Costa Rican\r\nofficials,\u0022 October 26, 2010.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$157,399","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Please see summary field for explanation","Case Summary":"In upholding Mr. Messent;s sentece, the Court of Appeals stated that, \u0022The government of Costa Rica, and therefore the citizens of Costa Rica, were in effect made to pay for the corruption of their own officials by foreigners and therefore they suffered a loss of not far short of the original $2 million as a result of the appellant\u0027s [Mr. Messent\u0027s] corrupt behaviour.\u0022  (Source: Messent, R. v [2011] EWCA Crim 644 (01 March 2011))  The Court also stated that, \u0022in the context of the observations in the 2004 United Convention against Corruption, we remind ourselves that corruption \u0027undermines a government\u0027s ability to provide basic services\u0027.\u0022 (Source: Ibid.)\nAccording to the October 26, 2010 press release by the UK Serious Fraud Office, UK insurance broker Julian Messent was sentenced to imprisonment \u0022after admitting making or authorising corrupt payments of almost US $2 million to Costa Rican officials in the state insurance company, Instituto Nacional de Seguros (INS) and the national electricity and telecommunications provider Instituto Costarricense de Electricidad (ICE). He was ordered to pay \u00a3100,000 compensation within 28 days to the Republic of Costa Rica or serve an additional 12 months imprisonment if he fails to do so.  Following a joint investigation by the Serious Fraud Office and the City of London Police which opened in 2006, Julian Messent (d.o.b. 20\/02\/60), who was a director of London-based insurance business PWS International Ltd (\u0022PWS\u0022), pleaded guilty at Southwark Crown Court to two counts of making corrupt payments between February 1999 and June 2002, contrary to s1 (1) of the Prevention of Corruption Act 1906. The sentence passed was 21 months imprisonment on each count to run concurrently. He also asked for 39 similar offences to be taken into consideration.\u0022 (Source: UK Serious Fraud Office Press Release, \u0022Insurance Broker jailed for bribing Costa Rican officials,\u0022 October 26, 2010.) The Press Release noted that there were ongoing prosecution in Costa Rica of the alleged bribe recipients and that the SFO was cooperating with the Costa Rican authorities in the matter.  Written evidence presented by the UK\u0027s Department for International Development (DFID) to the Parliament\u0027s International Development Committee stated that US$100,000 has been returned to Costa Rica  in the case involving Mr. Messent. (Source: UK Parliament, International Development Committee, \u0022Supplementary written evidence submitted by The Department for International Development (DFID),\u0022 June 2012.) \nAccording to the Serious Fraud Office\u0027s submission to the UK Parliament, \u0022There were a number of practical problems involved in the transmission of the payment to the authorities in Costa Rica. There has been discussion as well as to which organisation in Costa Rica should benefit from the funds.\u0022 (Source: UK Parliament, House of Commons, International Development Committee, \u0022Financial Crime and Development, Eleventh Report of Session 2010-12,\u0022 15 November 2011.)","Disposition of Criminal Case(s)":"According to the October 26, 2010 press release by the UK Serious Fraud Office, UK insurance broker \u0022Julian Messent was sentenced today to 21 months\u0027 imprisonment after admitting making or authorising corrupt payments of almost US $2 million to Costa Rican officials.\u0022 (Source: UK Serious Fraud Office Press Release, \u0022Insurance Broker jailed for bribing Costa Rican officials,\u0022 October 26, 2010.).  His sentence was upheld in 2011 by the England and Wales Court of Appeal (Criminal Division).  (Source: Messent, R. v [2011] EWCA Crim 644 (01 March 2011))","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Serious Fraud Office, City of London Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service","Jurisdiction of Asset Recovery: Courts Involved":"Southwark Crown Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Messent_Plea_UK_SFO_Press_Release_Oct_26_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Messent_UK_Appeals_Court_Judgment_Mar_1_2011.doc, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Messent_Plea_UK_SFO_Press_Release_Oct_26_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Messent_UK_SFO_Sentencing_PR_Oct_26_2010.pdf","Sources ":"\n\tMessent, R. v [2011] EWCA Crim 644 (01 March 2011), at http:\/\/www.bailii.org\/ew\/cases\/EWCA\/Crim\/2011\/644.html;\n\n\t\u00a0\n\n\tUK Serious Fraud Office Press Release, \u0022Insurance Broker jailed for bribing Costa Rican officials,\u0022 October 26, 2010, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-20...\n\n\t\u00a0\n\n\t\u00a0UK Parliament, International Development Committee, \u0022Supplementary written evidence submitted by The Department for International Development (DFID),\u0022 June 2012, accessed at http:\/\/www.publications.parliament.uk\/pa\/cm201213\/cmselect\/cmintdev\/130\/...\n\n\t\u00a0\n\n\tUK Parliament, House of Commons, International Development Committee, \u0022Financial Crime and Development\n\n\tEleventh Report of Session 2010-12,\u0022 15 November 2011, accessed at http:\/\/www.publications.parliament.uk\/pa\/cm201012\/cmselect\/cmintdev\/847\/....\n"},{"Case ID":"ARW-48","Case Title (Name of Public Official or Entity Allegedly Involved)":"David B. Chalmers, Jr. \/ Bayoil (USA) Inc. \/ Bayoil Supply \u0026 Trading, Limited (UN Oil-for-Food)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United States","Position of Public Official(s) (yrs in office)":"NA","Jurisdiction of Asset Recovery":"Iraq [Development Fund for Iraq], United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2005","Asset Recovery End":"2008","UNCAC Offenses Implicated":"Art. 2, Art.14, Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution, Criminal Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"In announcing the guilty pleas, the United States Attorney for the Southern District of New York, Mr. Michael Garcia \u0022praised the work of the Federal Bureau of Investigation, Criminal and Counterintelligence Divisions. He also expressed appreciation to the United States Treasury Department, Office of Foreign Assets Control; the United States Department of State; the United Nations Office of Legal Affairs; and the former Independent Inquiry Committee into the United Nations Oil-for-Food Program for their assistance in this investigation.\u0022 (Source: United States Attorney\u0027s Office for the Southern District of New York Press Release, \u0022U.S. ANNOUNCES FOUR GUILTY PLEAS IN OIL-FOR-FOOD CASE,\u0022 August 17, 2007.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$9,016,151.4","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to a press release by the United States Attorney\u0027s Office for the Southern District of New York, on August 7, 2007, David B. Chalmers, Jr. and his companies - Bayoil (USA) Inc., and Bayoil Supply \u0026 Trading, Limited - pleaded guilty to one count of conspiracy to commit wire fraud, in relation to their involvement in a kick-back scheme related to the UN Oil-for-Food program in Iraq.  (Source: United States Attorney\u0027s Office for the Southern District of New York Press Release, \u0022U.S. ANNOUNCES FOUR GUILTY PLEAS IN OIL-FOR-FOOD CASE,\u0022 August 17, 2007).  As described in the Order of Restitution in the case, as part of their sentencing,  Chalmers and the Bayoil companies had been ordered to pay restitution of $9,016,151.40, for which they had joint and several liability; the March 25, 2008 Order of Restitution ordered the three to pay the restitution to the Development Fund of Iraq, in care of Ambassador Srood Najib, to be used as restitution for the benefit of the Iraqi people. (Source: US v. Chalmers, et al, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Order of Restitution filed on March 25, 2008.)   The Development Fund of Iraq was established on May 21, 2003, by United Nations Security Council Resolution 1483 and originally overseen by the Coalition Provisional Authority, then by the Interim Iraqi government with the oversight of the International Advisory and Monitoring Board for Iraq; as of July 2011, the Government of Iraq assumed full autonomy for the proceeds of the Development Fund for Iraq. (Source: United Nations Security Council Press Statement, SC\/10307, IK\/636, \u0022Security Council Statement on the Development Fund for Iraq,\u0022 June 30, 2011.)","Disposition of Criminal Case(s)":"According to the Order of Restitution filed in US v. Chalmers, et al, on August 7, 2007, David B. Chalmers, Jr. and his companies - Bayoil (USA) Inc., and Bayoil Supply \u0026 Trading, Limited - pleaded guilty to one count of conspiracy to commit wire fraud, in violation of Section 1349 of Title 18, United States Code. (Source: US v. Chalmers, et al, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Order of Restitution filed on March 25, 2008.)","Jurisdiction of Origin: Investigative Agency":"Independent Inquiry Committee into the United Nations Oil-for-Food Program ","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, Criminal and Counterintelligence Divisions","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney for the Southern District of New York","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York","Documents":"","Sources ":"United States Attorney\u0027s Office for the Southern District of New York Press Release, \u0022U.S. ANNOUNCES FOUR GUILTY PLEAS IN OIL-FOR-FOOD CASE,\u0022 August 17, 2007, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/August07\/chalmersdionissie... \nUS v. Chalmers, et al, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Order of Restitution filed on March 25, 2008 and Court Docket Report as of October 26, 2011, both accessed via PACER; \nUnited Nations Security Council Press Statement, SC\/10307, IK\/636, \u0022Security Council Statement on the Development Fund for Iraq,\u0022 June 30, 2011, accessed at http:\/\/www.un.org\/News\/Press\/docs\/2011\/sc10307.doc.htm.\n"},{"Case ID":"ARW-74","Case Title (Name of Public Official or Entity Allegedly Involved)":"Halliburton \/ Kellogg Brown \u0026 Root LLC (TSKJ Consortium Nigeria Settlement)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United States","Position of Public Official(s) (yrs in office)":"NA","Jurisdiction of Asset Recovery":"Nigeria","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2010","Asset Recovery End":"2010","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine \/ Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Settlement agreement (Source: Hallliburton Press Release, \u0022Halliburton Confirms Agreement to Settle with Federal Government of Nigeria,\u0022 December 21, 2010.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$35,000,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a December 21, 2010 Press Release by Halliburton, as part of its agreement with the Federal Government of Nigeria (FGN), \u0022Halliburton agreed to pay US$32.5 million to the FGN and to pay an additional US$2.5 million for FGN\u0027s attorneys\u0027 fees and other expenses. Among other provisions, Halliburton agreed to provide reasonable assistance int the FGN\u0027s effort to recover amounts frozen in a Swiss bank account of a former TSKJ [the joint venture in develpment of the natural gas liqufaction project on Bonny Island, Nigeria] agent.\u0022 (Source: Hallliburton Press Release, \u0022Halliburton Confirms Agreement to Settle with Federal Government of Nigeria,\u0022 December 21, 2010; 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice by Mr. Mohammed Bello Adoke, SAN, Honourable Attorney-General of the Federation and Minister of Justice, 22 December 2010.)  Background to the Bonny Island project and misconduct are described in US v. Kellogg Brown \u0026 Root LLC, Case No. 4:09-cr-00071 (S.D. Tex.), Plea Agreement and Statement of Facts filed on February 11, 2009.  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.","Disposition of Criminal Case(s)":"According to a December 21, 2010 Press Release by Halliburton, pursuant to an agreement with the Federal Government of Nigeria (FGN), \u0022all lawsuits and charges against KBR and Halliburton corporate entities and associated persons have been withdrawn, the FGN agreed not to bring any further criminal charges or civil claims against those entities or persons.\u0022 (Source: Hallliburton Press Release, \u0022Halliburton Confirms Agreement to Settle with Federal Government of Nigeria,\u0022 December 21, 2010.)","Jurisdiction of Origin: Investigative Agency":"NA","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Ministry of Justice, Attorney General; Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"","Sources ":"Hallliburton Press Release, \u0022Halliburton Confirms Agreement to Settle with Federal Government of Nigeria,\u0022 December 21, 2010, accessed at www.halliburton.com\/public\/news\/pubsdata\/press_release\/2010\/corpnws_1221... \n2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice by Mr. Mohammed Bello Adoke, SAN, Honourable Attorney-General of the Federation and Minister of Justice, 22 December 2010; \nBBC News, \u0022Nigeria drops Dick Cheney bribery charges,\u0022 December 17, 2010 (quoting EFCC spokesman Femi Babafemi), accessed at http:\/\/www.bbc.co.uk\/news\/world-africa-12018900.\u00a0 \nSee also,\u00a0US v. Kellogg Brown \u0026 Root LLC, Case No. 4:09-cr-00071 (S.D. Tex.), Plea Agreement and Statement of Facts filed on February 11, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/kelloggb\/02-11-09kbr-pl....\n"},{"Case ID":"ARW-73","Case Title (Name of Public Official or Entity Allegedly Involved)":"Halliburton \/ Kellogg Brown \u0026 Root LLC (TSKJ Consortium Nigeria Settlement \/ Swiss Account)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria, United States","Position of Public Official(s) (yrs in office)":"NA","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2010","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Unspecified (Arising out of nonprosecution agreement between Government of Nigeria and Halliburton)","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Unknown","Stage in Asset Recovery Chain":"Unknown","Assets Frozen (USD)":"$135,000,000","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unknown","Case Summary":"According to a December 21, 2010 Press Release by Halliburton, as part of its agreement with the Federal Government of Nigeria (FGN), \u0022Halliburton agreed to pay US$32.5 million to the FGN and to pay an additional US$2.5 million for FGN\u0027s attorneys\u0027 fees and other expenses. Among other provisions, Halliburton agreed to provide reasonable assistance int the FGN\u0027s effort to recover amounts frozen in a Swiss bank account of a former TSKJ [the joint venture in develpment of the natural gas liqufaction project on Bonny Island, Nigeria] agent.\u0022 (Source: Hallliburton Press Release, \u0022Halliburton Confirms Agreement to Settle with Federal Government of Nigeria,\u0022 December 21, 2010; see also BBC News, \u0022Nigeria drops Dick Cheney bribery charges,\u0022 December 17, 2010 (quoting EFCC spokesman Femi Babafemi as stating that the settlement had been reached and mention of frozen foreign account.)\u00a0 The\u00a02010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice by Mr. Mohammed Bello Adoke, SAN, Honourable Attorney-General of the Federation and Minister of Justice, also noted the Halliburton settlement.\u00a0 (22 December 2010). Background to the Bonny Island project and misconduct are described in US v. Kellogg Brown \u0026 Root LLC, Case No. 4:09-cr-00071 (S.D. Tex.), Plea Agreement and Statement of Facts filed on February 11, 2009.  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.","Disposition of Criminal Case(s)":"According to a December 21, 2010 Press Release by Halliburton, pursuant to an agreement with the Federal Government of Nigeria (FGN), \u0022all lawsuits and charges against KBR and Halliburton corporate entities and associated persons have been withdrawn, the FGN agreed not to bring any further criminal charges or civil claims against those entities or persons.\u0022 (Source: Hallliburton Press Release, \u0022Halliburton Confirms Agreement to Settle with Federal Government of Nigeria,\u0022 December 21, 2010.)","Jurisdiction of Origin: Investigative Agency":"NA","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"US: Department of Justice (Fraud Section); Nigeria: Ministry of Justice, Economic and Financial Crimes Commission","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"","Sources ":"\n\tHallliburton Press Release, \u0022Halliburton Confirms Agreement to Settle with Federal Government of Nigeria,\u0022 December 21, 2010, accessed at www.halliburton.com\/public\/news\/pubsdata\/press_release\/2010\/corpnws_1221... BBC News, \u0022Nigeria drops Dick Cheney bribery charges,\u0022 December 17, 2010 (quoting EFCC spokesman Femi Babafemi), accessed at http:\/\/www.bbc.co.uk\/news\/world-africa-12018900; 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice by Mr. Mohammed Bello Adoke, SAN, Honourable Attorney-General of the Federation and Minister of Justice (22 December 2010).\u00a0 See also, US v. Kellogg Brown \u0026 Root LLC, Case No. 4:09-cr-00071 (S.D. Tex.), Plea Agreement and Statement of Facts filed on February 11, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/kelloggb\/02-11-09kbr-pl...\n"},{"Case ID":"ARW-143","Case Title (Name of Public Official or Entity Allegedly Involved)":"Noble Corporation (Nigeria Settlement)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Switzerland","Position of Public Official(s) (yrs in office)":"Unspecified Officials","Jurisdiction of Asset Recovery":"Nigeria","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2010","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Settlement agreement (Source: Noble Corporation, US Securities and Exchange Commission Form 8-K, January 31, 2011.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$2,500,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the Form 8-K filed by the Noble Corporation with the US Securities and Exchange Commission, the Nigerian Economic and Financial Crimes Commission and the Nigerian Attorney General\u0027s Office investigation related to the same activities as previously settled by Noble Corporation with the U.S. Department of Justice and the Securities Exchange Commission under the U.S. Foreign Corrupt Practices Act of certain reimbursement payments made by the company\u0027s Nigerian affiliate to customs agents in Nigeria.  The company stated that as part of the January 28, 2011 Non-prosecution agreement executed by a subsidiary of Noble-Swiss with the Government of Nigeria, the Noble-Swiss subsidiary will pay $2.5 million to resolve all charges and claims of the Nigerian government. (Sources:  Noble Corporation, US Securities and Exchange Commission Form 8-K, January 31, 2011; US Department of Justice: In Re: Noble Corporation, Nonprosecution Agreement and Statement of Facts, dated November 4, 2010.)  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.","Disposition of Criminal Case(s)":"According to the Form 8-K filed by the Noble Corporation with the US Securities and Exchange Commission, the Nigerian Economic and Financial Crimes Commission and the Nigerian Attorney General\u0027s Office initiated an investigation into alleged misconduct but all charges were resolved through the execution of a non-prosecution agreement dated January 28, 2011 by a subsidiary of Noble-Swiss. (Source:  Noble Corporation, SEC Form 8-K, January 31, 2011.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Ministry of Justice, Attorney General; Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Courts Involved":"N\/A","Documents":"","Sources ":"Noble Corporation US Securities and Exchange Commission Form 8-K, filed January 31, 2011, accessed at www.sec.gov\/Archives\/edgar\/data\/1169055\/000095012311006909\/h79316e8vk.htm; US Securities and Exchange Commission, \u0022Form 8-K\u0022 (Explanation) at http:\/\/www.sec.gov\/answers\/form8k.htm; In Re: Noble Corporation, Nonprosecution Agreement and Statement of Facts, dated November 4, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/noble-corp\/11-04-10nobl...\n"},{"Case ID":"ARW-89","Case Title (Name of Public Official or Entity Allegedly Involved)":"JGC Corporation (TSKJ Consortium Nigeria Settlement)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Japan","Position of Public Official(s) (yrs in office)":"NA","Jurisdiction of Asset Recovery":"Nigeria","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2010","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine and Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Settlement Agreement (Source: JGC Corporation\u0027s January 31, 2011 Notice of Loss and Revisions of Earnings Forecasts for Fiscal Year Ending March 31, 2011.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the JGC Corporation\u0027s January 31, 2011 Notice of Loss and Revisions of Earnings Forecasts for Fiscal Year Ending March 31, 2011, JGC reached a settlement with the Nigerian authorities in January 2011 to settle charges arising from the Bonny Island\/LNG project.  The company agreed to pay 2.5 billion yen. (Source: JGC Corporation\u0027s January 31, 2011 Notice of Loss and Revisions of Earnings Forecasts for Fiscal Year Ending March 31, 2011.)  Background on the Bonny Island project, TSKJ joint venture and the JGC Corporation\u0027s settlement with the US Department of Justice are described in US v. JGC Corporation,  Case No. 4:11-cr-00260 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts filed April 6, 2011.  Please note that the exact date of Nigerian settlement is not known; January 31, 2011 was used as date for purposes of currency conversion from yen to US dollars.  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.","Disposition of Criminal Case(s)":"According to the JGC Corporation\u0027s January 31, 2011 Notice of Loss and Revisions of Earnings Forecasts for Fiscal Year Ending March 31, 2011, JGC reached a settlement with the Nigerian authorities in January 2011. No other details were noted in the company\u0027s notice. (Source: JGC Corporation\u0027s January 31, 2011 Notice of Loss and Revisions of Earnings Forecasts for Fiscal Year Ending March 31, 2011.)","Jurisdiction of Origin: Investigative Agency":"NA","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Ministry of Justice, Attorney General; Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Courts Involved":"N\/A","Documents":"","Sources ":"JGC Corporation\u0027s January 31, 2011 Notice of Loss and Revisions of Earnings Forecasts for Fiscal Year Ending March 31, 2011, accessed at http:\/\/www.jgc.co.jp\/en\/06ir\/pdf\/financial_statements-summary\/FY10\/fy10_... \nUS v. JGC Corporation,  Case No. 4:11-cr-00260 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts filed April 6, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/jgc-corp\/04-6-11jgc-cor....\n"},{"Case ID":"ARW-176","Case Title (Name of Public Official or Entity Allegedly Involved)":"Snamprogetti Netherlands BV and ENI S.p.A. (TSKJ Consortium Nigeria Settlement)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Italy, Netherlands","Position of Public Official(s) (yrs in office)":"NA","Jurisdiction of Asset Recovery":"Nigeria","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2010","Asset Recovery End":"2010","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Settlement Agreement (Source: ENI\/Saipem company Press Release, \u0022Snamprogetti Netherlands BV enters agreement with Federal Government of Nigeria,\u0022 December 20, 2010.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$32,500,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a Press Release by the ENI company, as part of its subsidiary Snamprogetti Netherlands BV\u0027s settlement and non-prosecution agreement with the Nigerian authorities, Snamprogetti agreed to the payment of a criminal penalty of $30 million and of $2.5 million as reimbursement for legal costs and expenses incurred by the Nigerian authorities. In addition to dismissing all charges filed in Nigeria, the authorities agreed to renounce civil claims and criminal charges in any jurisdiction.  (Source: ENI\/Saipem company Press Release, \u0022Snamprogetti Netherlands BV enters agreement with Federal Government of Nigeria,\u0022 December 20, 2010.)  Background on the Bonny Island project, TSKJ joint venture and Snamprogetti Netherlands BV\u0027s settlement with the US Department of Justice are described in US v.Snamprogetti Netherlands BV, Case No. 4:10-cr-00460 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts, filed July 7, 2010.  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.","Disposition of Criminal Case(s)":"According to a Press Release by the ENI company, its subsidiary Snamprogetti Netherlands BV entered into a settlement and non-prosecution agreement with the Nigerian authorities to resolve an investigation into the activities of Snamprogetti, as member of the TSKJ consortium, in connection with contracts to build liquid natural [gas] faciltiies on Bonny Island, Nigeria. The Government of Nigeria agreed to dismiss all charges against Snamprogetti.  (Source: ENI\/Saipem company Press Release, \u0022Snamprogetti Netherlands BV enters agreement with Federal Government of Nigeria,\u0022 December 20, 2010.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Ministry of Justice, Attorney General; Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"ENI\/Saipem company Press Release, \u0022Snamprogetti Netherlands BV enters agreement with Federal Government of Nigeria,\u0022 December 20, 2010, accessed at http:\/\/www.saipem.com\/site\/download.jsp?idDocument=2013\u0026instance=2; \nUS v.Snamprogetti Netherlands BV, Case No. 4:10-cr-00460 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts, filed July 7, 2010, accessed at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/snamprogetti\/07-07-10sn...\n"},{"Case ID":"ARW-174","Case Title (Name of Public Official or Entity Allegedly Involved)":"Siemens AG (Nigeria Settlement)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Germany","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"Nigeria","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2010","Asset Recovery End":"2010","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution and Fine and Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Settlement Agreement (Source: Siemens, \u0022Legal Proceedings,\u0022 May 4, 2011; The 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice by Mr. Mohammed Bello Adoke, SAN, Honourable Attorney-General of the Federation and Minister of Justice, also noted the Halliburton settlement.\u00a0 (22 December 2010).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$46,000,000 (secondary source)","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the May 4, 2011 Siemens Company Statement on Legal Proceedings against it around the world, \u0022As previously reported, the Nigerian Economic and Financial Crimes Commission (EFCC) was conducting an investigation into alleged illegal payments by Siemens to Nigerian public officials between 2002 and 2005. In October 2010, the EFCC filed charges with the Federal High Court in Abuja and the High Court of the Federal Capital Territory against \u2013 among others \u2013 Siemens Ltd. Nigeria (Siemens Nigeria), Siemens AG and former board members of Siemens Nigeria. On November 22, 2010, the Nigerian Government and Siemens Nigeria entered into an out of court settlement, obligating Siemens Nigeria to make a payment in the mid double-digit Euro million range to Nigeria in exchange for the Nigerian Government withdrawing these criminal charges and refraining from the initiation of any criminal, civil or other actions \u2013 such as a debarment \u2013 against Siemens Nigeria, Siemens AG, and Siemens employees.\u0022 (Source: Siemens, \u0022Legal Proceedings,\u0022 May 4, 2011.)\u00a0 The 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice by Mr. Mohammed Bello Adoke, SAN, Honourable Attorney-General of the Federation and Minister of Justice, also noted the Halliburton settlement.\u00a0 (22 December 2010).\u00a0 For background on the US Foreign Corrupt Practices Act case and settlement with Siemens A.G., please see US v. Siemens A.G., Case No. 08-cr-367-RJL (D.D.C.), Plea Agreement ans Statement of Offense, both filed December 15, 2008.  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.","Disposition of Criminal Case(s)":"According to the May 4, 2011 Siemens Company Statement on Legal Proceedings against it around the world, the criminal charges filed against it by the Nigerian Economic and Financial Crimes Commission (EFCC) was dismissed in November 2010, pursuant to a settlement agreement between Siemens and the Nigerian authorities. (Source: Siemens, \u0022Legal Proceedings,\u0022 May 4, 2011.)","Jurisdiction of Origin: Investigative Agency":"Munich Public Prosecutor\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Courts Involved":"High Court - Abuja, High Court of the Federal Capital Territory","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Fcpablog_Aug_4_2011_SERAP_Petition_to_EFCC.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Company_Statement_Legal_Proceedings_Worldwide_May_4_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_US_DOJ_Plea_Agreement_Dec_15_2008.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_US_DOJ_Statement_of_Offense_December_15_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Fcpablog.com_Aug_4_2011_SERAP_Petition_to_EFCC.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Fcpablog_Aug_4_2011_SERAP_Petition_to_EFCC.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Company_Statement_Legal_Proceedings_Worldwide_May_4_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_US_DOJ_Plea_Agreement_Dec_15_2008.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_US_DOJ_Statement_of_Offense_December_15_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens_Company_Statement_Legal_Proceedings_Worldwide_May_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Fcpablog_Aug_4_2011_SERAP_Petition_to_EFCC.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Company_Statement_Legal_Proceedings_Worldwide_May_4_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_US_DOJ_Plea_Agreement_Dec_15_2008.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_US_DOJ_Statement_of_Offense_December_15_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens_US_DOJ_Plea_Agreement_Dec_15_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Fcpablog_Aug_4_2011_SERAP_Petition_to_EFCC.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Company_Statement_Legal_Proceedings_Worldwide_May_4_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_US_DOJ_Plea_Agreement_Dec_15_2008.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_US_DOJ_Statement_of_Offense_December_15_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens_US_DOJ_Statement_of_Offense_December_15_2008.pdf","Sources ":"The 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice by Mr. Mohammed Bello Adoke, SAN, Honourable Attorney-General of the Federation and Minister of Justice, also noted the Halliburton settlement.\u00a0 (22 December 2010). \nMarcus Cohen, David Elesinmogun \u0026 Obumneme Egwuatu, \u0022Will Nigeria Take Another Bite?,\u0022 FCPA Blog, August 4, 2011, accessed at http:\/\/www.fcpablog.com\/blog\/tag\/shell; \nSiemens, \u0022Legal Proceedings,\u0022 May 4, 2011, accessed at http:\/\/www.siemens.com\/press\/pool\/de\/events\/2011\/corporate\/2011-q2\/2011-... \nUS v. Siemens A.G., Case No. 08-cr-367-RJL (D.D.C.), Plea Agreement and Statement of Offense, both filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens-aktiengesellsch....\n"},{"Case ID":"ARW-185","Case Title (Name of Public Official or Entity Allegedly Involved)":"Tidewater, Inc. (Nigeria Settlement)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United States","Position of Public Official(s) (yrs in office)":"NA","Jurisdiction of Asset Recovery":"Nigeria","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2010","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Settlement Agreement (Source: Tidewater, Inc., US Securities and Exchange Commission Form 8-K filed March 3, 2011, at http:\/\/www.sec.gov\/Archives\/edgar\/data\/98222\/000119312511055141\/d8k.htm)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$6,300,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to Tidwater Inc.\u0027s March 3, 2011 Form 8-K filed with the US Securities and Exchange Commission, pursuant to a settlement agreement announced that day, Tidewater agreed to settle allegations that the Nigerian affiliate of a Swiss-based freight forwarder had made improper payments to government officials in Nigeria on behalf of Tidewater\u0027s foreign subsidiaries. The Nigerian investigation revolved around the same 2007 conduct detailed in Tidewater\u0027s settlements with the US Department of Justice and the Securities and Exchange Commission. Tidewater agreed to pay $6 million to the Government of Nigeria and an additional $300,000 for the Government of Nigeria\u0027s attorneys and other expenses. (Source: Technip Inc., SEC Form 8-K filed March 3, 2011.) Tidewater\u0027s settlements with the US Department of Justice and the Securities and Exchange Commission are detailed in: US v. Tidewater Marine International, Inc., Case No. 4:10-cr-00770 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts filed November 4, 2010; and US Securities and Exchange Commission, Litigation Release No. 21729 (November 4, 2010), in SEC v. Tidewater, Inc., Case No. 2:10-cv-04180 (E.D. La.), Complaint filed November 4, 2010. Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.","Disposition of Criminal Case(s)":"According to Technip Inc.\u0027s March 3, 2011 Form 8-K filed with the US Securities and Exchange Commission, pursuant to a settlement agreement announced that day, the Government of Nigeria had agreed to terminate its investigation into Tidewater\u0027s operations in Nigeria in 2007 and agreed not to bring criminal or civil claims against the company or associated persons in connection with those allegations. (Source: Technip Inc., SEC Form 8-K filed March 3, 2011.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Economic and Financial Crimes Commission; Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"N\/A","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_Nigeria_Settlement_SEC_Form_8-K_Mar_3_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_US_DOJ_Deferred_Prosecution_Agreement_Nov_4_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_US_SEC_Complaint_Nov_4_2010.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_US_SEC_Litigation_Release_Nov_4_2010.PDF\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Tidewater_SEC_Complaint_Nov_4_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_Nigeria_Settlement_SEC_Form_8-K_Mar_3_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_US_DOJ_Deferred_Prosecution_Agreement_Nov_4_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_US_SEC_Complaint_Nov_4_2010.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_US_SEC_Litigation_Release_Nov_4_2010.PDF\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Tidewater_SEC_Litigation_Release_Nov_4_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_Nigeria_Settlement_SEC_Form_8-K_Mar_3_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_US_DOJ_Deferred_Prosecution_Agreement_Nov_4_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_US_SEC_Complaint_Nov_4_2010.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_US_SEC_Litigation_Release_Nov_4_2010.PDF\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Tidewater_Nigeria_Settlement_SEC_Form_8-K_Mar_3_2011.pdf","Sources ":"Tidewater, Inc., US Securities and Exchange Commission Form 8-K filed March 3, 2011, at http:\/\/www.sec.gov\/Archives\/edgar\/data\/98222\/000119312511055141\/d8k.htm; US v. Tidewater Marine International, Inc., Case No. 4:10-cr-00770 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts filed November 4, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tidewater-intl\/11-04-10... US Securities and Exchange Commission, Litigation Release No. 21729 (November 4, 2010), in SEC v. Tidewater, Inc., Case No. 2:10-cv-04180 (E.D. La.), Complaint filed November 4, 2010, both accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21729.htm and http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21729.pdf.\n"},{"Case ID":"ARW-173","Case Title (Name of Public Official or Entity Allegedly Involved)":"Siemens AG (Italy Settlement)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Germany","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"Italy","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2004","Asset Recovery End":"2006","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Plea Bargain without Admission of Guilt or Responsibility (Source: Siemens, \u0022Legal Proceedings - Fiscal 2007,\u0022 November 8, 2007.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$8,522,530","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the Complaint in US Securities and Exchange Commission, in 2004, a Milan judge issued a written opinion that Siemens viewed bribery at least as a possible business strategy and that \u0022Subsequently, Siemens, along with two of its PG managers, entered into a plea bargain with criminal authorities in Italy pursuant to which Siemens paid a \u20ac0.5 million fine, gave up \u20ac6.2 million in profits and was barred fiom selling gas turbines in Italy for one year.\u0022  (Source: US Securities and Exchange Commission v. Siemens AG, Case No. 1:08-cv-02167 (D.D.C.), Complaint filed December 12, 2008, para 23.)  According to a 2007 Siemens company statement, \u0022the agreement was In Italy, legal proceedings against two former employees ended when the \u201cpatteggiamento\u201d (plea bargaining procedure without the admission of guilt or responsibility) by the charged employees and Siemens AG entered into force in November 2006.\u0022  (Source: Siemens, \u0022Legal Proceedings - Fiscal 2007,\u0022 November 8, 2007.)","Disposition of Criminal Case(s)":"According to the Complaint in US Securities and Exchange Commission, in 2004, a Milan judge issued a written opinion that Siemens viewed bribery at least as a possible business strategy and that \u0022Subsequently, Siemens, along with two of its PG managers, entered into a plea bargain with criminal authorities in Italy pursuant to which Siemens paid a \u20ac0.5 million fine, gave up \u20ac6.2 million in profits and was barred from selling gas turbines in Italy for one year.\u0022  (Source: US Securities and Exchange Commission v. Siemens AG, Case No. 1:08-cv-02167 (D.D.C.), Complaint filed December 12, 2008, para 23.)","Jurisdiction of Origin: Investigative Agency":"Munich Public Prosecutor\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Milan Pubilc Prosecutor","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"Milan Judge","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_US_SEC_Complaint_DDC_Dec_12_2008.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Company_Statement_Legal_Proceedings_2007.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens_SEC_Amended_Complaint.pdf","Sources ":"US Securities and Exchange Commission v. Siemens AG, Case No. 1:08-cv-02167 (D.D.C.), Complaint filed December 12, 2008, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20829.pdf; \nSiemens, \u0022Legal Proceedings - Fiscal 2007,\u0022 November 8, 2007, accessed at http:\/\/www.siemens.com\/press\/pool\/de\/events\/jahrespk2007\/legal-proceedin....)\n"},{"Case ID":"ARW-175","Case Title (Name of Public Official or Entity Allegedly Involved)":"Siemens AG (World Bank and EBRD Settlements)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Germany","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"World Bank","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Other (Administrative Sanctions)","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Settlement Agreement (Source: The World Bank Press Release, \u0022Siemens to pay $100m to fight corruption as part of World Bank Group settlement,\u0022 Press Release No:2009\/001\/EXT, July 2, 2009.)","Status of Asset Recovery ":"Completed (in part) and Ongoing (in part)","Stage in Asset Recovery Chain":"Other","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$70,000,000 (granted and committed)","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Establishment of Siemens Integrity Initiative","Case Summary":"According to the World Bank Press Release of July 2, 2009, Siemens and the World Bank announced a comprehensive settlement agreement \u0022in the wake of the company\u2019s acknowledged past misconduct in its global business and a World Bank investigation into corruption in a project in Russia involving a Siemens subsidiary. The settlement includes a commitment by Siemens to pay $100 million over the next 15 years to support anti-corruption work.\u0022 (Source: The World Bank Press Release, \u0022Siemens to pay $100m to fight corruption as part of World Bank Group settlement,\u0022 Press Release No:2009\/001\/EXT, July 2, 2009.)  According to Siemens, \u0022Over 30 projects from over 20 countries were selected for funding in the first funding round and will receive an overall funding up to US$ 40 million.\u0022  In December 2014, Siemens announced the selected grantees in the first group of the second round.  (Source:  Siemens A.G., World Bank, European Investment Bank Joint Press Release, \u0022Siemens Integrity Initiative enters the second round,\u0022 December 10, 2014; See also Siemens A.G., Integrity Initiative at http:\/\/www.siemens.com\/about\/sustainability\/en\/core-topics\/collective-ac... and http:\/\/www.siemens.com\/about\/sustainability\/en\/core-topics\/collective-ac... [last accessed June 27, 2016].)","Disposition of Criminal Case(s)":"N\/A (Administrative Sanctions)","Jurisdiction of Origin: Investigative Agency":"World Bank Integrity Vice Presidency","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"World Bank Integrity Vice Presidency","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"World Bank Integrity Vice Presidency","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_World_Bank_Settlement_WB_PR_Jul_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Integrity_Initiative_Overview_First_Round_Company_Website_Oct_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens-integrity-initiative-project-profiles-first-round_Sep_2011.PDF\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens_Integrity_Initiative_Overview_First_Round_Company_Website_Oct_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_World_Bank_Settlement_WB_PR_Jul_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Integrity_Initiative_Overview_First_Round_Company_Website_Oct_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens-integrity-initiative-project-profiles-first-round_Sep_2011.PDF\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens_World_Bank_Settlement_WB_PR_Jul_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_World_Bank_Settlement_WB_PR_Jul_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Integrity_Initiative_Overview_First_Round_Company_Website_Oct_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens-integrity-initiative-project-profiles-first-round_Sep_2011.PDF\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens-integrity-initiative-project-profiles-first-round_Sep_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_World_Bank_Settlement_WB_PR_Jul_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Integrity_Initiative_Overview_First_Round_Company_Website_Oct_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens-integrity-initiative-project-profiles-first-round_Sep_2011.PDF\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens_Integrity%20Initiative_Jan_2015.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_World_Bank_Settlement_WB_PR_Jul_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Integrity_Initiative_Overview_First_Round_Company_Website_Oct_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens-integrity-initiative-project-profiles-first-round_Sep_2011.PDF\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens_Integrity%20Initiative_Jan_2015_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_World_Bank_Settlement_WB_PR_Jul_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Integrity_Initiative_Overview_First_Round_Company_Website_Oct_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens-integrity-initiative-project-profiles-first-round_Sep_2011.PDF\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens_Second_Round_Joint_PR_Dec_10_2014.pdf","Sources ":"\n\tThe World Bank Press Release, \u0022Siemens to pay $100m to fight corruption as part of World Bank Group settlement,\u0022 Press Release No:2009\/001\/EXT, July 2, 2009, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,contentMDK:22234573~pag...\n\n\t\u00a0\n\n\tSiemens A.G., World Bank, European Investment Bank Joint Press Release, \u0022Siemens Integrity Initiative enters the second round,\u0022 December 10, 2014, at http:\/\/www.siemens.com\/press\/pool\/de\/pressemitteilungen\/2014\/corporate\/P...\n\n\t\u00a0\n\n\tSiemens Integrity Initiative, at http:\/\/www.siemens.com\/about\/sustainability\/en\/core-topics\/collective-ac... and http:\/\/www.siemens.com\/about\/sustainability\/en\/core-topics\/collective-ac... (last accessed June 27, 2016.)\n"},{"Case ID":"ARW-1","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alain Gagnon \/ Archive Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Canada","Position of Public Official(s) (yrs in office)":"Financial Auditor, Department of Public Works and Government Services (exact years in office unknown, but at least from 1996-2007)","Jurisdiction of Asset Recovery":"Canada","Jurisdiction of Asset Description":"Undertaking Recovery Effort","Asset Recovery Start":"2008","Asset Recovery End":"2008","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Treaty Between the Government of the United States of America and the Government of Canada on Mutual Legal Assistance in Criminal Matters (1985 U.S.T. LEXIS 230)","Contributing Factors in Asset Recovery":"Mr. Gagnon pleaded guilty and as part of his plea agreement, he assigned his property to the victim, namely Her Majesty the Queen in Right of Canada.  In addition, when served with the Canadian restitution order, the U.S. investment firms liquidated his accounts and voluntarily remitted the funds to the Canadian agency.  (Source:  In re: Restraint of All Assets Held in the Name of Alain Gagnon In, etc. Case No. 1:08-mc-00260-PLF (D.D.C.), Official Supplemental Request by Canada to the United States of America, document 6-1 filed on April 13, 2009.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"Please see Alain Gagnon \/ Archive Case - Jurisdiction of Asset Recovery United States","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"As part of his 2008 plea agreement, Mr. Gagnon assigned his property to the victim, namely Her Majesty the Queen in Right of Canada, by executing a \u0022Deed of Assignment.\u0022 The properties included funds held in the U.S. in accounts under his name with the firm Options Express in Chicago, FX Solutions in New Jersey, and Forex Capital Markets in New York. On April 28, 2008, the U.S. District Court for the District of Columbia acted upon the January 4, 2008 Request for Assistance by the Canadian court and ordered those funds to be restrained. Upon being served with the Canadian Order, however, the law firm acting on behalf of FX Solutions issued a check payable to the Receiver General for Canada in the amount of CAD $46,828.04. In October 2008, the Public Works and Government Services\u0027 Legal Counsel and case agents followed up with Forex Capital Markets and Options Express; each of the firms liquidated the accounts and remitted to the Public Works and Government Services all of the money in the investment accounts: $19,533.40 by Forex Capital and $50,931.68 by Options Express. (Source: In re: Restraint of All Assets Held in the Name of Alain Gagnon In, etc. Case No. 1:08-mc-00260-PLF (D.D.C.), Official Supplemental Request by Canada to the United States of America, document 6-1 filed on April 13, 2009 which also includes an official translation of the Order of Restitution and Order to Revoke Restraining Order in Director of Criminal and Penal Prosecutions v. Alain Gagnon, Respondent and Her Majesty the Queen in the Right of Canada, FX Solutions, FOREX Capital Markers, Mis-en-case, No. 550-01-030814-075, 550-26-000342-070, Court of Quebec, Criminal and Penal Division, Province of Quebec, District of Hull, signed on August 21, 2008).","Disposition of Criminal Case(s)":"On August 21, 2008, Mr. Gagnon pleaded guilty to fraud and breach of trust by a public officer, and sentenced in November 2008.  He had been charged by the Director of Criminal and Penal Prosecutions in the Province of Quebec (Canada) of fraud, breach of trust by a public officer and laundering proceeds of crime.  (Source:  In re: Restraint of All Assets Held in the Name of Alain Gagnon In, etc. Case No. 1:08-mc-00260-PLF (D.D.C.), Official Supplemental Request by Canada to the United States of America, document 6-1 filed on April 13, 2009.)","Jurisdiction of Origin: Investigative Agency":"Royal Canadian Mounted Police","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Director of Criminal and Penal Prosecutions in the Province of Quebec (Canada); Department of Public Works and Government Services, Legal Counsel","Jurisdiction of Origin: Courts Involved":"Court of Quebec, Criminal and Penal Division  ","Jurisdiction of Asset Recovery: Investigative Agency":"Royal Canadian Mounted Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Director of Criminal and Penal Prosecutions in the Province of Quebec (Canada); Department of Public Works and Government Services, Legal Counsel","Jurisdiction of Asset Recovery: Courts Involved":"Court of Quebec, Criminal and Penal Division","Documents":"","Sources ":"In re: Restraint of All Assets Held in the Name of Alain Gagnon In, etc. Case No. 1:08-mc-00260-PLF (D.D.C.), Official Supplemental Request by Canada to the United States of America, document 6-1 filed on April 13, 2009, which includes an official translation of the Order of Restitution and Order to Revoke Restraining Order in Director of Criminal and Penal Prosecutions v. Alain Gagnon, Respondent and Her Majesty the Queen in the Right of Canada, FX Solutions, FOREX Capital Markers, Mis-en-case, No. 550-01-030814-075, 550-26-000342-070, Court of Quebec, Criminal and Penal Division, Province of Quebec, District of Hull, signed 21st day of August 2008.\n"},{"Case ID":"ARW-2","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alain Gagnon \/ Archive Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Canada","Position of Public Official(s) (yrs in office)":"Financial Auditor, Department of Public Works and Government Services (exact years in office unknown, but at least from 1996-2007)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"2008","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Other","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Treaty Between the Government of the United States of America and the Government of Canada on Mutual Legal Assistance in Criminal Matters (1985 U.S.T. LEXIS 230)","Contributing Factors in Asset Recovery":"Mr. Gagnon pleaded guilty and as part of his plea agreement, he assigned his property to the victim, namely Her Majesty the Queen in Right of Canada.  In addition, when served with the Canadian restitution order, the U.S. investment firms liquidated his accounts and voluntarily remitted the funds to the Canadian agency.  (Source:  In re: Restraint of All Assets Held in the Name of Alain Gagnon In, etc. Case No. 1:08-mc-00260-PLF (D.D.C.), Official Supplemental Request by Canada to the United States of America, document 6-1 filed on April 13, 2009.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$112,656.68","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"As part of his 2008 plea agreement, Mr. Gagnon assigned his property to the victim, namely Her Majesty the Queen in Right of Canada, by executing a \u0022Deed of Assignment.\u0022 The properties included funds held in the U.S. in accounts under his name with the firm Options Express in Chicago, FX Solutions in New Jersey, and Forex Capital Markets in New York.  On April 28, 2008, the U.S. District Court for the District of Columbia acted upon the January 4, 2008 Request for Assistance by the Canadian court and ordered those funds to be restrained.  Upon being served with the Canadian Order, however, the law firm acting on behalf of FX Solutions issued a check payable to the Receiver General for Canada in the amount of CAD $46,828.04.  In October 2008, the Public Works and Government Services\u0027 Legal Counsel and case agents followed up with Forex Capital Markets and Options Express; each of the firms liquidated the accounts and remitted to the Public Works and Government Services all of the money in the investment accounts: $19,533.40 by Forex Capital and $50,931.68 by Options Express. (Source: In re: Restraint of All Assets Held in the Name of Alain Gagnon In, etc. Case No. 1:08-mc-00260-PLF (D.D.C.), Official Supplemental Request by Canada to the United States of America, document 6-1 filed on April 13, 2009 which also includes an official translation of the Order of Restitution and Order to Revoke Restraining Order in Director of Criminal and Penal Prosecutions v. Alain Gagnon, Respondent and Her Majesty the Queen in the Right of Canada, FX Solutions, FOREX Capital Markers, Mis-en-case, No. 550-01-030814-075, 550-26-000342-070, Court of Quebec, Criminal and Penal Division, Province of Quebec, District of Hull, signed on August 21, 2008).","Disposition of Criminal Case(s)":"On August 21, 2008, Mr. Gagnon pleaded guilty to fraud and breach of trust by a public officer, and sentenced in November 2008.  He had been charged by the Director of Criminal and Penal Prosecutions in the Province of Quebec (Canada) of fraud, breach of trust by a public officer and laundering proceeds of crime.  (Source:  In re: Restraint of All Assets Held in the Name of Alain Gagnon In, etc. Case No. 1:08-mc-00260-PLF (D.D.C.), Official Supplemental Request by Canada to the United States of America, document 6-1 filed on April 13, 2009.)","Jurisdiction of Origin: Investigative Agency":"Royal Canadian Mounted Police","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Director of Criminal and Penal Prosecutions in the Province of Quebec (Canada); Department of Public Works and Government Services, Legal Counsel","Jurisdiction of Origin: Courts Involved":"Court of Quebec, Criminal and Penal Division  ","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Criminal Division,  Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Columbia","Documents":"","Sources ":"In re: Restraint of All Assets Held in the Name of Alain Gagnon In, etc. Case No. 1:08-mc-00260-PLF (D.D.C.), Official Supplemental Request by Canada to the United States of America, document 6-1 filed on April 13, 2009, which includes an official translation of the Order of Restitution and Order to Revoke Restraining Order in Director of Criminal and Penal Prosecutions v. Alain Gagnon, Respondent and Her Majesty the Queen in the Right of Canada, FX Solutions, FOREX Capital Markers, Mis-en-case, No. 550-01-030814-075, 550-26-000342-070, Court of Quebec, Criminal and Penal Division, Province of Quebec, District of Hull, signed 21st day of August 2008.\n"},{"Case ID":"ARW-3","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alcatel-Lucent \/ Instituto Costarricense de Electricidad (ICE)  (Costa Rica Settlement Case)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Costa Rica","Position of Public Official(s) (yrs in office)":"President Miguel Angel Rodriguez (1998-2002) and other public officials, including Instituto Costarricense de Electricidad representatives","Jurisdiction of Asset Recovery":"France","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"2010","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"According to a U.S. Department of Justice Press Release, \u0022The settlement marked the first time in Costa Rica\u0027s history that a foreign corporation agreed to pay the government damages for corruption.\u0022 (Source:  U.S. Department of Justice Press Release, \u0022Alcatel-Lucent S.A. and Three Subsidiaries Agree to Pay $92 Million to Resolve Foreign Corrupt Practices Act Investigation,\u0022 December 27, 2010.); Concept of \u0022Social Damages\u0022 as basis for monetary damages first applied by Costa Rica in this case. (Source: Transparency International Blog, Ahernandez, \u0022Can bribes paid by private firms cause \u0027social damage\u0027?\u0022 January 26, 2010 at http:\/\/blog.transparency.org\/2010\/01\/26\/can-bribes-paid-by-private-firms-cause-%E2%80%9Csocial-damage%E2%80%9D\/.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$10,000,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"A copy of the Settlement Agreement between the Government of Costa Rica and Alcatel-Lucent was filed by the US Government as part of its Foreign Corrupt Practices Act case against Alcatel. (Source: US v. Alcatel-Lucent France S.A., et al, Case No. 1:10-cr-20906 (S.D.Fla.) and US v. Alcatel-Lucent, S.A., Case No. 1:10-cr-20907 (S.D.Fla), Government\u0027s Response to ICE\u0027s Petition for Victim Status and Restitution filed May 23, 2011, Exhibit 1: SETTLEMENT AGREEMENT BETWEEN ALCATEL-LUCENT FRANCE, AND THE OFFICE OF THE ATTORNEY GENERAL OF THE REPUBLIC, ON BEHALF OF THE COSTA RICAN STATE RELATING TO THE CIVIL RECOVERY ACTION INCLUDED IN CRIMINAL CASE 04-6835-647-PEA). According to a statement on its website, Alcatel-Lucent noted that it had entered into an agreement with the Costa Rican authorities to pay $10 million to settle civil claims in a corruption case in which it was alleged that the company had paid kickbacks to public officials, political parties and officials of the state-owned telecom company in return for a 2001 contract worth $149 million to supply cellular telephone equipment. The statement notes the company\u0027s earlier settlement with the U.S. authorities and continuing investigation by France. (Source: \u0022Alcatel-Lucent, September 2010: A responsible behaviour - Controversies\u0022 posted at the company\u0027s website at http:\/\/www.alcatel-lucent.com\/csr\/htm\/en\/pdf\/Controversies_Costa_Rica.pdf). One of the alleged officials who received the kickbacks is former Costa Rican president Miguel Angel Rodriguez. (Source: Acusacion de la Fiscalia, posted at http:\/\/www.nacion.com\/Generales\/Subsitios\/Sucesos\/2010\/ICEALCATEL.aspx) According to the U.S. Department of Justice, the case marks the first time in Costa Rica\u0027s history that a foreign corporation has agreed to pay the government damages for corruption. (Source: U.S. Department of Justice Press Release, \u0022Alcatel-Lucent S.A. and Three Subsidiaries Agree to Pay $92 Million to Resolve Foreign Corrupt Practices Act Investigation,\u0022 December 27, 2010.)","Disposition of Criminal Case(s)":"On April 28, 2011, former Costa Rican President Miguel Angel Rodriguez (1998-2002) was convicted and sentenced to five years\u0027 imprisonment for his role in the Alcatel bribery case. (Sources: Samuel Rubenfeld, \u0022Former Costa Rican President Sentenced to Prison over Alcatel Bribery,\u0022 Wall Street Journal Corruption Currents Blog, April 28, 2011; Indictment\/La Acusacion de la Fiscalia posted at http:\/\/www.nacion.com\/Generales\/Subsitios\/Sucesos\/2010\/ICEALCATEL.aspx).","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Attorney General and Prosecutor\u0027s Office (Costa Rica)","Jurisdiction of Origin: Courts Involved":"Unknown","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/10-crm-1481%20%20doj%20press%20release%20dec%202010%20settlement.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Acusacion_Rodriguez.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alcatel_Transparency_Intl_Blog_Jan_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alcatel_UK_Anti-Corruption_Forum_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alcatel-Lucent_Company_Statement_September_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alcatel_Rodriguez_Conviction_Wall_Street_Journal_Apr_28_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/ICE DOJ Response_SDFLA_May_23_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/ICE%20DOJ%20Response_SDFLA_May_23_2011.pdf","Sources ":"La Acusacion de la Fiscalia, posted at http:\/\/www.nacion.com\/Generales\/Subsitios\/Sucesos\/2010\/ICEALCATEL.aspx; U.S. Department of Justice Press Release, \u0022Alcatel-Lucent S.A. and Three Subsidiaries Agree to Pay $92 Million to Resolve Foreign Corrupt Practices Act Investigation,\u0022 December 27, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/December\/10-crm-1481.html; \u0022Alcatel-Lucent, September 2010: A responsible behaviour - Controversies\u0022 posted at the company\u0027s website at http:\/\/www.alcatel-lucent.com\/csr\/htm\/en\/pdf\/Controversies_Costa_Rica.pdf; UK Anti-Corruption Forum, February 2010 Newsletter, posted at http:\/\/www.anticorruptionforum.org.uk\/acf\/upload\/newsletters\/2010-02.pdf); Transparency International Blog, Ahernandez, \u0022Can bribes paid by private firms cause \u0027social damage\u0027?\u0022 January 26, 2010 at http:\/\/blog.transparency.org\/2010\/01\/26\/can-bribes-paid-by-private-firms... US v. Alcatel-Lucent France S.A., et al, Case No. 1:10-cr-20906 (S.D.Fla.) and US v. Alcatel-Lucent, S.A., Case No. 1:10-cr-20907 (S.D.Fla), Government\u0027s Response to ICE\u0027s Petition for Victim Status and Restitution filed May 23, 2011, Exhibit 1: SETTLEMENT AGREEMENT BETWEEN ALCATEL-LUCENT FRANCE, AND THE OFFICE OF THE ATTORNEY GENERAL OF THE REPUBLIC, ON BEHALF OF THE COSTA RICAN STATE RELATING TO THE CIVIL RECOVERY ACTION INCLUDED IN CRIMINAL CASE 04-6835-647-PEA\n"},{"Case ID":"ARW-4","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alexander Yakovlev and Vladimir Kuznetsov \/ United Nations Oil-for-Food Programme","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United Nations","Position of Public Official(s) (yrs in office)":"United Nations Oil-for-Food Programme unit chief (Yakovlev, 1985-2005); United Nations budget advisory committee member (2000-2003) and chair (2004-2005) (Kuznetsov)","Jurisdiction of Asset Recovery":"Liechtenstein","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2005","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"In announcing Mr. Yakovlev\u0027s plea, Mr. David N. Kelley, then-United States Attorney for the Southern District of New York \u0022praised the investigative efforts of the Federal Bureau of Investigation. In addition, Mr. KELLEY thanked the United Nations Office of Investigative Oversight Services for its assistance in the investigation.\u0022 (Source: United States Attorney for the Southern District of New York, Press Release, \u0022Former U.N. Procurement Officer Pleads Guilty to Federal Charges Arising from His Receipt of Hundreds of Thousands of Dollars from Foreign Companies Doing Business with the U.N.,\u0022 August 8, 2005.); United Nations sharing of information with United States Attorney\u0027s Office for the Southern District of New York and UN waiver of immunity for Mr. Yakovlev (Source: Opening statement by UN Chief of Staff Mark Malloch-Brown at a press conference on the Oil-for-Food programme (8 August 2005).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"NA","Case Summary":"Former United Nations officials Vladimir Kuznetsov and Alexander Yakovlev were charged with corruption and money laundering in U.S. federal court for their respective roles in the United Nations Oil-for-Food Programme case.  Mr. Kuznetsov was convicted of one count of money laundering following a jury trial in the U.S. District Court for Southern District of New York and ordered to pay a criminal fine of $73,671.  He satisfied this judgment on November 18, 2008.  His co-conspirator Alexander Yakovlev pleaded guilty in 2005 to three counts of wire fraud and money laundering.  As part of his plea agreement, Mr. Yakovlev had agreed to forfeit $900,000 held in bank accounts in Liechtenstein.  On December 22, 2010, the federal court for the Southern District of New York ordered the following accounts forfeited to the U.S. (pending any assertions of third-party claims):  (1) Liechtensteinische Landesbank AG and LLB Treuhand AG, 9490 Vaduz, Accounts numbered 208.63898 and 213.042.67, in the name of Alexander Yakovlev or Olga Yakoleva; and (2) LLB AG and LLB Treuhand AG, 9490 Vaduz, Accounts numbered 212.440.51 and 213.036.32 in the name of Angelus Finance Ltd, for which Alexander Yakovlev is the financial beneficiary.  On February 10, 2011, the court ented a Satisfaction of Forfeiture Money Judgment, noting that the accounts had been forfeited by the Principality of Liechtenstein.  (Sources: U.S. v. Kuznetsov, Case No. 1:05-cr-00916-DAB (S.D.N.Y.), Judgment filed in a criminal case, filed October 19, 2007; U.S. v. Yakovlev, Case No. 1:05-cr-00819-DAB (S.D.N.Y.), Consent Order of Forfeiture filed on December 22, 2010; Satisfaction of Forfeiture Money Judgment, filed February 10, 2011.)","Disposition of Criminal Case(s)":"On December 22, 2010, Mr. Yakovlev was sentenced to two years\u0027 supervised release.  (Source: US v. Yakovlev, Case No. 1:05-cr-00819-DAB (S.D.N.Y.), Judgment in a Criminal Case, filed on December 22, 2010.)   His sentence followed a guilty plea on August 8, 2005 on three counts:  conspiracy to commit wire fraud, wire fraud and conspiracy to commit money laundering. (Source: Id.)   Mr. Kuznetsov was sentenced, on October 12, 2007, to 51 months\u0027 imprisonment and two years\u0027 supervised release.  (Source: U.S. v. Kuznetsov, Case No. 1:05-cr-00916-DAB (S.D.N.Y.), Judgment filed in a criminal case, filed October 19, 2007.)","Jurisdiction of Origin: Investigative Agency":"Independent Inquiry Committee into the United Nations Oil-for-Food Programme; UN Office of Investigative Oversight Services","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney Daniel Gitner, Counsel for the United Nations (in Yakovlev matter) (Source: U.S. v. Yakovlev, Case No. 1:05-cr-00819-DAB (S.D.N.Y.), Order to reschedule sentencing, filed on October 27, 2010.)","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, UN Independent Inquiry Committee into the United Nations Oil-for-Food Programme","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Southern District of New York","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kuznetsov_Judgment_Oct_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_Consent_Order_Forfeiture_Dec_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_Judgment_Dec_22_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_Plea_USASDNY_PR_Aug_8_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_Satisfaction_Forfeiture_Judgment_Feb_10_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_UN_Third_Interim_Report_Aug_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_UN_Waiver_Immunity_UN_Statement_Aug_8_2005\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yakovlev_UN_Waiver_Immunity_UN_Statement_Aug_8_2005.pdf","Sources ":"U.S. v. Yakovlev, Case No. 1:05-cr-00819-DAB, Consent Order of Forfeiture filed on December 22, 2010, Judgment in a Criminal Case, filed on December 22, 2010 and Satisfaction of Forfeiture Money Judgment, filed February 10, 2011. See also, United Nations Independent Inquiry Committee into the United Nations Oil-for-Food Programme, Third Interim Report: The Conduct of Benon Sevan, The Conduct of Alexander Yakovlev, at http:\/\/www.iic-offp.org\/documents\/Third%20Interim%20Report.pdf. U.S. v. Kuznetsov, Case No. 1:05-cr-00916-DAB (S.D.N.Y.), Judgment filed in a criminal case, October 19, 2007; United States Attorney for the Southern District of New York Press Release, \u0022Former U.N. Procurement Officer Pleads Guilty to Federal Charges arising from His Receipt of Hundreds of Thousands of Dollars from Foreign Companies Doing Business with the U.N.,\u0022 August 8, 2005, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/August05\/yakovlevpleapr.pdf; Opening statement by UN Chief of Staff Mark Malloch-Brown at a press conference on the Oil-for-Food programme (8 August 2005), accessed at http:\/\/www.un.org\/News\/dh\/iraq\/oip\/open_stmnt_8aug05.htm\n"},{"Case ID":"ARW-5","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alexander Yakovlev and Vladimir Kuznetsov \/ United Nations Oil-for-Food Programme","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United Nations","Position of Public Official(s) (yrs in office)":"United Nations Oil-for-Food Programme unit chief (Yakovlev, 1985-2005); United Nations budget advisory committee member (2000-2003) and chair (2004-2005) (Kuznetsov)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2005","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"In announcing Mr. Yakovlev\u0027s plea, Mr. David N. Kelley, then-United States Attorney for the Southern District of New York \u0022praised the investigative efforts of the Federal Bureau of Investigation. In addition, Mr. KELLEY thanked the United Nations Office of Investigative Oversight Services for its assistance in the investigation.\u0022 (Source: United States Attorney for the Southern District of New York, Press Release, \u0022Former U.N. Procurement Officer Pleads Guilty to Federal Charges Arising from His Receipt of Hundreds of Thousands of Dollars from Foreign Companies Doing Business with the U.N.,\u0022 August 8, 2005.); United Nations sharing of information with United States Attorney\u0027s Office for the Southern District of New York and UN waiver of immunity for Mr. Yakovlev (Source: Opening statement by UN Chief of Staff Mark Malloch-Brown at a press conference on the Oil-for-Food programme (8 August 2005).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"Former United Nations officials Vladimir Kuznetsov and Alexander Yakovlev were charged with corruption and money laundering in U.S. federal court for their respective roles in the United Nations Oil-for-Food Programme case.  Mr. Kuznetsov was convicted of one count of money laundering following a jury trial in the U.S. District Court for Southern District of New York and ordered to pay a criminal fine of $73,671.  He satisfied this judgment on November 18, 2008.  His co-conspirator Alexander Yakovlev pleaded guilty in 2005 to three counts of wire fraud and money laundering.  As part of his plea agreement, Mr. Yakovlev had agreed to forfeit $900,000 held in bank accounts in Liechtenstein.  On December 22, 2010, the federal court for the Southern District of New York ordered the following accounts forfeited to the U.S. (pending any assertions of third-party claims):  (1) Liechtensteinische Landesbank AG and LLB Treuhand AG, 9490 Vaduz, Accounts numbered 208.63898 and 213.042.67, in the name of Alexander Yakovlev or Olga Yakoleva; and (2) LLB AG and LLB Treuhand AG, 9490 Vaduz, Accounts numbered 212.440.51 and 213.036.32 in the name of Angelus Finance Ltd, for which Alexander Yakovlev is the financial beneficiary.  On February 10, 2011, the court ented a Satisfaction of Forfeiture Money Judgment, noting that the accounts had been forfeited by the Principality of Liechtenstein.  (Sources: U.S. v. Kuznetsov, Case No. 1:05-cr-00916-DAB (S.D.N.Y.), Judgment filed in a criminal case, filed October 19, 2007; U.S. v. Yakovlev, Case No. 1:05-cr-00819-DAB (S.D.N.Y.), Consent Order of Forfeiture filed on December 22, 2010; Satisfaction of Forfeiture Money Judgment, filed February 10, 2011.)","Disposition of Criminal Case(s)":"On December 22, 2010, Mr. Yakovlev was sentenced to two years\u0027 supervised release.  (Source: US v. Yakovlev, Case No. 1:05-cr-00819-DAB (S.D.N.Y.), Judgment in a Criminal Case, filed on December 22, 2010.)   His sentence followed a guilty plea on August 8, 2005 on three counts:  conspiracy to commit wire fraud, wire fraud and conspiracy to commit money laundering. (Source: Id.)   Mr. Kuznetsov was sentenced, on October 12, 2007, to 51 months\u0027 imprisonment and two years\u0027 supervised release.  (Source: U.S. v. Kuznetsov, Case No. 1:05-cr-00916-DAB (S.D.N.Y.), Judgment filed in a criminal case, filed October 19, 2007.)","Jurisdiction of Origin: Investigative Agency":"Independent Inquiry Committee into the United Nations Oil-for-Food Programme; UN Office of Investigative Oversight Services","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney Daniel Gitner, Counsel for the United Nations (in Yakovlev matter) (Source: U.S. v. Yakovlev, Case No. 1:05-cr-00819-DAB (S.D.N.Y.), Order to reschedule sentencing, filed on October 27, 2010.)","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, UN Independent Inquiry Committee into the United Nations Oil-for-Food Programme","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Southern District of New York","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kuznetsov_Judgment_Oct_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_Consent_Order_Forfeiture_Dec_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_Judgment_Dec_22_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_Plea_USASDNY_PR_Aug_8_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_Satisfaction_Forfeiture_Judgment_Feb_10_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_UN_Third_Interim_Report_Aug_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_UN_Waiver_Immunity_UN_Statement_Aug_8_2005\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yakovlev_UN_Waiver_Immunity_UN_Statement_Aug_8_2005_0.pdf","Sources ":"U.S. v. Yakovlev, Case No. 1:05-cr-00819-DAB, Consent Order of Forfeiture filed on December 22, 2010, Judgment in a Criminal Case, filed on December 22, 2010 and Satisfaction of Forfeiture Money Judgment, filed February 10, 2011. See also, United Nations Independent Inquiry Committee into the United Nations Oil-for-Food Programme, Third Interim Report: The Conduct of Benon Sevan, The Conduct of Alexander Yakovlev, at http:\/\/www.iic-offp.org\/documents\/Third%20Interim%20Report.pdf. U.S. v. Kuznetsov, Case No. 1:05-cr-00916-DAB (S.D.N.Y.), Judgment filed in a criminal case, October 19, 2007; United States Attorney for the Southern District of New York Press Release, \u0022Former U.N. Procurement Officer Pleads Guilty to Federal Charges arising from His Receipt of Hundreds of Thousands of Dollars from Foreign Companies Doing Business with the U.N.,\u0022 August 8, 2005, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/August05\/yakovlevpleapr.pdf.\n"},{"Case ID":"ARW-6","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alfonso Portillo (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Guatemala","Position of Public Official(s) (yrs in office)":"President (2000-2004)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2012","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Unknown","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Unknown","Stage in Asset Recovery Chain":"Unknown","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"As part of his plea agreement, Mr. Portillo admitted that while serving as President of Guatemala, he had received US$2.5 million from the government of China, Taiwan purportedly for the \u0022Libraries for Peace\u0022 project but was in exchange for Guatemala\u0027s continued recognition of China, Taiwan\u0027s sovereignty.  (Source: US v. Portillo, Case No. 1:09-cr-01142-RPP (S.D.N.Y.), Judgment in a criminal case filed June 11, 2014 and US Government Sentencing Memorandum filed May 12, 2014.)  The 2009 Indictment filed against Mr. Portillo by the U.S. Attorney\u0027s Office for the Southern District of New York had alleged that Mr. Portillo laundered the funds through bank accounts located in a number of jurisdictions, including Switzerland.  Two wire transfers were made in August 2004 (for $337,976.16 and 1,234,439.81 Euros) from accounts in France to accounts at Banco Audi Suisse S.A. in Switzerland held in the names of Mr. Portillo\u0027s former wife and daughter; in June 2005, a trust was established in Liechtenstein (the beneficiaries of which were Mr. Portillo\u0027s former wife and daughter) into which all the money maintained at the Banco Audi Suisse S.A. was transferred and thereafter, held in the name of the trust and two disbursements were made by the trust, in the sum of $8,000 to his daughter and $10,000 to his former wife in July 2006 and in September 2006, respectively, from the Banco Audi Suisse S.A. account. (Source: U.S. v. Portillo, Case No. 1:09-cr-01142-RPP (S.D.N.Y.), Indictment filed on December 1, 2009 and unsealed on January 25, 2010; Court Docket Report as of March 19, 2014.)  As part of his judgment in the US criminal case, Mr. Portillo consented to and was sentenced to forfeit US$2.5 million to the U.S. representing criminal proceeds.  (Source: US v. Portillo, Case No. 1:09-cr-01142-RPP (S.D.N.Y.), Judgment in a criminal case filed June 11, 2014.)","Disposition of Criminal Case(s)":"According to the US court records, Mr. Portillo pleaded guilty to one count of conspiracy to commit money laundering in the United States District Court for the Southern District of New York; in June 2014, he was sentenced to 70 months\u0027 imprisonment.  (Source: US v. Portillo, Case No. 1:09-cr-01142-RPP (S.D.N.Y.), Judgment in a Criminal Case, filed June 11, 2014)","Jurisdiction of Origin: Investigative Agency":"Comision Internacional Contra la Impunidad en Guatemala (International Commission Against Impunity in Guatemala)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Comision Internacional Contra la Impunidad en Guatemala (International Commission Against Impunity in Guatemala), Special Prosecutor\u0027s Office","Jurisdiction of Origin: Courts Involved":"Tribunal Undecimo de Sentencia Penal (Eleventh Court of Criminal Judgment)","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_SDNY_Dkt_Rept_as_of_Mar_19_2014_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Consent_Forfeiture_Order_May_22_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Judgment_June_11_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Sentencing_PR_May_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Indictment.pdf","Sources ":"U.S. v. Portillo, Case No. 1:09-cr-01142-RPP (S.D.N.Y.), Indictment filed on December 1, 2009, unsealed on January 25, 2010; US Government Sentencing Memorandum filed May 12, 2014; Judgment in a Criminal Case filed June 11, 2014.\n"},{"Case ID":"ARW-7","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alfonso Portillo (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Guatemala","Position of Public Official(s) (yrs in office)":"President (2000-2004)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Request for Extradition","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"Consent Preliminary Order of Forfeiture","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"As part of his plea agreement, Mr. Portillo admitted that while serving as President of Guatemala, he had received US$2.5 million from the government of China, Taiwan purportedly for the \u0022Libraries for Peace\u0022 project but was in exchange for Guatemala\u0027s continued recognition of China, Taiwan\u0027s sovereignty. \u00a0(Source: US v. Portillo, Case No. 1:09-cr-01142-RPP (S.D.N.Y.), Judgment in a criminal case filed June 11, 2014 and US Government Sentencing Memorandum filed May 12, 2014.) \u00a0 The 2009 indictment filed by the U.S. Attorney for the Southern District of New York \u00a0alleged that the criminal proceeds had been laundered through a complex scheme involving close associates and family members and shell entities, involving banks in Florida and New York (as well those in England, France, Luxembourg, and Switzerland). \u00a0(Source: U.S. v. Portillo, Case No. 1:09-cr-01142-RPP (S.D.N.Y.), Indictment filed December 1, 2009 and unsealed on January 25, 2010.) \u00a0According to a US Department of State press briefing transcript of November 11, 2011, the US spokesman stated that \u0022We understand that President Colom has upheld the Guatemalan Constitutional Court\u2019s August 26 decision that authorized the extradition of former President Alfonso Portillo to the United States on charges of conspiracy to commit money-laundering.\u0022 \u00a0(Source: US Department of State Daily Press Briefing transcript, \u0022 U.S. Extradition Request for Former President Alfonso Portillo,\u0022 November 17, 2011, filed May 10, 2012 in US v. Portillo, 1:09-cr-01142 (SDNY), accessed via PACER.) \u00a0In May 2010, the US federal court for Southern District of New York denied Mr. Portillo\u0027s habeas petition which had challenged his custody in Guatemala based on the US extradition request. \u00a0(Source: US v. Portillo, Case No. 1:09-cr-01142 (SDNY), Opinion and Order filed May 10, 2012.) After the Indictment was unsealed, in 2010, Mr. Portillo was arrested in Guatemala, and detained pending his extradition to the United States. \u00a0In May 2013, he was extradited to the United States and remanded into custody. \u00a0(Source: \u00a0US v. Portillo, 1:09-cr-1142 (SDNY), Order of Remand May 28, 2013).","Disposition of Criminal Case(s)":"According to the US court records, Mr. Portillo pleaded guilty to one count of conspiracy to commit money laundering in the United States District Court for the Southern District of New York; in June 2014, he was sentenced to 70 months\u0027 imprisonment.  (Source: US v. Portillo, Case No. 1:09-cr-01142-RPP (S.D.N.Y.), Judgment in a Criminal Case, filed June 11, 2014)","Jurisdiction of Origin: Investigative Agency":"Comision Internacional Contra la Impunidad en Guatemala (International Commission Against Impunity in Guatemala)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Comision Internacional Contra la Impunidad en Guatemala (International Commission Against Impunity in Guatemala), Special Prosecutor\u0027s Office","Jurisdiction of Origin: Courts Involved":"Tribunal Undecimo de Sentencia Penal (Eleventh Court of Criminal Judgment)","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Internal Revenue Service, New York Field Office; U.S. Drug Enforcement Administration, New York Field Division","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Southern District of New York","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_SDNY_Opinion_Extradition_May_10_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_SDNY_USG_Extradition_Request_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Mem_Law_Support_Portillo_Pre_Trial_Mtns_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Remand_May_28_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_SDNY_Dkt_Rept_as_of_Mar_19_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Judgment_June_11_2014_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Sentencing_PR_May_2014_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Consent_Forfeiture_Order_May_22_2014_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Ct_Dkt_Rept_03182014_to_07272014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_SDNY_Indictment_Dec_2009.pdf","Sources ":"U.S. v. Portillo, Case No. 1:09-cr-01142-RPP (S.D.N.Y), Indictment filed December 1, 2009 and unsealed on January 25, 2010, and Status Report by U.S. Attorney dated January 25, 2010; Press Release by the United States Attorney for the Southern District of New York, \u0022Manhattan U.S. Attorney Unseals Money Laundering Charge against Former President of Guatemala,\u0022 January 25, 2010, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/January10\/portilloalfonsoi... US Department of State Daily Press Briefing transcript, \u0022 U.S. Extradition Request for Former President Alfonso Portillo,\u0022 November 17, 2011, filed May 10, 2012 and Opinion and Order filed May 10, 2012, Order of Remand filed May 28, 2013, US Government Sentencing Memorandum filed May 12, 2014, and Judgment in a Criminal Case filed June 11, 2014, in US v. Portillo, Case No. 1:09-cr-01142 (SDNY), accessed via PACER.\n"},{"Case ID":"ARW-14","Case Title (Name of Public Official or Entity Allegedly Involved)":"Aluminum Bahrain B.S.C. \/ Alcoa Case (Private Civil Action)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Bahrain","Position of Public Official(s) (yrs in office)":"Senior Officials of State Owned Entity (unnamed)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2008","Asset Recovery End":"2013","UNCAC Offenses Implicated":"Art.16, Art.18, Art.21","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Private civil action resulted in settlement agreement.","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"In October 2012, Alcoa Inc. announced that it had reached an $85 million settlement agreement with Aluminum Bahrain B.S.C. (\u0022Alba\u0022), a majority state owned enterprise to settle the civil suit that Alba had filed in 2008, in U.S. District Court for the Western District of Pennsylvania against the U.S. company and related parties. (Source: Aluminum Bahrain B.S.C. v. Alcoa, Inc., et al, Case No. 2:08-cv-00299-DWA (W.D. Pa.), Stipulation of Dismissal with Prejudice, filed October 9, 2012; Alcoa Press Release, \u0022Alcoa and Alba Resolve Civil Litigation,\u0022 October 9, 2012.) In 2009, it filed a similar suit in the Southern District of Texas against the Japanese company Sojitz Corporation and its U.S. affiliate, Sojitz Corporation of America. Alba alleged that the companies paid bribes to one or more senior officials of Alba and the Government of Bahrain in order to induce Alba to cede a controlling interest in that company to Alcoa and to overpay for alumina and in the Sojitz case, to secure below-market discounts on aluminum. In filing the civil Racketeer Influenced and Corrupt Organizations (RICO) suit against Alcoa, Alba sought damages in excess of $1 billion and in the Sojitz suit, $31 million in damages. According to Alcoa, the second of the two payments to Alba was completed in October 2013. (Source: Alcoa, Stakeholder Engagement, \u0022Committed to Ongoing, Transparent Engagement,\u0022 http:\/\/www.alcoa.com\/sustainability\/en\/info_page\/community_stakeholder.asp, accessed on July 27, 2014.)","Disposition of Criminal Case(s)":"The asset recovery resulted from a private civil action by the state owned entity.  In related enforcement actions by the US, in January 2014, Alcoa entered into settlements with the US Department of Justice and the Securities and Exchange Commission which included a guilty plea to one count of violation of the Foreign Corrupt Practices Act. (Source: US Department of Justice Press Release, \u0022Alcoa World Alumina Agrees to Plead Guilty to Foreign Bribery and Pay $223 Million in Fines and Forfeiture,\u0022 January 9, 2014.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Alcoa DOJ Enorcement: Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Pennsylvania and Texas: Akin Gump Strauss Hauer and Feld LLP (Lead Attorneys Colleen M. Coyle, Lauren B. Kerwin, Mark J. MacDougall);  Pennsylvania:  Buchanan Ingersoll \u0026 Rooney PC (Attorney Charles B. Gibbons); Department of Justice, Criminal Division, Fraud Section; U.S. Attorney\u0027s Office for the Southern District of Texas","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Western District of Pennsylvania and the U.S. District Court for the Southern District of Texas","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Complaint_Feb_27_2008.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Motion_Stay_Mar_20_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_Complaint_Dec_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_US_Justice_Department_Application_Intervene_May_27_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Aluminum_Bahrain_Amended_Complaint_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Complaint_Feb_27_2008.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Motion_Stay_Mar_20_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_Complaint_Dec_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_US_Justice_Department_Application_Intervene_May_27_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Aluminum_Bahrain_WDPA_Stipulation_Dismiss_Oct_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Complaint_Feb_27_2008.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Motion_Stay_Mar_20_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_Complaint_Dec_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_US_Justice_Department_Application_Intervene_May_27_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Aluminum_Bahrain_WDPA_Order_Reopen_Case_Nov_2011_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Complaint_Feb_27_2008.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Motion_Stay_Mar_20_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_Complaint_Dec_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_US_Justice_Department_Application_Intervene_May_27_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alba_Sojitz_US_SDTEX_Stipulation_Dismissal_Dec_21_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Complaint_Feb_27_2008.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Motion_Stay_Mar_20_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_Complaint_Dec_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_US_Justice_Department_Application_Intervene_May_27_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alba_Sojitz_US_SDTEX_Order_Dismissal_Jan_16_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Complaint_Feb_27_2008.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Motion_Stay_Mar_20_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_Complaint_Dec_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_US_Justice_Department_Application_Intervene_May_27_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/ALBA_Alcoa_US_DOJ_SEC_Settlement_PR_Jan_9_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Complaint_Feb_27_2008.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Motion_Stay_Mar_20_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_Complaint_Dec_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_US_Justice_Department_Application_Intervene_May_27_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alba_Alcoa_Stakeholder%20Engagement_Jul_27_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Complaint_Feb_27_2008.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Motion_Stay_Mar_20_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_Complaint_Dec_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_US_Justice_Department_Application_Intervene_May_27_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/ALBA_Alcoa_WDPA_Judgment_Jan_09_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Complaint_Feb_27_2008.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Motion_Stay_Mar_20_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_Complaint_Dec_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_US_Justice_Department_Application_Intervene_May_27_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/ALBA_Alcoa_WDPA_Plea_Agreement_Jan_09_2014.pdf","Sources ":"\n\n\t\tAluminum Bahrain B.S.C. v. Alcoa, Inc., Alcoa World Alumina LLC, et al, Case No. 2:08-cv-00299-DWA (W.D. Pa.), First Amended Complaint filed on November 28, 2011; and Stipulation to Dismiss with Prejudice filed October 9, 2012; Aluminum Bahrain B.S.C. v. Sojitz Corporation and Sojitz Corporation of America, Case No. 4:09-cv-04032 (S.D. Tex), Complaint filed on December 18, 2009, and United States\u0027 Application to Intervene and Stay Proceedings in the Instant Proceedings filed on May 27, 2010; Stipulation and Order to Dismiss, filed December 21, 2012 and January 16, 2013 respectively; Alcoa Press Release, \u0022Alcoa and Alba Resolve Civil Litigation,\u0022 October 9, 2012, accessed at http:\/\/www.alcoa.com\/global\/en\/news\/news_detail.asp?pageID=2012100900636....\n\n\t\t\u00a0\n\n\t\tAlcoa, Stakeholder Engagement, \u0022Committed to Ongoing, Transparent Engagement,\u0022 at http:\/\/www.alcoa.com\/sustainability\/en\/info_page\/community_stakeholder.asp (accessed on July 27, 2014); US Department of Justice Press Release, \u0022Alcoa World Alumina Agrees to Plead Guilty to Foreign Bribery and Pay $223 Million in Fines and Forfeiture,\u0022 January 9, 2014, at http:\/\/www.justice.gov\/opa\/pr\/2014\/January\/14-crm-019.html.\n\n\u00a0\n"},{"Case ID":"ARW-16","Case Title (Name of Public Official or Entity Allegedly Involved)":"Angolagate","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"","Position of Public Official(s) (yrs in office)":"Unspecified","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2000","Asset Recovery End":"2012","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Other","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"A monitoring solution for repatriated assets, involving Swiss bilateral aid channels was agreed upon with the administrative costs and fiduciary responsibilities borne by the Swiss Agency for Development and Cooperation (SDC) and implementation unit comprised of  SDC and Angolan representatives (Source: Ann Lugon-Moulin, \u0022Asset Recovery: Concrete Challenges for Development Assistance,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008).  ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Agreement between Angola and Switzerland for returned funds to be allocated to humanitarian projects in Angola; eligible projects include reconstruction, health and sanitation units, improvement of public utilitites and assistance to displaced populations.  Monitoring to be undertaken by the Swiss Development and Co-operation Agency (which is part of the Swiss Ministry of Foreign Affairs).  (Source: Paul Gully-Hart, \u0022International asset recovery of corruption-related assets: Switzerland,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (2008).  SHP Programme website, www.psh-angola.net - projects to date: $4.2 million for vocational training in two provinces and mine clearance project.)","Case Summary":"\n\tOn December 17, 2012, the Swiss Federal Department of Foreign Affairs announced that Switzerland and Angola signed an agreement, whereby Switzerland will return $43 million (SFr39.5 million) in frozen assets to Angola. According to the press release from the Swiss Agency for Development and Cooperation, the backdrop to the restitution are judicial proceedings of the Geneva judicial authorities regarding alleged money laundering, which at the end of 2008 led to the confiscation of the assets now to be restituted. The money will be used to fund development projects that directly benefit the population of Angola. (Source: Swiss Agency for Development and Cooperation Press Release, December 17, 2012.) \u00a0According to the terms of the agreement, Switzerland and Angola will implement the agreement jointly. The Swiss Agency for Development and Cooperation (SDC) will be responsible for its implementation on behalf of Switzerland, and the funds will benefit similar purposes as the first asset return. (Source: \u00a0Gretta Fenner Zinkernagel and Kodjo Attisso, International Centre for Asset Recovery, \u201cReturning Stolen Assets - Learning from past practice: Selected case studies\u201d [2013]).\u00a0\n\n\t\u00a0\n\n\tIn 2005, Switzerland and Angola signed an agreement to return $21 million to Angola. The funds were allocated to humanitarian projects in Angola, and monitored by the Swiss Development and Co-operation Agency (which is part of the Swiss Ministry of Foreign Affairs). Eligible projects include reconstruction, health and sanitation units, improvement of public utilities and assistance to displaced populations. (Source: Paul Gully Hart, \u0022International asset recovery of corruption-related assets: Switzerland,\u0022 in Mark Pieth ed., Recovering Stolen Assets (2008). According to the Social and Humanitarian Programme\u0027s website, $4.2 million had been allocated for vocational training in two provinces and other (unspecified) sums for a mine clearance project and agricultural development. (Source: SHP Programme, \u0022The reached results so far,\u0022 accessed at http:\/\/www.psh-angola.net\/en\/Home\/Projects.). Please see also, Swiss Federal Department of Foreign Affairs, \u0022Angolan-Swiss Socio-humanitarian Programme (SHP): Priorities,\u0022 at http:\/\/www.ddc.admin.ch\/en\/Home\/Countries\/Eastern_and_Central_Africa\/Ang...","Disposition of Criminal Case(s)":"According to the press release by the Swiss Agency for Development and Cooperation, unspecified \u0022criminal proceedings initiated by the Geneva judicial authorities were done so in connection with the restructuring of the Angolan debt to the Russian Federation.:\u00a0 (Source:\u00a0 Swiss Agency for Development and Cooperation, \u0022Switzerland and Angola sign agreement on the return of Angolan funds currently blocked in Switzerland to benefit humanitarian projects,\u0022 November 1, 2005, accessed at http:\/\/www.deza.admin.ch\/en\/Home\/News\/Close_up?itemID=21008.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Geneva Judicial Authorities","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Geneva Judicial Authorities","Jurisdiction of Asset Recovery: Courts Involved":"Geneva Judicial Authorities","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_France_Three_Acquitted_Associated_Press_Apr_29_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_Switzerland_Dictators_Assets_Mar_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_Switzerland_PSH_Angola_Projects_to_Date.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Angolagate_Swiss_Development_Agency_Press_Release_Nov_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_France_Three_Acquitted_Associated_Press_Apr_29_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_Switzerland_Dictators_Assets_Mar_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_Switzerland_PSH_Angola_Projects_to_Date.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Angolagate_Swiss_Asset_Return_PR_Dec_17_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_France_Three_Acquitted_Associated_Press_Apr_29_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_Switzerland_Dictators_Assets_Mar_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_Switzerland_PSH_Angola_Projects_to_Date.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Angolagate_Swiss_ICAR_Case_Study_2013.pdf","Sources ":"Switzerland website at www.psh-angola.net (last accessed November 10, 2013); Switzerland Federal Department of Foreign Affairs, \u0022Dictators\u0027 assets (Potentate funds),\u0022 October 4, 2010, accessed at http:\/\/www.eda.admin.ch\/eda\/en\/home\/topics\/finec\/intcr\/poexp.html; Paul Gully-Hart, \u0022International asset recovery of corruption-related assets: Switzerland,\u0022 and Ann Lugon-Moulin, \u0022Asset Recovery: Concrete Challenges for Development Assistance,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008). See also Swiss Agency for Development and Cooperation, \u0022Switzerland and Angola sign agreement on the return of Angolan funds currently blocked in Switzerland to benefit humanitarian projects,\u0022 November 1, 2005, accessed at http:\/\/www.deza.admin.ch\/en\/Home\/News\/Close_up?itemID=21008. Swiss Agency for Development and Cooperation Press Release, December 17, 2012, accessed at http:\/\/www.deza.admin.ch\/en\/Home\/News\/Close_up?itemID=217972; Gretta Fenner Zinkernagel and Kodjo Attisso, International Centre for Asset Recovery, \u201cReturning Stolen Assets - Learning from past practice: Selected case studies,\u0022 at http:\/\/www.baselgovernance.org\/fileadmin\/docs\/pdfs\/Events\/131024_Selecte...\n"},{"Case ID":"ARW-33","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ao Man Long (Hong Kong SAR, China)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"","Position of Public Official(s) (yrs in office)":"Secretary of Transport and Public Works (1999-2006)","Jurisdiction of Asset Recovery":"Hong Kong SAR, China","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"2009","UNCAC Offenses Implicated":"Art.16, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"The discrepancy between asset declarations filed by Mr. Ao and his wife as public officials and their assets was used as evidence against them.  Search of Mr. Ao\u0027s government-provided residence yielded a notebook containing details of his illegal bank accounts. (Source: Statements by the Commission Against Corruption in Macao SAR posted on its website.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$56,755,400","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to a public statement by the Macau Public Prosecution Office, US$56,755,400 has been recovered from Hong Kong SAR from bank accounts held in the names of inidividuals and companies of Mr. Ao and his family members.  (Source: \u0022The Public Prosecution Office has retrieved over HK$80,000,000 for the Macao SAR in the Ao Man Long case,\u0022 December 15, 2014, at http:\/\/www.mp.gov.mo\/en\/news\/2014\/news20141215en.pdf)\nAccording to Professor Simon N. M. Young of Hong Kong University Law School, due to an absence of a Mutual Legal Assistance Treaty between Macao and Hong Kong, Macao filed a civil suit to recover Mr. Ao\u0027s illicit assets from Hong Kong, SAR.  (Source: Simon N.M. Young, \u0022Why civil actions against corruption,\u0022 Journal of Financial Crime, Vol. 16, No. 2 (2009), pp. 144-159.)  Commission Against Corruption in Macao SAR stated on its website (February 5, 2009) that the Hong Kong High Court held the first hearing on February 4, 2009 concerning the recovery of the bribe money - HKD140 million deposited in 39 bank accounts and HKD80 million cash in different currencies kept in a safety deposit box.  (Source: http:\/\/www.ccac.org.mo\/en\/)  According to Macau News, in February 2009, the Hong Kong Court of First Instance Madame Justice Carlye Chu Fun-ling granted a judgment as part of the confiscation order sought by Macau\u0027s government to recover assets Mr. Ao and his relatives had retained in Hong Kong.  (Source: Macau News, \u0022\u0022Former Macau\u0027s secretary of transport and public works Ao Man Long to face second trial next week,\u0022 February 13, 2009.)  Civil actions are private in Hong Kong, and therefore, a copy of the judgment is not publicly available.  However, Hong Kong court decisions in the case initiated by Philip P.H. Wong, Kennedy, Y.H. Wong \u0026 Co. (a firm of solicitors) and Philip (Nominees) Limited challenging search warrants carried out by the Hong Kong\u0027s Independent Commission Against Corruption gives some insight into the Hong Kong authorities\u0027 role in the investigation of Mr. Ao\u0027s corporate entities formed through the corporate service provider. (Source: Between Philip P.H. Wong, Kennedy, Y.H. Wong \u0026 Co. (a firm of solicitors), Philip (Nominees) Limited and The Commissioner of the Independent Commission Against Corruption, CACV 4\/2008 and CACV 272\/2008, on appeal from HCAL No. 70 of 2007.)","Disposition of Criminal Case(s)":"According to statements by the Commission Against Corruption in Macao SAR, Mr. Ao was tried and convicted by the Macao Court of Final Appeal in two separate trials that ended in January 2008 and April 2009, respectively.  (Sources: Commission Against Corruption in Macao SAR, \u0022What\u0027s New - Detected Cases,\u0022 June 4, 2008 and \u0022What\u0027s New - Detected Cases,\u0022 April 22, 2009.)","Jurisdiction of Origin: Investigative Agency":"Commission Against Corruption of Macao SAR","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Macao Public Prosecutions Office","Jurisdiction of Origin: Courts Involved":"Macao Court of First Instance","Jurisdiction of Asset Recovery: Investigative Agency":"Independent Commission Against Corruption","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney Jacky Cheung (private civil action)","Jurisdiction of Asset Recovery: Courts Involved":"Hong Kong Court of First Instance","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Assets_Macau_Daily_Times_Nov_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macao_Anti-Corruption_Commission_Feb_5_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Anti-Corruption_Commission_Detected_Case_Apr_4_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_News_Second_Trial_Feb_13_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Case_36_2007_Judgment_Jan_30_2008_Chinese.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Case_36_2007_Judgment_Jan_30_2008_Portuguese.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Case_53_2008_Judgment_Apr_22_2009_Chinese.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Case_53_2008_Judgment_Apr_22_2009_Portuguese.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Second_Trial_Judgment_Apr_22_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Wong_ICAC_Commissioner_CACV_4_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ao_HK_Explain_Assets_Macau_Daily_Nov_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Assets_Macau_Daily_Times_Nov_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macao_Anti-Corruption_Commission_Feb_5_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Anti-Corruption_Commission_Detected_Case_Apr_4_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_News_Second_Trial_Feb_13_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Case_36_2007_Judgment_Jan_30_2008_Chinese.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Case_36_2007_Judgment_Jan_30_2008_Portuguese.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Case_53_2008_Judgment_Apr_22_2009_Chinese.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Case_53_2008_Judgment_Apr_22_2009_Portuguese.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Second_Trial_Judgment_Apr_22_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Wong_ICAC_Commissioner_CACV_4_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ao_Macao_PPO_PR_Dec_15_2014.pdf","Sources ":"Statements by Commission Against Corruption in Macao SAR (April 22, 2009 and February 5, 2009) and others posted on its official website at http:\/\/www.ccac.org.mo\/en\/; \n\u0022The Public Prosecution Office has retrieved over HK$80,000,000 for the Macao SAR in the Ao Man Long case,\u0022 December 15, 2014, at http:\/\/www.mp.gov.mo\/en\/news\/2014\/news20141215en.pdf;\nMacau News, \u0022Former Macau\u0027s secretary of transport and public works Ao Man Long to face second trial next week,\u0022 February 13, 2009, accessed at http:\/\/www.macaunews.com.mo\/index.php?option=com_content\u0026task=view\u0026id=30... Simon N.M.Young, \u0022Why civil actions against corruption,\u0022 Journal of Financial Crime, Vol. 16, No. 2 (2009) at 144-159 (purchased online); Philip P.H. Wong, Kennedy, Y.H. Wong \u0026 Co. (a firm of solicitors), Philip (Nominees) Limited and The Commissioner of the Independent Commission Against Corruption, CACV 4\/2008 and CACV 272\/2008, on appeal from HCAL No. 70 of 2007. Macao court judgments in Mr. Ao\u0027s underlying cases:  Acordam No Tribunal de Ultima Instancia da Regiao Administrativa Especial de Macau, Processo no. 36\/2007 and Acordao do Tribunal de Ultima Instancia da Regiao Administrative Especial de Macau, Processo cmum colectivo No. 53\/2008 (in Portuguese and Chinese).\n"},{"Case ID":"ARW-35","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ao Man Long (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"","Position of Public Official(s) (yrs in office)":"Secretary of Transport and Public Works (1999-2006)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"2015","UNCAC Offenses Implicated":"Art.16, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty between Hong Kong SAR, China and the United Kingdom; United Nations Convention against Corruption ","Contributing Factors in Asset Recovery":"According to Daniel Li, Deputy Commissioner of the Hong Kong Independent Commission Against Corruption (ICAC), \u0022This is one of the successful cases of cooperation between ICAC and other jurisdictions when asset recovery was involved.  All assets have been or are currently destined to be returned to Macao.  We could have taken the attitude that it is not our concern and simply carried out the minimal requirements of informing the Macao authorities and then sitting back and giving a minimal response, especially as this specific law germane to asset confiscation was not as such available between the two jurisdictions.  However we took up this challenge seriously; officers from Hong Kong and Macao worked tirelessly and enthusiastically, and, as a result, AO and his corrupt associates were deprived of vast profits from his criminal enterprise.\u0022 (Source: Daniel M C Li,  Deputy Commissioner and Head of Operations, Independent Commission Against Corruption, Hong Kong Special Administrative Region, \u0022Asset Recovery: Is Law Enforcement doing enough?, \u0022  The 4th IAACA Seminar, Dalian, People\u2019s Republic of China, 25 \u2013 28 June 2012.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"","Case Summary":"In November 2015, the Office of the Secretary for Administration and Justice of Macao SAR, China issued a statement announcing the return from UK of USD44,245,300 in corruption assets in Mr. Ao\u0027s case. According to the statement, Ms. Chan Hoi Fan, Secretary for Administration and Justice of the Macao Special Administrative Region, \u0022indicated that the UNCAC, as an international anti-corruption instrument, has established a very important legal system for fighting corruption at international level. The mechanisms for recovery of property and return of assets, in particular, provided the legal basis on which we are able to establish close cooperation with and to recover the illicit assets from the British Government. In 2010, with the strong support and assistance from the Central Government, the Macao SAR Government conveyed the request to the British Government via diplomatic channels for returning the corruption proceeds in Ao\u2019s case.\u0022 (Source:Office of the Secretary for Administration and Justice of Macao SAR, China, \u0022Most of the Illicit Assets Abroad in the Case of Ao Man Long Successfully Recovered,\u0022 November 3, 2015.)\nIn April 2007, the Commission Against Corruption in Macao SAR, China had reported on its location and seizure of more than 790 million patacas (USD$95 million) in Mr. Ao\u0027s accumulated assets, and stated that \u0022Until December 2006...the cash and bonds in Britain and other countries were equivalent to 275 million patacas.\u0022 (Source: Commission Against Corruption in Macao SAR, \u0022What\u0027s New - Detected Cases,\u0022 April 7, 2007.)    In June 2012, the Deputy Head of Hong Kong SAR, China\u0027s Independent Commission Against Corruption stated in a presentation that with regard to Mr. Ao\u0027s case, \u0022During the course of the asset tracing exercise we discovered that substantial funds had been sent to the United Kingdom and used to purchase a property.  This disclosed an offence of money laundering in Hong Kong and therefore we invoked Mutual Legal Assistance between Hong Kong and the UK as a means of freezing any potential sale of this property.  Eventually the property was sold under a court order and the funds are now banked in the UK awaiting repatriation to Macao.\u0022 (Source: Daniel M C Li,  Deputy Commissioner and Head of Operations, Independent Commission Against Corruption, Hong Kong Special Administrative Region, \u0022Asset Recovery: Is Law Enforcement doing enough?, \u0022  The 4th IAACA Seminar, Dalian, People\u2019s Republic of China, 25 \u2013 28 June 2012.)","Disposition of Criminal Case(s)":"According to statements by the Commission Against Corruption in Macao SAR, Mr. Ao was tried and convicted by the Macao Court of Final Appeal in two separate trials that ended in January 2008 and April 2009, respectively.  (Sources: Commission Against Corruption in Macao SAR, \u0022What\u0027s New - Detected Cases,\u0022 June 4, 2008 and \u0022What\u0027s New - Detected Cases,\u0022 April 22, 2009.)","Jurisdiction of Origin: Investigative Agency":"Commission Against Corruption of Macao SAR, China","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Macao Public Prosecutions Office","Jurisdiction of Origin: Courts Involved":"Court of First Instance","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Assets_Macau_Daily_Times_Nov_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macao_Anti-Corruption_Commission_Feb_5_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Anti-Corruption_Commission_Detected_Case_Apr_4_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_News_Second_Trial_Feb_13_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ao_HK_Explain_Assets_Macau_Daily_Nov_29_2007_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Assets_Macau_Daily_Times_Nov_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macao_Anti-Corruption_Commission_Feb_5_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Anti-Corruption_Commission_Detected_Case_Apr_4_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_News_Second_Trial_Feb_13_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ao-UK_Speech_Daniel%20Li_IAACA_June_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Assets_Macau_Daily_Times_Nov_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macao_Anti-Corruption_Commission_Feb_5_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Anti-Corruption_Commission_Detected_Case_Apr_4_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_News_Second_Trial_Feb_13_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ao%20Man%20Long_UK_Asset%20Return_Govt_Statement_Nov3%202015.pdf","Sources ":"Government Information Bureau of Macao SAR,  \u0022Most of the Illicit Assets Abroad in the Case of Ao Man Long Successfully Recovered,\u0022 November 3, 2015, at http:\/\/www.gcs.gov.mo\/showNews.php?PageLang=E\u0026DataUcn=93976;\nStatements by Commission Against Corruption in Macao SAR, particularly statement of April 4, 2007 which stated that of the over 790 million patacas in assets located, \u0022Until December 2006...the cash and bonds in Britain and other coutnries were equivalent to 275 million patacas,\u0022  accessed at its official website at http:\/\/www.ccac.org.mo\/en\/; Daniel M C Li,  Deputy Commissioner and Head of Operations, Independent Commission Against Corruption, Hong Kong Special Administrative Region, \u0022Asset Recovery: Is Law Enforcement doing enough?, \u0022  The 4th IAACA Seminar, Dalian, People\u2019s Republic of China, 25 \u2013 28 June 2012, accessed at http:\/\/www.iaaca.org\/Documents\/Presentation\/TheFourthIAACASeminar\/201207...  International Centre for Asset Recovery, Ao Man Long Case Study, UK Recovery, at http:\/\/www.assetrecovery.org\/kc\/node\/53b75da0-0d64-11de-a72f-27bb2e50913... \u0022Former Macau\u0027s secretary of transport and public works Ao Man Long to face second trial next week,\u0022 Macau News, February 13, 2009, accessed at http:\/\/www.macaunews.com.mo\/index.php?option=com_content\u0026task=view\u0026id=30... Poyi (Natalie) Cheung, \u0022CCAC: Ao couldn\u2019t explain his 850 million pataca assets,\u0022 Macau Daily Times, November 29, 2007, accessed at http:\/\/poyileung.wordpress.com\/2007\/11\/29\/ccac-ao-couldnt-explain-his-85...).\n"},{"Case ID":"ARW-17","Case Title (Name of Public Official or Entity Allegedly Involved)":"Arafat \u0022koko\u0022 Rahman (Singapore)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Bangladesh","Position of Public Official(s) (yrs in office)":"Son of Prime Minister Khaleda Zia (1991-1996, 2001-2006)","Jurisdiction of Asset Recovery":"Singapore","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"2013","UNCAC Offenses Implicated":"Art.16, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"United Nations Convention against Corruption","Contributing Factors in Asset Recovery":"Criminal conviction in Bangladesh, US foreign bribery case settlement with Siemens and subsequent non-conviction based asset forfeiture action against proceeds located in Singapore; also, as noted by the law firm Edwards Wildman, \u0022We understand that Mr Rahman\u2019s conviction appears to have been partially based on the offence of illicit enrichment, the usual method of enforcement through the mutual legal assistance procedure was not available in Singapore. Illicit enrichment is an offence in some countries where a public official gains a significant increase in his assets which he\/she cannot reasonably explain in relation to his\/her lawful income. This is a crime that is generally not considered punishable in many countries like the UK and Singapore, making enforcement of a confiscation order based on such an offence complicated. Further, Singapore does not have a (non-conviction based) civil forfeiture procedure. Despite these hurdles, Singapore was nevertheless able to return the funds in the Fairhill account by using a legal tool called the \u2018disposal inquiry\u2019 mechanism. It would be prudent to add that one suspects that this particular mechanism was only viable because of the specific facts of this case.\u0022 (Source:  Antonio Suarez-Martines, \u0022Civil forfeiture without borders: Bangladesh shows that where there\u2019s political will there\u2019s a way,\u0022 Edwards Wildman, September 9, 2013.) ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"No formal agreement but according to the Daily Star, the Chairman of the Anti-Corruption Commission stated that the returned assets would be used for anti-corruption initiatives. (Source:  Daily Star, \u0022S\u0027Pore returns Tk. 7.4 cr more,\u0022 August 28, 2013.)","Case Summary":"\n\tAccording to the Anti-Corruption Commission of Bangladesh, the U.S. and Bangladesh were engaged in joint efforts to recover Mr. Rahman\u0027s alleged bribery proceeds held in Singaporean bank accounts. \u00a0(Source: Anti-Corruption Commission of Bangladesh, \u0022US, Bangladesh joint effort to retrieve Coco \u0027bribes\u0027,\u0022 News Updates - Jan 2009.) \u00a0According to the Daily Star, between November 2012 through August 2013, Singapore returned $2,661,070 to Bangladesh in confiscated assets and accrued interest. \u00a0(Source: \u00a0Daily Star, \u0022S\u0027Pore returns Tk. 7.4 cr more,\u0022 August 28, 2013.)\n\n\t\u00a0\n\n\tA December 19, 2008 press report, the Anti-corruption Commission of Bangladesh had initiated an inquiry into alleged corruption proceeds held by Mr. Rahman in Singapore, and that Singapore had temporarily frozen S $2,061,093 and U.S. $261,477 in transactions by Mr. Rahman. \u00a0(Source: \u0022Singapore freezes Tk 11.6 cr of Koko: ACC begins probe,\u0022 Priyo.com, December 19, 2008.) \u00a0 The civil asset forfeiture complaint filed by the United States Government, in U.S. v. All Assets Held in the name of ZASZ Trading \u0026 Consulting Pte Ltd., had alleged that ZASZ is a Singapore company created at the direction of Mr. Rahman by Lim Siew Cheng of Henry Noon \u0026 Co Management Consultants firm, which also allegedly established Mr. Rahman\u0027s account at United Overseas Bank at the instruction of Mr. Rahman in 2004. \u00a0(Source: \u00a0U.S. v. All Assets Held in the Name of Zasz Trading and Consulting PTE Ltd., et. al, Case No. 1:09-cv-00021-JDB (D.D.C.), Amended Complaint for Forfeiture In Rem, Filed on August 21, 2009. \u00a0See also, case entry on asset recovery efforts by the United States.) \u00a0Singapore\u0027s Today Online reported that Mr. Lim Siew Cheng was fined on January 3, 2011 for his failure to inform authorities that the money he had been dealing with could have been obtained from criminal activity. (Source: Alkhatib, Shaffiq. \u00a0\u0022MD fined over suspect cash in bank accounts.\u0022 Today Online, Jan. 4, 2011, accessed at http:\/\/www.todayonline.com\/Print\/Singapore\/EDC110104-0000173\/MD-fined-ov....) \u00a0","Disposition of Criminal Case(s)":"According to the Press Trust of India, on June 23, 2011, Mr. Rahman was sentenced following his conviction in absentia on corruption charges. (Source: Press Trust of India, \u0022Former Bangladeshi premier Khaleda Zia\u0027s younger son jailed for bribery,\u0022 June 23, 2011.) According to the Daily Star, on April 27, 2011, Mr. Rahman\u0027s lawyers filed a petition to have his criminal case dismissed, pursuant to a February 9 ruling by the Bangladesh Supreme Court that acts committed before the passage of the Money Laundering Prevention Act of 2009 cannot be tried under it.  The article stated that the Anti-Corruption Commission of Bangladesh would take action after scrutinizing the Supreme Court\u0027s decision and the relevant laws.  (Source:  The Daily Star, \u0022Koko\u0027s lawyers for withdrawal of case,\u0022 April 28, 2011, accessed at http:\/\/www.thedailystar.net\/newDesign\/news-details.php?nid=183469.)  The trial had begun in Bangladesh in January 2011; he was being tried in absentia. (Source:  BDCAN, \u0022Trial of Arafat Rahman begins,\u0022 January 5, 2011).","Jurisdiction of Origin: Investigative Agency":"Anti-Corruption Commission of Bangladesh","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Anti-Corruption Commission of Bangladesh","Jurisdiction of Origin: Courts Involved":"Special Court","Jurisdiction of Asset Recovery: Investigative Agency":"Corruption Practices Investigation Bureau","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Amended_Complaint_Aug_21_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Default_Order_Apr_7_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Govt_Default_Memo_Exhibit_Feb_10_2010.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Dhaka_Asks_Gaea_News_Feb_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Singapore_Freeze_ICAR_Priyo_Dec_19_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Singapore_Intermediary_Today_Jan_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Trial_Begins_BDCAN_Jan_5_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Bangladesh_Sentenced_NDTV_Jun_23_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Rahman_Returns_3_Tranches_Daily_Star_Aug_28_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Amended_Complaint_Aug_21_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Default_Order_Apr_7_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Govt_Default_Memo_Exhibit_Feb_10_2010.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Dhaka_Asks_Gaea_News_Feb_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Singapore_Freeze_ICAR_Priyo_Dec_19_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Singapore_Intermediary_Today_Jan_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Trial_Begins_BDCAN_Jan_5_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Bangladesh_Sentenced_NDTV_Jun_23_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Rahman_US_Asset_Return_Edwards_Wildman_Blog_Sep_9_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Amended_Complaint_Aug_21_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Default_Order_Apr_7_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Govt_Default_Memo_Exhibit_Feb_10_2010.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Dhaka_Asks_Gaea_News_Feb_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Singapore_Freeze_ICAR_Priyo_Dec_19_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Singapore_Intermediary_Today_Jan_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Trial_Begins_BDCAN_Jan_5_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Bangladesh_Sentenced_NDTV_Jun_23_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Rahman_Bangladesh_Sentenced_NDTV_Jun_23_2011.pdf","Sources ":"\n\tAntonio Suarez-Martines, \u0022Civil forfeiture without borders: Bangladesh shows that where there\u2019s political will there\u2019s a way,\u0022 Edwards Wildman, September 9, 2013, at http:\/\/www.anticorruptionlaw.com\/blog.aspx?entry=5033; Daily Star, \u0022S\u0027Pore returns Tk. 7.4 cr more,\u0022 August 28, 2013, at http:\/\/www.thedailystar.net\/beta2\/news\/spore-returns-tk-7-4cr-more\/; \u0022Singapore freezes Tk 11.6 cr of Koko: ACC begins probe,\u0022 Priyo.com, December 19, 2008, as posted on www.assetrecovery.org\/kc\/node\/144dedf6-2b46-11de-900c-81c63910293a.2; Gaea News, \u0022Dhaka asks U.S. for money siphoned off by Zia\u0027s son,\u0022 February 2, 2009, as posted on www.assetrecovery.org\/kc\/node\/ba567240-2030-11de-a9b1-0d536ac86161.6; BDCAN, \u0022Trial of Arafat Rahman begins,\u0022 January 5, 2011, accessed at http:\/\/www.bdcan.ca\/banglanews\/news.details.php?news=1430; \n\n\t\u00a0\n\n\tU.S. v. All Assets Held in the Name of Zasz Trading and Consulting PTE Ltd., et. al, Case No. 1:09-cv-00021-JDB (D.D.C.), Amended Complaint for Forfeiture In Rem, filed August 21, 2009 and Memorandum Opinion and Order of Default Judgment and Judgment of Forfeiture, filed April 7, 2010 and Government Motion for Default Judgment and Exhibit 2, filed on February 19, 2010. \u00a0See also, Alkhatib, Shaffiq. \u00a0\u0022MD fined over suspect cash in bank accounts.\u0022 Today Online, Jan. 4, 2011, accessed at http:\/\/www.todayonline.com\/Print\/Singapore\/EDC110104-0000173\/MD-fined-ov... Press Trust of India, \u0022Former Bangladeshi premier Khaleda Zia\u0027s younger son jailed for bribery,\u0022 June 23, 2011, accessed at http:\/\/www.ndtv.com\/article\/world\/former-bangladeshi-premier-khaleda-zia...\n\n\t\u00a0\n"},{"Case ID":"ARW-18","Case Title (Name of Public Official or Entity Allegedly Involved)":"Arafat \u0022Koko\u0022 Rahman (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Bangladesh","Position of Public Official(s) (yrs in office)":"Son of Prime Minister Khaleda Zia (in office, 1991-1996, 2001-2006)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Efforts, Location of Recovery Effort","Asset Recovery Start":"2008","Asset Recovery End":"2013","UNCAC Offenses Implicated":"Art.16, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Criminal conviction in Bangladesh, US foreign bribery case settlement with Siemens and subsequent non-conviction based asset forfeiture action against proceeds located in Singapore; also, as noted by the law firm Edwards Wildman, \u0022We understand that Mr Rahman\u2019s conviction appears to have been partially based on the offence of illicit enrichment, the usual method of enforcement through the mutual legal assistance procedure was not available in Singapore. Illicit enrichment is an offence in some countries where a public official gains a significant increase in his assets which he\/she cannot reasonably explain in relation to his\/her lawful income. This is a crime that is generally not considered punishable in many countries like the UK and Singapore, making enforcement of a confiscation order based on such an offence complicated. Further, Singapore does not have a (non-conviction based) civil forfeiture procedure. Despite these hurdles, Singapore was nevertheless able to return the funds in the Fairhill account by using a legal tool called the \u2018disposal inquiry\u2019 mechanism. It would be prudent to add that one suspects that this particular mechanism was only viable because of the specific facts of this case.\u0022 (Source:  Antonio Suarez-Martines, \u0022Civil forfeiture without borders: Bangladesh shows that where there\u2019s political will there\u2019s a way,\u0022 Edwards Wildman, September 9, 2013.) ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"No formal agreement but according to the Daily Star, the Chairman of the Anti-Corruption Commission stated that the returned assets would be used for anti-corruption initiatives. (Source:  Daily Star, \u0022S\u0027Pore returns Tk. 7.4 cr more,\u0022 August 28, 2013.)","Case Summary":"\n\tAccording to the Anti-Corruption Commission of Bangladesh, the U.S. and Bangladesh were engaged in joint efforts to recover Mr. Rahman\u0027s bribery proceeds held in Singaporean bank accounts. \u00a0(Source: Anti-Corruption Commission of Bangladesh, \u0022US, Bangladesh joint effort to retrieve Coco \u0027bribes\u0027,\u0022 News Updates - Jan 2009.) \u00a0According to the Daily Star, between November 2012 through August 2013, Singapore returned $2,661,070 to Bangladesh in confiscated assets and accrued interest. \u00a0(Source: \u00a0Daily Star, \u0022S\u0027Pore returns Tk. 7.4 cr more,\u0022 August 28, 2013.)\n\n\t\u00a0\n\n\tIn January 2009, the US Department of Justice had filed a civil asset forfeiture complaint against assets held in three Singapore bank accounts that the Department of Justice had alleged were bribery proceeds in violation of the Foreign Corrupt Practices Act. (Source: U.S. v. All Assets Held in the Name of Zasz Trading and Consulting PTE Ltd., et. al, Case No. 1:09-cv-00021-JDB (D.D.C.), Amended Complaint for Forfeiture In Rem, filed August 21, 2009.) \u00a0 On April 7, 2010, the U.S. District Court for the District of Columbia granted a Default Judgment and Judgment of Forfeiture against the following: (1) all assets held in the name of ZASZ Trading and Consulting Pte Ltd., account number 352-015-540-4 (formerly 1093101397) held at the United Overseas Bank, Singapore and any properties traceable thereto; (2) up to and including $762,000 plus interest of the assets held in the name of Zulfikar Ali, account number 0174053746 at Standard Chartered Bank, Singapore and any property traceable thereto; and (3) up to and including $226,249 plus interest of the assets held in the name of Fazel Selim, account number 0174001770 at Standard Chartered Bank, Singapore and any property traceable thereto. (Source: U.S. v. All Assets Held in the Name of Zasz Trading and Consulting PTE Ltd., et. al, Case No. 1:09-cv-00021-JDB (D.D.C.), Memorandum Opinion and Order of Default Judgment and Judgment of Forfeiture, filed April 7, 2010.) \u00a0","Disposition of Criminal Case(s)":"According to the Press Trust of India, on June 23, 2011, Mr. Rahman was sentenced following his conviction in absentia on corruption charges. (Source: Press Trust of India, \u0022Former Bangladeshi premier Khaleda Zia\u0027s younger son jailed for bribery,\u0022 June 23, 2011.)  According to the Daily Star, on April 27, 2011, Mr. Rahman\u0027s lawyers filed a petition to have his criminal case dismissed, pursuant to a February 9 ruling by the Bangladesh Supreme Court that acts committed before the passage of the Money Laundering Prevention Act of 2009 cannot be tried under it.  The  article stated that the Anti-Corruption Commission of Bangladesh would take action after scrutinizing the Supreme Court\u0027s decision and the relevant laws.  (Source:  The Daily Star, \u0022Koko\u0027s lawyers for withdrawal of case,\u0022 April 28, 2011, accessed at http:\/\/www.thedailystar.net\/newDesign\/news-details.php?nid=183469.)  The trial had begun in Bangladesh in January 2011; he was being tried in absentia. (Source:  BDCAN, \u0022Trial of Arafat Rahman begins,\u0022 January 5, 2011).","Jurisdiction of Origin: Investigative Agency":"Anti-Corruption Commission of Bangladesh","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Anti-Corruption Commission of Bangladesh","Jurisdiction of Origin: Courts Involved":"Special Court","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, Washington Field Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section; Assistance by Criminal Division\u0027s Office of International Affairs","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Columbia","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Attorneys_File_Withdrawal_Daily_Star_Apr_28_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Amended_Complaint_Aug_21_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Default_Order_Apr_7_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_US_Justice_Dept_FCPA_Appendix_C.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Trial_Begins_BDCAN_Jan_5_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Bangladesh_Sentenced_NDTV_Jun_23_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Rahman_Returns_3_Tranches_Daily_Star_Aug_28_2013_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Attorneys_File_Withdrawal_Daily_Star_Apr_28_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Amended_Complaint_Aug_21_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Default_Order_Apr_7_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_US_Justice_Dept_FCPA_Appendix_C.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Trial_Begins_BDCAN_Jan_5_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Bangladesh_Sentenced_NDTV_Jun_23_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Rahman_US_Asset_Return_Edwards_Wildman_Blog_Sep_9_2013_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Attorneys_File_Withdrawal_Daily_Star_Apr_28_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Amended_Complaint_Aug_21_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Default_Order_Apr_7_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_US_Justice_Dept_FCPA_Appendix_C.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Trial_Begins_BDCAN_Jan_5_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Bangladesh_Sentenced_NDTV_Jun_23_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Rahman_Bangladesh_Sentenced_NDTV_Jun_23_2011_0.pdf","Sources ":"\n\tU.S. v. All Assets Held in the Name of Zasz Trading and Consulting PTE Ltd., et. al, Case No. 1:09-cv-00021-JDB (D.D.C.), Amended Complaint for Forfeiture In Rem, filed August 21, 2009 \u00a0Memorandum Opinion and Order of Default Judgment and Judgment of Forfeiture, filed April 7, 2010; \u00a0U.S. Department of Justice\u0027s Report to the United States Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf. \u00a0\n\n\t\u00a0\n\n\tAntonio Suarez-Martines, \u0022Civil forfeiture without borders: Bangladesh shows that where there\u2019s political will there\u2019s a way,\u0022 Edwards Wildman, September 9, 2013, at http:\/\/www.anticorruptionlaw.com\/blog.aspx?entry=503; Daily Star, \u0022S\u0027Pore returns Tk. 7.4 cr more,\u0022 August 28, 2013, at http:\/\/www.thedailystar.net\/beta2\/news\/spore-returns-tk-7-4cr-more\n\n\tSee also, The Daily Star, \u0022Koko\u0027s lawyers for withdrawal of case,\u0022 April 28, 2011, accessed at http:\/\/www.thedailystar.net\/newDesign\/news-details.php?nid=183469; \u00a0BDCAN, \u0022Trial of Arafat Rahman begins,\u0022 January 5, 2011, accessed at http:\/\/www.bdcan.ca\/banglanews\/news.details.php?news=1430; Press Trust of India, \u0022Former Bangladeshi premier Khaleda Zia\u0027s younger son jailed for bribery,\u0022 June 23, 2011, accessed at http:\/\/www.ndtv.com\/article\/world\/former-bangladeshi-premier-khaleda-zia...\n\n\t\u00a0\n"},{"Case ID":"ARW-19","Case Title (Name of Public Official or Entity Allegedly Involved)":"Arnoldo Aleman","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nicaragua","Position of Public Official(s) (yrs in office)":"President (1997-2002)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"2008","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation ","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"U.S.:  The establishment by the Immigration and Customs Enforcement of the first Politically Exposed Persons (PEPS) Task Force located in Miami, Florida. The PEPS Task Force was established in conjunction with ICE\u0027s international division, the U.S. Attorney\u0027s Office and the U.S. Department of State. The Task Force\u0027s goal is to identify, locate, and seize assets of corrupt politically exposed persons involved in the theft of embezzled government funds. An example that highlights the success of this Task Force is the conviction in Nicaragua of the former Nicaraguan President Arnoldo Aleman. ICE investigators worked with their Nicaraguan counterparts to discover and seize assets located in the United States belonging to Mr. Aleman valued in excess of $5 million dollars. Cooperation by U.S. and Nicaragua. (Source: Statement of Marcy M. Forman, Deputy Assistant Director, Financial Investigations, Immigration and Customs Enforcement, Department of Homeland Security, before House Government Reform Committee Subcommittee on Criminal Justice, Drug Policy and Human Resources, \u0022Terrorist Financing and Money Laundering Investigations: Who Investigates and How Effective Are They?,\u0022 May 11, 2004.","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unknown","Case Summary":"According to the U.S. Government website, America.gov, \u0022In 2004, U.S. authorities forfeited and transferred approximately $2.7 million of the former president\u0027s assets to the government of Nicaragua.\u0022  A 2005 U.S. Department of State report added that the funds were to be used for educational programs, with $100,000 going to support anti-corruption efforts of Nicaraguan Prosecutor General\u0027s Office. (Source: U.S. Department of State, Bureau of International Narcotics and Law Enforcement Affairs, International Narcotics Control Strategy Report, March 2005, accessed at http:\/\/www.state.gov\/p\/inl\/rls\/nrcrpt\/2005\/vol2\/html\/42382.htm).  Mr. Aleman had used fradulent shell companies and investment accounts to conceal his illicit proceeds. Assets identified and seized by the Immigration and Customs Enforcement, Miami Foreign Corrupt Investigations Group included seven certificates of deposit valued at $700,000, proceeds of the sale of a helicopter worth $671,000, a cabana at the Key Biscayne Ocean Club valued at $300,000, an investment account in Coral Gables, Fla., valued at $204,099, and a $150,000 deposit for the purchase of a Key Biscayne, Fla., condominium.  (Please note that according to the May 11, 2004 testimony of Ms. Marcy M. Forman, Deputy Assistant Director, Financial Investigations Division of the U.S. Immigration and Customs Enforcement: \u0022ICE investigators worked with their Nicaraguan counterparts to discover and seize assets located in the United States belonging to Aleman valued in excess of $5 million dollars.\u0022 Testimony before the House Committee on Government Reform, Subcommittee on Criminal Justice, Drug Policy and Human Resources.)","Disposition of Criminal Case(s)":"According to the University of Pittsburgh School of Law, Jurist Legal Research and News, in January 2009, the Nicaraguan Supreme Court overturned Mr. Aleman\u0027s 2003 conviction on money laundering and embezzlement charges. (Source: Andrew Gilmore, \u0022Nicaragua high court overturns corruption conviction of ex-president,\u0022 Jurist Legal Research and News, January 19, 2009, accessed at http:\/\/jurist.org\/paperchase\/2009\/01\/nicaragua-high-court-overturns.php.)","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General\u0027s Office, Nicaragua","Jurisdiction of Origin: Courts Involved":"Supreme Court","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Immigration and Customs Enforcement, Politically Exposed Persons Task Force","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney\u0027s Office for the Southern District of Florida","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of Florida","Documents":"","Sources ":"U.S. v. Proceeds of Certificates of Deposit Number 1271734730, et al, Case No. 03-20526-CIV-MORENO\/GARBER (S.D.Fla.), Amended Complaint for Forfeiture filed March 17, 2003; U.S.C.A. Mandate filed on October 7, 2008; Final Judgment filed October 9, 2008; \nCase description at http:\/\/www.america.gov\/anti-corruption.html; \nSee also, official website of the Prosecutor General of Nicaragua at www.pgr.gob.ni - follow links to Museo Digital de la Corrupcion and \u0022Hallazgos documentales de Actos Irregulares o Corruptos\u0022 for official documents and supporting documents on underlying cases. (Last accessed December 1, 2010).  \nU.S. Department of State, Bureau of International Narcotics and Law Enforcement Affairs, International Narcotics Control Strategy Report, March 2005, accessed at http:\/\/www.state.gov\/p\/inl\/rls\/nrcrpt\/2005\/vol2\/html\/42382.htm;\nAndrew Gilmore, \u0022Nicaragua high court overturns corruption conviction of ex-president,\u0022 Jurist Legal Research and News, January 19, 2009, accessed at http:\/\/jurist.org\/paperchase\/2009\/01\/nicaragua-high-court-overturns.php.\n"},{"Case ID":"ARW-20","Case Title (Name of Public Official or Entity Allegedly Involved)":"Augusto Pinochet","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Chile","Position of Public Official(s) (yrs in office)":"President (1973-1990); Commander-in-Chief of Chilean Army (1990-1998); \u0022Senator for life\u0022  (1998 to 2006)","Jurisdiction of Asset Recovery":"Spain","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"1979","Asset Recovery End":"2005","UNCAC Offenses Implicated":"Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"In 1998, Judge Garzon of Spain ordered a worldwide freeze on Mr. Pinochet\u0027s assets and ordered Riggs Bank to pay $8 million to a foundation established to assist victims of the Pinochet regime, to settle the Spanish case for violating  the 1998 court order (Source: United States Senate Permanent Subcommittee on Investigations, Money Laundering and Foreign Corruption: Enforcement and Effectiveness of the Patriot Act, Supplemental Staff Report on the U.S. Accounts Used by Augusto Pinochet (March 16, 2005), at footnote 5).  According to the Washington Post (February 26, 2005), Riggs Bank paid $8 million and its owners Joe and Robert Albritton paid  $1 million, for a total of $9 million.","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$8,000,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to an attorney familiar with the case, the civil society organization Consejo de Defensa del Estado brought two claims, in Spain and in the U.S., represented by an American attorney based in Miami.  The civil action in Spain was based on the claim that had Riggs Bank complied with Anti-Money Laundering regulations, Chile could have recovered its stolen assets much sooner.  (Source: Researcher telephone interview, November 2010).  In 1998, Judge Garzon of Spain ordered a worldwide freeze on Mr. Pinochet\u0027s assets and ordered Riggs Bank to pay $8 million to a foundation established to assist victims of the Pinochet regime, to settle the Spanish case for violating  the 1998 court order (Source: United States Senate Permanent Subcommittee on Investigations, Money Laundering and Foreign Corruption: Enforcement and Effectiveness of the Patriot Act, Supplemental Staff Report on the U.S. Accounts Used by Augusto Pinochet (March 16, 2005), at footnote 5).  According to the Washington Post (February 26, 2005), Riggs Bank paid $8 million and its owners Joe and Robert Albritton paid  $1 million, for a total of $9 million.  After deducting $1 million (mostly for legal expenses), $8 million was reported to have been given to the Salvador Allende Foundation in Santiago, Chile. (Source: Terrence O\u0027Hara, \u0022Allbrittons, Riggs to Pay Victims of Pinochet,\u0022 Washington Post, February 26, 2005).","Disposition of Criminal Case(s)":"A number of criminal proceedings had been instituted against Mr. Pinochet by the Chilean courts and by Spain\u0027s Fifth Central Magistrate of the National Court.  (Source: Regina v. Bartle and the Commissioner of Police for the Metropolis and Others Ex Parte Pinochet (on appeal from a Divisional Court of the Queen\u0027s Bench Division), Opinions of the Lords of Appeal, November 25, 1998.)","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Abogado Procuradora Fiscal - Santiago","Jurisdiction of Origin: Courts Involved":"Court of Appeals, Santiago","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Asset Recovery: Courts Involved":"Fifth Central Magistrate of the National Court","Documents":"","Sources ":"United States Senate Permanent Subcommittee on Investigations, Money Laundering and Foreign Corruption: Enforcement and Effectiveness of the Patriot Act, Supplemental Staff Report on the U.S. Accounts Used by Augusto Pinochet (March 16, 2005), accessed at http:\/\/levin.senate.gov\/newsroom\/supporting\/2005\/pinochetreport.pdf; \nTerrence O\u0027Hara, \u0022Allbrittons, Riggs to Pay Victims of Pinochet,\u0022 Washington Post, February 26, 2005.  \nSalvador Allende Foundation website: http:\/\/www.fundacionsalvadorallende.cl\/; \nRegina v. Bartle and the Commissioner of Police for the Metropolis and Others Ex Parte Pinochet (on appeal from a Divisional Court of the Queen\u0027s Bench Division), Opinions of the Lords of Appeal, November 25, 1998, accessed at http:\/\/www.publications.parliament.uk\/pa\/ld199899\/ldjudgmt\/jd981125\/pino....\n"},{"Case ID":"ARW-21","Case Title (Name of Public Official or Entity Allegedly Involved)":"Augusto Pinochet","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Chile","Position of Public Official(s) (yrs in office)":"President (1973-1990); Commander-in-Chief of Chilean Army (1990-1998); \u0022Senator for life\u0022  (1998 to 2006)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2000","Asset Recovery End":"2004","UNCAC Offenses Implicated":"Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"According to the March 2005 report by the U.S. Senate Permanent Subcommittee on Investigations on U.S. accounts used by Mr. Pinochet and his family and associates to conceal their illicit proceeds, at the order of Chilean Judge Sergio Munoz, Pinochet lawyer Oscar Aitken Lavanchy transferred $6.8 million from U.S. accounts (about $5.5 million from G.L.P. accounts; about $1.3 million from Trasker accounts) to a bank in Chile; on August 13, 2004, the bank deposited the funds into an account under control of the Santiago Court of Appeals.  (Source:  U.S. Senate Permanent Subcommittee on Investigations, Supplemental Staff Report on U.S. Accounts Used by Augusto Pinochet (March 16, 2005), at 56 and 62). ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to the March 2005 report by the U.S. Senate Permanent Subcommittee on Investigations on U.S. accounts used by Mr. Pinochet and his family and associates to conceal their illicit proceeds, at the order of Chilean Judge Sergio Munoz, Pinochet lawyer Oscar Aitken Lavanchy transferred $6.8 million from U.S. accounts (about $5.5 million from G.L.P. accounts; about $1.3 million from Trasker accounts) to a bank in Chile; on August 13, 2004, the bank deposited the funds into an account under control of the Santiago Court of Appeals.  (Source:  U.S. Senate Permanent Subcommittee on Investigations, Supplemental Staff Report on U.S. Accounts Used by Augusto Pinochet (March 16, 2005), at 56 and 62).","Disposition of Criminal Case(s)":"A number of criminal proceedings had been instituted against Mr. Pinochet by the Chilean courts and by Spain\u0027s Fifth Central Magistrate of the National Court.  (Source: Regina v. Bartle and the Commissioner of Police for the Metropolis and Others Ex Parte Pinochet (on appeal from a Divisional Court of the Queen\u0027s Bench Division), Opinions of the Lords of Appeal, November 25, 1998.)","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Abogado Procuradora Fiscal, Santiago","Jurisdiction of Origin: Courts Involved":"Court of Appeals, Santiago","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Senate Permanent Subcommittee on Investigations","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Asset Recovery: Courts Involved":"NA","Documents":"","Sources ":"United States Senate Permanent Subcommittee on Investigations, Money Laundering and Foreign Corruption: Enforcement and Effectiveness of the Patriot Act, Supplemental Staff Report on the U.S. Accounts Used by Augusto Pinochet (March 16, 2005), accessed at http:\/\/levin.senate.gov\/newsroom\/supporting\/2005\/pinochetreport.pdf; \nRegina v. Bartle and the Commissioner of Police for the Metropolis and Others Ex Parte Pinochet (on appeal from a Divisional Court of the Queen\u0027s Bench Division), Opinions of the Lords of Appeal, November 25, 1998, accessed at http:\/\/www.publications.parliament.uk\/pa\/ld199899\/ldjudgmt\/jd981125\/pino....\n"},{"Case ID":"ARW-22","Case Title (Name of Public Official or Entity Allegedly Involved)":"BAE Systems \/ Tanzania Radar Defence System Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"","Position of Public Official(s) (yrs in office)":"Unknown","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2010","Asset Recovery End":"2012","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"Memorandum of Understanding","Contributing Factors in Asset Recovery":"Settlement agreement by the Serious Fraud\u00a0Office and BAE included provision on ex gratia payment to Tanzania; Memorandum of Understanding by Serious Fraud Office, the Government of Tanzania, BAE Systems and the Department for International Development (DFID)\u00a0\u00a0(Source: UK Serious Fraud Office Press Release, \u0022BAE Systems will pay towards educating children in Tanzania after signing an agreement brokered by the Serious Fraud Office,\u0022 March 15, 2012.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"\u0022The Serious Fraud Office, the Government of Tanzania, BAE Systems and the Department for International Development (DFID) have now signed a Memorandum of Understanding enabling the payment of \u00a329.5 million plus accrued interest to be paid by BAE Systems for educational projects in Tanzania.\u0022 The funds will be used for the purchase of textbooks and other school supplies and\u00a0equipment.\u00a0(Source: UK Serious Fraud Office, \u0022BAE Systems will pay towards educating children in Tanzania after signing an agreement brokered by the Serious Fraud Office,\u0022 March 15, 2012.)\u00a0","Case Summary":"As part of the February 2010 settlement agreement by the Serious Fraud Office (SFO) and BAE Systems Plc, BAE agreed to pay GBP 30 million in ex gratia payment for the benefit of the people of Tanzania in a manner to be agreed between the SFO and the Company, less any financial orders imposed by the Court.  In December 2010, the Southwark Crown Court approved the settlement, and fined the company GBP 500,000 and ordered it to pay GBP 225,000 in costs to the Serious Fraud Office. (Sources: R v. BAE Systems PLC, Case No. S2010565, Southwark Crown Court, December 21, 2010; Serious Fraud Office Press Release, \u0022BAE fined in Tanzania defense contract case,\u0022 December 21, 2010.)\u00a0 The company had agreed to pay the legal costs separate from the GBP 30 million settlement amount.\u00a0 In March 2012, the SFO announced that a newly agreed upon Memorandum of Understanding will enable the\u00a0GBP 29.5 million plus accrued interest [amount unspecified] to be spent towards education projects in Tanzania.\u00a0 (Source: UK Serious Fraud Office Press Release, \u0022BAE Systems will pay towards educating children in Tanzania after signing an agreement brokered by the Serious Fraud Office,\u0022 March 15, 2012.)\u00a0\u00a0 For greater discussion of the case, see UK Parliament, House of Commons,\u00a0The International Development Committee, \u0022Financial Crime\u00a0and Development, Eleventh Report of Session 2010\u201312,\u0022 Volume I (30 November 2011) and Transparency International UK,\u00a0\u0022Deterring and Punishing Corporate Bribery:\u00a0 An Evaluation of UK Corporate Plea\u00a0Agreements and Civil\u00a0Recovery in Overseas\u00a0Bribery Cases,\u0022\u00a0(June 2012)","Disposition of Criminal Case(s)":"According to a press release by the UK Serious Fraud Office, in December 2010, the Southwark Crown Court approved the February 2010 settlement agreement by the Serious Fraud Office (SFO) and BAE Systems Plc in which the company agreed to plead guilty to one count of breaching its duty to keep accounting records contrary to section 221 of the Companies Act 1985.  (Source: Serious Fraud Office Press Release, \u0022BAE fined in Tanzania defense contract case,\u0022 December 21, 2010.)","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Origin: Courts Involved":"Unknown","Jurisdiction of Asset Recovery: Investigative Agency":"Serious Fraud Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service","Jurisdiction of Asset Recovery: Courts Involved":"Southwark Crown Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_Charge.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_Prosecution_Opening_Nov_22_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_Sentencing_Remarks_Dec_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_Settlement_Agreement_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_SFO_PR_DEC_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_SFO_PR_Feb_5_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_UK_DFID_Memorandum_to_Parliament_Apr_27_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/BAE_SFO_Press_Release_Mar_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_Charge.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_Prosecution_Opening_Nov_22_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_Sentencing_Remarks_Dec_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_Settlement_Agreement_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_SFO_PR_DEC_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_SFO_PR_Feb_5_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_UK_DFID_Memorandum_to_Parliament_Apr_27_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/UK_Parliament_Finan_Crimes_Hearing_Report_Nov_2011.pdf","Sources ":"R v. BAE Systems PLC, Case No. S2010565, Southwark Crown Court Sentencing Remarks of December 21, 2010 (http:\/\/www.judiciary.gov.uk\/media\/judgments\/2010\/r-v-bae-systems-plc);\nProsecution Note for Opening; Settlement Agreement and Plea; and the Charge, all provided in links within the United Kingdom Serious Fraud Office Press Release, \u0022BAE fined in Tanzania defence contract case,\u0022 December 21, 2010, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-20...); \nUK Serious Fraud Office Press Release, \u0022BAE Systems plc,\u0022 February 5, 2010, posted at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-20... \nUK Serious Fraud Office Press Release, \u0022BAE Systems will pay towards educating children in Tanzania after signing an agreement brokered by the Serious Fraud Office,\u0022 March 15, 2012,\u00a0accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-20... \nUK Parliament, House of Commons, The International Development Committee, \u0022Financial Crime and Development, Eleventh Report of Session 2010\u201312,\u0022 Volume I (30 November 2011), accessed at http:\/\/www.publications.parliament.uk\/pa\/cm201012\/cmselect\/cmintdev\/847\/...\nTransparency International UK, \u0022Deterring and Punishing Corporate Bribery:\u00a0 An Evaluation of UK Corporate Plea Agreements and Civil Recovery in Overseas Bribery Cases,\u0022 (June 2012), accessed at http:\/\/www.transparency.org.uk\/our-work\/publications\/243-policy-paper-se...\n"},{"Case ID":"ARW-27","Case Title (Name of Public Official or Entity Allegedly Involved)":"Bruce Rappaport","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Antigua and Barbuda","Position of Public Official(s) (yrs in office)":"Former Ambassador for Antigua and Barbuda to Israel and Russia (Rappaport, dates of position not specified but it was in 1990 when he was appointed to negotiate the debt repayment terms)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1996","Asset Recovery End":"2009","UNCAC Offenses Implicated":"Art.18","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"In his July 2009 announcement of the Government of Antigua and Barbuda\u0027s settlement agreement and payment received from Rappaport, the Attorney General and Minister of Legal Affairs, Hon. Justin Simon QC stated, \u0022Shortly after this Administration took office, I informed you by way of a Press Statement that the government had commissioned a financial forensic investigation and had secured the services of Mr. Robert Lindquist who had himself led like-investigations in Trinidad and Tobago where over Seven Million U.S. Dollars of illegal payments to public officials had been recovered, and that he was instrumental in the arrests and prosecutions of persons involved in the Piarco International Airport scandal in Trinidad.\u0022  (Mr. Simon\u0027s statement is posted at http:\/\/www.ab.gov.ag\/gov_v4\/article_details.php?id=68\u0026category=38).\r\n","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$12,000,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to a statement by the Attorney General of Antigua and Barbuda that was published on the official website of the Government of Antigua and Barbuda, Mr. Rappaport agreed to pay the government $12 million in settlement. In 2006, the Attorney General of Antigua Barbuda had obtained an injunction from the High Court of Antigua to freeze the Antigua account of Mr. Rappaport\u0027s Miami-based IHI Debt Settlement Associates, LLC. and Miami accounts of Mr. Rappaport\u0027s companies. (Source: Press Release by the Government of Antigua Barbuda, \u0022Government of Antigua Barbuda Recoups U.S. $12 million dollars in case against former government officials and others,\u0022 posted on July 10, 2009, at http:\/\/www.ab.gov.ag\/gov_v4\/article_details.php?id=68\u0026category=38, and Statement by Hon. Justin L. Simon QC, Attorney General and Minister of Legal Affairs, \u0022On the filing of Lawsuits against members of the former Government,\u0022 March 1, 2006, posted at http:\/\/www.ab.gov.ag\/gov_v2\/government\/pressreleases\/pressreleases2006\/p....)","Disposition of Criminal Case(s)":"No known criminal proceedings; Mr. Rappaport passed away in January 2010. (Source: Juliet Benjamin, \u0022Rappaport Dies,\u0022 Antigua Observer, January 9, 2010, accessed at http:\/\/www.antiguaobserver.com\/?p=20689.)","Jurisdiction of Origin: Investigative Agency":"Attorney General and Minister of Legal Affairs","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General and Minister of Legal Affairs","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Astigarraga David (Attorney Edward H. Davis, Jr.)","Jurisdiction of Asset Recovery: Courts Involved":"Miami-Dade County Circuit, Florida, United States","Documents":"","Sources ":"Press Release by the Government of Antigua and Barbuda, \u0022Government of Antigua Barbuda Recoups US $12 million dollars in case against former government officials and others,\u0022 Posted On: July 10, 2009, at  http:\/\/www.ab.gov.ag\/gov_v4\/article_details.php?id=68\u0026category=38, and Statement by Hon. Justin L. Simon QC, Attorney General and Minister of Legal Affairs, \u0022On the Filing of Lawsuits against Members of the Former Government,\u0022 March 1, 2006, posted at  http:\/\/www.ab.gov.ag\/gov_v2\/government\/pressreleases\/pressreleases2006\/p... \nAntigua and Barbuda v. Bruce Rappaport, et al, Case No. 06-03560 CA 25 (Eleventh Judicial Circuit Court in and for Miami-Dade County, Florida), Second Amended Complaint filed on October 10, 2007; Plaintiff\u0027s Notice of Dropping Certain Parties, dated February 20, 2009.  \nSee also, Juliet Benjamin, \u0022Rappaport Dies,\u0022 Antigua Observer, January 9, 2010, accessed at  http:\/\/www.antiguaobserver.com\/?p=20689.\n"},{"Case ID":"ARW-29","Case Title (Name of Public Official or Entity Allegedly Involved)":"Carlos F. Garcia \/ Ian Carl and Juan Paulo Depakakibo Garcia (Northern California Case)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"Former Comptroller of the Philippine Armed Forces (Carlos Garcia, 1990-2004), Sons (Ian Carl and Juan Paulo Depakakibo)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2003","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.15, Art.17, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ian Carl and Juan Paulo Depakakibo were apprehended pursuant to a routine search at the airport as they tried to enter the U.S. with the illegal bulk cash.  (Source:  U.S. v. Ian Carl Depakakibo and Juan Paulo Depakakibo, Case No. 08-cr-00888-MHP (N.D. Cal.)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"One-hundred thousand dollars in U.S. currency had been seized from Ian Carl and Juan Paulo Depakakibo when they tried to enter the U.S. with the cash.  In January 2011, the U.S. District Court for the District of Northern California forfeited the confiscated funds to the U.S. Government. The brothers had agreed, as part of their plea, to forfeit the $100,000 seized from them at the time of their arrest on December 19, 2003.  (Source:  U.S. v. Ian Carl Depakakibo and Juan Paulo Depakakibo, Case No. 08-cr-00888-MHP (N.D. Cal.), Final Order of Forfeiture, filed January 7, 2011); U.S. Immigration and Customs Service Press Release, \u0022Sons of former Philippine military comptroller charged with bulk cash smuggling,\u0022 February 25, 2009.)  They and their father, mother and a third brother have been charged in the Philippines with the crime of Plunder, for allegedly illegally amassing $9 million (303.27 million Philippine Pesos) while their father, General Carlos F. Garcia, had been the Comptroller of the Philippine Armed Forces. (Source:  Philippines Complaint and Arrest Warrant in the Plunder case, included as Annex A in extradition complaint filed on March 4, 2009, In the Matter of Extradition of Clarita Depakakibo Garcia, Case No. 2:09-mc-50231 (E.D. Mich.)","Disposition of Criminal Case(s)":"According to a September 9, 2010 press release by the U.S. Department of Justice, former Major General Garcia \u0022recently was found guilty in the Philippines of perjury for a false declaration of his assets and liabilities in 2000.\u0022 (Source: U.S. Department of Justice Press Release, \u0022Sons of Former Philippine General Plead Guilty to Bulk Cash Smuggling,\u0022 September 9, 2010.) His Plunder case was ongoing as of July 2013. (Source: Philippines Office of solicitor General, TRO - Garcia) According to the April 5, 2005 Information against former Mr. Garcia, his wife Clarita Garcia and their sons Ian Carl, Juan Paulo and Timothy Mark D. Garcia, the Philippines Ombudsman\u0027s Office has charged them with committing the crime of Plunder. (Source: In the Matter of Extradition of Clarita Depakakibo Garcia, Case No. 2:09-mc-50231 (E.D. Mich.), Annex A to Extradition compaint filed on March 4, 2009). In November 2010, Ian Carl and Juan Paulo Depakakibo were sentenced to time served by U.S. District Court for the Northern District of California, subsequent to their guilty plea on bulk cash smuggling charge. (Source: U.S. v. Ian Carl Depakakibo and Juan Paulo Depakakibo, Case No. 08-cr-00888-MHP (N.D. Cal.), Judgment in a Criminal Case, filed on December 1, 2010.)","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Ombudsman, Office of the Special Prosecutor","Jurisdiction of Origin: Courts Involved":"Sandiganbayan, Supreme Court (Third Division)","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Customs and Border Protection, San Francisco International Airport","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Northern District of California","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Northern District of California","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_Forfeiture_Motion_Oct_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_Forfeiture_Order_Nov_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_ICE_PR_Feb_25_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_Indictment_Dec_9_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_Judgment_Dec_1_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Complaint_Arrest_Warrant_Extradition_Complaint_Mar_9_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_US_NDCAL_Guilty_Pleas_Justice_Dept_Press_Release_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Depakakibo_Northern_California_Final_Order_Forfeiture_Jan_7_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Garcia_NDCAL_Forfeiture_Order_Nov_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_Forfeiture_Motion_Oct_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_Forfeiture_Order_Nov_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_ICE_PR_Feb_25_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_Indictment_Dec_9_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_Judgment_Dec_1_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Complaint_Arrest_Warrant_Extradition_Complaint_Mar_9_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_US_NDCAL_Guilty_Pleas_Justice_Dept_Press_Release_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Depakakibo_Northern_California_Final_Order_Forfeiture_Jan_7_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Garcia_NDCAL_Forfeiture_Order_Jan_2011.pdf","Sources ":"U.S. v. Ian Carl Depakakibo and Juan Paulo Depakakibo, Case No. 08-cr-00888-MHP (N.D. Cal.), Indictment filed on December 9, 2008; Order Granting Motion for Preliminary Order of Forfeiture, filed on November 2, 2010; Judgment in a Criminal Case, filed on December 1, 2010; and Final Order of Forfeiture filed January 7, 2011. See also, U.S. Immigration and Customs Service Press Release, \u0022Sons of former Philippine military comptroller charged with bulk cash smuggling,\u0022 February 25, 2009, accessed at http:\/\/www.ice.gov\/news\/releases\/0902\/090225sanfrancisco.htm; U.S. Department of Justice Press Release, \u0022Sons of Former Philippine General Plead Guilty to Bulk Cash Smuggling,\u0022 September 9, 2010, accessed at http:\/\/www.justice.gov\/usao\/can\/press\/2010\/2010_09_09_garcias.guiltyplea.... Philippines Complaint and Arrest Warrant in the Plunder case, included as Annex A in extradition complaint filed on March 4, 2009, In the Matter of Extradition of Clarita Depakakibo Garcia, Case No. 2:09-mc-50231 (E.D. Mich.)\n"},{"Case ID":"ARW-31","Case Title (Name of Public Official or Entity Allegedly Involved)":"Carlos Garcia \/ Clarita Garcia \/ Timothy Mark D. Garcia (New York Condominium)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"Former Comptroller of the Philippine Armed Forces (Carlos Garcia,1990-2004), Wife (Clarita Garcia), Son (Timothy Mark)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"2015","UNCAC Offenses Implicated":"Art.15, Art.17, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$1,384,940.28","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"","Case Summary":"Related to the General Carlos Garcia corruption cases in the Philippines, the U.S. filed criminal and civil actions against members of the Garcia family and their US assets.\u00a0 The actions include 2004 civil forfeiture proceedings in New York against an apartment that was allegedly purchased with corrupt proceeds, and 2009 extradition proceedings against Clarita Garcia (wife) and a third son Timothy Mark Garcia (who is not involved in the Northern California bulk cash smuggling case against Ian Carl and Juan Paulo D. Garcia).\u00a0 (Sources: U.S. v. All Right, Title and Interest in Real Property and Apputenance Located at Trump Park Avenue Condominium, Unit 6A, Case No. 1:04-cv-08918-RJH (S.D.N.Y.), Complaint filed November 10, 2004; In Re Clarita Depakakibo Garcia, Case No. 2:09-mc-50231-GCS (E.D. Mich.), Extradition Complaint filed March 4, 2009; unable to obtain copies of the extradition complaint against son Timothy and copy of a March 16, 2009 criminal complaint that were reported to have been filed against him in U.S. District Court for the Southern District of New York, as noted by\u00a0 Joseph G. Lariosa,\u00223rd son of Gen. Garcia now also detained in U.S.,\u0022 GMANews.TV posted at\u00a0 http:\/\/www.gmanews.tv\/story\/153224\/3rd-son-of-Gen-Garcia-now-also-detained-in-U.S.).\u00a0 On May 20, 2011, the US Government wrote to the court stating that the agreement with the Garcias for the forfeiture of the condominium had been stalled as it was contingent on the Philippine government\u0027s formal withdrawl of extradition requests of former general Garcia\u0027s sons and wife from the U.S.\u00a0 (Source: US v. All Right, Title and Interest in Real Property and Apputenance Located at Trump Park Avenue Condominium, Unit 6A, Case No. 1:04-cv-08918-RJH (S.D.N.Y.), Endorsed Letter to the Court by US Government dated May 20, 2011 and filed June 2, 2011.)\u00a0 In November 26, 2012, the US was granted a default judgment against the condominium.\u00a0 (Source: US v. All Right, Title and Interest in Real Property and Appurtenance Located at Trump Park Avenue Condominium, Unit 6A, Case No. 1:04-cv-08918-RJH (S.D.N.Y.), Default Judgment, November 26, 2012).\nAccording to a statement by the US Embassy Manila, on June 3, 2015, \u0022U.S. Ambassador Philip S. Goldberg presented Ombudsman Conchita Carpio-Morales with a check in the amount of U.S. $1,384,940.28 payable to the Republic of the Philippines. The check represents \u201cill-gotten\u201d gains acquired by former AFP Comptroller General Carlos F. Garcia.\u00a0 [\u00a0 ]\u00a0 Philippine and U.S. investigators worked closely together to determine that General Garcia laundered a substantial portion of his criminal proceeds through the United States.\u00a0 In particular, investigators with the U.S. Department of Homeland Security traced the criminal proceeds to two Citibank accounts in New York and a condominium in Trump Tower in New York.\u00a0 The U.S. Attorney\u0027s Office for the Southern District of New York then initiated civil forfeiture proceedings against those assets and eventually obtained default judgments of forfeiture.\u00a0 The net proceeds resulting from the sale of the condominium and the funds from the two Citibank accounts were returned to the Philippines by the United States today.\u0022\u00a0 (Source: US Embassy Manila, \u0022U.S. Helps Philippines Recover \u0027Ill-Gotten Gains\u0027\u201d, June 3, 2015, at http:\/\/manila.usembassy.gov\/press-photo-releases-2015\/us-helps-philippines-recover-ill-gotten-gains.html.)\n\u00a0","Disposition of Criminal Case(s)":"According to a June 3, 2015 statement by the Ombudsman of the Philippines, \u0022the Office of the Ombudsman filed criminal cases of perjury, money laundering and plunder against [Carlos] Garcia who eventually was convicted of perjury by the Sandiganbayan.\u00a0 In the last two criminal cases, Garcia pleaded to the lesser offenses of Indirect Bribery and Facilitating Money Laundering, which plea bargaining is the subject of review by the Supreme Court.\u00a0 Meanwhile, forfeiture proceedings are pending with the Sandiganbayan.\u0022\u00a0 (Source:\u00a0 Office of the Ombudsman, \u0022US turns over $1.38M proceeds of Garcia\u2019s forfeited assets,\u0022 June 3,2015.)\nAccording to the April 5, 2005 Information against former Mr. Garcia, his wife Clarita Garcia and their sons Ian Carl, Juan Paulo and Timothy Mark D. Garcia, the Philippines Ombudsman\u0027s Office had charged them with committing the crime of Plunder.\u00a0 (Source:\u00a0 In the Matter of Extradition of Clarita Depakakibo Garcia, Case No. 2:09-mc-50231 (E.D. Mich.), Annex A to Extradition compaint filed on March 4, 2009).\u00a0 In November 2010, Ian Carl and Juan Paulo Depakakibo were sentenced to time served by U.S. District Court for the Northern District of California, subsequent to their guilty plea on bulk cash smuggling charge.\u00a0\u00a0 (Source: U.S. v. Ian Carl Depakakibo and Juan Paulo Depakakibo, Case No. 08-cr-00888-MHP (N.D. Cal.), Judgment in a Criminal Case, filed on December 1, 2010.)\n\u00a0","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Ombudsman, Office of the Special Prosecutor","Jurisdiction of Origin: Courts Involved":"Sandiganbayan, Supreme Court (Third Division)","Jurisdiction of Asset Recovery: Investigative Agency":"Department of Homeland Security","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Southern District of New York; U.S. Attorney for the Eastern District of Michigan","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York; U.S. District Court for the Eastern District of Michigan","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_GMANEWS_Apr_10_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Complaint_Arrest_Warrant_Extradition_Complaint_Mar_9_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Sct_Oct_12_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_US_NDCAL_Guilty_Pleas_Justice_Dept_Press_Release_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_SDNY_USG_Letter_Status_Forfeiture_May_20_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Garcia_SDNY_Condo_Default_Judgment_Nov_26_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_GMANEWS_Apr_10_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Complaint_Arrest_Warrant_Extradition_Complaint_Mar_9_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Sct_Oct_12_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_US_NDCAL_Guilty_Pleas_Justice_Dept_Press_Release_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_SDNY_USG_Letter_Status_Forfeiture_May_20_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Garcia_SDNY_USG_Letter_Status_Forfeiture_May_20_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_GMANEWS_Apr_10_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Complaint_Arrest_Warrant_Extradition_Complaint_Mar_9_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Sct_Oct_12_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_US_NDCAL_Guilty_Pleas_Justice_Dept_Press_Release_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_SDNY_USG_Letter_Status_Forfeiture_May_20_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Gacria_US_SDNY_Asset%20Return_USEmbassy%20Manila%20Press_Jun3_2015_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_GMANEWS_Apr_10_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Complaint_Arrest_Warrant_Extradition_Complaint_Mar_9_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Sct_Oct_12_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_US_NDCAL_Guilty_Pleas_Justice_Dept_Press_Release_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_SDNY_USG_Letter_Status_Forfeiture_May_20_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Garcia_US%20Asset%20Return_Phil%20Ombudsman_statement_Jun3_2015_0.pdf","Sources ":"U.S. v. All Right, Title and Interest in Real Property and Apputenance Located at Trump Park Avenue Condominium, Unit 6A, Case No. 1:04-cv-08918-RJH (S.D.N.Y.), Complaint filed November 10, 2004 and Endorsed Letter to the Court by US Government dated May 20, 2011 and filed June 2, 2011 and Default Judgment filed November 26, 2012; In Re Clarita Depakakibo Garcia, Case No. 2:09-mc-50231-GCS (E.D. Mich.), extradition case filed March 4, 2009; unable to obtain copies of the extradition complaint against son Timothy and copy of a March 16, 2009 criminal complaint that were reported to have been filed against him in U.S. District Court for the Southern District of New York, noted by Joseph G. Lariosa,\u00223rd son of Gen. Garcia now also detained in U.S.,\u0022 GMANews.TV posted at\u00a0 http:\/\/www.gmanews.tv\/story\/153224\/3rd-son-of-Gen-Garcia-now-also-detained-in-U.S.); U.S. Department of Justice Press Release, \u0022Sons of Former Philippine General Plead Guilty to Bulk Cash Smuggling,\u0022 September 9, 2010, accessed at http:\/\/www.justice.gov\/usao\/can\/press\/2010\/2010_09_09_garcias.guiltyplea.press.html;\nUS Embassy Manila, \u0022U.S. Helps Philippines Recover \u0027Ill-Gotten Gains\u0027\u201d, June 3, 2015, at http:\/\/manila.usembassy.gov\/press-photo-releases-2015\/us-helps-philippines-recover-ill-gotten-gains.html; Office of the Ombudsman, \u0022US turns over $1.38M proceeds of Garcia\u2019s forfeited assets,\u0022 June 3,2015, at http:\/\/www.ombudsman.gov.ph\/index.php?home=1\u0026pressId=NjU3\n\u00a0\n"},{"Case ID":"ARW-32","Case Title (Name of Public Official or Entity Allegedly Involved)":"Carlos Perla","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"El Salvador","Position of Public Official(s) (yrs in office)":"Former head of the Salvadoran water authority, ANDA (Administracion Nacional de Acueductos y Alcantarillados) (1994-2002)","Jurisdiction of Asset Recovery":"Panama","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"$2,200,000 (Secondary Source)","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a November 4, 2010 article by elsalvador.com, El Salvador was seeking to have returned the $2.2 million frozen in the Panamanian bank accounts of Carlos Perla, the former head of the Salvadoran water authority, ANDA (Administracion Nacional de Acueductos y Alcantarillados).  El Salvador had made the request to have the funds frozen in 2004.  (Source: elsalvador.com, \u0022FGR busca recupar dinero de Carlos Perla,\u0022 November 4, 2010, posted at http:\/\/www.elsalvador.com\/mwedh\/nota\/nota_completa.asp?idCat=6358\u0026idArt=....)  In 2006, the U.S. Department of State had written in a report to Congress that \u0022[i]n El Salvador, the new Court of Accounts (Corte de Cuentas) conducted regular audits of public officials and employees with a view to preventing and sanctioning acts of corruption. As a result, El Salvador\u0027s attorney general has started numerous corruption-related prosecutions. The highest profile case is that of Carlos Perla, ex-president of the Salvadoran Water Authority (ANDA), who was accused of misappropriating $31 million during his tenure.\u0022 (Source: U.S. Department of State, Bureau of International Narcotics and Law Enforcement Affairs,\u0022Sixth Annual Report to Congress on the Inter-American Convention Against Corruption,\u0022 April 1, 2006.)","Disposition of Criminal Case(s)":"According to La Prensa, in July 2007 in El Salvador, Mr. Perla was sentenced to fifteen years\u0027 imprisonment, following his conviction on embezzlement charges. (Source:  Suchit Chavez and Jessica Avalos, \u0022Carlos Perla y Mario Orellana. candidatos a quedar en libertad,\u0022 La Prensa Grafica, February 10, 2011, accessed at http:\/\/www.laprensagrafica.com\/el-salvador\/judicial\/170762-carlos-perla-....)","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Origin: Courts Involved":"Court of Accounts (Corte de Cuentas) [secondary source]","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"","Sources ":"elsalvador.com, \u0022FGR busca recupar dinero de Carlos Perla,\u0022 November 4, 2010, posted at http:\/\/www.elsalvador.com\/mwedh\/nota\/nota_completa.asp?idCat=6358\u0026idArt=... \nSuchit Chavez and Jessica Avalos, \u0022Carlos Perla y Mario Orellana. candidatos a quedar en libertad,\u0022 La Prensa Grafica, February 10, 2011, accessed at http:\/\/www.laprensagrafica.com\/el-salvador\/judicial\/170762-carlos-perla-... \nU.S. Department of State, Bureau of International Narcotics and Law Enforcement Affairs,\u0022Sixth Annual Report to Congress on the Inter-American Convention Against Corruption,\u0022 April 1, 2006, accessed at http:\/\/www.state.gov\/p\/inl\/rls\/rpt\/67758.htm.\n"}],"settlements":[{"Case ID":"ST-536","Case Cluster ":"","Jurisdiction of Settlement":"","Jurisdiction of Settlement \/ Enforcement Agency":"","Jurisdiction of Foreign Public Official(s) ":"","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"","Other Jurisdictions of Settlement":"","Settlement with Individual or Legal Person?":"","Type of Settlement":"","Legal Form of Settlement":"","Monetary Sanctions  (Types)":"","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"","OECD Anti-Bribery Convention Articles Implicated":"","Offenses - Alleged":"","Offenses - Settled":"","Public Procurement Contract \/ SOE Involved?":"","Summary":"","Sources ":"","Documents":""},{"Case ID":"ST-447","Case Cluster ":"Eli Lilly \u0026 Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Brazil, China, Poland, Russia","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"12\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$29,398,734 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$13,955,196 ","Civil Prejudgment Interest (US$) ":"$6,743,538 ","Civil Fine \/ Penalty (US$)":"$8,700,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials; falsification of books and records; internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, in December 2012, Eli Lilly \u0026 Co. consented to the entry of a Cease and Desist Order in relation to alleged improper payments by its subsidiaries to foreign government officials to win millions of dollars of business in Russia, Brazil, China, and Poland. \u0022The SEC alleges that the Indianapolis-based pharmaceutical company\u2019s subsidiary in Russia used offshore \u201cmarketing agreements\u201d to pay millions of dollars to third parties chosen by government customers or distributors, despite knowing little or nothing about the third parties beyond their offshore address and bank account information. These offshore entities rarely provided any services and in some instances were used to funnel money to government officials in order to obtain business for the subsidiary. Transactions with offshore or government-affiliated entities did not receive specialized or closer review for possible FCPA violations. Paperwork was accepted at face value and little was done to assess whether the terms or circumstances surrounding a transaction suggested the possibility of foreign bribery.\r\n \r\n The SEC alleges that when the company did become aware of possible FCPA violations in Russia, Lilly did not curtail the subsidiary\u2019s use of the marketing agreements for more than five years. Lilly subsidiaries in Brazil, China, and Poland also made improper payments to government officials or third-party entities associated with government officials. [ ]\r\n \r\n Lilly agreed to pay disgorgement of $13,955,196, prejudgment interest of $6,743,538, and a penalty of $8.7 million for a total payment of $29,398,734. Without admitting or denying the allegations, Lilly consented to the entry of a final judgment permanently enjoining the company from violating the anti-bribery, books and records, and internal controls provisions of the FCPA. Lilly also agreed to comply with certain undertakings including the retention of an independent consultant to review and make recommendations about its foreign corruption policies and procedures. The settlement is subject to court approval.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Eli Lilly and Company with FCPA Violations,\u0022 December 20, 2012.)","Sources ":"US v. Eli Lilly and Company, Case No. 12-cv-02045 (DDC), Complaint filed December 20, 2012; SEC Press Release, \u0022SEC Charges Eli Lilly and Company with FCPA Violations,\u0022 December 20, 2012, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171487116","Documents":""},{"Case ID":"ST-448","Case Cluster ":"FLIR Systems","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"4\/8","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, civil Penalty","Total Monetary Sanctions (US$)":"$9,504,584 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$7,534,000 ","Civil Prejudgment Interest (US$) ":"$970,584 ","Civil Fine \/ Penalty (US$)":"$1,000,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, FLIR Systems, Inc. is an Oregon-based corporation founded in 1978 which develops infrared technology for use in thermal imaging and other sensing products and systems, night vision, and camera systems for government and commercial customers. \r\n \r\n\u0022According to the SEC\u2019s order instituting a settled administrative proceeding against FLIR, the company had few internal controls over gifts and travel out of its foreign sales offices. Two employees in its Dubai office provided expensive watches to government officials with the Saudi Arabia Ministry of Interior in 2009, and they arranged for the company to pay for a 20-night excursion by Saudi officials that included stops in Casablanca, Paris, Dubai, Beirut, and New York City. The value of the gifts and the extent and nature of the travel were falsely recorded in FLIR\u2019s books and records as legitimate business expenses, and the company\u2019s internal controls failed to catch the improper payments despite documentation suggesting that extravagant gifts and travel were being provided. \r\n \r\n The SEC\u2019s order finds that from 2008 to 2010, FLIR paid approximately $40,000 for additional travel by Saudi government officials, including multiple New Year\u2019s Eve trips to Dubai with airfare, hotel, and expensive dinners and drinks. FLIR also accepted cursory invoices from a FLIR company partner without any supporting documentation to pay extended travel of Egyptian officials in mid-2011.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Oregon-Based Defense Contractor With FCPA Violations,\u0022 April 8, 2015.)","Sources ":"US Securities and Exchange Commission Administrative Proceeding File No, 3-16478, In the Matter of Flir Systems Inc., April 8, 2015, at https:\/\/www.sec.gov\/litigation\/admin\/2015\/34-74673.pdf; SEC Press Release, \u0022SEC Charges Oregon-Based Defense Contractor With FCPA Violations,\u0022 April 8, 2015, at https:\/\/www.sec.gov\/news\/pressrelease\/2015-62.html","Documents":""},{"Case ID":"ST-449","Case Cluster ":"FLIR Systems","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"11\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$50,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$50,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022FLIR is headquartered in Oregon and produces thermal imaging, night vision, and infrared cameras and sensor systems. According to the SEC\u2019s order instituting a settled administrative proceeding, FLIR entered into a multi-million dollar contract to provide thermal binoculars to the Saudi government in November 2008. Timms and Ramahi were the primary sales employees responsible for the contract, and also were involved in negotiations to sell FLIR\u2019s security cameras to the same government officials. At the time, Timms was the head of FLIR\u2019s Middle East office in Dubai and Ramahi reported to him. \r\n \r\n The SEC\u2019s order finds that Timms and Ramahi traveled to Saudi Arabia in March 2009 and provided five officials with expensive luxury watches during meetings to discuss several business opportunities. Timms and Ramahi believed these officials were important to sales of both the binoculars and the security cameras. A few months later, they arranged for key officials, including two who received watches, to embark on what Timms referred to as a \u201cworld tour\u201d of personal travel before and after they visited FLIR\u2019s Boston facilities for a factory equipment inspection that was a key condition to fulfillment of the contract. The officials traveled for 20 nights with stops in Casablanca, Paris, Dubai, Beirut, and New York City. There was no business purpose for the stops outside of Boston, and the airfare and hotel accommodations were paid for by FLIR. Prior to providing the gifts and travel to the Saudi Arabian officials, Ramahi and Timms each had taken FCPA training at the company that specifically identified luxury watches and side trips as prohibited gifts.\r\n \r\n According to the SEC\u2019s order, when FLIR\u2019s finance department flagged the expense reimbursement request for the watches during an unrelated review of expenses in the Dubai office and questioned the $7,000 cost, Timms and Ramahi obtained a second, fabricated invoice showing a cost of 7,000 Saudi Riyal (approximately $1,900 in U.S. dollars) instead of the true cost of $7,000 in U.S. dollars. They directed FLIR\u2019s local third-party agent to provide false information to the company to back up their story that the original submission was merely a mistake. Ramahi and Timms also falsely claimed that FLIR\u2019s payment for the world tour had been a billing mistake by FLIR\u2019s travel agent, and again used false documentation and FLIR\u2019s third-party agent to bolster their cover-up efforts.\u0022 (Source: US SEC Press Release, \u0022SEC Sanctions Two Former Defense Contractor Employees for FCPA Violations,\u0022 November 17, 2014.)","Sources ":"US Securities and Exchange Commission Administrative Proceedings File No. 3-16281, In the Matter of\r\n Stephen Timms and Yasser Ramahi, November 17, 2014, at https:\/\/www.sec.gov\/litigation\/admin\/2014\/34-73616.pdf;\r\n \r\n SEC Press Release, \u0022SEC Sanctions Two Former Defense Contractor Employees for FCPA Violations,\u0022 November 17, 2014, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370543472839.","Documents":""},{"Case ID":"ST-450","Case Cluster ":"FLIR Systems","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"11\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$20,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$20,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022FLIR is headquartered in Oregon and produces thermal imaging, night vision, and infrared cameras and sensor systems. According to the SEC\u2019s order instituting a settled administrative proceeding, FLIR entered into a multi-million dollar contract to provide thermal binoculars to the Saudi government in November 2008. Timms and Ramahi were the primary sales employees responsible for the contract, and also were involved in negotiations to sell FLIR\u2019s security cameras to the same government officials. At the time, Timms was the head of FLIR\u2019s Middle East office in Dubai and Ramahi reported to him. \r\n \r\n The SEC\u2019s order finds that Timms and Ramahi traveled to Saudi Arabia in March 2009 and provided five officials with expensive luxury watches during meetings to discuss several business opportunities. Timms and Ramahi believed these officials were important to sales of both the binoculars and the security cameras. A few months later, they arranged for key officials, including two who received watches, to embark on what Timms referred to as a \u201cworld tour\u201d of personal travel before and after they visited FLIR\u2019s Boston facilities for a factory equipment inspection that was a key condition to fulfillment of the contract. The officials traveled for 20 nights with stops in Casablanca, Paris, Dubai, Beirut, and New York City. There was no business purpose for the stops outside of Boston, and the airfare and hotel accommodations were paid for by FLIR. Prior to providing the gifts and travel to the Saudi Arabian officials, Ramahi and Timms each had taken FCPA training at the company that specifically identified luxury watches and side trips as prohibited gifts.\r\n \r\n According to the SEC\u2019s order, when FLIR\u2019s finance department flagged the expense reimbursement request for the watches during an unrelated review of expenses in the Dubai office and questioned the $7,000 cost, Timms and Ramahi obtained a second, fabricated invoice showing a cost of 7,000 Saudi Riyal (approximately $1,900 in U.S. dollars) instead of the true cost of $7,000 in U.S. dollars. They directed FLIR\u2019s local third-party agent to provide false information to the company to back up their story that the original submission was merely a mistake. Ramahi and Timms also falsely claimed that FLIR\u2019s payment for the world tour had been a billing mistake by FLIR\u2019s travel agent, and again used false documentation and FLIR\u2019s third-party agent to bolster their cover-up efforts.\u0022 (Source: US SEC Press Release, \u0022SEC Sanctions Two Former Defense Contractor Employees for FCPA Violations,\u0022 November 17, 2014.)","Sources ":"US Securities and Exchange Commission Administrative Proceedings File No. 3-16281, In the Matter of\r\n Stephen Timms and Yasser Ramahi, November 17, 2014, at https:\/\/www.sec.gov\/litigation\/admin\/2014\/34-73616.pdf;\r\n \r\n SEC Press Release, \u0022SEC Sanctions Two Former Defense Contractor Employees for FCPA Violations,\u0022 November 17, 2014, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370543472839.","Documents":""},{"Case ID":"ST-451","Case Cluster ":"Frederic Cilins","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Guinea","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"7\/25","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Penalty, Criminal Forfeiture","Total Monetary Sanctions (US$)":"$95,000 ","Criminal Fine\/Penalty (US$) ":"$75,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$20,000 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Obstruction of Justice in FCPA investigation","Offenses - Settled":"Obstruction of Justice in FCPA investigation","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, In July 2014, Frederic Cilins was sentenced in the Southern District of New York to 24 months in prison for obstructing a federal criminal investigation into alleged bribes to obtain mining concessions in the Republic of Guinea: \u0022Cilins offered to bribe a witness in an FCPA investigation to stop the witness from talking to the FBI,\u201d said Assistant Attorney General Caldwell. \u201cToday\u2019s sentence holds Cilins accountable for his effort to undermine the integrity of our justice system, and sends a message that those who interfere with federal investigations will be prosecuted and sent to prison.\u201d\r\n \r\n \u201cFrederic Cilins went to great lengths to thwart a Manhattan federal grand jury\u2019s investigation into an alleged bribery scheme in the Republic of Guinea,\u201d said U.S. Attorney Bharara. \u201cIn an effort to prevent the federal authorities from learning the truth, Cilins paid a witness for her silence and to destroy key documents. Today, Cilins learned that no one can manipulate justice.\u201d\r\n \r\n \u201cCilins obstructed the efforts of the FBI during the course of this investigation,\u201d said Director in Charge Venizelos. \u201cHis guilty plea and sentence demonstrate our shared commitment with the department\u2019s Criminal Division and U.S. Attorney\u2019s Office to hold accountable those who seek to interfere with the administration of justice. This case should be a reminder to all those who try to circumvent the efforts of a law enforcement investigation: the original crime and the cover-up both lend themselves to prosecution.\u201d\r\n \r\n According to court documents, Cilins obstructed an ongoing federal investigation concerning potential violations of the Foreign Corrupt Practices Act (FCPA) and other crimes. Federal law enforcement was investigating whether a particular mining company with which Cilins was affiliated paid bribes to officials of a former governmental regime in the Republic of Guinea to obtain and retain valuable mining concessions in the Republic of Guinea\u2019s Simandou region. During monitored and recorded phone calls and face-to-face meetings, Cilins agreed to pay substantial sums of money to induce a witness to the alleged bribery scheme to leave the United States to avoid questioning by the FBI, as well as to give documents to Cilins for destruction that had been requested by the FBI as part of the investigation. Cilins also sought to induce the witness to sign an affidavit containing false statements regarding matters under investigation by the grand jury. That witness was the former wife of a now-deceased Guinean government official who held an office in Guinea that allowed him to influence the award of mining concessions.\u0022 (Source: US Department of Justice Press Release, \u0022French Citizen Sentenced for Obstructing a Criminal Investigation into Alleged Bribes Paid to Win Mining Rights in Guinea,\u0022 July 25, 2014.)","Sources ":"US v. Frederic Cilins, Case No. 13-cr-315 (SDNY), Superseding Indictment filed February 18, 2014, plea Agreement of March 7, 2014 and other court documents, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-frederic-cilins-court-docket-number-13-cr-00315-whp; \r\n \r\n US Department of Justice Press Release, \u0022French Citizen Sentenced for Obstructing a Criminal Investigation into Alleged Bribes Paid to Win Mining Rights in Guinea,\u0022 July 25, 2014, at https:\/\/www.justice.gov\/opa\/pr\/french-citizen-sentenced-obstructing-criminal-investigation-alleged-bribes-paid-win-mining.","Documents":""},{"Case ID":"ST-452","Case Cluster ":"Goodyear Tire \u0026 Rubber Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Angola, Kenya","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"2\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$16,228,065 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$14,122,525 ","Civil Prejudgment Interest (US$) ":"$2,105,540 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, Goodyear Tire \u0026 Rubber Company \u0022failed to prevent or detect more than $3.2 million in bribes during a four-year period due to inadequate FCPA compliance controls at its subsidiaries in sub-Saharan Africa. Bribes were generally paid in cash to employees of private companies or government-owned entities as well as other local authorities such as police or city council officials. The improper payments were falsely recorded as legitimate business expenses in the books and records of the subsidiaries, which were consolidated into Goodyear\u2019s books and records. [ ] \r\n \r\n The SEC\u2019s order finds that Goodyear\u2019s subsidiary in Kenya bribed employees of the Kenya Ports Authority, Armed Forces Canteen Organization, Nzoia Sugar Company, Kenyan Air Force, Ministry of Roads, Ministry of State for Defense, East African Portland Cement Co., and Telkom Kenya Ltd. Goodyear\u2019s subsidiary in Angola bribed employees of the Catoca Diamond Mine, which is owned by a consortium of mining interests including Angola\u2019s national mining company Endiama E.P. and Russian mining company ALROSA. Others bribed in Angola worked at UNICARGAS, Engevia Construction and Public Works, Electric Company of Luanda, National Service of Alfadega, and Sonangol.\u0022 (Source: SEC Press Release, \u0022SEC Charges Goodyear With FCPA Violations,\u0022 February 24, 2015, at https:\/\/www.sec.gov\/news\/pressrelease\/2015-38.html.)","Sources ":"US Securities and Exchange Commission Administrative Proceeding File No. 3-16400, February 24, 2015 at https:\/\/www.sec.gov\/litigation\/admin\/2015\/34-74356.pdf\r\n \r\n SEC Press Release, \u0022SEC Charges Goodyear With FCPA Violations,\u0022 february 24, 2015, at https:\/\/www.sec.gov\/news\/pressrelease\/2015-38.html.)","Documents":""},{"Case ID":"ST-453","Case Cluster ":"Griffiths Energy International","Jurisdiction of Settlement":"Canada","Jurisdiction of Settlement \/ Enforcement Agency":"Crown Prosecution Service","Jurisdiction of Foreign Public Official(s) ":"Chad","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"1\/25","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine; Victims Fund Surcharge","Total Monetary Sanctions (US$)":"$10,340,283 ","Criminal Fine\/Penalty (US$) ":"$8,991,550 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$1,348,733 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$1,348,733 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials, Abuse of Office","Offenses - Settled":"Bribery of Foreign Officials, Abuse of Office","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to an announcement by the Griffiths Energy company, \u0022Griffiths Energy International Inc. (\u0022Griffiths Energy\u0022 or \u0022the Company\u0022) announced today that it reached a settlement and resolution with respect to a previously disclosed charge under section 3(1)(b) of Canada\u0027s Corruption of Foreign Public Officials Act (\u0022CFPOA\u0022).\r\n \r\n As previously disclosed, the matter involved certain contracts entered into by the prior management and Board of Directors of Griffiths Energy during the period between August 30, 2009 and February 9, 2011. Prior management entered into consulting contracts (the \u0022Contracts\u0022) with two entities owned and controlled by a foreign public official and his spouse. At a court hearing on Tuesday the Company entered a guilty plea to the charge before the Court of Queen\u0027s Bench in Calgary, Alberta and agreed to pay a total fine of C$10.35 million. Today the Court accepted the settlement.\r\n \r\n \u0022Griffiths Energy regrets the actions of the prior management and Board. When we discovered the contracts we blew the whistle and cooperated with the authorities because this is how Griffiths Energy\u0027s current management and board conduct business,\u0022 said Gary Guidry, President and Chief Executive Officer. \u0022The negotiated resolution addresses the interests of all stakeholders. Now that the matter is closed, Griffiths Energy can focus all of its attention on oil exploration, development and production in Chad.\u0022\r\n \r\n In November 2011, as previously announced, Griffiths Energy voluntarily disclosed to the appropriate authorities that it had commenced an internal investigation into the Contracts. The exhaustive investigation, supervised by a special committee of independent directors of the Board and conducted by external legal counsel, was concluded in May 2012. At that time Griffiths Energy voluntarily shared the results with appropriate authorities and worked with them to conclude the matter today.\r\n \r\n The Company affirms that no influence was actually obtained as a result of providing the benefits to the foreign public official, and that the award of its Production Sharing Contracts was not in any way connected to the improper promises and benefits indirectly provided to the foreign public official. These proceedings have no impact on the security and veracity of the Company\u0027s significant license area in Chad and the case is now closed.\r\n \r\n Griffiths Energy\u0027s conduct since the discovery of these contracts, and the proactive and responsible steps taken by the current management and Board to immediately self-disclose these issues to law enforcement, were described at length by counsel and were considered by the Court to be significant factors in agreeing to the resolution that was jointly recommended by counsel to the Company and the Crown. The Court also took favourable notice that Griffiths Energy was prepared to self-disclose even though Canada had not yet established policies or protocols governing such voluntary disclosures, and Griffiths Energy received no tangible concessions from the authorities when it self-reported.\u0022 (Source: \u0022Griffiths Energy International Announces Settlement,\u0022 Canada News Wire, January 25, 2013, at http:\/\/www.newswire.ca\/news-releases\/griffiths-energy-international-announces-settlement-511886831.html)","Sources ":"R v. Griffiths Energy International Inc., Court of Queen\u0027s Bench of Alberta, Amended Agreed Statement of Facts, January 4, 2013, at http:\/\/www.millerchevalier.com\/portalresource\/Spring2013_GriffithsAmendedStatmentofFacts; \u0022Griffiths Energy International Announces Settlement,\u0022 Canada News Wire, January 25, 2013, at http:\/\/www.newswire.ca\/news-releases\/griffiths-energy-international-announces-settlement-511886831.html); Paul Michael Blyschak and John W. Boscariol, McCarthy Tetrault, \u0022A Closer Look at the Griffiths Energy Case: Lessons and Insights on Canadian Anti-Corruption Enforcement,\u0022 February 14, 2013, at http:\/\/www.mccarthy.ca\/article_detail.aspx?id=6176","Documents":""},{"Case ID":"ST-454","Case Cluster ":"Hewelett-Packard","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"4\/9","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$2,527,750 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$2,527,750 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"Falsification of Books and Records; Internal Controls Violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, three subsidiaries of the Hewlett-Packard company reached settlements with the agency in 2014. \u0022In Mexico, according to the non-prosecution agreement, HP Mexico falsified corporate books and records and circumvented HP internal controls in connection with contracts to sell hardware, software, and licenses to Mexico\u2019s state-owned petroleum company, Petroleos Mexicanos (Pemex). To secure the contracts, HP Mexico understood that it had to retain a certain third-party consultant with close ties to senior executives of Pemex. HP agreed to pay a $1.41 million \u201ccommission\u201d to the consultant and hid the payments by inserting into the deal structure another third party, which had been approved by HP as a channel partner. HP Mexico made the commission payment to the channel partner, which in turn forwarded the payments to the consultant. Shortly thereafter, the consultant paid one of the Pemex officials approximately $125,000.\u0022 (Source: DOJ Press Release, \u0022Hewlett-Packard Russia Agrees to Plead Guilty to Foreign Bribery,\u0022 April 9, 2014.)","Sources ":"US Department of Justice Nonprosecution Agreement, Re: Hewlett-Packard Mexico, S. de R.L. de C.V. and DOJ Press Release, \u0022Hewlett-Packard Russia Agrees to Plead Guilty to Foreign Bribery,\u0022 both April 9, 2014, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-hewlett-packard-mexico-s-de-rl-de-cv-2014","Documents":""},{"Case ID":"ST-455","Case Cluster ":"Hewlett-Packard","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Mexico, Poland, Russia","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"4\/9","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$31,472,250 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$26,472,250 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$5,000,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022From approximately 2003 to 2010 (the \u201crelevant period\u201d), HP Co.\u2019s indirect, wholly-owned subsidiaries in Russia, Mexico and Poland, by and through their employees, agents and intermediaries, made unlawful payments to various foreign government officials to obtain business. These payments were also falsely recorded in the subsidiaries\u2019 books and records and, ultimately, in HP Co.\u2019s books and records. In Russia, HP Co.\u2019s subsidiary (\u201cHP  Russia\u201d) made payments through HP Russia\u2019s agents to a Russian government official to retain a multi-million dollar contract with the federal prosecutor\u2019s office. The payments were made through shell companies engaged by the agents to perform purported services under the contract. In Poland, certain agents or employees of HP Co.\u2019s Polish subsidiary (\u201cHP Poland\u201d) provided gifts and cash bribes to a Polish government official to obtain contracts with Poland\u2019s national police agency. In Mexico, HP Co.\u2019s Mexican subsidiary (\u201cHP Mexico\u201d) made improper payments to a third party in connection with a sale of software to Mexico\u2019s state-owned petroleum agency. HP Co. and its consolidated subsidiaries (collectively, \u201cHP\u201d) earned approximately $29 million in illicit profits as a result of this improper conduct. \r\n \r\n 2. The payments and improper gifts to government officials made directly or through intermediaries were falsely recorded in the relevant HP subsidiaries\u2019 books and records as legitimate consulting and service contracts, commissions, or travel expenses. In fact, the true purpose of the payments and gifts was to make improper payments to foreign government officials to obtain lucrative government contracts for HP. During the relevant period, HP lacked sufficient internal controls to detect and prevent the improper payments and gifts made by executives and representatives of certain of its foreign subsidiaries.\u0022 As part of the company\u0027s consent to entry of a cease and desist order, it agreed to \u0022pay disgorgement of $29,000,000 and prejudgment interest of $5,000,000 to the United States Treasury. $2,527,750 of Respondent\u2019s disgorgement obligation will be satisfied by Respondent\u2019s payment of $2,527,750 in forfeiture as part of HP Mexico\u2019s resolution with the United States Department of Justice.\u0022 (Source: US Securities and Exchange Commission Administrative Proceeding In the Matter of Hewlett -Packard Company, File No. 3-15832, April 9, 2014)","Sources ":"US Securities and Exchange Commission, \r\n \r\n \u0022SEC Charges Hewlett-Packard With FCPA Violations,\u0022 April 9, 2014, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370541453075","Documents":""},{"Case ID":"ST-456","Case Cluster ":"Hewlett-Packard","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Poland","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"4\/9","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$15,450,224 ","Criminal Fine\/Penalty (US$) ":"$15,450,224 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"Falsification of Books and Records; Internal Controls Violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, three subsidiaries of the Hewlett-Packard company reached settlements with the agency in 2014. Pursuant to a Deferred Prosecution agreement, a criminal information alleging violations of books and records and internal controls provisions of the FCPA was filed against Hewlett-Packard Polska, SP Z.O.O. (HP Poland). According to the Information, HP Poland was charged with violating the accounting provision misconduct during 2006-2010, namely cash bribery payments to a Polish official in order to obtain contracts with the Polish National Police Agency, part of the Polish Ministry of the Interior and Administration. (Source: US v. Hewlett-Packard Polska, SP Z.O.O., Case No. 14-cr-202 (NDCA), Information and Deferred Prosecution Agreement filed April 9, 2014, and US Department of Justice Press Release, \u0022HewlettPackard Russia Agrees to Plead Guilty to Foreign Bribery,\u0022 April 9, 2014.)","Sources ":"US v. Hewlett Packard Polska, SP Z.O.O., Case No. 14-cr-202 (NDCA), Information and Deferred Prosecution Agreement filed April 9, 2014, and US Department of Justice Press Release, \u0022HewlettPackard Russia Agrees to Plead Guilty to Foreign Bribery,\u0022 April 9, 2014, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-hewlett-packard-polska-sp-z-oocourt-docket-number-cr-14-202-ejd.","Documents":""},{"Case ID":"ST-457","Case Cluster ":"Hewlett-Packard","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Russia","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"4\/9","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$58,772,250 ","Criminal Fine\/Penalty (US$) ":"$58,772,250 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, the Russian subsidiary of the Hewlett-Packard company pleaded guilty to violation of FCPA charges: \u0022According to curt documents, in 1999, the Russian government announced a project to automate the computer and telecommunications infrastructure of its Office of the Prosecutor General of the Russian Federation (GPO). Not only was that project itself worth more than $100 million, but HP Russia viewed it as the \u201cgolden key\u201d that could unlock the door to another $100 to $150 million dollars in business with Russian government agencies. To secure a contract for the first phase of project, ultimately valued at more than \u20ac 35 million, HP Russia executives and other employees structured the deal to create a secret slush fund totaling several million dollars, at least part of which was intended for bribes to Russian government officials.\r\n \r\n As admitted in a statement of facts, HP Russia created excess profit margins for the slush fund through an elaborate buyback\r\n deal structure, whereby (1) HP sold the computer hardware and other technology products called for under the contract to a Russian channel partner, (2) HP bought the same products back from an intermediary company at a nearly \u20ac8 million markup and paid the intermediary an additional \u20ac4.2 million for purported services, and (3) HP sold the same products to the GPO at the increased price. The payments to the intermediary were then largely transferred through a cascading series of shell companies \u2013 some of which were directly associated with government officials \u2013 registered in the United States, United Kingdom, British Virgin Islands and Belize. Much of these payments from the intermediary were laundered through offshore bank accounts in Switzerland, Lithuania, Latvia and Austria. Portions of the funds were spent on travel, cars, jewelry, clothing, expensive watches, swimming pool technology, furniture, household appliances and other luxury goods. To keep track of these corrupt payments, the conspirators inside HP Russia kept two sets of books: secret spreadsheets that detailed the categories of recipients of the corrupt funds and sanitized versions that hid the corrupt payments from others outside of HP Russia. They also entered into offthebooks side agreements. As one example, an HP Russia executive executed a letter agreement to pay \u20ac2.8 million in purported \u201ccommission\u201d fees to a U.K.registered shell company, which was linked to a director of the Russian government agency responsible for managing the GPO project. HP Russia never disclosed the existence of the agreement to internal or external auditors or management outside of HP Russia and conducted no due diligence of the shell company.\u0022 (Source: US Department of Justice Press Release, \u0022HewlettPackard Russia Agrees to Plead Guilty to Foreign Bribery,\u0022 April 4, 2014.)","Sources ":"US v. ZAO Hewlett-Packard A.O., Case No. 14-cr-201 (NDCA), Information and Plea Agreement filed April 9, 2014, and US Department of Justice Press Release, \u0022HewlettPackard Russia Agrees to Plead Guilty to Foreign Bribery,\u0022 April 9, 2014, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-zao-hewlett-packard-aocourt-docket-number-cr-14-201-dlj","Documents":""},{"Case ID":"ST-458","Case Cluster ":"Hitachi Ltd.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"South Africa","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"9\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$19,000,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$19,000,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records, Internal Controls Violation","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, in September 2015, the agency \u0022charged Tokyo-based conglomerate Hitachi, Ltd. with violating the Foreign Corrupt Practices Act (FCPA) when it inaccurately recorded improper payments to South Africa\u2019s ruling political party in connection with contracts to build two multi-billion dollar power plants. Hitachi has agreed to pay $19 million to settle the SEC charges.\r\n \r\n The SEC alleges that Hitachi sold a 25-percent stake in a South African subsidiary to a company serving as a front for the African National Congress (ANC). This arrangement gave the front company and the ANC the ability to share in the profits from any power station contracts that Hitachi secured. Hitachi was ultimately awarded two contracts to build power stations in South Africa and paid the ANC\u2019s front company approximately $5 million in \u201cdividends\u201d based on profits derived from the contracts. Through a separate, undisclosed arrangement, Hitachi paid the front company an additional $1 million in \u201csuccess fees\u201d that were inaccurately booked as consulting fees without appropriate documentation. [ ] \r\n \r\n Hitachi was aware that Chancellor House Holdings (Pty) Ltd. was a funding vehicle for the ANC during the bidding process. \r\n Hitachi nevertheless continued to partner with Chancellor and encourage the company to use its political influence to help obtain government contracts from Eskom Holdings SOC Ltd., a public utility owned and operated by the South African government.\r\n \r\n Hitachi paid \u201csuccess fees\u201d to Chancellor for its exertion of influence during the Eskom tender process pursuant to a separate, unsigned side-arrangement.\u0022 (Source: SEC Press Release, \u0022SEC Charges Hitachi With FCPA Violations,\u0022 September 28, 2015.)","Sources ":"US Securities and Exchange Commission v. Hitachi Ltd., Case No. 1:15-cv-1573 (DDC), Complaint filed September 28, 2015, at https:\/\/www.sec.gov\/litigation\/complaints\/2015\/comp-pr2015-212.pdf;\r\n \r\n SEC Press Release, \u0022SEC Charges Hitachi With FCPA Violations,\u0022 September 28, 2015, at https:\/\/www.sec.gov\/news\/pressrelease\/2015-212.html","Documents":""},{"Case ID":"ST-459","Case Cluster ":"IAP Worldwide Services Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Kuwait","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"6\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022A Florida defense and government contracting company, IAP Worldwide Services Inc. (IAP), entered into a nonprosecution agreement and agreed to pay a $7.1 million penalty to resolve the government\u2019s investigation into whether the company conspired to bribe Kuwaiti officials in order to secure a government contract. [James M. Rama, a] former vice president of IAP also pleaded guilty today to conspiracy to violate the Foreign Corrupt Practices Act (FCPA) for his involvement in the bribery scheme. [ ] In 2004, Kuwait\u2019s Ministry of the Interior (MOI) initiated the Kuwait Security Program (KSP), a project that was intended to provide nationwide surveillance capabilities for several Kuwaiti government agencies primarily through the use of closed circuit television. The project was divided into two phases: a planning and feasibility period called \u201cPhase I\u201d and an installation period called \u201cPhase II.\u201d The MOI was responsible for overseeing the KSP, including selecting contractors to facilitate its implementation. Revenues from the Phase II contract were expected to be substantially greater than from Phase I.\r\n \r\n According to admissions made in connection with both the nonprosecution agreement and Rama\u2019s plea agreement, IAP and Rama schemed to ensure that IAP worked as the consultant for Phase I so that it could tailor the requirements for the Phase II contracts to IAP\u2019s strengths, which would give the company an advantage in the Phase II bidding. To that end, both IAP and Rama admitted that in February 2006, executives and senior employees of IAP, including Rama, set up a shell company called \u201cRamaco\u201d to bid on Phase I, in part to conceal IAP\u2019s role in crafting the Phase II requirements and its conflict of interest in connection with securing the Phase II contract.\r\n \r\n Ultimately, Ramaco secured the Phase I contract for approximately $4 million. According to admissions made in connection with both agreements, the Rama and IAP agreed that half of that amount would be diverted to a consultant who would pay bribes to Kuwaiti government officials to assist IAP in obtaining and retaining the Phase I contract and to obtain the Phase II contract. IAP and Rama admitted that they disguised the payments by transferring funds Ramaco received to an IAP bank account and then to the consultant through a series of accounts and intermediaries. According to the factual statements incorporated into both the nonprosecution agreement and Rama\u2019s plea agreement, between September 2006 and March 2008, IAP and its coconspirators paid the consultant approximately $1,783,688 understanding that some or all of the funds would be used to bribe Kuwaiti government officials.\u0022 (Source: DOJ Press Release, \u0022IAP Worldwide Services Inc. Resolves Foreign Corrupt Practices Act investigation,\u0022 June 16, 2015.)\r\n \r\n According to the Nonprosecution Agreement, the company agreed to pay the monetary penalty in the present value amount of $7,100,000 to the United States Treasury over a period of three years. (Source: Nonprosecution Agreement of June 15, 2015). Mr. Rama was sentenced to four months\u0027 imprisonment and no monetary sanctions were imposed, given his financial and personal circumstances and that it was his first offense. (Source: US v. Rama, Case No. 15-cr-143(EDVA), Judgment October 15, 2015 and Position of the United States with respect Sentencing, filed October 2, 2015.)","Sources ":"Nonprosecution Agreement by IAP Worldwide Services Inc. and DOJ Press Release, \u0022IAP Worldwide Services Inc. Resolves Foreign Corrupt Practices Act investigation,\u0022 June 16, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/iap; US v. James M. Rama, Case No. 15-cr-143 (EDVA), Information filed June 15, 2015, Plea Agreement and Statement of Facts, at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/james-rama; Judgment October 15, 2015 and Position of the United States with respect Sentencing, filed October 2, 2015, both accessed via PACER.","Documents":""},{"Case ID":"ST-460","Case Cluster ":"IAP Worldwide Services Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Kuwait","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"6\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Ciminal Penalty","Total Monetary Sanctions (US$)":"$7,100,000 ","Criminal Fine\/Penalty (US$) ":"$7,100,000 ","Criminal Fine \/ Penalty (Explanation)":"$0 ","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"NA","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022A Florida defense and government contracting company, IAP Worldwide Services Inc. (IAP), entered into a nonprosecution agreement and agreed to pay a $7.1 million penalty to resolve the government\u2019s investigation into whether the company conspired to bribe Kuwaiti officials in order to secure a government contract. [James M. Rama, a] former vice president of IAP also pleaded guilty today to conspiracy to violate the Foreign Corrupt Practices Act (FCPA) for his involvement in the bribery scheme. [ ] In 2004, Kuwait\u2019s Ministry of the Interior (MOI) initiated the Kuwait Security Program (KSP), a project that was intended to provide nationwide surveillance capabilities for several Kuwaiti government agencies primarily through the use of closed circuit television. The project was divided into two phases: a planning and feasibility period called \u201cPhase I\u201d and an installation period called \u201cPhase II.\u201d The MOI was responsible for overseeing the KSP, including selecting contractors to facilitate its implementation. Revenues from the Phase II contract were expected to be substantially greater than from Phase I.\r\n \r\n According to admissions made in connection with both the nonprosecution agreement and Rama\u2019s plea agreement, IAP and Rama schemed to ensure that IAP worked as the consultant for Phase I so that it could tailor the requirements for the Phase II contracts to IAP\u2019s strengths, which would give the company an advantage in the Phase II bidding. To that end, both IAP and Rama admitted that in February 2006, executives and senior employees of IAP, including Rama, set up a shell company called \u201cRamaco\u201d to bid on Phase I, in part to conceal IAP\u2019s role in crafting the Phase II requirements and its conflict of interest in connection with securing the Phase II contract.\r\n \r\n Ultimately, Ramaco secured the Phase I contract for approximately $4 million. According to admissions made in connection with both agreements, the Rama and IAP agreed that half of that amount would be diverted to a consultant who would pay bribes to Kuwaiti government officials to assist IAP in obtaining and retaining the Phase I contract and to obtain the Phase II contract. IAP and Rama admitted that they disguised the payments by transferring funds Ramaco received to an IAP bank account and then to the consultant through a series of accounts and intermediaries. According to the factual statements incorporated into both the nonprosecution agreement and Rama\u2019s plea agreement, between September 2006 and March 2008, IAP and its coconspirators paid the consultant approximately $1,783,688 understanding that some or all of the funds would be used to bribe Kuwaiti government officials.\u0022 (Source: DOJ Press Release, \u0022IAP Worldwide Services Inc. Resolves Foreign Corrupt Practices Act investigation,\u0022 June 16, 2015.)\r\n \r\n According to the Nonprosecution Agreement, the company agreed to pay the monetary penalty in the present value amount of $7,100,000 to the United States Treasury over a period of three years. (Source: Nonprosecution Agreement of June 15, 2015).","Sources ":"Nonprosecution Agreement by IAP Worldwide Services Inc. and DOJ Press Release, \u0022IAP Worldwide Services Inc. Resolves Foreign Corrupt Practices Act investigation,\u0022 June 16, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/iap","Documents":""},{"Case ID":"ST-461","Case Cluster ":"Ignacio Cueto Plaza","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/4","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$75,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$75,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No","Summary":"According to the US Securities and Exchange Commission Administrative Summary, \u0022An SEC investigation found that Ignacio Cueto Plaza, who was serving as president and chief operating officer at the time, authorized a sham consulting agreement and the company wired $1.15 million in payments to the consultant\u2019s Virginia-based brokerage account. The unsigned agreement falsely stated that the consultant would undertake a study of existing air routes in Argentina. Cueto knew no such study would be performed and the consultant instead agreed to help settle the labor dispute, and Cueto also nderstood it was possible that the consultant would pass a portion of the payments along to union officials in Argentina. Cueto pproved the payments to get the unions to abandon their threats to enforce the single-function rule and to get them to accept a wage increase lower than the amount asked for in negotiations.\u0022 (Source: US SEC Administrative Summary, \u0022Airline Executive Settles FCPA Charges,\u0022 February 4, 2016.)","Sources ":"US SEC Administrative Proceeding File No. 3-17100, In the Matter of Ignacio Cueto Plaza, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77057.pdf; Summary, \u0022Airline Executive Settles FCPA Charges,\u0022 February 4, 2016, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77057-s.pdf.","Documents":""},{"Case ID":"ST-462","Case Cluster ":"Innospec","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Indonesia, Iraq","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"8\/4","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Legal Costs","Total Monetary Sanctions (US$)":"$16,818 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$16,818 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office, \u0022Four men were today sentenced for their roles in bribing state officials in Indonesia and Iraq, following a Serious Fraud Office investigation into Associated Octel Corporation (subsequently renamed Innospec).\r\n \r\n Dennis Kerrison, 69, of Chertsey, Surrey, was sentenced to 4 years in prison.\r\n Paul Jennings, 57, of Neston, Cheshire, was sentenced to 2 years in prison.\r\n Miltiades Papachristos, 51 of Thessaloniki, Greece, was sentenced to 18 months in prison.\r\n David Turner, 59, of Newmarket, Suffolk, was sentenced to a 16 month suspended sentence with 300\r\n hours unpaid work \r\n \r\n Mr Kerrison and Dr Papachristos were convicted of conspiracy to commit corruption in June 2014 in relation to Indonesia only. Mr Jennings pleaded guilty in June 2012 to two charges of conspiracy to commit corruption and in July 2012 to a further charge of conspiracy to commit corruption in relation to Indonesia and Iraq. Dr Turner pleaded guilty to three charges of conspiracy to commit corruption in January 2012 in relation to Indonesia and Iraq. [ ]\r\n \r\n Upon sentencing the defendants, HHJ Goymer said:\r\n \r\n \u201cCorruption in this company was endemic, institutionalised and ingrained\u2026 but despite being a separate legal entity it is not an automated machine\u037e decisions are made by human minds. [ ]\r\n \r\n Innospec itself pleaded guilty in March 2010 to bribing state officials in Indonesia and was fined $12.7 million in England with additional penalties being imposed in the USA. Dr Turner was also ordered to pay \u00a310,000 towards prosecution costs and Mr Jennings was ordered to pay \u00a35000 towards these costs. Dr Turner and Mr Jennings have already been subject to disgorgement pay \u00a35000 towards these costs. Dr Turner and Mr Jennings have already been subject to disgorgement of benefit by the US Securities and Exchange Commission. The matter of costs for Mr Kerrison and Dr Papachristos has been adjourned pending the hearing of confiscation proceedings against them.\u0022 (Source: UK Serious Fraud Office Press Reease, \u0022Four sentenced for role in Innospec corruption,\u0022 August 4, 2014.)","Sources ":"UK Serious Fraud Office Press Release, \u0022Four sentenced for role in Innospec corruption,\u0022 August 4, 2014, at https:\/\/www.sfo.gov.uk\/2014\/08\/04\/four-sentenced-role-innospec-corruption\/.","Documents":""},{"Case ID":"ST-463","Case Cluster ":"Innospec","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Indonesia, Iraq","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"8\/4","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Legal Costs","Total Monetary Sanctions (US$)":"$8,409 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$8,409 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office, \u0022Four men were today sentenced for their roles in bribing state officials in Indonesia and Iraq, following a Serious Fraud Office investigation into Associated Octel Corporation (subsequently renamed Innospec).\r\n \r\n Dennis Kerrison, 69, of Chertsey, Surrey, was sentenced to 4 years in prison.\r\n Paul Jennings, 57, of Neston, Cheshire, was sentenced to 2 years in prison.\r\n Miltiades Papachristos, 51 of Thessaloniki, Greece, was sentenced to 18 months in prison.\r\n David Turner, 59, of Newmarket, Suffolk, was sentenced to a 16 month suspended sentence with 300\r\n hours unpaid work \r\n \r\n Mr Kerrison and Dr Papachristos were convicted of conspiracy to commit corruption in June 2014 in relation to Indonesia only. Mr Jennings pleaded guilty in June 2012 to two charges of conspiracy to commit corruption and in July 2012 to a further charge of conspiracy to commit corruption in relation to Indonesia and Iraq. Dr Turner pleaded guilty to three charges of conspiracy to commit corruption in January 2012 in relation to Indonesia and Iraq. [ ]\r\n \r\n Upon sentencing the defendants, HHJ Goymer said:\r\n \r\n \u201cCorruption in this company was endemic, institutionalised and ingrained\u2026 but despite being a separate legal entity it is not an automated machine\u037e decisions are made by human minds. [ ]\r\n \r\n Innospec itself pleaded guilty in March 2010 to bribing state officials in Indonesia and was fined $12.7 million in England with additional penalties being imposed in the USA. Dr Turner was also ordered to pay \u00a310,000 towards prosecution costs and Mr Jennings was ordered to pay \u00a35000 towards these costs. Dr Turner and Mr Jennings have already been subject to disgorgement pay \u00a35000 towards these costs. Dr Turner and Mr Jennings have already been subject to disgorgement of benefit by the US Securities and Exchange Commission. The matter of costs for Mr Kerrison and Dr Papachristos has been adjourned pending the hearing of confiscation proceedings against them.\u0022 (Source: UK Serious Fraud Office Press Reease, \u0022Four sentenced for role in Innospec corruption,\u0022 August 4, 2014.)","Sources ":"UK Serious Fraud Office Press Release, \u0022Four sentenced for role in Innospec corruption,\u0022 August 4, 2014, at https:\/\/www.sfo.gov.uk\/2014\/08\/04\/four-sentenced-role-innospec-corruption\/.","Documents":""},{"Case ID":"ST-464","Case Cluster ":"JLT Specialty Limited","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Financial Conduct Authority","Jurisdiction of Foreign Public Official(s) ":"Cameroon, China, Ecuador, Egypt, Gabon, Nigeria, Sudan, Unspecified West African countries","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"12\/19","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Final Notice","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$3,063,080 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$3,063,080 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Lack of Bribery Controls","Offenses - Settled":"Lack of Bribery Controls","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Financial Conduct Authority\u0027s Final Notice, JLT Specialty Limited \u0022provides insurance broking, risk management and claims consulting services to a wide range of national and international corporate clients. \r\n \r\n 2.2. The Authority has found that JLTSL breached Principle 3 by failing to take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems and controls for countering the risks of bribery and corruption associated with making payments to overseas third parties that helped JLTSL win and retain business from overseas clients (\u201cOverseas Introducers\u201d) in that: \r\n (1) during the whole of the Relevant Period, JLTSL failed to conduct adequate due diligence before entering into a relationship with an Overseas Introducer. In particular JLTSL did not take adequate steps to assess whether the Overseas Introducer was connected with the clients it introduced and\/or any public officials; \r\n (2) during the whole of the Relevant Period, JLTSL failed adequately to assess the risk associated with each piece of new insurance business introduced by an Overseas Introducer, which meant that JLTSL could not ensure that it took sufficient steps to counter the risk of bribery and corruption prior to making payments to Overseas Introducers; and \r\n (3) during the period 7 June 2011 to 9 May 2012 (\u201cthe Alarm Bells Period\u201d), JLTSL failed adequately to implement its own anti-bribery and corruption policies, which resulted in the risk of JLTSL entering into higher risk relationships with Overseas Introducers without sufficient senior management oversight and approval. Moreover, JLTSL failed to carry out adequate checks, which would have enabled it to identify that its policies were not being implemented correctly. \r\n 2.3. The Authority has found no evidence to suggest that JLTSL has permitted any illicit payment or inducement to any Overseas Introducer during the Relevant Period, nor that JLT intended to permit any illicit payment or inducement to any Overseas Introducer during the Relevant Period.\u0022 (Source: UK FCA Final Notice, File Reference Number 310428, December 19, 2013.)","Sources ":"UK Financial Conduct Authority, Final Notice to JLT Specialty Limited, Firm Reference Number 310428, December 19, 2013.","Documents":""},{"Case ID":"ST-465","Case Cluster ":"Keyuan Petrochemicals, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"2\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$1,000,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$1,000,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations; Violation of Anti-Fraud and Reporting provisions","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No","Summary":"According to the US Securities and Exchange Commission, \u0022Keyuan Petrochemicals, Inc., a China-based issuer formed through a reverse merger in April 2010, with violations of the anti-fraud, reporting, books and records, and internal control provisions of the federal securities laws. The SEC further charged Aichun Li, Keyuan\u2019s former Chief Financial Officer, with aiding and abetting Keyuan\u2019s reporting and books and records violations and for failing to implement internal accounting controls. Keyuan and Li have agreed to settle the SEC\u2019s claims against them.\r\n \r\n According to the SEC\u2019s complaint, between May 2010 and January 2011, in what was its first year as a U.S. public company, Keyuan systematically failed to disclose in its SEC filings numerous material related party transactions, as required by U.S. Generally Accepted Accounting Principles (\u201cGAAP\u201d) and Commission rules and regulations. The related parties included the company\u2019s three founding and controlling shareholders, including its current Chief Executive Officer, entities controlled by or affiliated with these persons, and entities controlled by Keyuan\u2019s management or their family members. The related party transactions included sales of products, purchases of raw materials, loan guarantees, and short term financing.\r\n \r\n Keyuan also operated an off-balance sheet cash account that was kept off the company\u2019s books by the former Vice President of Accounting. The account was used to pay for various items, including cash bonuses for senior officers and reimbursements to the CEO for business expenses, including travel, entertainment, and rent for an apartment. The account was also used to fund gifts\u2014both cash and non-cash\u2014 for Chinese government officials. By failing to properly record these transactions on the company\u2019s books and records, the company misstated its reported balances in its financial statements filed with the Commission.\r\n \r\n The SEC further alleges that Keyuan\u2019s then-CFO Aichun Li, a resident of North Carolina, played a role in the company\u2019s failure to disclose the related party transactions. Li was hired to ensure the company\u2019s compliance with U.S. accounting and financial reporting regulations, and she received information and encountered red flags that should have indicated that the company was not properly identifying or disclosing related party transactions. Despite such knowledge, Li signed Keyuan\u2019s registration statements and quarterly reports that failed to disclose material related party transactions.\u0022 (Source: SEC Litigation Release, \u0022Securities and Exchange Commission v. Keyuan Petrochemicals, Inc. and Aichun Li, Civil Action No. 13-cv-263 (D.D.C.), February 28, 2013.)","Sources ":"US Securities and Exchange Commission v. Keyuan Petrochemicals, Inc. and Aichun Li, Civil Action No. 13-cv-263 (D.D.C.), Complaint filed on February 28, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-30.pdf; and Litigation Release at https:\/\/www.sec.gov\/litigation\/litreleases\/2013\/lr22627.htm","Documents":""},{"Case ID":"ST-466","Case Cluster ":"Keyuan Petrochemicals, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"2\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$25,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$25,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No","Summary":"According to the US Securities and Exchange Commission, \u0022Keyuan Petrochemicals, Inc., a China-based issuer formed through a reverse merger in April 2010, with violations of the anti-fraud, reporting, books and records, and internal control provisions of the federal securities laws. The SEC further charged Aichun Li, Keyuan\u2019s former Chief Financial Officer, with aiding and abetting Keyuan\u2019s reporting and books and records violations and for failing to implement internal accounting controls. Keyuan and Li have agreed to settle the SEC\u2019s claims against them.\r\n \r\n According to the SEC\u2019s complaint, between May 2010 and January 2011, in what was its first year as a U.S. public company, Keyuan systematically\r\n failed to disclose in its SEC filings numerous material related party transactions, as required by U.S. Generally Accepted Accounting Principles\r\n (\u201cGAAP\u201d) and Commission rules and regulations. The related parties included the company\u2019s three founding and controlling shareholders,\r\n including its current Chief Executive Officer, entities controlled by or affiliated with these persons, and entities controlled by Keyuan\u2019s management or their family members. The related party transactions included sales of products, purchases of raw materials, loan guarantees, and short term financing.\r\n \r\n Keyuan also operated an off-balance sheet cash account that was kept off the company\u2019s books by the former Vice President of Accounting. The\r\n account was used to pay for various items, including cash bonuses for senior officers and reimbursements to the CEO for business expenses,\r\n including travel, entertainment, and rent for an apartment. The account was also used to fund gifts\u2014both cash and non-cash\u2014 for Chinese\r\n government officials. By failing to properly record these transactions on the company\u2019s books and records, the company misstated its reported balances in its financial statements filed with the Commission.\r\n \r\n The SEC further alleges that Keyuan\u2019s then-CFO Aichun Li, a resident of North Carolina, played a role in the company\u2019s failure to disclose the related\r\n party transactions. Li was hired to ensure the company\u2019s compliance with U.S. accounting and financial reporting regulations, and she received\r\n information and encountered red flags that should have indicated that the company was not properly identifying or disclosing related party transactions. Despite such knowledge, Li signed Keyuan\u2019s registration statements and quarterly reports that failed to disclose material related party transactions.\u0022 (Source: SEC Litigation Release, \u0022Securities and Exchange Commission v. Keyuan Petrochemicals, Inc. and Aichun Li, Civil Action No. 13-cv-263 (D.D.C.), February 28, 2013.)","Sources ":"US Securities and Exchange Commission v. Keyuan Petrochemicals, Inc. and Aichun Li, Civil Action No. 13-cv-263 (D.D.C.), Complaint filed on February 28, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-30.pdf; and Litigation Release at https:\/\/www.sec.gov\/litigation\/litreleases\/2013\/lr22627.htm","Documents":""},{"Case ID":"ST-467","Case Cluster ":"Koninklijke Philips Electronics","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Poland","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"4\/5","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$4,515,178 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$3,120,597 ","Civil Prejudgment Interest (US$) ":"$1,394,581 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, from at least 1999 through 2007, employees of Philips\u2019s Polish subsidiary, Philips Polska sp. z o.o. (\u201cPhilips Poland\u201d) made improper payments to healthcare officials in Poland regarding public tenders proffered by Polish healthcare facilities to purchase medical equipment. According to the Cease and Desist Order, \u0022Since at least 1999, Philips has participated in public tenders to sell medical equipment to Polish healthcare facilities. From 1999 through 2007, in at least 30 transactions, employees of Philips Poland made improper payments to public officials of Polish healthcare facilities to increase the likelihood that public tenders for the sale of medical equipment would be awarded to Philips.\r\n \r\n 4. Representatives of Philips Poland entered into arrangements with officials of various Polish healthcare facilities whereby Philips submitted the technical specifications of its medical equipment to officials drafting the tenders who incorporated the specifications of Philips\u2019 equipment into the contracts. Incorporating the specifications of Philips\u2019 equipment in the tenders\u2019\r\n requirements greatly increased the likelihood that Philips would be awarded the bids.\r\n \r\n 5. Certain of the healthcare officials involved in the arrangements with Philips also decided whom to award the tenders, and when Philips was awarded the contracts, the officials were paid the improper payments by employees of Philips Poland.\r\n \r\n 6. The improper payments made by employees of Philips Poland to the Polish healthcare officials usually amounted to 3% to 8% of the contracts\u2019 net value. [ ]\r\n \r\n 7. At times, Philips Poland employees also kept a portion of the improper payments as a \u201ccommission.\u201d The Philips Poland employees involved in the improper payments often utilized a third party agent to assist with the improper arrangements and payments to Polish healthcare officials.\u0022 The SEC did not impose a civil penalty, in light of the company\u0027s cooperation in the investigation. (Source: Administrative Proceeding File No. 3-15265, In the Matter of Koninklijke Philips Electronics NV, April 5, 2013).","Sources ":"US SEC Administrative Proceeding File No. 3-15265, In the Matter of Koninklijke Philips Electronics NV, April 5, 2013, at https:\/\/www.sec.gov\/litigation\/admin\/2013\/34-69327.pdf;","Documents":""},{"Case ID":"ST-468","Case Cluster ":"Las Vegas Sands Corp.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China (including Macao SAR)","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"4\/7","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$9,000,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$9,000,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"Falsification of Books and Records, Internal Controls Violations","Public Procurement Contract \/ SOE Involved?":"No","Summary":"According to the US Securities and Exchange Commission, \u0022Las Vegas Sands Corp. has agreed to pay a $9 million penalty to settle charges that it violated the Foreign Corrupt Practices Act (FCPA) by failing to properly authorize or document millions of dollars in payments to a consultant facilitating business activities in China and Macao.\r\n \r\n An SEC investigation found that LVS kept inaccurate books and records and frequently lacked supporting documentation or proper approvals for more than $62 million in payments to a consultant in Asia. The consultant acted as an intermediary to obscure the company\u2019s role in certain business transactions such as the purchases of a basketball team and a building in China, where casino gambling isn\u2019t permitted. At one point, LVS could not account for more than $700,000 transferred to the consultant for team expenses, yet continued to transfer millions of dollars to him. A portion of the payments were improperly recorded in company books and records, such as money supposedly spent on artwork for the building when none was actually purchased. [ ] \r\n  \r\n According to the SEC\u2019s order instituting a settled administrative proceeding:\r\n \r\n LVS transferred $6 million to a consultant internally referred to as a \u201cbeard\u201d to buy a team to play in the Chinese Basketball Association, which did not permit gaming companies to own a team. The company transferred an additional $8 million to the consultant to cover the costs of operating the team without any documentation of those costs.\r\n \r\n LVS used the same consultant as a beard to purchase a building in Beijing from a Chinese state-owned-entity, ostensibly to develop a business center for U.S. companies seeking to do business in China. Despite concerns by some employees that the real estate purchase was solely for political purposes, approximately $43 million in payments were made to the consultant without research, analysis, or proper approval by any LVS employee authorized to approve the amounts paid. \r\n \r\n Approximately $900,000 paid to an entity controlled by the consultant was recorded in company books and records as \u201cproperty management fees\u201d when no property management services were actually performed. Approximately $1.4 million was recorded as \u201carts and crafts\u201d when the entity never actually obtained any artwork for the building.\r\n LVS failed to prevent employees from circumventing policies and procedures for purchases, reimbursements to outside counsel, and comps to customers. For example, one employee obtained a cash advance of $28,000 and a cash reimbursement of $86,000 without proper authorization. An outside counsel requested reimbursement of $25,000 for expenses incurred on a business trip but provided no documentation, and later admitted that he actually requested the funds for a friend. In its casinos in Macao, LVS employees did not track which customers received comps to ensure they weren\u2019t providing improper gifts to government officials.\u0022 (Source: SEC Press Release, \u0022Las Vegas Sands Paying Penalty for FCPA Violations,\u0022 April 7, 2016.)","Sources ":"US Securities and Exchange Commission, In the Matter of Las Vegas Sands Corp., Administrative Proceeding File No. 3-17204, April 7, 2016, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77555.pdf; Press Release, \u0022Las Vegas Sands Paying Penalty for FCPA Violations,\u0022 April 7, 2016, at https:\/\/www.sec.gov\/news\/pressrelease\/2016-64.html.","Documents":""},{"Case ID":"ST-469","Case Cluster ":"Layne Christensen Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Burkina Faso, Democratic Republic of Congo, Guinea, Mali, Tanzania","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"10\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$5,127,193 ","Criminal Fine\/Penalty (US$) ":"NA","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"NA","Criminal Restitution \/ Reparation (US$)":"NA","Criminal Legal \/ Procedural Costs (US$)":"NA","Civil Disgorgement of Profits (US$) ":"$3,893,472.42 ","Civil Prejudgment Interest (US$) ":"$858,720.68 ","Civil Fine \/ Penalty (US$)":"$375,000 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art. 16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign public officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs, Tax, Permits)","Summary":"According to the US Securities and Exchange Commission, Layne Christen Co, \u0022a global water management, construction, and drilling company headquartered in Texas was charged with violating the Foreign Corrupt Practices Act (FCPA) by making improper payments to foreign officials in several African countries in order to obtain beneficial treatment and reduce its tax liability. [ ] \n \n  According to the SEC\u2019s order instituting settled administrative proceedings, Layne\u2019s misconduct occurred from 2005 to 2010. In addition to favorable tax treatment, the improper payments helped the company obtain customs clearance, work permits, and relief from inspections by immigration and labor officials in various African countries. \n \n Among the findings in the SEC\u2019s order:\n \n Layne paid nearly $800,000 to foreign officials in Mali, Guinea, and the Democratic Republic of the Congo (DRC) to reduce its tax liability and avoid associated penalties for delinquent payment. The bribes enabled Layne to realize more than $3.2 million in improper tax savings. \n \n Layne made improper payments to customs officials in Burkina Faso and the DRC to avoid paying customs duties and obtain clearance to import and export its equipment. The bribes were falsely recorded as legal fees and commissions in the company\u2019s books and records.\n \n Layne paid more than $23,000 in cash to police, border patrol, immigration officials, and labor inspectors in Burkina Faso, Guinea, Tanzania, and the DRC to obtain border entry for its equipment and employees. The bribes also helped secure work permits for its expatriate employees and avoid penalties for non-compliance with local immigration and labor regulations.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Texas-Based Layne Christensen Company With FCPA Violations,\u0022 October 27, 2014.)","Sources ":"US SEC Administrative Proceeding File No. 3-16216, In the Matter of Layne Christensen, October 24, 2014, at\n https:\/\/www.sec.gov\/litigation\/admin\/2014\/34-73437.pdf; SEC Press Release, \u0022SEC Charges Texas-Based Layne Christensen Company With FCPA Violations,\u0022 October 27, 2014., at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370543291857","Documents":""},{"Case ID":"ST-470","Case Cluster ":"Maxwell Technologies, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"1\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$8,000,000 ","Criminal Fine\/Penalty (US$) ":"$8,000,000 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Books and Records violation","Offenses - Settled":"Bribery of Foreign Officials; Books and Records violation","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Maxwell Technologies Inc., a publicly-traded manufacturer of energy-storage and power-delivery products based in San Diego, has agreed to pay an $8 million criminal penalty to resolve charges related to the Foreign Corrupt Practices Act (FCPA) for bribing Chinese government officials to secure sales of Maxwell\u2019s products to state-owned manufacturers of electric-utility infrastructure in several Chinese provinces. [ ]\r\n \r\n The department filed a deferred prosecution agreement and a criminal information against Maxwell in U.S. District Court for the Southern District of California today. The two-count information charges Maxwell with one count of violating the FCPA\u2019s anti-bribery provisions and one count of violating the FCPA\u2019s books-and-records provisions.\r\n \r\n According to court documents, Maxwell\u2019s wholly-owned Swiss subsidiary, Maxwell S.A., engaged a Chinese agent to sell Maxwell\u2019s products in China. From at least July 2002 through May 2009, Maxwell S.A. paid more than $2.5 million to its Chinese agent to secure contracts with Chinese customers, including contracts for the sale of Maxwell\u2019s high-voltage capacitor products to state-owned manufacturers of electrical-utility infrastructure. The agent in turn used Maxwell S.A.\u2019s money to bribe officials at the state-owned entities in connection with the sales contracts. Maxwell S.A. paid its Chinese agent approximately $165,000 in 2002 and increased the payments to the agent to $1.1 million in 2008. In its books and records, Maxwell mischaracterized the bribes as sales-commission expenses. According to court documents, Maxwell\u2019s U.S. management discovered the bribery scheme in late 2002.\u0022 (Source: US Department of Justice Press Release, \u0022Maxwell Technologies Inc. Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $8 Million Criminal Penalty,\u0022 January 31, 2011.)","Sources ":"US v. Maxwell Technologies, Inc., Case No, 11-cr-329 (SDCA), Information and Deferred Prosecution Agreement filed January 31, 2011; Department of Justice Press Release, \u0022Maxwell Technologies Inc. Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $8 Million Criminal Penalty,\u0022 January 31, 2011, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-maxwell-technologies-inc-court-docket-number11-cr-329-jm","Documents":""},{"Case ID":"ST-471","Case Cluster ":"Mead Johnson Nutrition","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"7\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits; Prejudgment Interest; Civil Penalty","Total Monetary Sanctions (US$)":"$12,030,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$7,770,000 ","Civil Prejudgment Interest (US$) ":"$1,260,000 ","Civil Fine \/ Penalty (US$)":"$3,000,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, the \u0022Mead Johnson Nutrition Company has agreed to settle charges that its Chinese subsidiary made improper payments to health care professionals at government-owned hospitals to recommend the company\u2019s infant formula to patients who were new or expectant mothers. [  ] \r\n \r\n An SEC investigation found that employees funded the improper payments through \u0027distributor allowance\u0027 funds paid to third-party distributors who market, sell, and distribute the company\u2019s products in China. Although the funds contractually belonged to the distributors, employees exercised some control over how the money was spent and provided specific guidance to distributors on how to use the funds. Cash and other incentives were subsequently paid to health care professionals in China hospitals to recommend Mead Johnson Nutrition products and provide the company with contact information for patients who were new or expectant mothers so it could market its infant formula to them directly. The company did not accurately reflect in its books and records the more than $2 million in improper payments made during a five-year period.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Mead Johnson Nutrition With FCPA Violations,\u0022 July 28, 2015.)","Sources ":"US Securities and Exchange Commission Administrative Proceeding File No. 3-16704, In the Matter of Mead Johnson Nutrition, at https:\/\/www.sec.gov\/litigation\/admin\/2015\/34-75532.pdf;\r\n \r\n SEC Press Release, \u0022SEC Charges Mead Johnson Nutrition With FCPA Violations,\u0022 July 28, 2015, at https:\/\/www.sec.gov\/news\/pressrelease\/2015-154.html","Documents":""},{"Case ID":"ST-472","Case Cluster ":"Nordam Group","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"7\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,000,000 ","Criminal Fine\/Penalty (US$) ":"$2,000,000 ","Criminal Fine \/ Penalty (Explanation)":"$0 ","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022The NORDAM Group Inc., a provider of aircraft maintenance, repair and overhaul (MRO) services based in Tulsa, Okla., has entered into an agreement with the Department of Justice to pay a $2 million penalty to resolve violations of the Foreign Corrupt Practices Act (FCPA).[ ]\r\n \r\n According to the agreement, NORDAM, its subsidiaries and affiliates paid bribes to employees of airlines created, controlled and exclusively owned by the People\u2019s Republic of China in order to secure contracts to perform MRO services for those airlines. The bribes were paid both directly and indirectly to the airline employees. In an effort to disguise the bribes, three employees of NORDAM\u2019s affiliate entered into sales representation agreements with fictitious entities and then used the money paid by NORDAM to those entities to pay bribes to the airline employees.\u0022 (Source: US Department of Justice Press Release, \u0022The Nordam Group Inc. Resolves Foreign Corrupt Practices Act Violations and Agrees to Pay $2 Million Penalty,\u0022 July 17, 2012.)\r\n \r\n The Nonprosecution Agreement notes that the company had demonstrated that any fine exceeding $2 million would substantially jeopardize the company\u0027s continued viability. It also states that customer invoices were artificially inflacted to offset the bribes paid to those customers\u0027 employees (para 7) and that the company \u0022paid as high as $1.5 million in bribes to secure roughly $2.48 million in profits from state-owned and controlled customers in China.\u0022 (Source: US DOJ, In re: Nordam Group Inc., July 6, 2012.)","Sources ":"US Department of Justice Nonprosecution Agreement (July 6, 2012) and Press Release, \u0022The Nordam Group Inc. Resolves Foreign Corrupt Practices Act Violations and Agrees to Pay $2 Million Penalty,\u0022 July 17, 2012, both at https:\/\/www.justice.gov\/criminal-fraud\/case\/re-nordam-group-inc-2012.","Documents":""},{"Case ID":"ST-473","Case Cluster ":"Nordion (Canada) Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Russua","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"3\/3","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$375,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$375,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Licensing)","Summary":"According to the US Securities and Exchange Commission Administrative Proceeding release, \u0022From at least 2004 through 2011, Nordion, Inc. (\u201cNordion\u201d), a global health science company, violated the books and records and internal accounting controls provisions of the Foreign Corrupt Practices Act of 1977 (\u201cFCPA\u201d) in connection with payments made to a third party agent to obtain Russian government approval to distribute TheraSphere, Nordion\u2019s liver cancer treatment, in Russia. Nordion failed to record those payments in a manner that accurately and fairly reflected the transactions in its books and records. Nordion also failed to devise and maintain adequate internal accounting controls to provide sufficient reassurances that Nordion funds were used as authorized, that third-party agents were appropriately vetted, and that Nordion adequately trained its employees to conduct business in countries with significant corruption risks.\u0022 The Administrative Summary notes that the scheme failed and Nordion was unable to distribute TheraSphere in Russia and did not profit from the scheme. (Source: In re: Nordion (Canada) Inc., Administrative Proceeding File No. 3-17153, and Administrative Summary.)","Sources ":"US Securities and Exchange Commission, In re: Nordion (Canada) Inc., Administrative Proceeding File No. 3-17153, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77290.pdf; Administrative Summary, \u0022SEC Charges Engineer and Former Employer with Bribe Scheme in Russia,\u0022 March 3, 2016, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77288-s.pdf.","Documents":""},{"Case ID":"ST-474","Case Cluster ":"Nordion (Canada) Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Russia","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"3\/3","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits; Prejudgment Interest; Civil Penalty","Total Monetary Sanctions (US$)":"$178,950 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$100,000 ","Civil Prejudgment Interest (US$) ":"$12,950 ","Civil Fine \/ Penalty (US$)":"$66,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Licensing)","Summary":"According to the US Securities and Exchange Commission Administrative Proceeding release, \u0022From at least 2004 through 2011, Nordion, Inc. (\u201cNordion\u201d), a global health science company, violated the books and records and internal accounting controls provisions of the Foreign Corrupt Practices Act of 1977 (\u201cFCPA\u201d) in connection with payments made to a third party agent to obtain Russian government approval to distribute TheraSphere, Nordion\u2019s liver cancer treatment, in Russia. Nordion failed to record those payments in a manner that accurately and fairly reflected the transactions in its books and records. Nordion also failed to devise and maintain adequate internal accounting controls to provide sufficient reassurances that Nordion funds were used as authorized, that third-party agents were appropriately vetted, and that Nordion adequately trained its employees to conduct business in countries with significant corruption risks.\u0022 The Administrative Summary notes that the scheme failed and Nordion was unable to distribute TheraSphere in Russia and did not profit from the scheme. (Source: In re: Nordion (Canada) Inc., Administrative Proceeding File No. 3-17153, and Administrative Summary.) Mr. Gourevitch, former employee, arranged for the improper payments to a third party agent and provided false documentation to the company to conceal the payments. (Source: US SEC Administrative Summary, \u0022SEC Charges Engineer and Former Employer with Bribe Scheme in Russia,\u0022 March 3, 2016.)","Sources ":"US Securities and Exchange Commission, Administrative Summary, \u0022SEC Charges Engineer and Former Employer with Bribe Scheme in Russia,\u0022 March 3, 2016, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77288-s.pdf","Documents":""},{"Case ID":"ST-475","Case Cluster ":"Novartis AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"3\/26","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits; Prejudgment Interest; Civil Penalty","Total Monetary Sanctions (US$)":"$25,000,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$21,500,000 ","Civil Prejudgment Interest (US$) ":"$1,500,000 ","Civil Fine \/ Penalty (US$)":"$2,000,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Press Release, \u0022Novartis AG has agreed to pay $25 million to settle charges that it violated the Foreign Corrupt Practices Act (FCPA) when its China-based subsidiaries engaged in pay-to-prescribe schemes to increase sales.\r\n \r\n An SEC investigation found that employees of two China-based Novartis subsidiaries gave money, gifts, and other things of value to health care professionals, which led to several million dollars in sales of pharmaceutical products to China\u2019s state health institutions. The schemes, which lasted a period of years, involved certain complicit managers within Novartis\u2019 China based subsidiaries. Novartis failed to devise and maintain a sufficient system of internal\r\n accounting controls and lacked an effective anti-corruption compliance program to detect and prevent these schemes. As a result, the improper payments were not accurately reflected in Novartis\u2019 books and records.\u0022 (Source: US Securities and Exchange Commission, Litigation Release and In re: Novartis AG, Administrative Proceeding File No. 3-17177, March 23, 2016.)","Sources ":"US Securities and Exchange Commission, In re: Novartis AG, Administrative Proceeding File No. 3-17177, March 2, 2016, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77431.pdf; Litigation Release at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77431-s.pdf.","Documents":""},{"Case ID":"ST-476","Case Cluster ":"Olympus Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Central and South America","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"3\/1","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$28,000,000 ","Criminal Fine\/Penalty (US$) ":"$28,000,000 ","Criminal Fine \/ Penalty (Explanation)":"$0 ","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, as part of a larger enforcement action involving payment of kick-backs by the Olympus Corporation of America, its Miami based subsidiary Olympus Latin America \u0022was charged with FCPA violations in connection with improper payments to health officials in Central and South America, and OLA entered into a separate three year DPA. According to court documents, from 2006 until August 2011, OLA implemented a plan to increase medical equipment sales in Central and South America by providing payments to health care practitioners at government owned health care facilities. These payments included cash, money transfers, personal grants, personal travel and free or heavily discounted equipment. The primary method to deliver these illicit benefits was through \u201ctraining centers,\u201d nominally set up to educate and train doctors, but which OLA used to provide benefits to preselected practitioners. OLA and its conspirators paid nearly $3 million to practitioners to induce the purchase of Olympus products and recognized more than $7.5 million in profits as a result.\u0022 (Source: US Department of Justice Press Release, \u0022Medical Equipment Company Will Pay $646 Million for Making Illegal Payments to Doctors and Hospitals in United States and Latin America,\u0022 March 1, 2016.)","Sources ":"US Department of Justice Press Release, \u0022Medical Equipment Company Will Pay $646 Million for Making Illegal Payments to Doctors and Hospitals in United States and Latin America,\u0022 March 1, 2016, at https:\/\/www.justice.gov\/opa\/pr\/medical-equipment-company-will-pay-646-million-making-illegal-payments-doctors-and-hospitals","Documents":""},{"Case ID":"ST-477","Case Cluster ":"Oracle Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"India","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"8\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$2,000,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$2,000,000 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Press Release, the agency alleged that \u0022certain employees of the India subsidiary of the Redwood Shores, Calif.-based enterprise systems firm structured transactions with India\u0027s government on more than a dozen occasions in a way that enabled Oracle India\u0027s distributors to hold approximately $2.2 million of the proceeds in unauthorized side funds. Those Oracle India employees then directed the distributors to make payments out of these side funds to purported local vendors, several of which were merely storefronts that did not provide any services to Oracle. Oracle\u0027s subsidiary documented certain payments with fake invoices. [ ] \r\n \r\n According to the SEC\u0027s complaint filed in U.S. District Court for the Northern District of California, the misconduct at Oracle\u0027s India subsidiary - Oracle India Private Limited - occurred from 2005 to 2007. Oracle India sold software licenses and services to India\u0027s government through local distributors, and then had the distributors \u0022park\u0022 excess funds from the sales outside Oracle India\u0027s books and records.\r\n \r\n For example, according to the SEC\u0027s complaint, Oracle India secured a $3.9 million deal with India\u0027s Ministry of Information Technology and Communications in May 2006. As instructed by Oracle India\u0027s then-sales director, only $2.1 million was sent to Oracle to record as revenue on the transaction, and the distributor kept $151,000 for services rendered. Certain other Oracle India employees further instructed the distributor to park the remaining $1.7 million for \u0022marketing development purposes.\u0022 Two months later, one of those same Oracle India employees created and provided to the distributor eight invoices for payments to purported third-party vendors ranging from $110,000 to $396,000. In fact, none of these storefront-only third parties provided any services or were included on Oracle\u0027s approved vendor list. The third-party payments created the risk that the funds could be used for illicit purposes such as bribery or embezzlement.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Oracle Corporation With FCPA Violations Related to Secret Side Funds in India,\u0022 August 16, 2012.)","Sources ":"US Securities and Exchange Corporation v. Oracle Corporation, Case No. 12-cv-4310 (NDCA), Complaint filed August 16, 2012, at https:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-158.pdf;\r\n SEC Press Release, \u0022SEC Charges Oracle Corporation With FCPA Violations Related to Secret Side Funds in India,\u0022 August 16, 2012, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171483848","Documents":""},{"Case ID":"ST-478","Case Cluster ":"Orofix International","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"7\/5","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,220,000 ","Criminal Fine\/Penalty (US$) ":"$2,220,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations","Offenses - Settled":"Internal controls violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Deferred Prosecution Agreement with Orthofix, a Curacao incorporated medical devices company with corporate offices in Texas, the company agreed to be charged with one count internal controls violations. According to the SEC\u2019s complaint filed in U.S. District Court for the Eastern District of Texas, \u0022the bribes began in 2003 and continued until 2010. Initially, Promeca [S.A. de CV, the company\u0027s Mexico-based subsidiary] falsely recorded the bribes as cash advances and falsified its invoices to support the expenditures. Later, when the bribes got much larger, Promeca falsely recorded them as promotional and training costs. Because of the bribery scheme, Promeca\u2019s training and promotional expenses were significantly over budget. Orthofix did launch an inquiry into these expenses, but did very little to investigate or diminish the excessive spending. Later, upon discovery of the bribe payments through a Promeca executive, Orthofix immediately self-reported the matter to the SEC and implemented significant remedial measures. The company terminated the Promeca executives who orchestrated the bribery scheme.\u0022 (Sources: US v. Orthofix International, N.V., Case No. 12-cr-00150 (EDTX), Information filed July 10, 2012 and Deferred Prosecution Agreement and Statement of Facts; SEC Press Release, \u0022SEC Charges Orthofix International With FCPA Violations,\u0022 July 10, 2012.)\r\n \r\n According to the Complaint filed in the case by the SEC, \u0022 From 2003 to 2010, Orthofix\u2019s wholly-owned Mexican subsidiary, Promeca S.A. de C.V. (\u201cPromeca\u201d), repeatedly paid bribes totaling approximately 317,000 to Mexican officials in order to obtain and retain sales contracts from Instituto Mexicano del Seguro Social (\u201cIMSS\u201d), the Mexican government-owned healthcare and social services institution. Promeca employees referred to these payments as \u0027chocolates.\u0027\u201d (Source: US Securities and Exchange Commission v. Orthofix N.V., Case No. 12-cr-150 (EDTX), Complaint filed July 5, 2012, at https:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-133.pdf.)","Sources ":"US v. Orthofix International, N.V., Case No. 12-cr-150 (EDTX), Information filed July 10, 2012 and Deferred Prosecution Agreement and Statement of Facts, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-orthofix-international-nv-court-docket-number-412-cr-00150-ras; SEC Press Release, \u0022SEC Charges Orthofix International With FCPA Violations,\u0022 July 10, 2012, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171483164","Documents":""},{"Case ID":"ST-479","Case Cluster ":"Orofix International","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Mexico","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"7\/5","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits; Prejudgment Interest","Total Monetary Sanctions (US$)":"$5,225,701 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$4,983,644 ","Civil Prejudgment Interest (US$) ":"$242,057 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the SEC\u2019s complaint filed in U.S. District Court for the Eastern District of Texas, \u0022the bribes began in 2003 and continued until 2010. Initially, Promeca [S.A. de CV, the company mexico-based subsidiary] falsely recorded the bribes as cash advances and falsified its invoices to support the expenditures. Later, when the bribes got much larger, Promeca falsely recorded them as promotional and training costs. Because of the bribery scheme, Promeca\u2019s training and promotional expenses were significantly over budget. Orthofix did launch an inquiry into these expenses, but did very little to investigate or diminish the excessive spending. Later, upon discovery of the bribe payments through a Promeca executive, Orthofix immediately self-reported the matter to the SEC and implemented significant remedial measures. The company terminated the Promeca executives who orchestrated the bribery scheme.\u0022 (Sources: US SEC Press Release, \u0022SEC Charges Orthofix International With FCPA Violations,\u0022 July 10, 2012.)\r\n \r\n According to the Complaint filed in the case by the SEC, \u0022 From 2003 to 2010, Orthofix\u2019s wholly-owned Mexican subsidiary, Promeca S.A. de C.V. (\u201cPromeca\u201d), repeatedly paid bribes totaling approximately 317,000 to Mexican officials in order to obtain and retain sales contracts from Instituto Mexicano del Seguro Social (\u201cIMSS\u201d), the Mexican government-owned\r\n healthcare and social services institution. Promeca employees referred to these payments as \u0027chocolates.\u0027\u201d (Source: US Securities and Exchange Commission v. Orthofix N.V., Case No. 4:12-cv-419 (ED Tex), Complaint filed July 5, 2012, at https:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-133.pdf.)","Sources ":"US Securities and Exchange Commission v. Orthofix N.V., Case No. 4:12-cv-419 (ED Tex), Complaint filed July 5, 2012, at https:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-133.pdf;\r\n \r\n SEC Press Release, \u0022SEC Charges Orthofix International With FCPA Violations,\u0022 July 10, 2012, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171483164","Documents":""},{"Case ID":"ST-480","Case Cluster ":"PBSJ Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Qatar","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"1\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Disgorgement of Profit, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$3,407,875 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$2,892,504 ","Civil Prejudgment Interest (US$) ":"$140,371 ","Civil Fine \/ Penalty (US$)":"$375,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, falsification of books and records; internal controls violations","Offenses - Settled":"Bribery of foreign officials, falsification of books and records; internal controls violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, the agency agreed to a deferred prosecution agreement (DPA) with The PBSJ Corporation and issued a Cease and Desist Order against the company\u0027s former President Walid Hatoum. PBSJ is now known as The Atkins North America Holdings Corporation and no longer offers public stock in the U.S.\r\n \r\n According to the SEC, its \u0022investigation found that Walid Hatoum, who has agreed to settle the SEC\u2019s charges, offered to funnel funds to a local company owned and controlled by a foreign official in order to secure two multi-million Qatari government contracts for PBSJ in 2009. The foreign official subsequently provided Hatoum and PBSJ\u2019s international subsidiary with access to confidential sealed-bid and pricing information that enabled the PBSJ subsidiary to tender winning bids for a hotel resort development project in Morocco and a light rail transit project in Qatar. [ ] \r\n  \r\n According to the SEC\u2019s order instituting a settled administrative proceeding against Hatoum, he also offered employment to a second foreign official in return for assistance as the bribery scheme began to unravel and PBSJ lost the hotel resort contract. Even though the bribes themselves were not consummated before the scheme was uncovered by the company, PBSJ earned approximately $2.9 million in illicit profits because it continued work on the light rail project until a replacement company could be found.\u0022 (US SEC Press Release, \u0022SEC Charges Former Executive at Tampa-Based Engineering Firm With FCPA Violations,\u0022 January 22, 2015.)","Sources ":"US Securities and Exchange Commission v. PBSJ, Deferred Prosecution Agreement, at https:\/\/www.sec.gov\/news\/press\/2015\/2015-13-dpa.pdf;\r\n \r\n SEC Press Release, \u0022SEC Charges Former Executive at Tampa-Based Engineering Firm With FCPA Violations,\u0022 January 22, 2015","Documents":""},{"Case ID":"ST-481","Case Cluster ":"PBSJ Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Qatar (and Morocco project)","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"1\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$50,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$50,000 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, the agency agreed to a deferred prosecution agreement (DPA) with The PBSJ Corporation and issued a Cease and Desist Order against the company\u0027s former President Walid Hatoum. PBSJ is now known as The Atkins North America Holdings Corporation and no longer offers public stock in the U.S.\r\n \r\n According to the SEC, its \u0022investigation found that Walid Hatoum, who has agreed to settle the SEC\u2019s charges, offered to funnel funds to a local company owned and controlled by a foreign official in order to secure two multi-million Qatari government contracts for PBSJ in 2009. The foreign official subsequently provided Hatoum and PBSJ\u2019s international subsidiary with access to confidential sealed-bid and pricing information that enabled the PBSJ subsidiary to tender winning bids for a hotel resort development project in Morocco and a light rail transit project in Qatar. [ ] \r\n  \r\n According to the SEC\u2019s order instituting a settled administrative proceeding against Hatoum, he also offered employment to a second foreign official in return for assistance as the bribery scheme began to unravel and PBSJ lost the hotel resort contract. Even though the bribes themselves were not consummated before the scheme was uncovered by the company, PBSJ earned approximately $2.9 million in illicit profits because it continued work on the light rail project until a replacement company could be found.\u0022 (US SEC Press Release, \u0022SEC Charges Former Executive at Tampa-Based Engineering Firm With FCPA Violations,\u0022 January 22, 2015.)","Sources ":"US Securities and Exchange Commission Administrative Proceeding, File No. 3-16351, In the Matter of Walid Hatoum, January 22, 2015, at https:\/\/www.sec.gov\/litigation\/admin\/2015\/34-74112.pdf; US Securities and Exchange Commission v. PBSJ, Deferred Prosecution Agreement, at https:\/\/www.sec.gov\/news\/press\/2015\/2015-13-dpa.pdf; SEC Press Release, \u0022SEC Charges Former Executive at Tampa-Based Engineering Firm With FCPA Violations,\u0022 January 22, 2015.","Documents":""},{"Case ID":"ST-482","Case Cluster ":"Petro Tiger","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Colombia","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"9\/25","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$30,000 ","Criminal Fine\/Penalty (US$) ":"$30,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials and Wire Fraud","Offenses - Settled":"Conspiracy to Bribe Foreign Officials and Wire Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Two former chief executive officers of PetroTiger Ltd. \u2013 a British Virgin Islands oil and gas company with operations in Colombia and offices in New Jersey \u2013 have been charged for their alleged participation in a scheme to pay bribes to foreign government officials in violation of the Foreign Corrupt Practices Act (FCPA), to defraud PetroTiger, and to launder proceeds of those crimes. In addition, PetroTiger\u2019s former general counsel pleaded guilty to bribery and fraud charges in connection with the same scheme. [ ] \r\n \r\n According to the charges, former co-CEOs of PetroTiger Joseph Sigelman, 42, formerly of Miami and the Philippines, and Knut Hammarskjold, 42, of Greenville, S.C.; former general counsel Gregory Weisman, 42, of Moorestown, N.J., and others allegedly paid bribes to an official in Colombia in exchange for the official\u2019s assistance in securing approval for an oil services contract worth roughly $39 million. [ ] \r\n \r\n Weisman pleaded guilty on Nov. 8, 2013, to a criminal information charging one count of conspiracy to violate the FCPA and to commit wire fraud. [ ] \r\n \r\n The charges allege the defendants made three separate payments from PetroTiger\u2019s bank account in the United States to the official\u2019s bank account in Colombia to secure approval from Colombia\u2019s state-owned and state-controlled oil company for a lucrative oil services contract in the country. According to the charges, to conceal the bribes, the defendants first attempted to make the payments to a bank account in the name of the foreign official\u2019s wife, for purported consulting services she did not perform. The charges allege that Sigelman and Hammarskjold provided Weisman invoices including her bank account information. The defendants made the payments directly to the official\u2019s bank account when attempts to transfer the money to his wife\u2019s account failed.\r\n \r\n In addition, court documents allege that the defendants attempted to secure kickback payments at the expense of PetroTiger\u2019s board members. According to the criminal charges, the defendants were negotiating an acquisition of another company on behalf of PetroTiger, including on behalf of several members of PetroTiger\u2019s board of directors who were helping to fund the acquisition. In exchange for negotiating a higher purchase price for the acquisition, two of the owners of the target company agreed to kick back to the defendants a portion of the increased purchase price. According to the charges, to conceal the kickback payments, the defendants had the payments deposited into Sigelman\u2019s bank account in the Philippines, created a \u201cside letter\u201d to falsely justify the payments, and used the code name \u0027Manila Split\u0027 to refer to the payments amongst themselves.\u0022 (Source: US Department of Justice Press Release, \u0022Foreign Bribery Charges Unsealed Against Former Chief Executive Officers of Oil Services Company,\u0022 January 6, 2014.) In September 2015, Mr. Weisman was ordered to pay $30,000 criminal fine and two years\u0027 probation. (Source: US v. Weisman, Case No. 13-cr-730 (D. NJ), Judgment filed September 14, 2015.)","Sources ":"US v. Weisman, Case No. 13-cr-730 (D. NJ), Plea Agreement filed September 25, 2013 and other court documents and Department of Justice Press Release, \u0022Foreign Bribery Charges Unsealed Against Former Chief Executive Officers of Oil Services Company,\u0022 January 6, 2014, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-gregory-weisman-court-docket-number-13-cr-00730-jei;\r\n \r\n Judgment filed September 14, 2015, accessed via PACER.","Documents":""},{"Case ID":"ST-483","Case Cluster ":"Petro Tiger","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Colombia","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"6\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Restitution","Total Monetary Sanctions (US$)":"$339,015 ","Criminal Fine\/Penalty (US$) ":"$100,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$239,015.45 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Wire Fraud","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, in 2015, the \u0022former co-chief executive officer (CEO) of PetroTiger Ltd. \u2013 a British Virgin Islands oil and gas company with operations in Colombia and formerly with an office in New Jersey \u2013 pleaded guilty today to conspiring to pay bribes to a foreign government official in violation of the Foreign Corrupt Practices Act (FCPA). [ ] \r\n \r\n At his plea hearing, Sigelman admitted to conspiring with co-CEO Knut Hammarskjold, PetroTiger\u2019s former general counsel Gregory Weisman, and others to make illegal payments of $333,500 to David Duran, an employee of the Colombian national oil company, Ecopetrol. Sigelman admitted to making the payments in exchange for Duran\u2019s assistance in securing a $45 million oil services contract for PetroTiger. \r\n \r\n Sigelman is the third former PetroTiger executive to plead guilty in the case. On Nov. 8, 2013, Weisman pleaded guilty to conspiracy to violate the FCPA and to commit wire fraud. On Feb. 18, 2014, Hammarskjold pleaded guilty to conspiracy to violate the FCPA and to commit wire fraud.\r\n \r\n The case was brought to the attention of the department through a voluntary disclosure by PetroTiger, which fully cooperated with the department\u2019s investigation. Based on PetroTiger\u2019s voluntary disclosure, cooperation, and remediation, among other factors, the department declined to prosecute PetroTiger.\u0022 (Source: US DOJ Press Release, \u0022Former Chief Executive Officer of Oil Services Company Pleads Guilty to Foreign Bribery Charge,\u0022 June 5, 2015.)","Sources ":"US v. Sigelman, Case No. 14-cv-263 (D. NJ), Plea Agreement filed June 15, 2015 and DOJ Press Release, \u0022Former Chief Executive Officer of Oil Services Company Pleads Guilty to Foreign Bribery Charge,\u0022 June 5, 2015, at https:\/\/www.justice.gov\/opa\/pr\/former-chief-executive-officer-oil-services-company-pleads-guilty-foreign-bribery-charge; other related court documents at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-joseph-sigelman-court-docket-number-14-cr-00263-jei; Amended Judgment filed June 23, 2015 accessed at Pacer.","Documents":""},{"Case ID":"ST-484","Case Cluster ":"Petro Tiger","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Colombia","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"9\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Restitution","Total Monetary Sanctions (US$)":"$121,592.93 ","Criminal Fine\/Penalty (US$) ":"$15,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$106,592.93 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Defraud US, Wire Fraud, Conspiracy to Commit Wire Fraud, Mail Fraud (Attempt and Conspiracy, Violation of Foreign Securities Exchanges, Conspriacy to Defraud US, Conspiracy to Commit ML","Offenses - Settled":"Conspiracy to Defraud US","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Mr. Knut Hammarskjold, the former chief executive officer of PetroTiger Ltd., a British Virgin Islands oil and gas company with operations in Colombia and offices in New Jersey, pleaded guilty for his role in a scheme to pay bribes to foreign government officials and to defraud PetroTiger: \u0022According to the charges, [Mr. Hammarskjold and his co-defendants] allegedly paid bribes to an official in Colombia in exchange for the official\u2019s assistance in securing approval for an oil services contract worth roughly $39 million. To conceal the bribes, the defendants allegedly first attempted to make the payments to a bank account in the name of the foreign official\u2019s wife, for purported consulting services she did not perform. The charges allege that Sigelman and Hammarskjold provided Weisman invoices including her bank account information. The defendants made the payments directly to the official\u2019s bank account when attempts to transfer the money to his wife\u2019s account failed.\r\n \r\n In addition, court documents allege that the defendants attempted to secure kickback payments at the expense of several of PetroTiger\u2019s board members. According to the criminal charges, the defendants were negotiating an acquisition of another company on behalf of PetroTiger, including on behalf of several members of PetroTiger\u2019s board of directors who were helping to fund the acquisition. In exchange for negotiating a higher purchase price for the acquisition, two of the owners of the target company agreed to kick back to the defendants a portion of the increased purchase price. According to the charges, to conceal the kickback payments, the defendants had the payments deposited into Sigelman\u2019s bank account in the Philippines, created a \u201cside letter\u201d to falsely justify the payments, and used the code name \u201cManila Split\u201d to refer to the payments amongst themselves.\u0022 (Source: US DOJ Press Release, \u0022Former Chief Executive Officer of Oil Services Company Pleads Guilty to Foreign Bribery Charges,\u0022 February 18, 2014.) Mr. Hammarskjold was ordered to pay $15,000 in criminal fine and $106,592.23 in restitution to Petro Tiger Ltd. (Source: US v. Hammarskjold, Case No. 14-cr-65 (D. NJ), Judgment filed September 14, 2015.)","Sources ":"US v. Hammarskjold, Case No. 14-cr-65 (D. NJ), Judgment filed September 14, 2015, accessed via Pacer; other court documents and related press releases including DOJ Press Release, \u0022Former Chief Executive Officer of Oil Services Company Pleads Guilty to Foreign Bribery Charges,\u0022 February 18, 2014, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-knut-hammarskjold-court-docket-number-14-cr-00065-jei","Documents":""},{"Case ID":"ST-485","Case Cluster ":"Pfizer H.C. P. Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Bulgaria, Croatia, Kazakhstan, Russia","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"8\/7","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$15,000,000 ","Criminal Fine\/Penalty (US$) ":"$15,000,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Pfizer H.C.P. Corporation, an indirect wholly owned subsidiary of Pfizer Inc., has agreed to pay a $15 million penalty to resolve an investigation of Foreign Corrupt Practices Act (FCPA) violations. [ ] In a related matter, Pfizer Inc. and Wyeth LLC reached settlements today with the Securities and Exchange Commission (SEC) under which Pfizer Inc. agreed to pay more than $26.3 million in disgorgement of profits, including pre-judgment interest, to resolve concerns involving the conduct of its subsidiaries. Wyeth, which had been acquired by Pfizer Inc. in 2009, agreed to pay $18.8 million in disgorgement of profits, including pre-judgment interest, to resolve concerns involving the conduct of Wyeth subsidiaries.\r\n \r\n As part of the resolution, the department today filed a two-count criminal information charging Pfizer H.C.P. with conspiracy and violations of the FCPA in connection with improper payments made to government officials, including publicly-employed regulators and health care professionals in Bulgaria, Croatia, Kazakhstan and Russia. The department and Pfizer H.C.P. agreed to resolve the investigation by entering into a deferred prosecution agreement. [ ] \r\n  \r\n According to court documents, Pfizer H.C.P. made a broad range of improper payments to numerous government officials in Bulgaria, Croatia, Kazakhstan and Russia \u2013 including hospital administrators, members of regulatory and purchasing committees and other health care professionals \u2013 and sought to improperly influence government decisions in these countries regarding the approval and registration of Pfizer Inc. products, the award of pharmaceutical tenders and the level of sales of Pfizer Inc. products. According to court documents, Pfizer H.C.P. used numerous mechanisms to improperly influence government officials, including sham consulting contracts, an exclusive distributorship and improper travel and cash payments. \r\n \r\n Pfizer H.C.P. admitted that between 1997 and 2006, it paid more than $2 million of bribes to government officials in Bulgaria, Croatia, Kazakhstan and Russia. Pfizer H.C.P. also admitted that it made more than $7 million in profits as a result of the bribes.\u0022 (Source: US Department of Justice Press Release, \u0022Pfizer H.C.P. Corp. Agrees to Pay $15 Million Penalty to Resolve Foreign Bribery Investigation,\u0022 August 7, 2012.)","Sources ":"US v. Pfizer H.C.P. Corporation, Case No. 12-cr-169 (DDC), Information and Deferred Prosecution Agreement filed August 7, 2012; Department of Justice Press Release, \u0022Pfizer H.C.P. Corp. Agrees to Pay $15 Million Penalty to Resolve Foreign Bribery Investigation,\u0022 August 7, 2012, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-pfizer-hcp-corporation-court-docket-number-12-cr-169.","Documents":""},{"Case ID":"ST-486","Case Cluster ":"Pfizer H.C. P. Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Bulgaria, China, Croatia, Czech Republic, Italy, Kazakhstan, Russia, Serbia","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"8\/7","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit; Prejudgment interest; Civil Penalty","Total Monetary Sanctions (US$)":"$37,753,248 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$17,217,831 ","Civil Prejudgment Interest (US$) ":"$1,658,793 ","Civil Fine \/ Penalty (US$)":"$18,876,624 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records; Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, the agency alleged that \u0022employees and agents of Pfizer\u2019s subsidiaries in Bulgaria, China, Croatia, Czech Republic, Italy, Kazakhstan, Russia, and Serbia made improper payments to foreign officials to obtain regulatory and formulary approvals, sales, and increased prescriptions for the company\u2019s pharmaceutical products. They tried to conceal the bribery by improperly recording the transactions in accounting records as legitimate expenses for promotional activities, marketing, training, travel and entertainment, clinical trials, freight, conferences, and advertising.\r\n \r\n The SEC separately charged another pharmaceutical company that Pfizer acquired a few years ago \u2013 Wyeth LLC \u2013 with its own FCPA violations. Pfizer and Wyeth agreed to separate settlements in which they will pay more than $45 million combined to settle their respective charges. In a parallel action, the Department of Justice announced that Pfizer H.C.P. Corporation agreed to pay a $15 million penalty to resolve its investigation of FCPA violations. [ ] \r\n  \r\n According to the SEC\u2019s complaint against Pfizer filed in U.S. District Court for the District of Columbia, the misconduct dates back as far as 2001. Employees of Pfizer\u2019s subsidiaries authorized and made cash payments and provided other incentives to bribe government doctors to utilize Pfizer products. In China, for example, Pfizer employees invited \u201chigh-prescribing doctors\u201d in the Chinese government to club-like meetings that included extensive recreational and entertainment activities to reward doctors\u2019 past product sales or prescriptions. Pfizer China also created various \u201cpoint programs\u201d under which government doctors could accumulate points based on the number of Pfizer prescriptions they wrote. The points were redeemed for various gifts ranging from medical books to cell phones, tea sets, and reading glasses. In Croatia, Pfizer employees created a \u201cbonus program\u201d for Croatian doctors who were employed in senior positions in Croatian government health care institutions. Once a doctor agreed to use Pfizer products, a percentage of the value purchased by a doctor\u2019s institution would be funneled back to the doctor in the form of cash, international travel, or free products.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Pfizer with FCPA Violations,\u0022 August 7, 2012.)","Sources ":"US SEC v. Pfizer, Case No. 12-cv-1303 (DDC), Complaint at https:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-152-pfizer.pdf;\r\n \r\n US SEC v. Wyeth, Case No. 12-cv-1304 (DDC), Complaint at https:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-152-wyeth.pdf;\r\n \r\n SEC Press Release, \u0022SEC Charges Pfizer with FCPA Violations,\u0022 August 7, 2012, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171483696","Documents":""},{"Case ID":"ST-487","Case Cluster ":"Pfizer H.C. P. Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, Indonesia, Pakistan, Saudi Arabia","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"8\/7","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit; Prejudgment Interest","Total Monetary Sanctions (US$)":"$18,876,624 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$17,217,831 ","Civil Prejudgment Interest (US$) ":"$1,658,793 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records; Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, the agency alleged that \u0022employees and agents of Pfizer\u2019s subsidiaries in Bulgaria, China, Croatia, Czech Republic, Italy, Kazakhstan, Russia, and Serbia made improper payments to foreign officials to obtain regulatory and formulary approvals, sales, and increased prescriptions for the company\u2019s pharmaceutical products. They tried to conceal the bribery by improperly recording the transactions in accounting records as legitimate expenses for promotional activities, marketing, training, travel and entertainment, clinical trials, freight, conferences, and advertising.\r\n \r\n The SEC separately charged another pharmaceutical company that Pfizer acquired a few years ago \u2013 Wyeth LLC \u2013 with its own FCPA violations. Pfizer and Wyeth agreed to separate settlements in which they will pay more than $45 million combined to settle their respective charges. In a parallel action, the Department of Justice announced that Pfizer H.C.P. Corporation agreed to pay a $15 million penalty to resolve its investigation of FCPA violations. [ ] \r\n  \r\n According to the SEC\u2019s complaint against Pfizer filed in U.S. District Court for the District of Columbia, the misconduct dates back as far as 2001. Employees of Pfizer\u2019s subsidiaries authorized and made cash payments and provided other incentives to bribe government doctors to utilize Pfizer products. In China, for example, Pfizer employees invited \u201chigh-prescribing doctors\u201d in the Chinese government to club-like meetings that included extensive recreational and entertainment activities to reward doctors\u2019 past product sales or prescriptions. Pfizer China also created various \u201cpoint programs\u201d under which government doctors could accumulate points based on the number of Pfizer prescriptions they wrote. The points were redeemed for various gifts ranging from medical books to cell phones, tea sets, and reading glasses. In Croatia, Pfizer employees created a \u201cbonus program\u201d for Croatian doctors who were employed in senior positions in Croatian government health care institutions. Once a doctor agreed to use Pfizer products, a percentage of the value purchased by a doctor\u2019s institution would be funneled back to the doctor in the form of cash, international travel, or free products.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Pfizer with FCPA Violations,\u0022 August 7, 2012.)","Sources ":"US SEC v. Pfizer, Case No. 12-cv-1303 (DDC), Complaint at https:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-152-pfizer.pdf;\r\n \r\n US SEC v. Wyeth, Case No. 12-cv-1304 (DDC), Complaint at https:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-152-wyeth.pdf;\r\n \r\n SEC Press Release, \u0022SEC Charges Pfizer with FCPA Violations,\u0022 August 7, 2012, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171483696","Documents":""},{"Case ID":"ST-488","Case Cluster ":"PTC Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profit; Prejudgment Interest","Total Monetary Sanctions (US$)":"$13,622,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$11,858,000 ","Civil Prejudgment Interest (US$) ":"$1,764,000 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of books and records; Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the SEC Press Release, PTC Inc., a Needham, Massachusetts based technology company, consented to the Cease and Desist Order. According to the SEC, \u0022From at least 2006 into 2011, two wholly-owned PTC subsidiaries (collectively, \u201cPTC-China\u201d) provided improper payments totaling nearly $1.5 million to government officials (\u201cChinese government officials\u201d or \u201cofficials\u201d) who were employed by Chinese state owned entities (\u201cSOEs\u201d) that were PTC customers. These payments were made to obtain or retain business from the SOEs. Specifically, PTC-China provided non-business travel, primarily sightseeing and tourist activities, as well as improper gifts and entertainment, to the Chinese government officials. PTC earned approximately $11.85 million in profits from sales contracts with SOEs whose officials received the improper payments.\r\n 2. PTC-China made these improper payments in two primary ways: 1) by providing at least $1,179,912 to third party agents, disguised as commission payments or sub-contracting fees, which were then used to pay for non-business related foreign travel for Chinese government officials; and 2) by allowing its sales staff to provide Chinese government officials with gifts and excessive entertainment of over $274,313. The payments were recorded as legitimate commissions and business expenses in PTC-China\u2019s books and records, when in fact they were improper payments designed to benefit the Chinese government officials. PTC-China\u2019s books and records were consolidated into PTC\u2019s books and records, thereby causing PTC\u2019s books and records to be inaccurate. PTC failed to devise and maintain an adequate system of internal accounting controls sufficient to prevent and detect these improper payments that occurred over several years.\u0022 (Source: US Securities and Exchange Commission, In the Matter of PTC Inc., Administrative Proceeding File No. 3-17118, February 16, 2016, Summary.)","Sources ":"US Securities and Exchange Commission, In the Matter of PTC Inc., Administrative Proceeding File No. 3-17118, February 16, 2016, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77145.pdf; Press Release, \u0022SEC: Tech Company Bribed Chinese Officials,\u0022 February 16, 2016, at https:\/\/www.sec.gov\/news\/pressrelease\/2016-29.html.","Documents":""},{"Case ID":"ST-489","Case Cluster ":"PTC Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$14,540,000 ","Criminal Fine\/Penalty (US$) ":"$14,540,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"The US Department of Justice Press Release stated, \u0022According to admissions made in the resolution documents, Parametric Technology (Shanghai) Software\r\n Company Ltd. and Parametric Technology (Hong Kong) Ltd. (collectively, PTC China), through local business partners, arranged and paid for employees of various Chinese state owned enterprises to travel to the United States, ostensibly for training at PTC Inc.\u2019s headquarters in Massachusetts, but primarily for recreational travel to other parts of the United States, including New York, Los Angeles, Las Vegas and Hawaii. PTC China paid a total of more than $1 million through its business partners to fund these trips, while during the same time period, PTC China entered into more than $13 million in contracts with the Chinese stateowned\r\n entities. Company employees typically accompanied the Chinese officials on these trips. PTC China admitted that the cost of these recreational trips was routinely hidden within the price of PTC China\u2019s software sales to the Chinese state owned entities whose employees went on the trips.\u0022 (Source: US Department of Justice, \u0022PTC Inc. Subsidiaries Agree to Pay More Than $14 Million to Resolve Foreign Bribery Charges,\u0022 February 16, 2016.)","Sources ":"US Department of Justice, \u0022PTC Inc. Subsidiaries Agree to Pay More Than $14 Million to Resolve Foreign Bribery Charges,\u0022 February 16, 2016.","Documents":""},{"Case ID":"ST-490","Case Cluster ":"PTC Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Falsification of books and records; internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"See related entry, US Securities and Exchange Commission Cease and Desist Order issued against PTC Inc. The SEC announced that the Deferred Prosecution Agreement with Mr. Yuan was the first \u0022with an individual in an FCPA case. DPAs facilitate and reward cooperation in SEC investigations by foregoing an enforcement action against an individual who agrees to cooperate fully and truthfully throughout the period of deferred prosecution. FCPA charges will be deferred for three years against Yu Kai Yuan, a former employee at one of PTC\u2019s Chinese subsidiaries, as a result of significant cooperation he has provided during the SEC\u2019s investigation.\u0022 (Source: US Securities and Exchange Commission Press Release, \u0022SEC: Tech Company Bribed Chinese Officials,\u0022 February 16, 2016; See also, SEC-Yu Kai Yuan Deferred Prosecution Agreement, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77145-dpa.pdf","Sources ":"SEC-Yu Kai Yuan Deferred Prosecution Agreement, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77145-dpa.pdf; US Securities and Exchange Commission Press Release, \u0022SEC: Tech Company Bribed Chinese Officials,\u0022 February 16, 2016, at https:\/\/www.sec.gov\/news\/pressrelease\/2016-29.html.","Documents":""},{"Case ID":"ST-491","Case Cluster ":"Qualcomm Incorporated","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"3\/1","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$7,500,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$7,500,000 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of books and records; Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Securities and Exchange Commission Press Release related to the US telecommunications company, \u0022Qualcomm Incorporated has agreed to pay $7.5 million to settle charges that it violated the Foreign Corrupt Practices Act (FCPA) by hiring relatives of Chinese government officials deciding whether to select the company\u2019s mobile technology products amid increasing competition in the international telecommunications market.\r\n An SEC investigation found that Qualcomm also provided gifts, travel, and entertainment to try to influence officials at government-owned telecom companies in China. With insufficient internal controls to detect improper payments, Qualcomm misrepresented in its books and records that the things of value provided to foreign officials were legitimate business expenses. [ ] The SEC\u2019s order finds that Qualcomm violated the anti-bribery, internal controls, and books-and-records provisions of the Securities Exchange Act of 1934. Without admitting or denying the findings, Qualcomm agreed to pay the $7.5 million penalty and self-report to the SEC for the next two years with annual reports and certifications of its FCPA compliance. \u0022 (Source: US SEC Press Release, \u0022SEC: Qualcomm Hired Relatives of Chinese Officials to Obtain Business,\u0022 March 1, 2016, at http:\/\/www.sec.gov\/news\/pressrelease\/2016-36.html)","Sources ":"US SEC Press Release, \u0022SEC: Qualcomm Hired Relatives of Chinese Officials to Obtain Business,\u0022 March 1, 2016, at http:\/\/www.sec.gov\/news\/pressrelease\/2016-36.html","Documents":""},{"Case ID":"ST-492","Case Cluster ":"Ralph Lauren Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"4\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Penalty","Total Monetary Sanctions (US$)":"$882,000 ","Criminal Fine\/Penalty (US$) ":"$882,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Department of Justice, \u0022Ralph Lauren Corporation (RLC), a New York based apparel company, has agreed to pay an $882,000 penalty to resolve allegations that it violated the Foreign Corrupt Practices Act (FCPA) by bribing government officials in Argentina to obtain improper customs clearance of merchandise, announced Mythili Raman, the Acting Assistant Attorney General for the Criminal Division, and Loretta E. Lynch, the United States Attorney for the\r\n Eastern District of New York.\r\n \r\n According to the agreement, the manager of RLC\u2019s subsidiary in Argentina bribed customs officials in Argentina over the span of five years to improperly obtain paperwork necessary for goods to clear customs\u037e permit clearance of items without the necessary paperwork and\/or the clearance of prohibited items\u037e and on occasion, to avoid inspection entirely. RLC\u2019s employee disguised the payments by funneling them through a customs clearance agency, which created fake invoices to justify the improper payments. During these five years, RLC did not have an anticorruption program and did not provide any anticorruption training or oversight with respect to its subsidiary in Argentina.\u0022 (Source: US DOJ Press Release, \u0022Ralph Lauren Corporation Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $882,000 Monetary Penalty,\u0022 April 22, 2013.)","Sources ":"US Department of Justice Press Release, \u0022Ralph Lauren Corporation Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $882,000 Monetary Penalty,\u0022 April 22, 2013 and Nonprosecution Agreement and Statement of Facts, at https:\/\/www.justice.gov\/sites\/default\/files\/criminal-fraud\/legacy\/2013\/04\/23\/Ralph-Lauren.-NPA-Executed.pdf.","Documents":""},{"Case ID":"ST-493","Case Cluster ":"Ralph Lauren Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"4\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Disgorgement of Profits; Prejudgment Interest","Total Monetary Sanctions (US$)":"$734,845.79 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$593,000 ","Civil Prejudgment Interest (US$) ":"$141,845.79 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"Bribery of Foreign Officials; Falsification of Books and Records; Internal Controls Violations","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission, the agency entered into its firt Nonprosecution Agreement (NPA) in an FCPA action: \u0022Ralph Lauren Corporation\u0027s Argentine subsidiary paid bribes to government and customs officials to improperly secure the importation of Ralph Lauren Corporation\u0027s products in Argentina. The purpose of the bribes, paid through its customs broker, was to obtain entry of Ralph Lauren Corporation\u0027s products into the country without necessary paperwork, avoid inspection of prohibited products, and avoid inspection by customs officials. The bribe payments and gifts to Argentine officials totaled $593,000 during a four-year period.\r\n \r\n Under the NPA, Ralph Lauren Corporation agreed to pay $593,000 in disgorgement and $141,845.79 in prejudgment interest.\u0022 The misconduct took place between approximately 2004 through 2009. (Source: US SEC Press Release, \u0022SEC Announces Non-Prosecution Agreement With Ralph Lauren Corporation Involving FCPA Misconduct,\u0022 April 22, 2013.)","Sources ":"US Securities and Exchange Commission Nonprosecution Agreement with Ralph Lauren Corporation, at https:\/\/www.sec.gov\/news\/press\/2013\/2013-65-npa.pdf;\r\n Press Release, \u0022SEC Announces Non-Prosecution Agreement With Ralph Lauren Corporation Involving FCPA Misconduct,\u0022 April 22, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171514780","Documents":""},{"Case ID":"ST-494","Case Cluster ":"Rheinmetall AG","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Bremen Public Prosecution Office","Jurisdiction of Foreign Public Official(s) ":"Greece","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"12\/8","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Section 30 Administrative Act (OWiG)","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$45,531,981 ","Criminal Fine\/Penalty (US$) ":"$368,481 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$45,163,500 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Foreign Bribery","Offenses - Settled":"Breach of Trust","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Bremen Public Prosecution, the Rheinmetall AG accepted a settlement on behalf of its subsidiary, Rheinmetall Defence Electronics GmbH (RDE). According to the Prosecution\u0027s press release, in the framework of the sale of air defense systems (type ASRAD) to Greece, RDE was deemed responsible for not having taken the necessary measures to impede undue payments to Greek public officials. The press release noted that proceedings against RDE\u0027s predecessor company, STN Atlas GmbH and related individuals were ongoing. (Source: Staatsanwaltschaft Bremen, P r e s s e m i t t e i l u n g 13 \/ 2014, \u0022Staatsanwaltschaft verh\u00e4ngt Geldbu\u00dfe in H\u00f6he von \u00fcber 37 Millionen Euro gegen die Rheinmetall Defence Electro-nics GmbH,\u0022 December 11, 2014.)","Sources ":"Staatsanwaltschaft Bremen, P r e s s e m i t t e i l u n g 13 \/ 2014, \u0022Staatsanwaltschaft verh\u00e4ngt Geldbu\u00dfe in H\u00f6he von \u00fcber 37 Millionen Euro gegen die Rheinmetall Defence Electronics GmbH,\u0022 December 11, 2014 and Pr e s s e m i t t e i l u n g 3 \/ 2014, \u0022Ermittlungsma\u00dfnahmen in den Verfahren gegen Verantwortliche von Rheinmetall Defence Elektronics GmbH und von Atlas Elektronik GmbH,\u0022 April 14, 2014, both accessible at http:\/\/www.staatsanwaltschaft.bremen.de\/sixcms\/detail.php?gsid=bremen120.c.12313.de.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Nr.%203%202014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Nr.%2013.pdf"},{"Case ID":"ST-495","Case Cluster ":"Rino International Corp.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"5\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Not specified","Summary":"According to the US Securities and Exchange Commission, RINO, a holding company for subsidiaries that manufacture, install, and service equipment for the Chinese steel industry, became a China-based U.S. issuer through a reverse merger in October 2007. According to the SEC\u2019s complaint, [Cheif Executive Officer David] Zou, a Chinese national living in China, and [Chairman of the Board] Qiu, a Chinese national living in California, diverted some of the proceeds from an offering of securities by RINO in December 2009. Zou and Qiu are alleged to have used the proceeds to purchase a $3.5 million family home for personal use. RINO, Zou, and Qiu initially failed to disclose this diversion, and conflicting information was provided to RINO\u2019s outside auditor about the expenditure. Zou and Qiu also used offering proceeds to pay for automobiles as well as designer clothing and accessories without recording them as personal expenses or otherwise disclosing them in RINO\u2019s public filings.\r\n \r\n The Commission further alleges that RINO\u2019s SEC filings contained materially false and misleading statements and omissions concerning RINO\u2019s revenue and operations between 2008 and 2010. According to the complaint, RINO maintained two conflicting sets of financial records \u2013 one set of books for filings in China and another set of books for filings in the U.S. The Chinese books reflected sales of approximately $31 million from the first quarter of 2008 through the first three quarters of 2010. But the U.S. books that formed the basis for RINO\u2019s SEC filings contained false contracts and portrayed sales revenues of approximately $491 million during that same time period \u2013 more than 15 times greater than the revenues recorded in the Chinese books. The complaint alleges that Zou and Qiu knew or were reckless in not knowing that the U.S. books were supported by false contracts and, nonetheless, signed and certified RINO\u2019s public filings containing false and misleading statements and omissions about RINO\u2019s revenue and operations.\u0022 (Source: SEC Litigation Release, \u0022SEC Charges RINO, Its CEO, and Its Chairman of the Board with Scheme to Overstate Revenues and Divert Money for Personal Use,\u0022 May 15, 2013.)","Sources ":"US Securities and Exchange Commission v. Rino International, Dejun David Zhou, and Jianping Qiu, Case No, 13-cv-711, SEC Litigation Release, \u0022SEC Charges RINO, Its CEO, and Its Chairman of the Board with Scheme to Overstate Revenues and Divert Money for Personal Use,\u0022 May 15, 2013, at https:\/\/www.sec.gov\/litigation\/litreleases\/2013\/lr22699.htm.","Documents":""},{"Case ID":"ST-496","Case Cluster ":"Rino International Corp.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"5\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Civil Penalty","Total Monetary Sanctions (US$)":"$1,850,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,750,000 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$100,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records; Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Not specified","Summary":"According to the US Securities and Exchange Commission, RINO, a holding company for subsidiaries that manufacture, install, and service equipment for the Chinese steel industry, became a China-based U.S. issuer through a reverse merger in October 2007. According to the SEC\u2019s complaint, [Cheif Executive Officer David] Zou, a Chinese national living in China, and [Chairman of the Board] Qiu, a Chinese national living in California, diverted some of the proceeds from an offering of securities by RINO in December 2009. Zou and Qiu are alleged to have used the proceeds to purchase a $3.5 million family home for personal use. RINO, Zou, and Qiu initially failed to disclose this diversion, and conflicting information was provided to RINO\u2019s outside auditor about the expenditure. Zou and Qiu also used offering proceeds to pay for automobiles as well as designer clothing and accessories without recording them as personal expenses or otherwise disclosing them in RINO\u2019s public filings.\r\n \r\n The Commission further alleges that RINO\u2019s SEC filings contained materially false and misleading statements and omissions concerning RINO\u2019s revenue and operations between 2008 and 2010. According to the complaint, RINO maintained two conflicting sets of financial records \u2013 one set of books for filings in China and another set of books for filings in the U.S. The Chinese books reflected sales of approximately $31 million from the first quarter of 2008 through the first three quarters of 2010. But the U.S. books that formed the basis for RINO\u2019s SEC filings contained false contracts and portrayed sales revenues of approximately $491 million during that same time period \u2013 more than 15 times greater than the revenues recorded in the Chinese books. The complaint alleges that Zou and Qiu knew or were reckless in not knowing that the U.S. books were supported by false contracts and, nonetheless, signed and certified RINO\u2019s public filings containing false and misleading statements and omissions about RINO\u2019s revenue and operations.\u0022 (Source: SEC Litigation Release, \u0022SEC Charges RINO, Its CEO, and Its Chairman of the Board with Scheme to Overstate Revenues and Divert Money for Personal Use,\u0022 May 15, 2013.)","Sources ":"US Securities and Exchange Commission v. Rino International, Dejun David Zhou, and Jianping Qiu, Case No, 13-cv-711, SEC Litigation Release, \u0022SEC Charges RINO, Its CEO, and Its Chairman of the Board with Scheme to Overstate Revenues and Divert Money for Personal Use,\u0022 May 15, 2013, at https:\/\/www.sec.gov\/litigation\/litreleases\/2013\/lr22699.htm.","Documents":""},{"Case ID":"ST-497","Case Cluster ":"Rino International Corp.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"5\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Civil Penalty","Total Monetary Sanctions (US$)":"$1,900,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,750,000 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$150,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Not specified","Summary":"According to the US Securities and Exchange Commission, RINO, a holding company for subsidiaries that manufacture, install, and service equipment for the Chinese steel industry, became a China-based U.S. issuer through a reverse merger in October 2007. According to the SEC\u2019s complaint, [Cheif Executive Officer David] Zou, a Chinese national living in China, and [Chairman of the Board] Qiu, a Chinese national living in California, diverted some of the proceeds from an offering of securities by RINO in December 2009. Zou and Qiu are alleged to have used the proceeds to purchase a $3.5 million family home for personal use. RINO, Zou, and Qiu initially failed to disclose this diversion, and conflicting information was provided to RINO\u2019s outside auditor about the expenditure. Zou and Qiu also used offering proceeds to pay for automobiles as well as designer clothing and accessories without recording them as personal expenses or otherwise disclosing them in RINO\u2019s public filings.\r\n \r\n The Commission further alleges that RINO\u2019s SEC filings contained materially false and misleading statements and omissions concerning RINO\u2019s revenue and operations between 2008 and 2010. According to the complaint, RINO maintained two conflicting sets of financial records \u2013 one set of books for filings in China and another set of books for filings in the U.S. The Chinese books reflected sales of approximately $31 million from the first quarter of 2008 through the first three quarters of 2010. But the U.S. books that formed the basis for RINO\u2019s SEC filings contained false contracts and portrayed sales revenues of approximately $491 million during that same time period \u2013 more than 15 times greater than the revenues recorded in the Chinese books. The complaint alleges that Zou and Qiu knew or were reckless in not knowing that the U.S. books were supported by false contracts and, nonetheless, signed and certified RINO\u2019s public filings containing false and misleading statements and omissions about RINO\u2019s revenue and operations.\u0022 (Source: SEC Litigation Release, \u0022SEC Charges RINO, Its CEO, and Its Chairman of the Board with Scheme to Overstate Revenues and Divert Money for Personal Use,\u0022 May 15, 2013.)","Sources ":"US Securities and Exchange Commission v. Rino International, Dejun David Zhou, and Jianping Qiu, Case No, 13-cv-711, SEC Litigation Release, \u0022SEC Charges RINO, Its CEO, and Its Chairman of the Board with Scheme to Overstate Revenues and Divert Money for Personal Use,\u0022 May 15, 2013, at https:\/\/www.sec.gov\/litigation\/litreleases\/2013\/lr22699.htm.","Documents":""},{"Case ID":"ST-498","Case Cluster ":"SAP SE","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Panama","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/1","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits; Prejudgment Interest","Total Monetary Sanctions (US$)":"$3,888,896 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$3,700,000 ","Civil Prejudgment Interest (US$) ":"$188,896 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, the software manufacturer company \u0022SAP\u2019s deficient internal controls allowed a former SAP executive to pay $145,000 in bribes to a senior Panamanian government official and offer bribes to two others in exchange for lucrative sales contracts. The SEC charged the SAP executive, Vicente E. Garcia, in a separate enforcement action last year that included a parallel criminal action. Garcia has been sentenced to 22 months in prison.\r\n \r\nAccording to the SEC\u2019s order instituting a settled administrative proceeding:\r\n \r\n SAP is headquartered in Germany and executes most of its sales through a network of worldwide corporate partners, including a partner in Panama.\r\n \r\n The bribery scheme involved providing large discounts of up to 82 percent to SAP\u2019s Panamanian partner, who used the excessive discounts to create a slush fund out of which to pay bribes to Panamanian officials on Garcia\u2019s behalf so SAP could sell software.\r\n \r\n SAP had no requirements for heightened anti-corruption scrutiny for such large discounts.\r\n \r\n SAP falsely recorded the slush fund as legitimate discounts on the books of SAP\u2019s Mexican subsidiary, and the figures were subsequently consolidated into SAP\u2019s financial statements.\r\n \r\n SAP failed to devise and maintain a sufficient system of internal accounting controls to provide reasonable assurances that the discounts were recorded in accordance with U.S. Generally Accepted Accounting Principles.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Software Company With FCPA Violations,\u0022 February 1, 2016.)","Sources ":"US SEC Press Release, \u0022SEC Charges Software Company With FCPA Violations,\u0022 February 1, 2016, at https:\/\/www.sec.gov\/news\/pressrelease\/2016-17.html","Documents":""},{"Case ID":"ST-499","Case Cluster ":"SAP SE","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Panama","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"8\/12","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"$0 ","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022Vicente Eduardo Garcia, 65, of Miami, was sentenced to 22 months in prison by U.S. District Judge Charles R. Breyer of the Northern District of California. On Aug. 12, 2015, Garcia pleaded guilty to one count of conspiracy to violate the Foreign Corrupt Practices Act (FCPA). On July 15, 2015, Garcia and the U.S. Securities and Exchange Commission (SEC) entered into a settlement of the parallel SEC investigation in which Garcia agreed, among other things, to pay disgorgement of $85,965 plus prejudgment interest. For this reason, the United States did not request, and the court did not order, forfeiture in the criminal action.\r\n \r\n In his plea, Garcia admitted that in late 2009, to secure for SAP a multimillion-dollar contract to provide a Panamanian state agency with a technology upgrade package, Garcia conspired with others to bribe two Panamanian government officials directly and a third official through an agent. Garcia admitted that the conspirators used sham contracts and false invoices to disguise the true nature of the bribes and that he believed paying such bribes was necessary to secure the initial and any future Panamanian government contracts. Panamanian officials awarded the $14.5 million contract, which included $2.1 million in SAP software licenses, to SAP\u2019s partner as well as subsequent contracts that also included the provision of SAP products. Garcia personally received over $85,000 in kickbacks for arranging the bribes.\u0022 (Source: US DOJ Press Release, \u0022Former Executive Sentenced for Conspiracy to Bribe Panamanian Officials,\u0022 December 16, 2015.)","Sources ":"US DOJ Press Release, \u0022Former Executive Sentenced for Conspiracy to Bribe Panamanian Officials,\u0022 December 16, 2015, at https:\/\/www.justice.gov\/opa\/pr\/former-executive-sentenced-conspiracy-bribe-panamanian-officials","Documents":""},{"Case ID":"ST-500","Case Cluster ":"SAP SE","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Panama","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"8\/12","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profit; Prejudgment interest","Total Monetary Sanctions (US$)":"$92,395 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$85,965 ","Civil Prejudgment Interest (US$) ":"$6,430 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, the agency\u0027s \u0022investigation found that Vicente E. Garcia, the former vice president of global and strategic accounts for SAP SE, orchestrated a scheme to pay $145,000 in bribes to one government official and promised to pay two others in order to obtain four contracts to sell SAP software to the Panamanian government. He essentially caused SAP, which is headquartered in Germany and executes most of its sales through a network of worldwide corporate partners, to sell software to a partner in Panama at discounts of up to 82 percent. The excessive discounts enabled the partner to create a slush fund from its excessive earnings on the other end of the sales and tap that money to pay the bribes to Panamanian government officials so SAP could sell the software. Garcia, who lives in Miami, also received kickbacks from the slush fund into his bank account.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Former Software Executive With FCPA Violations,\u0022 August 12, 2015.) Mr. Garcia was ordered to pay \u0022disgorgement of $85,965, representing the kickback Garcia received in connection with the bribery scheme, and prejudgment interest of $6,430 to the Securities and Exchange Commission for transfer to the general fund of the United States Treasury subject to Exchange Act Section 21F(g)(3).\u0022 (Source: US SEC Administrative Proceeding File No. 3-16750, In the Matter of Vicente E. Garcia, August 12, 2015.)","Sources ":"US Securities and Exchange Commission, Administrative Proceeding File No. 3-16750, In the Matter of Vicente E. Garcia, August 12, 2015., at https:\/\/www.sec.gov\/litigation\/admin\/2015\/34-75684.pdf;\r\n \r\n US SEC Press Release, \u0022SEC Charges Former Software Executive With FCPA Violations,\u0022 August 12, 2015, at https:\/\/www.sec.gov\/news\/pressrelease\/2015-165.html","Documents":""},{"Case ID":"ST-501","Case Cluster ":"SBM Offshore NV","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Openbaar Ministrie (Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Angola, Brazil, Equatorial Guinea","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"11\/12","Other Jurisdictions of Settlement":"Brazil","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Out of Court Settlement","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$240,000,000 ","Criminal Fine\/Penalty (US$) ":"$40,000,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$200,000,000 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art.1, Art. 2","Offenses - Alleged":"Bribery of Foreign Public Officials","Offenses - Settled":"Bribery of Foreign Public Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Openbaar Ministrie press release, \u0022SBM Offshore has accepted an offer from the Dutch Public Prosecutor\u0027s Service (Openbaar Ministerie) to enter into an out-of-court settlement. The settlement consists of a payment by SBM Offshore to the Openbaar Ministerie of US$ 240,000,000 in total. This amount consists of a US$ 40,000,000 fine and US$ 200,000,000 disgorgement (ontneming van wederrechtelijk verkregen voordeel). This settlement relates to improper payments to sales agents and foreign government officials in Equatorial Guinea, Angola and Brazil in the period from 2007 through 2011 as identified by the Openbaar Ministerie and the Dutch Fiscal Intelligence and Investigation Service (Fiscale Inlichtingenen Opsporingsdienst\u037e FIOD). According to the Openbaar Ministerie\u0027s those payments\r\n constitute the indictable offences of bribery in the public and the private sector as well as forgery (valsheid in geschrifte).(Source: Openbaar Ministrie press release, \u0022SBM Offshore N.V. settles bribery case for US$240,000,000,\u0022 November 12, 2014 at https:\/\/www.om.nl\/vaste-onderdelen\/zoeken\/@87201\/sbm-offshore-settles\/).","Sources ":"Openbaar Ministrie press release, \u0022SBM Offshore N.V. settles bribery case for US$240,000,000,\u0022 November 12, 2014 at https:\/\/www.om.nl\/vaste-onderdelen\/zoeken\/@87201\/sbm-offshore-settles\/","Documents":""},{"Case ID":"ST-502","Case Cluster ":"SBM Offshore NV","Jurisdiction of Settlement":"Brazil","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Netherlands (SBM Offshore NV)","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"4\/4","Other Jurisdictions of Settlement":"Brazil","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"out-of-court settlement, on a no admission of guilt basis","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$68,662.50 ","Criminal Fine\/Penalty (US$) ":"$68,662.50 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$68,662.50 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Prosecution by affected jurisdiction","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Foreign Bribery","Offenses - Settled":"Foreign Bribery","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to press statements by SBM Offshore, the company\u0027s CEO and Member of the Supervisory Board agreed to an out of court settlement on a non admission of guilt basis for bribes allegedly paid to officials of the majority Brazilian government owned Petrobras. The settlement agreement was approved by a judge. (Sources: SBM Offshore Press Releases, \u0022Confirmation of the Settlement Regarding Allegations Against CEO and Member of the Supervisory Board,\u0022 April 6, 2016 and \u0022Settlement Regarding Accusations against CEO and Member of the Supervisory Board,\u0022 January 25, 2016.) According to SBM Offshore\u0027s 2015 Full-Year Earnings report, the company had set aside $245 million for a possible settlement with the Brazilian authorities. (Source: SBM Offshore 2015 Full-Year Earnings Report, \u0022Compliance,\u0022 Ferbuary 10, 2016.)","Sources ":"SBM Offshore Full Year 2015 Earnings, \u0022Compliance,\u0022 February 10, 2016 at http:\/\/www.sbmoffshore.com\/?press-release=sbm-offshore-2015-full-year-earnings; SBM Offshore Press Releases, \u0022Confirmation of the Settlement Regarding Allegations Against CEO and Member of the Supervisory Board,\u0022 April 6, 2016, at http:\/\/www.sbmoffshore.com\/?press-release=confirmation-settlement-regarding-allegations-ceo-member-supervisory-board, and \u0022Settlement Regarding Accusations against CEO and Member of the Supervisory Board,\u0022 January 25, 2016, at \r\n  http:\/\/www.sbmoffshore.com\/?press-release=settlement-regarding-accusations-ceo-member-supervisory-board \r\n \r\n  but no official information is provided in the Controladoria-Geral da Uniao (General Attorney Office) web page. http:\/\/www.cgu.gov.br\/assuntos\/responsabilizacao-de-empresas","Documents":""},{"Case ID":"ST-503","Case Cluster ":"SBM Offshore NV","Jurisdiction of Settlement":"Brazil","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Netherlands (SBM Offshore NV)","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"4\/4","Other Jurisdictions of Settlement":"Brazil","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"out-of-court settlement, on a no admission of guilt basis","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$68,662.50 ","Criminal Fine\/Penalty (US$) ":"$68,662.50 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$68,662.50 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Prosecution by affected jurisdiction","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Foreign Bribery","Offenses - Settled":"Foreign Bribery","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to press statements by SBM Offshore, the company\u0027s CEO and Member of the Supervisory Board agreed to an out of court settlement on a non admission of guilt basis for bribes allegedly paid to officials of the majority Brazilian government owned Petrobras. The settlement agreement was approved by a judge. (Sources: SBM Offshore Press Releases, \u0022Confirmation of the Settlement Regarding Allegations Against CEO and Member of the Supervisory Board,\u0022 April 6, 2016 and \u0022Settlement Regarding Accusations against CEO and Member of the Supervisory Board,\u0022 January 25, 2016.) According to SBM Offshore\u0027s 2015 Full-Year Earnings report, the company had set aside $245 million for a possible settlement with the Brazilian authorities. (Source: SBM Offshore 2015 Full-Year Earnings Report, \u0022Compliance,\u0022 Ferbuary 10, 2016.)","Sources ":"SBM Offshore Full Year 2015 Earnings, \u0022Compliance,\u0022 February 10, 2016 at http:\/\/www.sbmoffshore.com\/?press-release=sbm-offshore-2015-full-year-earnings; SBM Offshore Press Releases, \u0022Confirmation of the Settlement Regarding Allegations Against CEO and Member of the Supervisory Board,\u0022 April 6, 2016, at http:\/\/www.sbmoffshore.com\/?press-release=confirmation-settlement-regarding-allegations-ceo-member-supervisory-board, and \u0022Settlement Regarding Accusations against CEO and Member of the Supervisory Board,\u0022 January 25, 2016, at \r\n  http:\/\/www.sbmoffshore.com\/?press-release=settlement-regarding-accusations-ceo-member-supervisory-board \r\n \r\n  but no official information is provided in the Controladoria-Geral da Uniao (General Attorney Office) web page. http:\/\/www.cgu.gov.br\/assuntos\/responsabilizacao-de-empresas","Documents":""},{"Case ID":"ST-504","Case Cluster ":"SciClone Pharmaceuticals Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/4","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profit; Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$12,826,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$9,426,000 ","Civil Prejudgment Interest (US$) ":"$900,000 ","Civil Fine \/ Penalty (US$)":"$2,500,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022From at least 2007 to 2012, employees of SciClone subsidiaries, who acted as agents of SciClone in conducting business in China, gave money, gifts and other things of value to foreign officials, including healthcare professionals (\u201cHCPs\u201d) who were employed by state-owned hospitals in China, in order to obtain sales of SciClone pharmaceutical products. Various means were employed, and these schemes were known to and condoned by various managers within SciClone\u2019s China-based corporate structure. The related transactions were falsely recorded in SciClone\u2019s books and records as legitimate business expenses, such as sponsorships, travel and entertainment, conferences, honoraria, and promotion expenses. During this period, SciClone also failed to devise and maintain a sufficient system of internal accounting controls and lacked an effective anti-corruption compliance program.","Sources ":"US Securities and Exchange Commission, In the Matter of Sciclone Pharmaceuticals Inc, Administrative Proceeding File No. 3-17101, february 4, 2016, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77058.pdf.","Documents":""},{"Case ID":"ST-505","Case Cluster ":"Securency Intl Pty Ltd.","Jurisdiction of Settlement":"Australia","Jurisdiction of Settlement \/ Enforcement Agency":"Commonwealth Director of Public Prosecutions","Jurisdiction of Foreign Public Official(s) ":"Malaysia","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"8\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"False Accounting","Offenses - Settled":"False Accounting","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Sentencing in R v. Ellery, David John Ellery pleaded guilty to one charge of false accounting,\r\n contrary to s 83(1)(a) of the Crimes Act 1958 (Vic). \u0022The offence occurred between 28 June and 19 July 2006. At the time, [Mr. Ellery was] the chief financial officer, and a company secretary, of Securency International Pty Ltd\r\n (\u201cSecurency\u201d).\r\n 3 Securency is an Australian company, which is jointly owned by the Reserve Bank of Australia and a British company, Innovia Films BVBA. Securency manufactures and supplies a range of unique substances used in banknotes and security documents.\r\n Its polymer substrate product is used by various people, including another Reserve Bank subsidiary, Note Printing Australia Limited (\u201cNote Printing\u201d), in the printing\r\n of banknotes.\r\n 4 In 1999 and 2000, Note Printing and Securency each negotiated and entered into separate agreements with a Malaysian man, Abdul Kayum Syed Ahmad (\u201cKayum\u201d),\r\n and\/or his company, Aksavest Sdn Bhd, appointing them as their agent in Malaysia.\r\n The agency agreements provided that the agent was to be remunerated in the form of success-based commissions, based on the contracts which the agent obtained for the relevant company. The agent was to bear the cost of any expenses incurred in order to obtain contracts.\r\n 5 In December 2003, Note Printing entered into a contract to supply Bank Negara Malaysia with 160 million 5 ringgit polymer banknotes. Securency was not a party to the banknote contract. Note Printing used Securency\u2019s polymer substrate in manufacturing the banknotes, and the contract price of $15.2 million included a price for that substrate. Note Printing paid Kayum substantial commission payments, in respect of the 2003 contract.\r\n 6 The Commonwealth Director of Public Prosecutions has brought charges against Securency, Note Printing, and various former officers of the two companies, alleging\r\n that they conspired with each other and with Kayum, between October 2001 and December 2003, to offer bribes to officials in the Malaysian bank, in order to obtain the business of supplying 5 ringgit polymer banknotes. The DPP alleges that the bribes were to be paid from the commission payable to Kayum.\r\n 7 The DPP does not allege that [Mr. Ellery was] a participant in the alleged Malaysian conspiracy, or that [he was] involved in it when, in mid-2006, [he] committed the false accounting offence to which [he has] pleaded guilty.\u0022 (Source: R v. Ellery [2012] VSC 349, Sentencing.)","Sources ":"R v. Ellery [2012] VSC 349, Sentencing at http:\/\/www.austlii.edu.au\/cgi-bin\/sign.cgi\/au\/cases\/vic\/VSC\/2012\/349;\r\n \r\nAustralia Federal Police Media Release, \u0022Foreign bribery charges laid in Australia,\u0022 July 1, 2011, at http:\/\/www.afp.gov.au\/media-centre\/news\/afp\/2011\/july\/foreign-bribery-charges-laid-in-australia.aspx; \u0022Further charges laid in foreign bribery investigation,\u0022 August 10, 2011, at http:\/\/www.afp.gov.au\/media-centre\/news\/afp\/2011\/august\/further-charges-laid-in-foreign-bribery-investigation; \r\n Robert Wyld, \u0022An Update From Australia \u2013 Securency\r\n Banknote Printing Bribery Scandal\r\n Secures First Conviction And Sentence\r\n And Pressure Increases On Australia\u2019s\r\n Central Bank,\u0022 FCPA Professor, August 30, 2012, at http:\/\/fcpaprofessor.com\/an-update-from-australia-securency-banknote-printing-bribery-scandal-secures-first-conviction-and-sentence-and-pressure-increases-on-australias-central-bank\/;\r\n \r\n Sentencing document","Documents":""},{"Case ID":"ST-506","Case Cluster ":"Siemens","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"2\/3","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$8,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$8,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022On December 13, 2011, the Commission filed a Civil Action charging Bock, Signer, Truppel and four other senior executives of Siemens and its regional company in Argentina with violations of the anti-bribery, books and records, and internal controls provisions of the FCPA. The Commission alleged that between 2001 and 2007, the defendants paid bribes to senior government officials in Argentina to retain a $1 billion contract (\u201cthe DNI contract\u201d) to produce national identity cards for Argentine citizens. The officials included two Argentine presidents and cabinet ministers in two presidential administrations.\r\n \r\n The Commission\u2019s complaint alleged that Bock and Signer, both senior Siemens managers based in Germany, took various actions to revive the DNI contract after it was cancelled by government officials in Argentina, and made sure that the bribery connected to the contract went undetected. Truppel, a former CFO of Siemens Argentina with close ties to government officials, assisted their efforts. The Commission\u2019s complaint also alleged that Uriel Sharef, a member of Siemens Managing Board, or \u201cVorstand,\u201d and the most senior officer charged in connection with the scheme, met with payment intermediaries in the U.S. and agreed to pay bribes to Argentine officials while enlisting subordinates to conceal payments and circumvent Siemens\u2019 internal accounting controls. [ ]\r\n \r\n The Commission previously announced that on April 16, 2013, a final judgment was entered by the Court against Uriel Sharef, a former officer and board member of Siemens, for his role in the long standing bribery scheme. The final judgment, to which Sharef consented without admitting or denying the allegations in the Commission\u2019s complaint, enjoined him from violating the anti-bribery and related books and records and internal controls provisions of the FCPA, and ordered him to pay a $275,000 civil penalty. Bernd Regendantz settled with the Commission when the complaint was filed, and allegations against Herbert Steffen and Carlos Sergi were dismissed.\u0022 (Source: US Securities and Exchange Commission Press Release, \u0022SEC Concludes Its Case Against Former Siemens Executives Charged with Bribery in Argentina, Obtaining Judgments over $1.8 Million,\u0022 February 10, 2014.)","Sources ":"US Securities and Exchange Commission Press Release, \u0022SEC Concludes Its Case Against Former Siemens Executives Charged with Bribery in Argentina, Obtaining Judgments over $1.8 Million,\u0022 February 10, 2014, at https:\/\/www.sec.gov\/litigation\/litreleases\/2014\/lr22923.htm","Documents":""},{"Case ID":"ST-507","Case Cluster ":"Siemens","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"2\/4","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$524,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$524,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022On December 13, 2011, the Commission filed a Civil Action charging Bock, Signer, Truppel and four other senior executives of Siemens and its regional company in Argentina with violations of the anti-bribery, books and records, and internal controls provisions of the FCPA. The Commission alleged that between 2001 and 2007, the defendants paid bribes to senior government officials in Argentina to retain a $1 billion contract (\u201cthe DNI contract\u201d) to produce national identity cards for Argentine citizens. The officials included two Argentine presidents and cabinet ministers in two presidential administrations.\r\n \r\n The Commission\u2019s complaint alleged that Bock and Signer, both senior Siemens managers based in Germany, took various actions to revive the DNI contract after it was cancelled by government officials in Argentina, and made sure that the bribery connected to the contract went undetected. Truppel, a former CFO of Siemens Argentina with close ties to government officials, assisted their efforts. The Commission\u2019s complaint also alleged that Uriel Sharef, a member of Siemens Managing Board, or \u201cVorstand,\u201d and the most senior officer charged in connection with the scheme, met with payment intermediaries in the U.S. and agreed to pay bribes to Argentine officials while enlisting subordinates to conceal payments and circumvent Siemens\u2019 internal accounting controls. [ ]\r\n \r\n The Commission previously announced that on April 16, 2013, a final judgment was entered by the Court against Uriel Sharef, a former officer and board member of Siemens, for his role in the long standing bribery scheme. The final judgment, to which Sharef consented without admitting or denying the allegations in the Commission\u2019s complaint, enjoined him from violating the anti-bribery and related books and records and internal controls provisions of the FCPA, and ordered him to pay a $275,000 civil penalty. Bernd Regendantz settled with the Commission when the complaint was filed, and allegations against Herbert Steffen and Carlos Sergi were dismissed.\u0022 (Source: US Securities and Exchange Commission Press Release, \u0022SEC Concludes Its Case Against Former Siemens Executives Charged with Bribery in Argentina, Obtaining Judgments over $1.8 Million,\u0022 February 10, 2014.)","Sources ":"US Securities and Exchange Commission Press Release, \u0022SEC Concludes Its Case Against Former Siemens Executives Charged with Bribery in Argentina, Obtaining Judgments over $1.8 Million,\u0022 February 10, 2014, at https:\/\/www.sec.gov\/litigation\/litreleases\/2014\/lr22923.htm","Documents":""},{"Case ID":"ST-508","Case Cluster ":"Siemens","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"2\/4","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$937,957 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$316,452 ","Civil Prejudgment Interest (US$) ":"$97,505 ","Civil Fine \/ Penalty (US$)":"$524,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022On December 13, 2011, the Commission filed a Civil Action charging Bock, Signer, Truppel and four other senior executives of Siemens and its regional company in Argentina with violations of the anti-bribery, books and records, and internal controls provisions of the FCPA. The Commission alleged that between 2001 and 2007, the defendants paid bribes to senior government officials in Argentina to retain a $1 billion contract (\u201cthe DNI contract\u201d) to produce national identity cards for Argentine citizens. The officials included two Argentine presidents and cabinet ministers in two presidential administrations.\r\n \r\n The Commission\u2019s complaint alleged that Bock and Signer, both senior Siemens managers based in Germany, took various actions to revive the DNI contract after it was cancelled by government officials in Argentina, and made sure that the bribery connected to the contract went undetected. Truppel, a former CFO of Siemens Argentina with close ties to government officials, assisted their efforts. The Commission\u2019s complaint also alleged that Uriel Sharef, a member of Siemens Managing Board, or \u201cVorstand,\u201d and the most senior officer charged in connection with the scheme, met with payment intermediaries in the U.S. and agreed to pay bribes to Argentine officials while enlisting subordinates to conceal payments and circumvent Siemens\u2019 internal accounting controls. [ ]\r\n \r\n The Commission previously announced that on April 16, 2013, a final judgment was entered by the Court against Uriel Sharef, a former officer and board member of Siemens, for his role in the long standing bribery scheme. The final judgment, to which Sharef consented without admitting or denying the allegations in the Commission\u2019s complaint, enjoined him from violating the anti-bribery and related books and records and internal controls provisions of the FCPA, and ordered him to pay a $275,000 civil penalty. Bernd Regendantz settled with the Commission when the complaint was filed, and allegations against Herbert Steffen and Carlos Sergi were dismissed.\u0022 (Source: US Securities and Exchange Commission Press Release, \u0022SEC Concludes Its Case Against Former Siemens Executives Charged with Bribery in Argentina, Obtaining Judgments over $1.8 Million,\u0022 February 10, 2014.)","Sources ":"US Securities and Exchange Commission Press Release, \u0022SEC Concludes Its Case Against Former Siemens Executives Charged with Bribery in Argentina, Obtaining Judgments over $1.8 Million,\u0022 February 10, 2014, at https:\/\/www.sec.gov\/litigation\/litreleases\/2014\/lr22923.htm","Documents":""},{"Case ID":"ST-509","Case Cluster ":"Siemens","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"4\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$275,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$275,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, Uriel Sharef, a former officer and board member of Siemens Aktiengesellschaft (Siemens) settled with the agency in 2013. \u0022The settlement resolves the Commission\u0027s civil action against Sharef for his role in Siemens\u0027 decade-long bribery scheme to retain a $1 billion government contract to produce national identity cards for Argentine citizens. The final judgment, to which Sharef consented, enjoins him from violating the anti-bribery and related internal controls provisions of the FCPA and orders him to pay a $275,000 civil penalty, the second highest penalty assessed against an individual in an FCPA case.\r\n \r\n On December 13, 2011, the Commission filed a civil action against Uriel Sharef and six other defendants, alleging that between 2001 and 2007, Sharef, along with other Siemens executives, paid bribes to senior government officials in Argentina in connection with a government contract to provide national identity cards to all Argentine citizens. The officials included two Argentine presidents and cabinet ministers in two presidential administrations. During this period, Sharef was a member of Siemens Managing Board, or \u201cVorstand,\u201d and was the most senior officer charged in connection with the scheme. Sharef met with payment intermediaries in the United States and agreed to pay $27 million in bribes to Argentine officials. Sharef also enlisted subordinates to conceal the payments by circumventing Siemens\u0027 internal accounting controls.\r\n \r\n According to the SEC\u0027s complaint, approximately $31.3 million of the $100 million in bribes paid were made after March 12, 2001, when Siemens became a U.S. issuer subject to U.S. securities laws. As a result of the bribe payments it made, Siemens received an arbitration award in 2007 against the government of Argentina of more than $217 million plus interest for the contract. In August 2009, after settling bribery charges with the U.S. and Germany, Siemens waived the arbitration award.\u0022 (Source: US Securities and Exchange Commission Litigation Release, \u0022Former Siemens Executive Uriel Sharef Settles Bribery Charges,\u0022 April 16, 2013.)","Sources ":"US Securities and Exchange Commission Litigation Release, \u0022Former Siemens Executive Uriel Sharef Settles Bribery Charges,\u0022 April 16, 2013, at https:\/\/www.sec.gov\/litigation\/litreleases\/2013\/lr22676.htm","Documents":""},{"Case ID":"ST-510","Case Cluster ":"Siemens Industrial Turbomachinery","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Russia","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"11\/12","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Summary Punishment Order","Monetary Sanctions  (Types)":"Criminal Compensation; Criminal Reparations","Total Monetary Sanctions (US$)":"$10,863,765 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$10,728,061 ","Criminal Restitution \/ Reparation (US$)":"$135,704 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$135,704 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"in the form of a donation to the International Committee of the Red Cross (ICRC).","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art, 2, Art. 8","Offenses - Alleged":"Inadequate enforcement of compliance regulations","Offenses - Settled":"Inadequate enforcement of compliance regulations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Media Release issued by the Swiss Office of the Attorney General, \u0022The Office of the Attorney General of Switzerland (OAG) has concluded a criminal investigation into the Swedish company Siemens Industrial Turbomachinery (SIT). The investigation was closed after SIT admitted inadequate enforcement of compliance regulations in relation to Yamal gas pipeline projects and paid CHF 125,000 in reparation. SIT also paid US$ 10.6 million in compensation for unlawfully obtained profits.\r\n \r\nThe OAG investigated the circumstances behind contracts awarded to the Swedish company, acquired by Siemens in 2003, for the supply of gas turbines during the construction of the pipeline, which runs from the gas fields on the Russian Yamal peninsula to Western Europe. In the course of project, initiated by Russia\u0027s largest natural gas production company, bribes were paid to senior executives of the Russian state-owned company. SIT made the unlawful payments between 2004 and 2006 via bank accounts held by the end recipients in Switzerland. This was the connecting factor that gave rise to the OAG\u0027s investigation.\r\n \r\n The SIT accepts that it did not take all the required and reasonable organisational steps to prevent bribes being paid to foreign public officials in connection with projects to build compressor stations and to supply gas turbines for the Yamal pipeline network. In particular, it admitted basic failures in checking consultancy agreements. The company is therefore guilty of organisational offences under Art. 102 of the Swiss Criminal Code (SCC). SIT has paid reparation of CHF 125,000 in the form of a donation to the International Committee of the Red Cross (ICRC).\r\n \r\n As a consequence, the OAG closed the investigation into SIT based on Art. 53 SCC and at the same time ordered the forfeiture of unlawfully obtained assets. The profits obtained unlawfully from the projects concerned amount to US$ 10.6 million. The OAG ordered SIT to pay a corresponding sum in compensation to the State (Art. 71 para. 1 SCC). The compensation has now been paid.\u0022 (Source: \u0022Bribery relating to the construction of Yamal Pipeline: Siemens subsidiary pays reparation,\u0022 November 12, 2013,)","Sources ":"Swiss Office of the Attorney General Media Release, \u0022Bribery relating to the construction of Yamal Pipeline: Siemens subsidiary pays reparation,\u0022 November 12, 2013, at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026print_style=yes\u0026msg-id=50913","Documents":""},{"Case ID":"ST-511","Case Cluster ":"Smith \u0026 Wesson","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia, Pakistan, Others","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"7\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profit; Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$2,034,892 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$107,852 ","Civil Prejudgment Interest (US$) ":"$21,040 ","Civil Fine \/ Penalty (US$)":"$1,906,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, the agency\u0027s \u0022order instituting a settled administrative proceeding, the Springfield, Mass. based firearms manufacturer sought to break into new markets overseas starting in 2007 and continuing into early 2010. During that period, Smith \u0026 Wesson\u2019s international sales staff engaged in a pervasive effort to attract new business by offering, authorizing, or making illegal payments or providing gifts meant for government officials in Pakistan, Indonesia, and other foreign countries. [ ]\r\n \r\n According to the SEC\u2019s order, Smith \u0026 Wesson retained a third party agent in Pakistan in 2008 to help the company obtain a deal to sell firearms to a Pakistani police department. Smith \u0026 Wesson officials authorized the agent to provide more than $11,000 worth of guns to Pakistani police officials as gifts, and then make additional cash payments. Smith \u0026 Wesson ultimately won a contract to sell 548 pistols to the Pakistani police for a profit of $107,852.\r\n \r\n The SEC\u2019s order finds that Smith \u0026 Wesson employees made or authorized improper payments related to multiple other pending or contemplated international sales contracts. For example, in 2009, Smith \u0026 Wesson attempted to win a contract to sell firearms to an Indonesian police department by making improper payments to its third party agent in Indonesia. The agent indicated he would provide a portion of that money to Indonesian officials under the guise of legitimate firearm lab testing costs. He said Indonesian police officials expected to be paid additional amounts above the actual cost of testing the guns. Smith \u0026 Wesson officials authorized and made the inflated payment, but a deal was never consummated.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Smith \u0026 Wesson with FCPA Violations,\u0022 July 28, 2014.)","Sources ":"US Securities and Exchange Commission, In the Matter of Smith \u0026 Wesson Holding Corporation, Administrative Proceeding File No. 3-15986, July 28, 2016, at https:\/\/www.sec.gov\/litigation\/admin\/2014\/34-72678.pdf; Press Release, \u0022SEC Charges Smith \u0026 Wesson with FCPA Violations,\u0022 July 28, 2014, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370542384677;","Documents":""},{"Case ID":"ST-512","Case Cluster ":"SNC-Lavalin","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Federal Prosecutor General","Jurisdiction of Foreign Public Official(s) ":"Bangladesh","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"8\/5","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture, Criminal Restitution","Total Monetary Sanctions (US$)":"$40,300,000 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$27,000,000 ","Criminal Restitution \/ Reparation (US$)":"$13,300,000 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$13,300,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Return to SNC Lavalin (Partie Plaignante)","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of foreign officials; Money laundering; Fraud; Mismanagement","Offenses - Settled":"Bribery of foreign officials; Money laundering; Fraud; Mismanagement","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Wall Street Journal and other secondary sources, the Swiss Federal Cirminal Court approved the plea agreement by Mr. Riad Ben Aissa, which included forfeiture of CHF 40 milion forfeited of which CHF 13 million was provided to SNC-Lavalin, which was permitted to file claim as a victim. (Source: James V. Grimaldi and Margaret T. Coker, \u0022Canadian Firm Recoups Cash in Bribery Probe,\u0022 December 11, 2014; Greg McArthur, \u0022Swiss court grants SNC special status in fraud case against former executive,\u0022 May 22, 2013.)","Sources ":"Acte d\u0027accusation en procedure simplifiee, Riad Ben Aissa, August 5, 2014, at http:\/\/nawaat.org\/portail\/wp-content\/uploads\/Acte_Accusation_riadh_Ben_Aissa_ALSTOM.pdf; James V. Grimaldi and Margaret T. Coker, \u0022Canadian Firm Recoups Cash in Bribery Probe,\u0022 December 11, 2014, at http:\/\/www.wsj.com\/articles\/canadian-firm-recoups-cash-in-bribery-case-1418343614; Greg McArthur, \u0022Swiss court grants SNC special status in fraud case against former executive,\u0022 May 22, 2013, at http:\/\/www.theglobeandmail.com\/report-on-business\/swiss-court-grants-snc-special-status-in-fraud-case-against-former-executive\/article12053350\/; Brian Hutchinson, \u0022Inside the \u0027clandestine world\u0027 of SNC-Lavalin\u0027s fallen star Riadh Ben Aissa,\u0022 March 18, 2015, at http:\/\/business.financialpost.com\/legal-post\/inside-the-clandestine-world-of-snc-lavalins-fallen-star-riadh-ben-aissa","Documents":""},{"Case ID":"ST-513","Case Cluster ":"SNC-Lavalin Inc.","Jurisdiction of Settlement":"World Bank","Jurisdiction of Settlement \/ Enforcement Agency":"Integrity","Jurisdiction of Foreign Public Official(s) ":"Bangladesh","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"4\/17","Other Jurisdictions of Settlement":"Switzerland (Ben Aissa)","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Negotiated Resolution Agreement","Monetary Sanctions  (Types)":"None specified","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"Ten years debarment of SNC-Lavalin Inc. and over 100 related entities","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Violation of World Bank Procurement Guidelines","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Violation of World Bank Procurement Guidelines","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the World Bank, SNC-Lavalin Inc. and \u0022over 100 affiliates - [were debarred] for a period of 10 years following the company\u2019s misconduct in relation to the Padma Multipurpose Bridge Project in Bangladesh, as well as misconduct under another Bank-financed project. SNC-Lavalin Inc. is a subsidiary of SNC-Lavalin Group, a Canadian company, and represents more than 60% of its business. \r\n \r\nThe debarment is part of a Negotiated Resolution Agreement between the World Bank and SNC-Lavalin Group following a World Bank investigation into allegations of bribery schemes involving SNC-Lavalin Inc. and officials in Bangladesh.\r\n \r\n While the investigation was ongoing, the World Bank\u2019s Integrity Vice Presidency also learned of misconduct by SNC-Lavalin Inc. in relation to the World Bank-financed Rural Electrification and Transmission project in Cambodia. [ ]\r\n \r\n SNC-Lavalin\u2019s misconduct involved a conspiracy to pay bribes and misrepresentations when bidding for Bank-financed contracts in violation of the World Bank\u2019s procurement guidelines. Under the Agreement, the SNC-Lavalin Group and its affiliates commit to cooperating with the World Bank\u2019s Integrity Vice Presidency and continuing to improve their internal compliance program. The debarment of SNC-Lavalin Inc. qualifies for cross-debarment by other MDBs under the Agreement of Mutual Recognition of Debarments that was signed on April 9, 2010.\u0022 (Source: World Bank, \u0022World Bank Debars SNC-Lavalin Inc. and its Affiliates for 10 years,\u0022 April 17, 2013.)","Sources ":"World Bank, \u0022World Bank Debars SNC-Lavalin Inc. and its Affiliates for 10 years,\u0022 April 17, 2013, at http:\/\/www.worldbank.org\/en\/news\/press-release\/2013\/04\/17\/world-bank-debars-snc-lavalin-inc-and-its-affiliates-for-ten-years","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/SNC-Lavalin%20Inc%20debarment_WB%20Press%20Release.pdf"},{"Case ID":"ST-514","Case Cluster ":"Standard Bank","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Tanzania","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"11\/30","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Compensation (to Tanzania), Disgorgement of Profits, Financial Penalty, Legal Costs","Total Monetary Sanctions (US$)":"$32,742,222.58 ","Criminal Fine\/Penalty (US$) ":"$16,800,000 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$8,400,000 ","Criminal Restitution \/ Reparation (US$)":"$7,046,197 ","Criminal Legal \/ Procedural Costs (US$)":"$496,026 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$7,046,197 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Compensation to Tanzania (US$6 million and $1 million in interest)","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Failure to Prevent Bribery","Offenses - Settled":"Failure to Prevent Bribery","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Crown Court Judgment, \u0022the Government of Tanzania wished to raise funds by way of a sovereign note private placement. Stanbic Bank Tanzania Ltd (\u201cStanbic\u201d), which is a subsidiary of Standard Bank Group Ltd (a publicly owned company registered in South Africa), was not licensed to deal with non-local foreign investors in the debt capital market and so Stanbic involved Standard Bank, another subsidiary of the same group that was licensed, and together they sought to obtain instructions to raise the funds. Negotiations did not progress until Stanbic entered into an agreement with a Tanzanian company called Enterprise Growth Market Advisors Limited (\u201cEGMA\u201d). \r\n \r\n 7. Two of the three directors and shareholders of EGMA were the Commissioner of the Tanzania Revenue Authority (and, thus, a member of the Government of Tanzania) and the former Chief Executive Officer of Tanzanian Capital Markets and Securities Authority (\u201cCMSA\u201d). EGMA\u2019s fee was agreed at 1% of the funds raised and in order to meet the cost of that agreement, the fee for the placement was increased from 1.4% to 2.4%. In the event, although the potential for corrupt practices to affect this type of business were well known, Standard Bank, which did not have adequate measures in place to guard against such risks, relied on Stanbic to conduct appropriate due diligence in relation to EGMA; Standard Bank made no enquiry about EGMA or its role. \r\n \r\n 8. The mandate to raise the funds was placed with Standard Bank and Stanbic and US $600 million was raised but there is no evidence that EGMA provided any services in relation to the transaction. Meanwhile, EGMA had opened a bank account with Stanbic and its fee of US $6 million was paid (as agreed) via Stanbic into the account. Very shortly thereafter the vast majority of the sum had been withdrawn in cash. The withdrawals excited the concern of staff at Stanbic who referred the matter to the head office of Standard Bank Group Ltd; Standard Bank were alerted and very quickly thereafter, a law firm was appointed to investigate the matter and, within three weeks of the first report, both the Serious and Organised Crime Agency and the SFO were informed.\u0022 The Judgment also makes note of Standard Bank\u0027s settlement with the US Securities and Exchange Commission. (Source: Judgment in Between : SERIOUS FRAUD OFFICE Applicant - and - STANDARD BANK PLC (Now known as ICBC Standard Bank plc), Case No: U20150854, Crown Court (Queen\u0027s Bench Division), November 30, 2015.)","Sources ":"Judgment in Between SERIOUS FRAUD OFFICE Applicant - and - STANDARD BANK PLC (Now known as ICBC Standard Bank plc), Case No: U20150854, Crown Court (Queen\u0027s Bench Division), November 30, 2015, at https:\/\/www.judiciary.gov.uk\/wp-content\/uploads\/2015\/11\/sfo-v-standard-bank_Final_1.pdf; UK Serious Fraud Office Press Release, \u0022SFO agrees first UK DPA with Standard Bank,\u0022 November 30, 2015, which includes links to the Deferred Prosecution Agreement, Statement of Facts and Judgments at https:\/\/www.sfo.gov.uk\/2015\/11\/30\/sfo-agrees-first-uk-dpa-with-standard-bank\/","Documents":""},{"Case ID":"ST-515","Case Cluster ":"Standard Bank","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Tanzania","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"11\/30","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits; Civil Penalty","Total Monetary Sanctions (US$)":"$4,200,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"See Note - other civil monetary sanctions","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$4,200,000 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"Standard Bank was ordered to pay disgorgement of $8.4 million; this amount was deemed satisfied by the payment of $4.2 million in penalty to the US and $4.2 million in penalty to the UK.","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Negligent Securities Fraud","Offenses - Settled":"Negligent Securities Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, Standard Bank Plc was charged \u0022with failing to disclose certain payments in connection with debt issued by the Government of Tanzania in 2013. The London-based bank acted as a lead manager for the offering and failed to disclose payments made by an affiliate to a Tanzanian firm that received a portion of the proceeds of the $600 million offering but performed no substantive role in the transaction.\r\n \r\n Standard Bank, now ICBC Standard Bank Plc, agreed to settle the SEC\u2019s charges by paying a $4.2 million penalty and admitting the facts underlying the SEC\u2019s charges that were admitted in a related settlement with the United Kingdom\u2019s Serious Fraud Office (SFO). As part of that coordinated global settlement, the SFO also announced a settlement today in an action it brought against Standard in the U.K. for Standard\u2019s violations of Section 7 of the U.K.\u2019s Bribery Act of 2010. The Bribery Act of 2010 is similar to the Unites States\u2019 Foreign Corrupt Practices Act (FCPA). The SEC would not have jurisdiction to bring charges under the FCPA because Standard was not an \u201cissuer\u201d as defined by that Act. Standard will pay a total of approximately $36.9 million in monetary relief in the SEC and U.K. actions. \r\n \r\n [Accordng to the SEC\u0027s Cease and Desist] order,] the offering documents and statements to potential investors in the sovereign debt offering were materially misleading because they failed to disclose that Standard\u2019s affiliate, Stanbic Bank Tanzania Limited, would pay $6 million of the proceeds to Enterprise Growth Markets Advisors Limited (EGMA), a private Tanzanian firm. The order found Standard did not seek to understand EGMA\u2019s role in the transaction despite red flags that the $6 million payment was intended to induce the Government of Tanzania to select Standard and Stanbic as managers for the offering. One of EGMA\u2019s directors was a representative of the Government of Tanzania and the offering was not finalized until Standard and Stanbic committed to pay EGMA one percent of the proceeds of the offering. Standard and Stanbic split 1.4 percent of the proceeds, with each receiving $4.2 million for their participation in the transaction. [ ] \r\n \r\n The SEC\u2019s order requires Standard to cease and desist from committing or causing any violations and any future violations of Section 17(a)(2) of the Securities Act of 1933 that prohibits obtaining money by any materially untrue statement or omission, and to pay a $4.2 million civil penalty. The order also requires Standard to pay disgorgement of $8.4 million, which the Commission has deemed satisfied by a payment of equal amount in the U.K. matter.\u0022 (Source: US SEC Press Release, \u0022Standard Bank to Pay $4.2 Million to Settle SEC Charges Bank Agrees to $36.9 Million Global Settlement with the SEC and the U.K.\u2019s Serious Fraud Office,\u0022 November 30, 2015.)","Sources ":"US Securities and Exchange Commission, In the Matter of Standard Bank, Plc, Administrative Proceedings File No. 3-16973, at https:\/\/www.sec.gov\/litigation\/admin\/2015\/33-9981.pdf; SEC Press Release, \u0022Standard Bank to Pay $4.2 Million to Settle SEC Charges Bank Agrees to $36.9 Million Global Settlement with the SEC and the U.K.\u2019s Serious Fraud Office,\u0022 November 30, 2015, at https:\/\/www.sec.gov\/news\/pressrelease\/2015-268.html","Documents":""},{"Case ID":"ST-516","Case Cluster ":"Stryker Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina, Greece, Mexico, Poland, Romania","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"10\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profit; Prejudgment interest, Civil Penalty","Total Monetary Sanctions (US$)":"$13,283,523 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$7,502,635 ","Civil Prejudgment Interest (US$) ":"$2,280,888 ","Civil Fine \/ Penalty (US$)":"$3,500,000 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, Stryker is a Michigan corporation with its principal executive offices in Kalamazoo, Michigan. Stryker manufactures and distributes medical devices and products in more than 100 countries around the world. The Company \u0022made approximately $2.2 million in unlawful payments to various government employees including public health care professionals (collectively, the \u201cforeign officials\u201d) in Mexico, Poland, Romania, Argentina, and Greece. Stryker incorrectly described these expenses in the company\u2019s books and records as legitimate consulting and service contracts, travel expenses, charitable donations, or commissions, when in fact the payments were improperly made by Stryker to obtain or retain business. Stryker earned approximately $7.5 million in illicit profits as a result of these payments.\u0022 (Source: US Securities and Exchange Commission, In the Matter of Stryker Corporation, Administrative Proceeding File No. 3-15587, October 24, 2013.)","Sources ":"US Securities and Exchange Commission, In the Matter of Stryker Corporation, Administrative Proceeding File No. 3-15587, October 24, 2013, at https:\/\/www.sec.gov\/litigation\/admin\/2013\/34-70751.pdf","Documents":""},{"Case ID":"ST-517","Case Cluster ":"Subramanian Krishnan","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Unspecified (misconduct by Asia Pacific regional office)","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"9\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$60,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$60,000 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Internal Controls Violations","Offenses - Settled":"Internal Controls Violations","Public Procurement Contract \/ SOE Involved?":"No","Summary":"According to the US Securities and Exchange Commission, \u0022On September 28, 2012, the Securities and Exchange Commission filed a partially-settled civil injunctive action in the U.S. District Court for the District of Minnesota against Subramanian Krishnan (Krishnan). In its complaint, the Commission alleges that Krishnan, the former Chief Financial Officer (CFO) of Digi International, Inc. (Digi), engaged in conduct which resulted in the filing of inaccurate reports and accompanying certifications in Digi\u2019s annual quarterly reports from March 2005 through May 2010.\r\n \r\n Krishnan engaged in a course of conduct, as a result of which corporate funds were used to pay for unauthorized travel and entertainment\r\n expenses. Krishnan authorized such expenses for Digi employees, caused the Company to file inaccurate reports, failed to enforce Digi\u2019s internal controls, demonstrated a lack of management integrity, failed to act to reveal inaccurate reports, and wrongly certified that he evaluated the effectiveness of Digi\u2019s internal controls and disclosed they were effective.\u0022 (Source: SEC Litigation Release, \u0022SEC Charges Former CFO with Evading Internal Controls to Pay for Unauthorized Travel and Entertainment,\u0022 September 28, 2012.)","Sources ":"US SEC v. Subramanian Krishnan, Case No. 12-cv-2495 (D. Minn), Complaint filed September 28, 2012 and FInal Judgment of July 5, 2013, accessed via Pacer; SEC Litigation Release, \u0022SEC Charges Former CFO with Evading Internal Controls to Pay for Unauthorized Travel and Entertainment,\u0022 September 28, 2012, at https:\/\/www.sec.gov\/litigation\/litreleases\/2012\/lr22500.htm","Documents":""},{"Case ID":"ST-518","Case Cluster ":"Sweett Group","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"United Arab Emirates","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/19","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation, Legal Costs","Total Monetary Sanctions (US$)":"$3,358,610 ","Criminal Fine\/Penalty (US$) ":"$2,004,130 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$1,218,440 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$136,040 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Failure to Prevent Bribery","Offenses - Settled":"Failure to Prevent Bribery","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office, in February 2016, construction and professional services company \u0022Sweett Group PLC was sentenced and ordered to pay \u00a32.25 million as a result of a conviction arising from a Serious Fraud Office investigation into its activities in the United Arab Emirates.\r\n \r\nThe company pleaded guilty in December 2015 to a charge of failing to prevent an act of bribery intended to secure and retain a contract with Al Ain Ahlia Insurance Company (AAAI), contrary to Section 7(1)(b) of the Bribery Act 2010.\r\n \r\n The relevant conduct occurred between 1 December 2012 and 1 December 2015. [ ]\r\n \r\n His Honour Judge Beddoe described the offence as a system failure and said that the offending was patently committed over a period of time.\r\n \r\n Referring to Section 7 of the Bribery Act 2010 and to Sweett\u2019s ignorance of its subsidiary\u2019s actions , HHJ Bedoe said:\r\n \r\n The whole point of section 7 is to impose a duty on those running such companies throughout the world properly to supervise them. Rogue elements can only operate in this way \u2013 and operate for so long \u2013 because of a failure properly to supervise what they are doing and the way they are doing it.\r\n \r\n The SFO\u2019s investigation into Sweett Group PLC, which commenced on 14 July 2014, uncovered that its subsidiary company, Cyril Sweett International Limited had made corrupt payments to Khaled Al Badie, the Vice Chairman of the Board and Chairman of the Real Estate and Investment Committee of AAAI to secure the award of a contract with AAAI for the building of the Rotana Hotel in Abu Dhabi.\r\n \r\n The amount is broken down as \u00a31.4m in fine, \u00a3851,152.23 in confiscation. Additionally, \u00a395,031.97 in costs were awarded to the SFO.\r\n \r\n The judge ordered the confiscation order to be paid within three months. Half of the fine is to be paid by 19 February 2017 and the other half by 19 February 2018.\r\n \r\n The SFO\u2019s investigation into individuals continues.\u0022 (Source: UK Serious Fraud Office, \u0022Sweett Group PLC sentenced and ordered to pay \u00a32.25 million after Bribery Act conviction,\u0022 February 19, 2016.)","Sources ":"US Serious Fraud Office Press Release, \u0022Sweett Group PLC sentenced and ordered to pay [GBP] 2.25million after Bribery Act conviction,\u0022 February 19, 2016, at\r\n https:\/\/www.sfo.gov.uk\/2016\/02\/19\/sweett-group-plc-sentenced-and-ordered-to-pay-2-3-million-after-bribery-act-conviction\/","Documents":""},{"Case ID":"ST-519","Case Cluster ":"Tenam Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Russia","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"12\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$2,126,622.36 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$2,126,622.36 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy - Money Laundering; Conspiracy to Interfere with Interstate Commerce by Extortion","Offenses - Settled":"Conspiracy - Money Laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022A former Russian official residing in Maryland was sentenced [on December 15, 2015] to 48 months in prison for conspiracy to commit money laundering in connection with his role in arranging more than $2 million in corrupt payments to influence the awarding of contracts with a Russian state-owned nuclear energy corporation. [ ] \r\n  \r\nVadim Mikerin [ ] was also ordered to forfeit $2,126,622.36. [ ] \r\n \r\n According to court documents, Mikerin was the director of the Pan American Department of JSC Techsnabexport (TENEX), a subsidiary of Russia\u2019s State Atomic Energy Corporation and the sole supplier and exporter of Russian Federation uranium and uranium enrichment services to nuclear power companies worldwide, and the president of TENAM Corporation, a wholly owned subsidiary and the official representative of TENEX. Court documents show that between 2004 and October 2014, conspirators agreed to make corrupt payments to influence Mikerin and to secure improper business advantages for U.S. companies that did\r\n business with TENEX, in violation of the Foreign Corrupt Practices Act (FCPA). Mikerin admitted that he conspired with Daren Condrey, Boris Rubizhevsky and others to transmit approximately $2,126,622 from Maryland and elsewhere in the United States to offshore shell company bank accounts located in Cyprus, Latvia and Switzerland with the intent to promote the FCPA violations. Mikerin further admitted that the conspirators used consulting agreements and code words to disguise the corrupt payments.\u0022 \r\n \r\n Two other defendants in the case also pleaded guilty. Daren Condrey pleaded guilty on June 17, 2015, to conspiring to violate the Foreign Corrupt Practices Act (FCPA) and conspiring to commit wire fraud. Boris Rubizhevsky pleaded guilty on June 15,\r\n 2015, to conspiracy to commit money laundering. As of April 18, 2016, Mr. Condrey and Mr. Rubizhevsky appear to be awaiting sentencing. (Source: US v. Condrey, Case No. 15-cr-336 and US v. Rubizhevsky, Case No. 15-cr-332 (D. Md.), Court Docket Reports as of April 18, 2016, accessed via Pacer.)","Sources ":"US v. Mikherin, Case No. 14-cr-529 (D. Md.), Superseding Information, Plea Agreement and Department of Justice press Release, \u0022Former Russian Nuclear Energy Official Sentenced to 48 Months in Prison for Money Laundering Conspiracy Involving Foreign Corrupt Practices Act Violations,\u0022 December 15, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/vadim-mikerin; Court documents related to US v. Rubizhevsky at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/boris-rubizhevsky; US v. Condrey, at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/daren-condrey","Documents":""},{"Case ID":"ST-520","Case Cluster ":"Torvald Klaveness","Jurisdiction of Settlement":"Norway","Jurisdiction of Settlement \/ Enforcement Agency":"OKOKRIM","Jurisdiction of Foreign Public Official(s) ":"Bahrain","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"5\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Penalty Notice","Monetary Sanctions  (Types)":"Criminal Fine and Confiscation","Total Monetary Sanctions (US$)":"$5,401,300 ","Criminal Fine\/Penalty (US$) ":"$3,375,810 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$2,025,490 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a press statement issued by OKOKRIM, in the period July 2003-March 2004, Caburnes Chartering AS (parent company Torvald Klaveness) paid bribes to senior officials in connection with freight shipping agreements with Aluminum Bahrain BSC (ALBA), a majority state owned entity. (Source: OKOKRIM, \u0022Millionforelegg for bestikkelser,\u0022 last updated May 15, 2014.). See related entry, Alcoa settlements with the US Department of Justice and the Securities and Exchange Commission.","Sources ":"OKOKRIM, \u0022Millionforelegg for bestikkelser,\u0022 last updated May 15, 2014, at http:\/\/www.okokrim.no\/wwww-9k5f5x;\r\n \r\nOKOKRIM Annual Report 2014, at http:\/\/www.okokrim.no\/www\/okokrim\/resource.nsf\/files\/2545112408-okokrim_annualreport_2014\/$FILE\/okokrim_annualreport_2014.pdf","Documents":""},{"Case ID":"ST-521","Case Cluster ":"Total S.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iran","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"5\/29","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$245,200,000 ","Criminal Fine\/Penalty (US$) ":"$245,200,000 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials; Falsifcation of Books and Records; Internal Controls Violations","Offenses - Settled":"Conspiracy to Bribe Foreign Officials; Falsifcation of Books and Records; Internal Controls Violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, in 2013 Total SA agreed to a deferred prosecution agreement which stated in part, \u0022in 1995 Total sought to re-enter the Iranian oil and gas market by attempting to obtain a contract with the National Iranian Oil Company (NIOC) to develop the Sirri A and E oil and gas fields. In May 1995, Total entered into negotiations with an Iranian official who served as the Chairman of an Iranian state-owned and state-controlled engineering company. Total subsequently entered into a purported consulting agreement pursuant to which Total would corruptly make payments to an intermediary designated by the Iranian official to secure NIOC signing a development agreement with Total for the Sirri A and E project, which NIOC did in July 1995. Over the next two-and-a- half years, Total paid approximately $16 million in bribes under the purported consulting agreement. \r\n \r\n In 1997, Total sought to negotiate a contract with NIOC to develop a portion of the South Pars gas field, the world\u2019s largest gas field. At the direction of the Iranian official, Total and a second intermediary entered into another purported consulting agreement that called for Total to make large payments to the intermediary. In September 1997, Total executed a contract with NIOC that granted it a 40 percent interest in developing phases two and three of the South Pars gas field. Over the next seven years, Total made unlawful payments of approximately $44 million pursuant to the second purported consulting agreement. In sum, between 1995 and 2004, at the direction of the Iranian official, Total corruptly made approximately $60 million in bribe payments under the agreements for the purpose of inducing the Iranian official to use his influence in connection with Total\u2019s efforts to obtain and retain lucrative oil rights in the Sirri A and E and South Pars oil and gas fields. Total mischaracterized the unlawful payments as \u201cbusiness development expenses\u201d when they were, in fact, bribes designed to corruptly influence a foreign official. Further, Total failed to implement effective internal accounting controls, permitting the consulting agreements\u2019 true nature and true participants to be concealed and thereby failing to maintain accountability for assets.\u0022 (Source: US DOJ Press Release, \u0022French Oil and Gas Company, TOTAL, S.A., charged in the United States and France in connection with an international bribery scheme,\u0022 May 29, 2013.)","Sources ":"US v. Total SA, Case No. 1:13-cr-239 (EDVA), Information and Deferred Prosecution Agreement filed May 29, 2013 and DOJ Press Release, \u0022French Oil and Gas Company, TOTAL, S.A., charged in the United States and France in connection with an international bribery scheme,\u0022 May 29, 2013, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-total-sa-court-docket-number-113-cr-239.","Documents":""},{"Case ID":"ST-522","Case Cluster ":"Total S.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iran","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"5\/29","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profit","Total Monetary Sanctions (US$)":"$153,000,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$153,000,000 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, in 2013, the agency \u0022charged France-based oil and gas company Total S.A. with violating the Foreign Corrupt Practices Act (FCPA) by paying $60 million in bribes to intermediaries of an Iranian government official who then exercised his influence to help the company obtain valuable contracts to develop significant oil and gas fields in Iran.\r\n \r\n The SEC alleges that Total made more than $150 million in profits through the bribery scheme. Total attempted to cover up the true nature of the illegal payments by entering into sham consulting agreements with intermediaries of the Iranian official and mischaracterizing the bribes in its books and records as legitimate \u201cbusiness development expenses\u201d related to the consulting agreements. Total had inadequate systems to properly review the consulting agreements and lacked sufficient internal controls to comply with federal laws prohibiting bribery. [ ] \r\n \r\n Total negotiated a development contract in 1995 with the National Iranian Oil Company (NIOC) for the country\u2019s Sirri A and E oil and gas fields. Prior to executing the contract, Total held a meeting with the Iranian official and agreed to enter into a purported consulting agreement with an intermediary he designated. They agreed that Total would make payments to the intermediary under the guise of a consulting agreement when the real purpose was to induce the Iranian official to use his influence to help obtain NIOC\u2019s approval of the development agreement. After the contract was executed, Total corruptly made the bribery payments that resulted in NIOC allowing Total to develop the Sirri A and E oil and gas fields and make more than $150 million in profits.\u0022 (Source: SEC Press Release, \u0022SEC Charges Total S.A. for Illegal Payments to Iranian Official,\u0022 May 29, 2013.)","Sources ":"US Securities and Exchange Commission, In the Matter of Total S.A., Administrative Proceeding File No. 3-15338, at https:\/\/www.sec.gov\/litigation\/admin\/2013\/34-69654.pdf;\r\n \r\n SEC Press Release, \u0022SEC Charges Total S.A. for Illegal Payments to Iranian Official,\u0022 May 29, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171575006","Documents":""},{"Case ID":"ST-523","Case Cluster ":"Tyco International Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"9\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosection Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$13,680,000 ","Criminal Fine\/Penalty (US$) ":"$13,680,000 ","Criminal Fine \/ Penalty (Explanation)":"which includes $2.1 million fine imposed on its subsidiary Tyco Valve and Controls Middle East","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records","Offenses - Settled":"Falsification of Books and Records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, in 2012, Tyco International Ltd, a company based in Switzerland that manufactures and sells products related to security, fire protection and energy agreed to pay a $13.68 million penalty for falsifying books and records in connection with payments by its subsidiaries to government officials in various countries in order to obtain and retain business. [ ]  \r\n \r\nTyco Valves \u0026 Controls Middle East Inc. (TVC ME) \u2013 an indirect, wholly owned subsidiary of Tyco that sold and marketed valves and other industrial equipment throughout the Middle East for the oil, gas, petrochemical, commercial construction, water treatment and desalination industries \u2013 pleaded guilty [on September 24, 2012] for conspiring to violate the anti\u00adbribery provisions of the FCPA. According to the criminal information to which TVC ME pleaded guilty, the company paid bribes to officials employed by Saudi Aramco, an oil and gas company controlled and managed by the government of the Kingdom of Saudi Arabia, in order to obtain contracts with Saudi Aramco.\u0022 (Source: US Department of Justice Press Release, \u0022Subsidiary of Tyco International Ltd. Pleads Guilty, Is Sentenced for Conspiracy to Violate Foreign Corrupt Practices Act,\u0022 September 24, 2012.)","Sources ":"US Department of Justice, In re: Tyco International Ltd., Non-Proseccution Agreement, September 20, 2012 and Press Release, \u0022Subsidiary of Tyco International Ltd. Pleads Guilty, Is Sentenced for Conspiracy to Violate Foreign Corrupt Practices Act,\u0022 September 24, 2012, at https:\/\/www.justice.gov\/criminal-fraud\/case\/re-tyco-international-ltd-2012.","Documents":""},{"Case ID":"ST-524","Case Cluster ":"Tyco International Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Turkey","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"9\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$13,131,509 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$10,564,992 ","Civil Prejudgment Interest (US$) ":"$2,566,517 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, in 2012 the agency \u0022charged Tyco International Ltd. with violating the Foreign Corrupt Practices Act (FCPA) when subsidiaries arranged illicit payments to foreign officials in more than a dozen countries.\r\n \r\n The SEC alleges that subsidiaries of the Swiss-based global manufacturer perpetuated schemes that typically involved payments of fake \u201ccommissions\u201d or the use of third-party agents to funnel money improperly to obtain lucrative contracts. Overall, Tyco reaped illicit benefits amounting to more than $10.5 million as a result of the paid to win business.\r\n \r\n Tyco, whose securities are publicly traded in the U.S., agreed to pay more than $26 million to settle the SEC\u2019s charges and resolve a criminal matter announced today by the U.S. Department of Justice. [ ] \r\n \r\n The SEC alleges that Tyco subsidiaries operated 12 different illicit payment schemes around the world starting before 2006 and continuing until 2009. The most profitable scheme occurred in Germany, where agents of a Tyco subsidiary paid third parties to secure contracts or avoid penalties or fines in several countries. These payments were falsely recorded as \u201ccommissions\u201d in Tyco\u2019s books and records when they were in fact bribes to pay off government customers. Tyco\u2019s benefit as a result of these illicit payments was more than $4.6 million.\r\n \r\n According to the SEC\u2019s complaint, Tyco\u2019s subsidiary in China signed a contract with the Chinese Ministry of Public Security for $770,000 but reportedly paid approximately $3,700 to the \u201csite project team\u201d of a state-owned corporation to be able to obtain the contract. This amount was improperly recorded as a commission. Tyco\u2019s subsidiary in France recorded payments to individuals from 2005 to 2009 for \u201cbusiness introduction services.\u201d However, one of the individuals receiving payments was a security officer at a government-owned mining company in Mauritania, and many of the earlier payments were deposited in the official\u2019s personal bank account in France. In Thailand, Tyco\u2019s subsidiary had a contract to install a CCTV system in the Thai Parliament House in 2006, and paid more than $50,000 to a Thai entity that acted as a consultant. The invoice for the payment refers to \u201crenovation work,\u201d but Tyco is unable to ascertain what, if any, work was actually done.\r\n \r\n The SEC alleges that another scheme occurred in Turkey, where Tyco\u2019s subsidiary retained a New York City-based sales agent who made illicit payments involving the sale of microwave equipment in September 2006 to an entity controlled by the Turkish government. Employees at Tyco\u2019s subsidiary were well aware that the agent was paying foreign government customers to obtain orders. One internal e-mail stated, \u201cHell, everyone knows you have to bribe somebody to do business in Turkey. Nevertheless, I\u2019ll play it dumb if [the sales agent] should call.\u201d The benefit obtained by Tyco as a result of the September 2006 deal was $44,513.\u0022 (Source: US Securities and Exchange Commission, Litigation Release No. 22491, \u0022SEC Charges TYCO with Making Illicit Payments to Foreign Officials,\u0022 September 24, 2012.)","Sources ":"Securities and Exchange Commission v. Tyco International Ltd, 1:12-cv-01583 (D.D.C.), Complaint filed Sept. 24, 2012), at\r\n https:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-196.pdf; US Securities and Exchange Commission, Litigation Release No. 22491 \/ September 24, 2012, \u0022SEC Charges TYCO with Making Illicit Payments to Foreign Officials,\u0022 at https:\/\/www.sec.gov\/litigation\/litreleases\/2012\/lr22491.htm","Documents":""},{"Case ID":"ST-525","Case Cluster ":"Tyco International Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"9\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"Tyco Valve and Controls Middle East was fined $2.1 million but this amount was included in its parent company\u0027s fine","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, in 2012, Tyco International Ltd, a company based in Switzerland that manufactures and sells products related to security, fire protection and energy agreed to pay a $13.68 million penalty for \u0022falsifying books and records in connection with payments by its subsidiaries to government officials in various countries in order to obtain and retain business. [ ]  \r\n \r\n Tyco Valves \u0026 Controls Middle East Inc. (TVC ME) \u2013 an indirect, wholly owned subsidiary of Tyco that sold and marketed valves and other industrial equipment throughout the Middle East for the oil, gas, petrochemical, commercial construction, water treatment and desalination industries \u2013 pleaded guilty [on September 24, 2012] for conspiring to violate the anti\u00adbribery provisions of the FCPA. According to the criminal information to which TVC ME pleaded guilty, the company paid bribes to officials employed by Saudi Aramco, an oil and gas company controlled and managed by the government of the Kingdom of Saudi Arabia, in order to obtain contracts with Saudi Aramco.\u0022 (Source: US Department of Justice Press Release, \u0022Subsidiary of Tyco International Ltd. Pleads Guilty, Is Sentenced for Conspiracy to Violate Foreign Corrupt Practices Act,\u0022 September 24, 2012.)","Sources ":"US Department of Justice, In re: Tyco International Ltd., Nonproseccution Agreement, September 20, 2012 and Press Release, \u0022Subsidiary of Tyco International Ltd. Pleads Guilty, Is Sentenced for Conspiracy to Violate Foreign Corrupt Practices Act,\u0022 September 24, 2012, at https:\/\/www.justice.gov\/criminal-fraud\/case\/re-tyco-international-ltd-2012; \r\n \r\nUS v. Tyco Valves and Controls Middle East, Case No. 1:12-cr-00418-(EDVA), Information, Plea Agreement and Judgment at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-tyco-valves-and-controls-middle-east-inc-court-docket-number-112,","Documents":""},{"Case ID":"ST-526","Case Cluster ":"VimpelCom Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Uzbekistan","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/18","Other Jurisdictions of Settlement":"Netherlands","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine; Criminal Forfeiture","Total Monetary Sanctions (US$)":"$230,326,398 ","Criminal Fine\/Penalty (US$) ":"$190,326,398.40 ","Criminal Fine \/ Penalty (Explanation)":"Please see case summary for explanation.","Criminal Forfeiture \/ Confiscation (US$)":"$40,000,000 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"No (License)","Summary":"According to the US Department of Justice, \u0022Amsterdam-based VimpelCom Limited, the world\u2019s sixth largest telecommunications company and an issuer of publicly traded securities in the United States, and its wholly owned Uzbek subsidiary, Unitel LLC, entered into resolutions with the Department of Justice today in which they admitted to a conspiracy to make more than $114 million in bribery payments to a government official in Uzbekistan between 2006 and 2012 to enable them to enter and continue operating in the Uzbek telecommunications market. [ ] According to the companies\u2019 admissions, VimpelCom and Unitel, through various executives and employees, paid bribes to an Uzbek government official, who was a close relative of a high ranking government official and had influence over the Uzbek governmental body that regulated the telecom industry. The companies structured and concealed the bribes through various payments to a shell company that certain VimpelCom and Unitel management knew was beneficially owned by the foreign official. The bribes were paid on multiple\r\n occasions between approximately 2006 and 2012 so that VimpelCom could enter the Uzbek market and Unitel could gain valuable telecom assets and continue operating in Uzbekistan. VimpelCom and Unitel contemplated additional bribes in 2013, but those bribes were not completed before VimpelCom opened an internal investigation.\r\n In addition, VimpelCom admitted that it falsified its books and records and attempted to conceal and disguise the bribery scheme by classifying payments as equity transactions, consulting and repudiation agreements and reseller transactions. VimpelCom also failed to implement and enforce adequate internal accounting controls, which allowed the bribe payments to occur without detection or remediation. Moreover, when the board of directors sought an FCPA legal opinion assessing corruption risks involved in the transactions, certain VimpelCom management withheld crucial information from outside counsel performing the review that restricted the scope of FCPA opinions, rendering them worthless. Rather than implement and enforce a strong anticorruption ethic, certain VimpelCom executives sought ways to give the company plausible deniability of illegality while knowingly proceeding with corrupt business transactions.\u0022 (Source: US Department of Justice Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million\u037e United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016.) According to the Deferred Prosecution Agreement, the company agrees to pay $460,326,398.40, $40,000 of which will be paid as forfeiture; the amount was to be offset by sanctions paid to The Prosecution Service of the Netherlands, up to $230,326,398.40. As to the forfeited funds, the company \u0022acknowledges that at least $40,000,000 was proceeds of transactions in violation of the anti-bribery provisions of the FCPA.\u0022 (VimpelCom Deferred Prosecution Agreement, paras 8 and 9.)","Sources ":"US v. VimpelCom and US v. Unitel, Case No. 16-cr-17 (SDNY), Information filed in both on February 18, 2016, Vimpelcom Deferred Prosecution Agreement and Statement of Facts filed February 22, 2016 and Unitel Plea Agreement filed February 22, 2016, at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/vimpelcom;\r\n US Department of Justice Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million\u037e United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/NCB_First%20Global%20Accts_Notice%20Verified%20Claim%20by%20Uzbekistan_01252016.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Vimpelcom_CivilAssetForfeiture%20Complaint_Feb2016.pdf"},{"Case ID":"ST-527","Case Cluster ":"VimpelCom Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Uzbekistan","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/18","Other Jurisdictions of Settlement":"Netherlands","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement","Total Monetary Sanctions (US$)":"$167,500,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$167,500,000 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, falsification of books and records; internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (License)","Summary":"According to the US Securities and Exchange Commission Complaint, \u0022VimpeiCom Ltd (\u0022VimpelCom\u0022) is a corporation organized under the laws of Bermuda. VimpelCom was headquartered in Moscow, Russia until 2010, when it moved its headquarters to Amsterdam, the Netherlands. VimpelCom issues and maintains a class of publicly traded securities registered pursuant to Section 12(b) ofthe Securities Exchange Act of 1934, which are now traded on the NASDAQ, and were traded on the New York Stock Exchange prior to September 2013.\u0022 (Source: US v. VimpelCom Ltd., Complaint filed in Southern District of New York, at http:\/\/www.sec.gov\/litigation\/complaints\/2016\/comp-pr2016-34.pdf.)\r\n \r\n According to the SEC press release announcing the settlement with Vimpelcom, \u0022The SEC alleges that VimpelCom offered and paid bribes to an Uzbek government official related to the President of Uzbekistan as the company entered the Uzbek telecommunications market and sought government-issued licenses, frequencies, channels, and number blocks. At least $114 million in bribe payments were funneled through an entity affiliated with the Uzbek official, and approximately a half-million dollars in bribes were disguised as charitable donations made to charities directly affiliated with the Uzbek official. [ ] \r\n \r\n \u0027VimpelCom made massive revenues in Uzbekistan by paying over $100 million to an official with significant influence over top leaders of the Uzbek government,\u0027 said Andrew J. Ceresney, Director of the SEC Enforcement Division. \u0027These old-fashioned bribes, hidden through sham contracts and charitable contributions, left the company\u2019s books and records riddled with inaccuracies.\u0027 [ ] \r\n  \r\n The SEC\u2019s complaint was filed in U.S. District Court for the Southern District of New York. VimpelCom consented to the entry of a court order ordering the company to pay disgorgement and retain an independent monitor, and permanently enjoining the company from future violations of Sections 30A, 13(b)(2)(A), and 13(b)(2)(B) of the Securities Exchange Act of 1934. [ ] \r\n \r\n The SEC appreciates the significant assistance of the Department of Justice\u2019s Criminal Division, Fraud and Asset Forfeiture Money Laundering Sections as well as the following agencies: Internal Revenue Service, Department of Homeland Security, Public Prosecution Service of the Netherlands (Openbaar Ministrie), National Authority for Investigation and Prosecution of Economic and Environmental Crime in Norway (\u00d8KOKRIM), Swedish Prosecution Authority, Office of the Attorney General in Switzerland, and Corruption Prevention and Combating Bureau in Latvia. Other valuable assistance was provided by the British Virgin Islands Financial Services Commission, Caymans Islands Monetary Authority, Bermuda Monetary Authority, and Central Bank of Ireland, Estonia Financial Supervisory Authority (Finantsinspektioon), Comisi\u00f3n Nacional del Mercado de Valores (Spain), Latvian Financial and Capital Market Commission, UAE Securities and Commodities Authority, Banking Commission of the Marshall Islands, and Gibraltar Financial Services Commission.\u0022 The company was ordered by the SEC to pay $375 million in disgorgement, with $167.5 million to be paid to the Dutch authorities and $40 million in settlement with the US Department of Justice. (Sources: Securities and Exchange Commission Press Release, \u0022VimpelCom to Pay $795 Million in Global Settlement for FCPA Violations,\u0022 February 18, 2016; US v. VimpleCom, Case No. 16-cv-2016 (SDNY), Final Judgment filed February 22, 2016.)","Sources ":"US Securities and Exchange Commission v. VimpelCom Ltd., Case No. 1:16-cv-1266 (SDNY), Complaint, at http:\/\/www.sec.gov\/litigation\/complaints\/2016\/comp-pr2016-34.pdf and FInal Judgment filed February 22, 2016, accessed at Pacer; Securities and Exchange Commission Press Release, \u0022VimpelCom to Pay $795 Million in Global Settlement for FCPA Violations,\u0022 February 18, 2016, at http:\/\/www.sec.gov\/news\/pressrelease\/2016-34.html","Documents":""},{"Case ID":"ST-528","Case Cluster ":"VimpelCom Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Uzbekistan","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/22","Other Jurisdictions of Settlement":"Netherlands","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"See related case, VimpelCom Limited","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"No (License)","Summary":"According to the US Department of Justice, \u0022Amsterdam-based VimpelCom Limited, the world\u2019s sixth-largest telecommunications company and an issuer of publicly traded securities in the United States, and its wholly owned Uzbek subsidiary, Unitel LLC, entered into resolutions with the Department of Justice today in which they admitted to a conspiracy to make more than $114 million in bribery payments to a government official in Uzbekistan between 2006 and 2012 to enable them to enter and continue operating in the Uzbek telecommunications market.\r\n[ ] VimpelCom and Unitel, through various executives and employees, paid bribes to an Uzbek government official, who was a close relative of a high-ranking government official and had influence over the Uzbek governmental body that regulated the telecom industry. The companies structured and concealed the bribes through various payments to a shell company that certain VimpelCom and Unitel management knew was beneficially owned by the foreign official. The bribes were paid on multiple occasions between approximately 2006 and 2012 so that VimpelCom could enter the Uzbek market and Unitel could gain valuable telecom assets and continue operating in Uzbekistan. VimpelCom and Unitel contemplated additional bribes in 2013, but those bribes were not completed before VimpelCom opened an internal investigation.\u0022 (Source: DOJ Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million; United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016.) According to the Unitel Plea Agreement, given the complexities of the overall disposition and the interrelationship between VimpelCom and Unitel and the monetary sanctions imposed on VimpelCom by the US and Dutch authorities, it was agreed that no financial penalties would be imposed on Unitel. (Source: US v. Unitel LLC, Case No. 16-cr-1737 (SDNY), Plea Agreement filed February 22, 2016, at 8.)","Sources ":"US v. Unitel LLC, Case No. 16-cr-1737 (SDNY), Information filed February 18, 2016 and Plea Agreement filed February 22, 2016, at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/vimpelcom;\r\n \r\nDOJ Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million; United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016, at https:\/\/www.justice.gov\/opa\/pr\/vimpelcom-limited-and-unitel-llc-enter-global-foreign-bribery-resolution-more-795-million","Documents":""},{"Case ID":"ST-529","Case Cluster ":"VimpelCom Limited","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Openbaar Ministrie (Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Uzbekistan","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/18","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Out of Court Settlement","Monetary Sanctions  (Types)":"Criminal Fine; Criminal Confiscation","Total Monetary Sanctions (US$)":"$397,500,000 ","Criminal Fine\/Penalty (US$) ":"$100,000,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$297,500,000 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, falsification of books and records; internal controls violations","Offenses - Settled":"Bribery of foreign officials, falsification of books and records; internal controls violations","Public Procurement Contract \/ SOE Involved?":"No (License)","Summary":"According to the Press Release issued by the Openbaar Ministrie (Public Prosecution Service, DPP), \u0022The criminal investigation was initiated in 2013. The Dutch criminal investigation was carried out by the FIOD under supervision of the National Prosecutor\u2019s Office for Serious Fraud, Environmental Crime and Asset Confiscation (\u201cFunctioneel Parket\u201d). During the investigation, Vimpelcom\u2019s head office in Amsterdam was searched in March 2014. Vimpelcom has initiated its own investigation into its activities in Uzbekistan. This investigation was conducted by internal investigators, by an American specialized law firm and by forensic accountants. Both the DPPS and the US authorities were regularly informed about the results of this internal investigation. [ ]\u0022 VipelCom was fined US$!00 million and subject to confiscation of illegally obtained proceeds totaling US$130 million; US$167.5 million was confiscated from its subsidiary Unitel. (Source: Openbaar Ministrie, Vimpelcom pays close to 400 million dollars to the Netherlands for bribery in Uzbekistan,\u0022 February 16, 2016. See also, Statement of Facts. Both at https:\/\/www.om.nl\/algemeen\/english\/@93227\/vimpelcom-pays-close\/) The US Department of Justice press release stated that \u0022Under the terms of its resolution with the SEC, VimpelCom agreed to a total of $375 million in disgorgement of profits and prejudgment interest, to be divided between the SEC and OM.\u0022 (Source: US DOJ Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million\u037e United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016.)","Sources ":"Openbaar Ministrie, Vimpelcom pays close to 400 million dollars to the Netherlands for bribery in Uzbekistan,\u0022 February 16, 2016. See also, Statement of Facts (link to downloadable PDF), at https:\/\/www.om.nl\/algemeen\/english\/@93227\/vimpelcom-pays-close\/; US DOJ Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million\u037e United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016","Documents":""},{"Case ID":"ST-530","Case Cluster ":"Weatherford International Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food); Unspecified Africa and Middle East countries","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"11\/26","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$87,178,256 ","Criminal Fine\/Penalty (US$) ":"$87,178,256 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations","Offenses - Settled":"Internal controls violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Weatherford Services Limited (Weatherford Services), a subsidiary of Weatherford International, today agreed to plead guilty to violating the anti-bribery provisions of the FCPA. As part of a coordinated FCPA resolution, the department today also filed a criminal information in U.S. District Court for the Southern District of Texas charging Weatherford International with one count of violating the internal controls provisions of the FCPA. To resolve the charge, Weatherford International has agreed to pay an $87.2 million criminal penalty as part of a deferred prosecution agreement with the department. [ ] \r\n  \r\n In a separate matter, Weatherford International and four of its subsidiaries today agreed to pay a combined $100 million to resolve a criminal and administrative export controls investigation conducted by the U.S. Attorney\u2019s Office for the Southern District of Texas, the Department of Commerce\u2019s Bureau of Industry and Security, and the Department of the Treasury\u2019s Office of Foreign Assets Control. As part of the resolution of that investigation, Weatherford International has agreed to enter into a deferred prosecution agreement for a term of two years and two of its subsidiaries have agreed to plead guilty to export controls charges. [ ] \r\n  \r\n The combined investigations resulted in the conviction of three Weatherford subsidiaries, the entry by Weatherford International into two deferred prosecution agreements and a civil settlement, and the payment of a total of $252,690,606 in penalties and fines. \r\n \r\n FCPA Violations\r\n \r\n According to court documents filed by the department, prior to 2008, Weatherford International knowingly failed to establish an effective system of internal accounting controls designed to detect and prevent corruption, including FCPA violations. The company failed to implement these internal controls despite operating in an industry with a substantial corruption risk profile and despite growing its global footprint in large part by purchasing existing companies, often themselves in countries with high corruption risks. As a result, a permissive and uncontrolled environment existed within which employees of certain of Weatherford International\u2019s wholly owned subsidiaries in Africa and the Middle East were able to engage in corrupt conduct over the course of many years, including both bribery of foreign officials and fraudulent misuse of the United Nations\u2019 Oil for Food Program.\r\n \r\n Court documents state that Weatherford Services employees established and operated a joint venture in Africa with two local entities controlled by foreign officials and their relatives from 2004 through at least 2008. The foreign officials selected the entities with which Weatherford Services would partner, and Weatherford Services and Weatherford International employees knew that the members of the local entities included foreign officials\u2019 relatives and associates. Notwithstanding the fact that the local entities did not contribute capital, expertise or labor to the joint venture, neither Weatherford Services nor Weatherford International investigated why the local entities were involved in the joint venture. The sole purpose of those local entities, in fact, was to serve as conduits through which Weatherford Services funneled hundreds of thousands of dollars in payments to the foreign officials controlling them. In exchange for the payments they received from Weatherford Services through the joint venture, the foreign officials awarded the joint venture lucrative contracts, gave Weatherford Services inside information about competitors\u2019 pricing, and took contracts away from Weatherford Services\u2019 competitors and awarded them to the joint venture.\r\n \r\n Additionally, Weatherford Services employees in Africa bribed a foreign official so that he would approve the renewal of an oil services contract, according to court documents. Weatherford Services funneled bribery payments to the foreign official through a freight forwarding agent it retained via a consultancy agreement in July 2006. Weatherford Services generated sham purchase orders for consulting services the freight forwarding agent never performed, and the freight forwarding agent, in turn, generated sham invoices for those same nonexistent services. When paid for those invoices, the freight forwarding agent passed at least some of those monies on to the foreign official with the authority to approve Weatherford Services\u2019 contract renewal. In exchange for these payments, the foreign official awarded the renewal contract to Weatherford Services in 2006.\r\n \r\n Further, according to court documents, in a third scheme in the Middle East, from 2005 through 2011, employees of Weatherford Oil Tools Middle East Limited (WOTME), another Weatherford International subsidiary, awarded improper \u201cvolume discounts\u201d to a distributor who supplied Weatherford International products to a government-owned national oil company, believing that those discounts were being used to create a slush fund with which to make bribe payments to decision-makers at the national oil company. Between 2005 and 2011, WOTME paid approximately $15 million in volume discounts to the distributor.\u0022(Source: US DOJ Press Release, \u0022Three Subsidiaries of Weatherford International Limited Agree to Plead Guilty to FCPA and Export Control Violations,\u0022 November 26, 2013.)","Sources ":"US v. Weatherford International Limited, Case No. 13-cr-733 (S.D. Tex), Information and Deferrred Prosecution Agreement filed November 26, 2013 and DOJ Press Release, \u0022Three Subsidiaries of Weatherford International Limited Agree to Plead Guilty to FCPA and Export Control Violations,\u0022 November 26, 2013, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-weatherford-international-ltd-court-docket-number-13-cr-733","Documents":""},{"Case ID":"ST-531","Case Cluster ":"Weatherford International Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Congo (Republic of), Iraq (UN Oil-for-Food), Angola, Algeria, Albania","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"11\/26","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$65,612,360.34 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$59,337,937 ","Civil Prejudgment Interest (US$) ":"$4,399,423.34 ","Civil Fine \/ Penalty (US$)":"1,875,000","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, falsification of books and records; internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes; No (Tax)","Summary":"According to the US Securities and Exchange Commission, Weatherford International, an oil services company\u0027s \u0022misconduct occurred from at least 2002 to 2011. In Angola, for example, Weatherford\u2019s legal department permitted its subsidiary to use an agent who insisted that an FCPA clause be omitted from the consultancy agreement. The company took no steps to determine whether the agent was paying bribes to foreign officials, and the agent used sham work orders and invoices to pay bribes that ensured the renewal of a lucrative oil services contract for Weatherford in Angola. The same agent made illicit payments to obtain commercial contracts for Weatherford in Congo. The company also allowed its subsidiary to enter into a joint venture agreement with companies whose beneficial owners included Angolan oil company officials and a relative of an Angolan Minister in order to win business. A Weatherford employee reported in a 2006 ethics questionnaire that Weatherford personnel were making payments to government officials in Angola and elsewhere, but the company failed to investigate. \r\n \r\n The SEC\u2019s complaint also alleges that Weatherford failed to perform due diligence on a distributor suggested by an official at a national oil company in the Middle East. From 2005 to 2011, Weatherford and its subsidiaries awarded more than $11.8 million in improper \u201cvolume discounts\u201d to the distributor \u2013 money intended for the creation of a slush fund to pay foreign officials. \r\n \r\n According to the SEC\u2019s complaint, the misconduct went beyond the use of agents or other third parties. Weatherford provided improper travel and entertainment to officials of a state-owned company in Algeria with no legitimate business purpose. For example, Weatherford paid for a 2006 FIFA World Cup trip by two of the officials, the July 2006 honeymoon of an official\u2019s daughter, and an October 2005 religious trip to Saudi Arabia by an official and his family that was improperly recorded as a donation in Weatherford\u2019s books and records. Weatherford\u2019s Middle East subsidiary also made more than $1.4 million in improper payments to obtain nine contracts under the Oil-for-Food program in 2002. Iraqi ministries demanded improper \u201cinland transportation fees\u201d in an effort to subvert the UN program. Weatherford\u2019s subsidiary complied with the Iraqi demands and paid more than $115,000 in fees despite invoices that included charges inconsistent with the actual deliveries. Weatherford obtained more than $7 million in profits from the misconduct.\r\n \r\n The SEC further alleges that managers at Weatherford\u2019s subsidiary in Italy flouted the lack of internal controls and misappropriated more than $200,000 in company funds, some of which was improperly paid to Albanian tax auditors. The managers misreported cash advances, diverted payments on previously paid invoices, misappropriated government rebate checks, and received reimbursement for such purchases as golf equipment and perfume that did not relate to business activities. \r\n \r\n According to the SEC\u2019s complaint, Weatherford employees created false accounting and inventory records from 2002 to 2007 to hide the illegal commercial sales to Cuba, Syria, Sudan, and Iran. During this time period, exporting or re-exporting goods or services from the U.S. to these sanctioned countries was prohibited. The falsified financial statements and books and records of Weatherford subsidiaries involved in the misconduct were consolidated into the financial statements of the parent company.\u0022 (Source: SEC Press Release, \u0022SEC Charges Weatherford International With FCPA Violations,\u0022 November 26, 2013.)\r\n \r\n According to the Judgment in the case, the company \u0022is liable for disgorgement of $90,984,844 representing profits gained as a result of the conduct alleged in the Complaint, together with prejUdgment interest thereon in the amount of $4,399,423.34 for a total of $95,384,267.34 (\u0022disgorgement obligation\u0022). A portion of the Defendant\u0027s disgorgement obligation in the amount of $31,646,907 shall be deemed satisfied by Defendant\u0027s entry into a written Deferred Prosecution Agreement (\u0022DPA\u0022) with the U.S.\r\n Attorney\u0027s Office for the Southern District of Texas, wherein Defendant agrees to make a payment in an amount greater than or equal to $31,646,907 within one year of the entry of the Final Judgment. In the event that Defendant\u0027s DP A requires a payment less than $31,646,907, the Defendant acknowledges that its disgorgement obligation will be credited up to the amount of the payment required by the DP A, with the remaining balance due and payable to the SEC within 14 days of payment pursuant to the DP A in the parallel criminal proceeding. Defendant is also liable for a civil penalty in the amount of$I,875,000 pursuant to Section 21(d)(3) of the Exchange Act [15 U.S.c. \u00a7 78u(d)(3)]. Defendant shall satisfy this obligation by paying $1,875,000 within 14 days after entry of this Final Judgment.\u0022 (US SEC v. Weatherford International Ltd., Case No. 13-cv-3500, Judgment filed December 19, 2013.)","Sources ":"US Securities and Exchange Commission v. Weatherford International Ltd., Case No. 13-cv-3500 (S.D. Tex.), Complaint filed November 26, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-252.pdf; Judgment accessed via Pacer; SEC Press Release, \u0022SEC Charges Weatherford International With FCPA Violations,\u0022 November 26, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370540415694","Documents":""},{"Case ID":"ST-532","Case Cluster ":"Weatherford International Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Angola","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"11\/26","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$420,000.00 ","Criminal Fine\/Penalty (US$) ":"$420,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0","Criminal Restitution \/ Reparation (US$)":" $0","Criminal Legal \/ Procedural Costs (US$)":"$0","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Weatherford Services Limited (Weatherford Services), a subsidiary of Weatherford International, today agreed to plead guilty to violating the anti-bribery provisions of the FCPA. [ ] Court documents state that Weatherford Services employees established and operated a joint venture in Africa with two local entities controlled by foreign officials and their relatives from 2004 through at least 2008. The foreign officials selected the entities with which Weatherford Services would partner, and Weatherford Services and Weatherford International employees knew that the members of the local entities included foreign officials\u2019 relatives and associates. Notwithstanding the fact that the local entities did not contribute capital, expertise or labor to the joint venture, neither Weatherford Services nor Weatherford International investigated why the local entities were involved in the joint venture. The sole purpose of those local entities, in fact, was to serve as conduits through which Weatherford Services funneled hundreds of thousands of dollars in payments to the foreign officials controlling them. In exchange for the payments they received from Weatherford Services through the joint venture, the foreign officials awarded the joint venture lucrative contracts, gave Weatherford Services inside information about competitors\u2019 pricing, and took contracts away from Weatherford Services\u2019 competitors and awarded them to the joint venture.\r\n \r\n Additionally, Weatherford Services employees in Africa bribed a foreign official so that he would approve the renewal of an oil services contract, according to court documents. Weatherford Services funneled bribery payments to the foreign official through a freight forwarding agent it retained via a consultancy agreement in July 2006. Weatherford Services generated sham purchase orders for consulting services the freight forwarding agent never performed, and the freight forwarding agent, in turn, generated sham invoices for those same nonexistent services. When paid for those invoices, the freight forwarding agent passed at least some of those monies on to the foreign official with the authority to approve Weatherford Services\u2019 contract renewal. In exchange for these payments, the foreign official awarded the renewal contract to Weatherford Services in 2006.\u0022 (Source: US DOJ Press Release, \u0022Three Subsidiaries of Weatherford International Limited Agree to Plead Guilty to FCPA and Export Control Violations,\u0022 November 26, 2013.) The Information and Plea Agreement filed in US v. Weatherford Services Limited identifies the African country as Angola. (Source: US v. Weatherford Services Limited, Case No. 13-cr-734 (S.D. Tex), Information and Plea Agreement filed November 26, 2013.)","Sources ":"US v. Weatherford Services Limited, Case No. 13-cr-734 (S.D. Tex), Information and Plea Agreement filed November 26, 2013 and DOJ Press Release, \u0022Three Subsidiaries of Weatherford International Limited Agree to Plead Guilty to FCPA and Export Control Violations,\u0022 November 26, 2013, at https:\/\/www.justice.gov\/opa\/pr\/three-subsidiaries-weatherford-international-limited-agree-plead-guilty-fcpa-and-export.","Documents":""},{"Case ID":"ST-533","Case Cluster ":"Yara International ASA","Jurisdiction of Settlement":"Nigeria, Norway","Jurisdiction of Settlement \/ Enforcement Agency":"OKOKRIM","Jurisdiction of Foreign Public Official(s) ":"India, Libya","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"1\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Penalty Notice","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$44,182,500 ","Criminal Fine\/Penalty (US$) ":"$44,182,500 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.17","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign public officials","Offenses - Settled":"Bribery of Foreign Public Officials","Public Procurement Contract \/ SOE Involved?":"Not specified","Summary":"According to the press release by Yara International, \u0022The Board of Yara International ASA has informed the Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime (\u00d8kokrim) that the company acknowledges guilt and accepts a corporate fine and confiscation totalling NOK 295 million. This relates to agreements dating back to 2007 and earlier.\r\n In April 2011 Yara International ASA launched an external investigation and concurrently notified \u00d8kokrim of possible irregularities. The main findings of the external investigation were published in June 2012. [ ] The fine of NOK 270 million is related to historical irregularities linked to the establishment of Lifeco (Libya), an unrealized project in India and Yara\u0027s activities in Switzerland. In addition \u00d8kokrim has imposed a confiscation of NOK 25 million related to earlier phosphate deliveries.\u0022 (Source: YARA International ASA Media Release, \u0022Yara accepts corporate penalty,\u0022 January 15, 2014.)","Sources ":"http:\/\/www.okokrim.no\/wwww-9fdaqu;\r\n \r\n YARA International ASA Media Release, \u0022Yara accepts corporate penalty,\u0022 January 15, 2014, at http:\/\/yara.com\/media\/press_releases\/1754700\/press_release\/201401\/yara-accepts-corporate-penalty\/; \r\n \r\n See also, The Nordic Page, \u0022The Biggest Corruption Trial in Norway Continues,\u0022 January 6, 2015, at http:\/\/www.tnp.no\/norway\/economy\/4769-biggest-corruption-trial-in-norway-continues-india-libya-yara-bribe;","Documents":""},{"Case ID":"ST-397","Case Cluster ":"Alcoa \/ Aluminum Bahrain (ALBA)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Bahrain","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"1\/9","Other Jurisdictions of Settlement":"United Kingdom (Bruce Hall only)","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$223,000,000 ","Criminal Fine\/Penalty (US$) ":"$209,000,000 ","Criminal Fine \/ Penalty (Explanation)":"Owing to \u0022undue burden\u0022 to the company, fine to be paid in five annual installments of $41,800,000; forfeiture to IRS","Criminal Forfeiture \/ Confiscation (US$)":"$14,000,000 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice press release announcing the plea agreement, \u0022Alcoa World Alumina has agreed to plead guilty in the Western District of Pennsylvania to one count of violating the antibribery provisions of the FCPA in connection with a 2004 corrupt transaction, to pay a criminal fine of $209 million, and to administratively forfeit $14 million. [ ] As admitted in the charging documents, in 2004, Alcoa World Alumina corruptly secured a long-term alumina supply agreement with Alba by agreeing to purportedly sell over 1.5 million metric tons of alumina to Alba [Aluminium Bahrain B.S.C.] through offshore shell companies owned by Consultant A. The sham distributorship permitted Consultant A to mark up the price of alumina by approximately $188 million from 2005 to 2009, the duration of the corrupt supply agreement. Court filings allege that Consultant A used the markup to pay tens of millions in corrupt kickbacks to Bahraini government officials, including senior members of Bahrain\u2019s Royal Family. To conceal the illicit payments, Consultant A and the government officials used various offshore bank accounts, including accounts held under aliases, at several major financial institutions around the world, including in Guernsey, Luxembourg, Liechtenstein and Switzerland.\u0022 (Source: US Department of Justice Press Release, \u0022Alcoa World Alumina Agrees to Plead Guilty to Foreign Bribery and Pay $223 Million in Fines and Forfeiture,\u0022 January 9, 2014.)","Sources ":"US v. Alcoa World Alumina LLC, Case No. 4-cr-7 (WDPA), Information, Plea Agreement and Judgment filed on January 9, 2014 and\r\n US Department of Justice Press Release, \u0022Alcoa World Alumina Agrees to Plead Guilty to Foreign Bribery and Pay $223 Million in Fines and Forfeiture,\u0022 January 9, 2014, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-alcoa-world-alumina-llc-court-docket-number-14-cr-00007-dwa","Documents":""},{"Case ID":"ST-398","Case Cluster ":"Alcoa \/ Aluminum Bahrain (ALBA)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Bahrain","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"1\/9","Other Jurisdictions of Settlement":"United Kingdom (Bruce Hall only)","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement","Total Monetary Sanctions (US$)":"$161,000,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$161,000,000 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Falsification of books and records; Internal controls violations,","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Press Release announcing the Cease and Desist Order issued against Alcoa Inc., \u0022An SEC investigation found that more than $110 million in corrupt payments were made to Bahraini officials with influence over contract negotiations between Alcoa and a major government-operated aluminum plant. Alcoa\u2019s subsidiaries used a London-based consultant with connections to Bahrain\u2019s royal family as an intermediary to negotiate with government officials and funnel the illicit payments to retain Alcoa\u2019s business as a supplier to the plant. Alcoa lacked sufficient internal controls to prevent and detect the bribes, which were improperly recorded in Alcoa\u2019s books and records as legitimate commissions or sales to a distributor. [ ] Alcoa will pay $175 million in disgorgement of ill-gotten gains, of which $14 million will be satisfied by the company\u2019s payment of forfeiture in the parallel criminal matter. Alcoa also will pay a criminal fine of $209 million.\u0022 (Source: US Securities and Exchange Press Release, \u0022SEC Charges Alcoa With FCPA Violations,\u0022 January 9, 2014.) Please note that the $14 million was administratively forfeited to the Internal Revenue Service; the disgorgement was to be paid in five annual installments. (Source: US Securities and Exchange Commission, In the Matter of Alcoa Inc. Cease and Desist Order, Administrative Proceeding File No. 3-15673, January 9, 2014)","Sources ":"US Securities and Exchange Cease and Desist Order in the Matter of Alcoa Inc. Administrative Proceeding File No. 3-15673, January 9, 2014 at http:\/\/www.sec.gov\/litigation\/admin\/2014\/34-71261.pdf; SEC Press Release, \u0022SEC Charges Alcoa With FCPA Violations,\u0022 January 9, 2014, at http:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370540596936","Documents":""},{"Case ID":"ST-399","Case Cluster ":"Alcoa \/ Aluminum Bahrain (ALBA)","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Bahrain","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"7\/22","Other Jurisdictions of Settlement":"United States (Alcoa only)","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Confiscation, criminal restitution, logal costs","Total Monetary Sanctions (US$)":"$7,168,324 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$6,143,560 ","Criminal Restitution \/ Reparation (US$)":"$853,970 ","Criminal Legal \/ Procedural Costs (US$)":"$170,794 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to corrupt; Corruption; Acquire and transfer criminal property","Offenses - Settled":"Conspiracy to corrupt","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office, \u0022Bruce Hall was today sentenced to 16 months in prison for conspiracy to corrupt, in relation to contracts\r\n Bruce Hall was today sentenced to 16 months in prison for conspiracy to corrupt, in relation to contracts for the supply of goods and services to a Bahraini company, Aluminium Bahrain B.S.C. (Alba). Mr Hall served as CEO of Alba, from September 2001 to June 2005.\r\n \r\n Judge Loraine Smith, who presided over the hearing, heard how Mr Hall received \u00a32.9 million in corrupt\r\n payments between 2002 and 2005, including 10,000 Bahraini dinars in cash from Sheikh Isa bin Ali Al\r\n Khalifa, a member of the Bahraini royal family and at the time Bahrain\u2019s minister of finance and Alba\u2019s\r\n chairman. The payments were made in exchange for Mr Hall agreeing to and allowing corrupt arrangements that Sheikh Isa had been involved in before Mr Hall\u2019s appointment as CEO to continue.\r\n As a result of these corrupt payments, Mr Hall will need to pay a confiscation order of \u00a33,070,106.03 in\r\n seven days or face serving an additional term of imprisonment of 10 years. Mr Hall must, in addition to\r\n the confiscation order, pay Alba compensation in the amount of \u00a3500,010 and pay \u00a3100,000 as a\r\n contribution to prosecution costs.\r\n [ ] As part of Mr Hall\u2019s mitigation he also agreed to divest himself of other corrupt payments he received\r\n during his time as the CEO of Alba. These payments were not part of the indictment as the SFO did not\r\n have the jurisdiction to prosecute for the conduct acknowledged by Mr Hall. In order to recover these\r\n payments received by Mr Hall, which amount to US$900,000, the Director of the SFO elected to launch\r\n proceedings under Part 5 of the Proceeds of Crime Act 2002 in the High Court. These proceedings were\r\n finalised at the High Court on 17 July 2014 but could not be made public until the start of the Mr Hall\u2019s\r\n sentencing hearing yesterday.\u0022 (Source: UK Serious Fraud Office Press Office, \u0022Bruce Hall sentenced to 16 months in prison,\u0022 July 22, 2014.)","Sources ":"UK Serious Fraud Office Press Office, \u0022Bruce Hall sentenced to 16 months in prison,\u0022 July 22, 2014, at https:\/\/www.sfo.gov.uk\/2014\/07\/22\/bruce-hall-sentenced-16-months-prison\/;\r\n \r\n See also, US Securities and Exchange Cease and Desist Order in the Matter of Alcoa Inc. Administrative Proceeding File No. 3-15673, January 9, 2014 at http:\/\/www.sec.gov\/litigation\/admin\/2014\/34-71261.pdf; SEC Press Release, \u0022SEC Charges Alcoa With FCPA Violations,\u0022 January 9, 2014, at http:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370540596936","Documents":""},{"Case ID":"ST-400","Case Cluster ":"Allianz SE","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"12\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profit, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$12,396,423 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$5,315,649 ","Civil Prejudgment Interest (US$) ":"$1,765,125 ","Civil Fine \/ Penalty (US$)":"$5,315,649 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records; Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Press Release announcing the Cease and Desist Order, \u0022These proceedings arise out of violations of the books and records and internal controls provisions of the Foreign Corrupt Practices Act (\u201cFCPA\u201d) by Allianz SE (\u201cAllianz\u201d or the \u201cCompany\u201d), through its Indonesian majority-owned subsidiary, PT Asuransi Allianz Utama (\u201cUtama\u201d). Between 2001 and 2008, Utama managers made improper payments to employees of state-owned entities in Indonesia in order to obtain and retain business. Allianz learned of the improper payments from two complaints made several years apart. The first complaint was submitted in 2005 alleging significant misconduct, including unsupported payments to agents. A subsequent audit of Utama\u2019s accounting records uncovered that managers at Utama were using \u201cspecial purpose accounts\u201d to make illicit payments, many to government officials, in order to secure business in Indonesia. Despite the audit, the conduct continued. The second complaint was lodged in 2009 to Allianz\u2019s external auditors and alleged that Allianz created illicit off-the-books accounts. In response, Allianz began an internal investigation. The Commission staff opened an investigation in April 2010 after receiving an anonymous complaint of possible FCPA violations. The investigation determined that from at least 2001 through December 2008, the Utama managers, with the assistance of others in the Indonesian office, made payments to employees of state-owned entities in Indonesia to procure or retain insurance contracts related to large government projects in Indonesia. As a result of improper payments of approximately $650,626 to agents and employees of state-owned entities and others, Allianz realized $5,315,649 in profits.\u0022 The SEC\u2019s order found that Allianz violated the books and records and internal controls provisions of the FCPA, specifically Sections 13(b)(2)(A) and 13(b)(2)(B) of the Securities Exchange Act of 1934. Without admitting or denying the findings, Allianz agreed to cease and desist from further violations and pay disgorgement of $5,315,649, prejudgment interest of $1,765,125, and a penalty of $5,315,649 for a total of $12,396,423. (Source: US Securities and Exchange Commission, In the Matter of Allianz SE, Inc. Cease and Desist Order, Administrative Proceeding File No. 3-15132, December 17, 2012.)","Sources ":"US Securities and Exchange Commission, In the Matter of Allianz SE, Inc. Cease and Desist Order, Administrative Proceeding File No. 3-15132, December 17, 2012, at http:\/\/www.sec.gov\/litigation\/admin\/2012\/34-68448.pdf; SEC Press Release, \u0022SEC Charges Germany-Based Allianz SE with FCPA Violations,\u0022 at http:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171486902","Documents":""},{"Case ID":"ST-401","Case Cluster ":"Alstom","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Egypt","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"11\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"Criminal Fine to be paid by Alstom S.A. (parent company)","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Alstom S.A., a French power and transportation company, was sentenced in November 2015 to pay a $772,290,000 fine to resolve criminal charges related to a widespread corruption scheme involving at least $75 million in secret bribes paid to government officials in countries around the world. According to the Department of Justice, Alstom and its subsidiaries - Alstom Prom, Alstom Power and Alstom T\u0026D - \u0022through various executives and employees, paid bribes to government officials and falsified books and records in connection with power, grid and transportation projects for state-owned entities around the world, including in Indonesia, Egypt, Saudi Arabia, the Bahamas and Taiwan. In Indonesia, for example, Alstom, Alstom Prom and Alstom Power paid bribes to government officials\u2014including a high-ranking member of the Indonesian Parliament and high-ranking members of Perusahaan Listrik Negara, the state-owned electricity company in Indonesia\u2014in exchange for assistance in securing several contracts to provide power related services valued at approximately $375 million. In total, Alstom paid more than $75 million to secure more than $4 billion in projects around the world, with a profit to the company of approximately $300 million.\r\n \r\n Alstom and its subsidiaries also attempted to conceal the bribery scheme by retaining consultants who purportedly provided consulting services on behalf of the companies, but who actually served as conduits for corrupt payments to the government officials. Internal Alstom documents refer to some of the consultants in code, including \u201cMr. Geneva,\u201d \u201cMr. Paris,\u201d \u201cLondon,\u201d \u201cQuiet Man\u201d and \u201cOld Friend.\u201d\r\n \r\n The sentence, which is the largest criminal fine ever imposed in an FCPA case, reflects a number of factors, including: Alstom\u2019s failure to voluntarily disclose the misconduct, even though it was aware of related misconduct at a U.S. subsidiary that previously resolved corruption charges with the department in connection with a power project in Italy\u037e Alstom\u2019s refusal to fully cooperate with the department\u2019s investigation for several years\u037e the breadth of the companies\u2019 misconduct, which spanned many years, occurred in countries around the globe and in several business lines, and involved sophisticated schemes to bribe high-level government officials\u037e Alstom\u2019s lack of an effective compliance and ethics program at the time of the conduct\u037e and Alstom\u2019s prior criminal misconduct, including conduct that led to resolutions with various other governments and the World Bank.\u0022 (Source: US Department of Justice Press Release, \u0022Alstom Sentenced to Pay $772 Million Criminal Fine to Resolve Foreign Bribery Charges,\u0022 November 1, 2015.)","Sources ":"US v. Alstom S.A., Case No. 14-cr-246 (D. Conn), Information and Plea Agreement filed December 22, 2014; US Department of Justice Press Release, \u0022Alstom Sentenced to Pay $772 Million Criminal Fine to Resolve Foreign Bribery Charges,\u0022 November 1, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-alstom-sa-et-al-court-docket-number-314-cr-00245-jba-314-cr","Documents":""},{"Case ID":"ST-402","Case Cluster ":"Alstom","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Bahamas; Egypt; Indonesia; Saudi Arabia","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"11\/13","Other Jurisdictions of Settlement":"Unknown (Bahamas: Criminal conviction following trial)","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Crimimal Fine","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"Criminal Fine to be paid by Alstom S.A. (parent company)","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Alstom S.A., a French power and transportation company, was sentenced in November 2015 to pay a $772,290,000 fine to resolve criminal charges related to a widespread corruption scheme involving at least $75 million in secret bribes paid to government officials in countries around the world.\r\n \r\nAccording to the Department of Justice, Alstom and its subsidiaries - Alstom Prom, Alstom Power and Alstom T\u0026D - \u0022through various executives and employees, paid bribes to government officials and falsified books and records in connection with power, grid and transportation projects for state-owned entities around the world, including in Indonesia, Egypt, Saudi Arabia, the Bahamas and Taiwan. In Indonesia, for example, Alstom, Alstom Prom and Alstom Power paid bribes to government officials\u2014including a high-ranking member of the Indonesian Parliament and high-ranking\r\n members of Perusahaan Listrik Negara, the stat-eowned electricity company in Indonesia\u2014in exchange for assistance in securing several contracts to provide power related services valued at approximately $375 million. In total, Alstom paid more than $75 million to secure more than $4 billion in\r\n projects around the world, with a profit to the company of approximately $300 million.\r\n \r\n Alstom and its subsidiaries also attempted to conceal the bribery scheme by retaining consultants who purportedly provided consulting services on behalf of the companies, but who actually served as conduits for corrupt payments to the government officials. Internal Alstom documents refer to some of the consultants in code, including \u201cMr. Geneva,\u201d \u201cMr. Paris,\u201d \u201cLondon,\u201d \u201cQuiet Man\u201d and \u201cOld Friend.\u201d\r\n \r\n The sentence, which is the largest criminal fine ever imposed in an FCPA case, reflects a number of factors, including: Alstom\u2019s failure to voluntarily disclose the misconduct, even though it was aware of related misconduct at a U.S. subsidiary that previously resolved corruption charges with the department in connection with a power project in Italy\u037e Alstom\u2019s refusal to fully cooperate with the department\u2019s investigation for several years\u037e the breadth of the companies\u2019 misconduct, which spanned many years, occurred in countries around the globe and in several business lines, and involved sophisticated schemes to bribe high-level government officials\u037e Alstom\u2019s lack of an effective compliance and ethics program at the time of the conduct\u037e and Alstom\u2019s prior criminal misconduct, including conduct that led to resolutions with various other governments and the World Bank.\u0022 (Source: US Department of Justice Press Release, \u0022Alstom Sentenced to Pay $772 Million Criminal Fine to Resolve Foreign Bribery Charges,\u0022 November 1, 2015.)\r\n \r\n According to secondary sources, in May 2016, a former board member of the Bahamas Electricity Company was convicted following trial of accepting bribes. (Source: Lamech Johnson, \u0022Update: Ramsey convicted of multiple charges in Bec bribe,\u0022 May 4, 2016, at http:\/\/www.tribune242.com\/news\/2016\/may\/04\/ramsey-guilty-most-charges-bec-bribe-case\/)","Sources ":"US v. Alstom S.A., Case No. 14-cr-246 (D. Conn), Information and Plea Agreement filed December 22, 2014; US Department of Justice Press Release, \u0022Alstom Sentenced to Pay $772 Million Criminal Fine to Resolve Foreign Bribery Charges,\u0022 November 1, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-alstom-sa-et-al-court-docket-number-314-cr-00245-jba-314-cr; See also, Office of the Attorney-General Statement in Response to Nassau Guardian Editorial, Thursday 28 May 2015, at http:\/\/www.bahamas.gov.bs\/wps\/portal\/public\/Agency%20News%20and%20Press%20Release\/Office%20of%20the%20Attorney-General%20Statement%20in%20Response%20to%20Nassau%20Guardian%20Editorial%20Thursday%2028%20May%202015\/!ut\/p\/b1\/vZfZsqJIEIafpR_AtqCKorhkF9lXkRtCRFERBBcQnn50ejqmz_TMcS66rboi4s_4Kv_KTGCaTONpUq-6fbG67k_16vh8TnAKVdt0RURMghEHNCqwNEl2oArZh2D5EID_WDz4Fg9Uk-cf8SoDMNBCx-AddkbbOj1dTOPZkhWyi9bLspcmPmEW9VLko8mhvYB5azUbpGhXEjR3YdNpmA10yOV9tassWB2AFxF1rO0NZ5TDjnMyDnRlMO_PMjpVzU3H3WHOpSJs0mrAZbxbonCX8pfChjt73vPbXNTCdp1qE4kPPJdB2q25H6roGAWgn2epmJi5dRB5LfbtTHMb_jBTZFmZFHEgoqLHF0NwgTJJ2sWcZ-KV2K9nldFGzbY2EVv6pqGNoys3JL1eM5m9ceTEkqphE8al49UYBSE9NrezGQUdZ8FJ7kwKZVme_vL0E9M-85RiXsQj8PFOQRQKQJuZukREAsGMfRH_AHzg23TwrAmRwnrIAB3hf8b_LPhfNfWf8ehV_GKafGrR04E_BZ-V7avCTT53Ab0S4O8C1Uam_BQwRHnmwRgO5igigKk1O1Wb6fIhY384SRCBhwzwnk-5gFjUNJjGAKX-YWi0sRy9A7jbZknApdyPlBRCU5I8KyxpK1cs_2BDSqZ0yzBBwLr9ZfRsK8-cPPJCgZcUXWaVfwI_HtwH6HcDVcYmD6_ZwOEZGqg29W4gfKulqmOD357hh6JB7q-_w_k02WfV135dfQVfCYcphiWIIxggRNhpdFhiTnrOeM3aNuFV3Rw2YxTu-0LYFbpCudUOlWGHw1kJWa70jnh9KMc0KR40Z_RGyBdxVatdcKNOyhwKNHUi4rJvpV5WB0Zc-K4QkpLenqKmSBYnNcapwkzsUAzyWdnmQh7CUA-hcsuybN2Z1bnJTklz0MSUhRqlcV44nOCyLC5ZrjgZonWzLKG7Wx8xA-_nXrrmhXTJVTzReMQO_JcvnzeJjtifDB49zQo8K5DmBhgjJwiM2AqPhp_7lPkwnAoBHUhh7wc6fTUE078G3w1mi2XqvuhKg3kvUNfxu4HwzUARvBtIvxv47qLx0bsz_PV9-GHQsYhDDI1ZmgBIQZp7Djpwfw46SY4cxMxW5v3CCsMuL-e3aq5o_gKXO3ZDz_WC5bk5OyHCxJ7wu2pThOKqBdZ6jaWyHwBDubSm0wMvUpdMy7EmbpWtpK6Da2l5mL_g1IY8ie1F3cNtISuDx6ar0U2ze0NYT41WTY8htPXgfBxgLfjXWpwnXrgeuQ7c8smEakSrfz3IqH8z0DLP2uMtwEOqpAwfwIebihN8M5AGQWRacjM3QTGYckFZlvPdwHXtg82rQfZmoD7D7wbC3w7UafgAGtCwiEjROng3kP7lwA9dhwDEiBAW0xRNEwQe3xddyAnBxexlZ9Tj-n7JEtHVK-QVx_tp37czwHer-7xTy8rKYAmDVHh0hyDXwcFk23ttYTlJpb3RhN7xyNTHzQ0m6xwqIXMwcG-25UwHg1JER3_lmQqyXHlGk3LZnbymvqa3-IzDPL7vYrNw2_OqituNyMYb5xo-fkVz_nBbqYGw3JidLPHbYacMPgdhZ5-MZdH38jEsLub61jYlnzjZEAu1a_G7jb6PTDMQeS-_7E2Zc4Pkdul7w6Lum1ZnFvbSPF7XaIYkergtb_2WuxJ5vCa9OrRRvD_WrsLcVyzbymq4XdyRO5yV8XSimQlcLbItdz6OOI0sYOm-Qb5Mmyrs9McysCd7s54if29YdT9t8qPgOUf-ADdQn-4!\/dl4\/d5\/L2dBISEvZ0FBIS9nQSEh\/; Lamech Johnson, \u0022Update: Ramsey convicted of multiple charges in Bec bribe,\u0022 May 4, 2016, at http:\/\/www.tribune242.com\/news\/2016\/may\/04\/ramsey-guilty-most-charges-bec-bribe-case\/","Documents":""},{"Case ID":"ST-403","Case Cluster ":"Alstom","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Egypt, Indonesia, Saudi Arabia","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"11\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"Criminal Fine to be paid by Alstom S.A. (parent company)","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Alstom S.A., a French power and transportation company, was sentenced in November 2015 to pay a $772,290,000 fine to resolve criminal charges related to a widespread corruption scheme involving at least $75 million in secret bribes paid to government officials in countries around the world.\r\n \r\n According to the Department of Justice, Alstom and its subsidiaries - Alstom Prom, Alstom Power and Alstom T\u0026D - \u0022through various executives and employees, paid bribes to government officials and falsified books and records in connection with power, grid and transportation projects for state-owned entities around the world, including in Indonesia, Egypt, Saudi Arabia, the Bahamas and Taiwan. In Indonesia, for example, Alstom, Alstom Prom and Alstom Power paid bribes to government officials\u2014including a high-ranking member of the Indonesian Parliament and high-ranking\r\n members of Perusahaan Listrik Negara, the stat-eowned electricity company in Indonesia\u2014in exchange for assistance in securing several contracts to provide power related services valued at approximately $375 million. In total, Alstom paid more than $75 million to secure more than $4 billion in\r\n projects around the world, with a profit to the company of approximately $300 million.\r\n \r\n Alstom and its subsidiaries also attempted to conceal the bribery scheme by retaining consultants who purportedly provided consulting services on behalf of the companies, but who actually served as conduits for corrupt payments to the government officials. Internal Alstom documents refer to some of the consultants in code, including \u201cMr. Geneva,\u201d \u201cMr. Paris,\u201d \u201cLondon,\u201d \u201cQuiet Man\u201d and \u201cOld Friend.\u201d\r\n \r\n The sentence, which is the largest criminal fine ever imposed in an FCPA case, reflects a number of factors, including: Alstom\u2019s failure to voluntarily disclose the misconduct, even though it was aware of related misconduct at a U.S. subsidiary that previously resolved corruption charges with the department in connection with a power project in Italy\u037e Alstom\u2019s refusal to fully cooperate with the department\u2019s investigation for several years\u037e the breadth of the companies\u2019 misconduct, which spanned many years, occurred in countries around the globe and in several business lines, and involved sophisticated schemes to bribe high-level government officials\u037e Alstom\u2019s lack of an effective compliance and ethics program at the time of the conduct\u037e and Alstom\u2019s prior criminal misconduct, including conduct that led to resolutions with various other governments and the World Bank.\u0022 (Source: US Department of Justice Press Release, \u0022Alstom Sentenced to Pay $772 Million Criminal Fine to Resolve Foreign Bribery Charges,\u0022 November 1, 2015.)","Sources ":"US v. Alstom S.A., Case No. 14-cr-246 (D. Conn), Information and Plea Agreement filed December 22, 2014; US Department of Justice Press Release, \u0022Alstom Sentenced to Pay $772 Million Criminal Fine to Resolve Foreign Bribery Charges,\u0022 November 1, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-alstom-sa-et-al-court-docket-number-314-cr-00245-jba-314-cr","Documents":""},{"Case ID":"ST-404","Case Cluster ":"Alstom","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Bahamas; Egypt; Indonesia; Saudi Arabia; Taiwan, China","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"11\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$772,290,000 ","Criminal Fine\/Penalty (US$) ":"$772,290,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records; Internal controls violations","Offenses - Settled":"Falsification of books and records; Internal controls violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Alstom S.A., a French power and transportation company, was sentenced in November 2015 to pay a $772,290,000 fine to resolve criminal charges related to a widespread corruption scheme involving at least $75 million in secret bribes paid to government officials in countries around the world.\r\n \r\n According to the Department of Justice, Alstom and its subsidiaries - Alstom Prom, Alstom Power and Alstom T\u0026D - \u0022through various executives and employees, paid bribes to government officials and falsified books and records in connection with power, grid and transportation projects for state-owned entities around the world, including in Indonesia, Egypt, Saudi Arabia, the Bahamas and Taiwan. In Indonesia, for example, Alstom, Alstom Prom and Alstom Power paid bribes to government officials\u2014including a high-ranking member of the Indonesian Parliament and high-ranking\r\n members of Perusahaan Listrik Negara, the stat-eowned electricity company in Indonesia\u2014in exchange for assistance in securing several contracts to provide power related services valued at approximately $375 million. In total, Alstom paid more than $75 million to secure more than $4 billion in\r\n projects around the world, with a profit to the company of approximately $300 million.\r\n \r\n Alstom and its subsidiaries also attempted to conceal the bribery scheme by retaining consultants who purportedly provided consulting services on behalf of the companies, but who actually served as conduits for corrupt payments to the government officials. Internal Alstom documents refer to some of the consultants in code, including \u201cMr. Geneva,\u201d \u201cMr. Paris,\u201d \u201cLondon,\u201d \u201cQuiet Man\u201d and \u201cOld Friend.\u201d\r\n \r\n The sentence, which is the largest criminal fine ever imposed in an FCPA case, reflects a number of factors, including: Alstom\u2019s failure to voluntarily disclose the misconduct, even though it was aware of related misconduct at a U.S. subsidiary that previously resolved corruption charges with the department in connection with a power project in Italy\u037e Alstom\u2019s refusal to fully cooperate with the department\u2019s investigation for several years\u037e the breadth of the companies\u2019 misconduct, which spanned many years, occurred in countries around the globe and in several business lines, and involved sophisticated schemes to bribe high-level government officials\u037e Alstom\u2019s lack of an effective compliance and ethics program at the time of the conduct\u037e and Alstom\u2019s prior criminal misconduct, including conduct that led to resolutions with various other governments and the World Bank.\u0022 (Source: US Department of Justice Press Release, \u0022Alstom Sentenced to Pay $772 Million Criminal Fine to Resolve Foreign Bribery Charges,\u0022 November 1, 2015.)","Sources ":"US v. Alstom S.A., Case No. 14-cr-246 (D. Conn), Information and Plea Agreement filed December 22, 2014; US Department of Justice Press Release, \u0022Alstom Sentenced to Pay $772 Million Criminal Fine to Resolve Foreign Bribery Charges,\u0022 November 1, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-alstom-sa-et-al-court-docket-number-314-cr-00245-jba-314-cr","Documents":""},{"Case ID":"ST-405","Case Cluster ":"Alstom S.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Indonesia","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"5\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$88,000,000 ","Criminal Fine\/Penalty (US$) ":"$88,000,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials; Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials; Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Marubeni Corporation, a Japanese trading company involved in the handling of products and provision of services in a broad range of sectors around the world, including power generation pleaded guilty in 2014 to \u0022one count of conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA) and seven counts of violating the FCPA. The company signed a plea agreement in which it admitted its criminal conduct, agreed to maintain and implement an enhanced global anti-corruption compliance program and to cooperate with the department\u2019s ongoing investigation, and agreed to pay an $88 million fine, which the court accepted in imposing the sentence. The plea agreement cites Marubeni\u2019s refusal to cooperate with the department\u2019s investigation when given the opportunity to do so, its lack of an effective compliance and ethics program at the time of the offense, and its failure to timely remediate as several of the factors considered by the department in determining the resolution.\r\n \r\n According to the court filings, Marubeni and its employees, together with others, paid bribes to officials in Indonesia \u2013 including a high-ranking member of the Indonesian Parliament and high-ranking members of Perusahaan Listrik Negara (PLN), the state-owned and state-controlled electricity company in Indonesia \u2013 in exchange for assistance in securing a $118 million contract, known as the Tarahan project, for the company and its consortium partner to provide power-related services for the citizens of Indonesia. To conceal the bribes, Marubeni and its consortium partner retained two consultants purportedly to provide legitimate consulting services on behalf of the power company and its subsidiaries in connection with the Tarahan project. The primary purpose for hiring the consultants, however, was to use the consultants to pay bribes to Indonesian officials.\r\n \r\n Also according to court filings, the first consultant retained by Marubeni and its co-conspirators received hundreds of thousands of dollars in his U.S. bank account to be used to bribe the member of Parliament. The consultant then allegedly transferred the bribe money to a bank account in Indonesia for the benefit of the official. E-mails between the co-conspirators discuss in detail the use of the first consultant to funnel bribes to the member of Parliament and the influence that the member of Parliament could exert over the Tarahan project.\r\n \r\n As admitted in court documents, in the fall of 2003, Marubeni and its co-conspirators determined that the first consultant was not effectively bribing key officials at PLN. As a result, Marubeni and its consortium partner decided to reduce the first consultant\u2019s commission from three percent of the total contract value to one percent, and pay the remaining two percent to a second consultant who could more effectively bribe officials at PLN. In an e-mail between two employees of Marubeni\u2019s consortium partner, they discussed a meeting between Marubeni, an executive from the consortium partner, and the first consultant, stating that the consultant \u201ccommitted to convince [the member of Parliament] that \u2018one\u2019 [percent] is enough.\u201d Marubeni and its co-conspirators were successful in securing the Tarahan project and subsequently made payments to the consultants for the purpose of bribing the Indonesian officials.\r\n \r\n Frederic Pierucci, a current executive at Marubeni\u2019s consortium partner, pleaded guilty on July 29, 2013, to one count of conspiring to violate the FCPA and one count of violating the FCPA. David Rothschild, a former vice president of regional sales at the consortium partner, pleaded guilty on Nov. 2, 2012 to one count of conspiracy to violate the FCPA. Lawrence Hoskins, a former senior vice president for the Asia region for the consortium partner, and William Pomponi, a former vice president of regional sales at the consortium partner, were charged in a second superseding indictment on July 30, 2013.\u0022 (Source: US DOJ Press Release, \u0022Marubeni Corporation Sentenced for Foreign Bribery Violations,\u0022 May 15, 2014.)","Sources ":"US v. Marubeni Corporation, Case No. 14-cr-52 (D. Conn), Information and Plea Agreement filed March 19, 2014, and DOJ Press Release, \u0022Marubeni Corporation Sentenced for Foreign Bribery Violations,\u0022 May 15, 2014, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-marubeni-corporation-court-docket-number-14-cr-00052-jba.","Documents":""},{"Case ID":"ST-406","Case Cluster ":"Archer Daniels Midland Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Ukraine, Venezuela","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"12\/20","Other Jurisdictions of Settlement":"Germany","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$0.00 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"As part of the Non-Prosecution Agreement, ADM agreed to pay $9,450,000 in criminal fine, from which any amounts ordered against ACTI Ukraine would be deducted.","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"No (VAT Fraud - Ukraine)","Summary":"According to the US Department of Justice, \u0022Alfred C. Toepfer International Ukraine Ltd. (ACTI Ukraine), a subsidiary of ADM, pleaded guilty in the Central District of Illinois to one count of conspiracy to violate the anti-bribery provisions of the FCPA and agreed to pay $17.8 million in criminal fines. The Department of Justice also entered into a non-prosecution agreement (NPA) with ADM in connection with the company\u2019s failure to implement an adequate system of internal financial controls to address the making of improper payments both in Ukraine and by an ADM joint venture in Venezuela. [ ] \r\n \r\n According to the charges, from 2002 to 2008, ACTI Ukraine, a trader and seller of commodities based in the Ukraine, together with Alfred C. Toepfer International G.m.b.H. (ACTI Hamburg), another subsidiary of ADM, paid third-party vendors to pass on bribes to Ukrainian government officials to obtain VAT refunds. The charges allege that, in total, ACTI Ukraine and ACTI Hamburg paid roughly $22 million to two vendors, nearly all of which was to be passed on to Ukrainian government officials to obtain over $100 million in VAT refunds, resulting in a benefit to ACTI Ukraine and ACTI Hamburg of roughly $41 million.\r\n \r\n According to the NPA with ADM, a number of concerns were expressed to ADM executives, including an e-mail calling into question potentially illegal \u201cdonations\u201d by ACTI Ukraine and ACTI Hamburg to recover the VAT refunds, yet nonetheless failed to implement sufficient anti-bribery compliance policies and procedures to prevent corrupt payments.\u0022 (Source: US DOJ Press Release, \u0022ADM Subsidiary Pleads Guilty to Conspiracy to Violate the Foreign Corrupt Practices Act,\u0022 December 20, 2013.)","Sources ":"US DOJ Press Release, \u0022ADM Subsidiary Pleads Guilty to Conspiracy to Violate the Foreign Corrupt Practices Act,\u0022 December 20, 2013.","Documents":""},{"Case ID":"ST-407","Case Cluster ":"Archer Daniels Midland Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Ukraine","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"12\/20","Other Jurisdictions of Settlement":"Germany","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit, Prejudgment Interest","Total Monetary Sanctions (US$)":"$36,467,366 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$33,342,012 ","Civil Prejudgment Interest (US$) ":"$3,125,354 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records; Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (VAT Fraud)","Summary":"According to the US Securities and Exchange Commission Press Release, the agency \u0022today charged global food processor Archer-Daniels-Midland Company (ADM) for failing to prevent illicit payments made by foreign subsidiaries to Ukrainian government officials in violation of the Foreign Corrupt Practices Act (FCPA).\r\n \r\n An SEC investigation found that ADM\u2019s subsidiaries in Germany and Ukraine paid $21 million in bribes through intermediaries to secure the release of value-added tax (VAT) refunds. The payments were then concealed by improperly recording the transactions in accounting records as insurance premiums and other purported business expenses. ADM had insufficient anti-bribery compliance controls and made approximately $33 million in illegal profits as a result of the bribery by its subsidiaries. [ ] \r\n \r\n According to the SEC\u2019s complaint filed in U.S. District Court for the Central District of Illinois, the bribery occurred from 2002 to 2008. Ukraine imposed a 20 percent VAT on goods purchased in its country. If the goods were exported, the exporter could apply for a refund of the VAT already paid to the government on those goods. However, at times the Ukrainian government delayed paying VAT refunds it owed or did not make any refund payments at all. On these occasions, the outstanding amount of VAT refunds owed to ADM\u2019s Ukraine affiliate reached as high as $46 million.\r\n \r\n The SEC alleges that in order to obtain the VAT refunds that the Ukraine government was withholding, ADM\u2019s subsidiaries in Germany and Ukraine devised several schemes to bribe Ukraine government officials to release the money. The bribes paid were generally 18 to 20 percent of the corresponding VAT refunds. For example, the subsidiaries artificially inflated commodities contracts with a Ukrainian shipping company to provide bribe payments to government officials. In another scheme, the subsidiaries created phony insurance contracts with an insurance company that included false premiums passed on to Ukraine government officials. The misconduct went unchecked by ADM for several years because of its deficient and decentralized system of FCPA oversight over subsidiaries in Germany and Ukraine.\u0022 (Source: US Securities and Exchange Commission, \u0022SEC Charges Archer-Daniels-Midland Company With FCPA Violations,\u0022 December 20, 2013.)","Sources ":"US v. Archer-Daniels Midland Company, Case No. 2:13-cv-2279 (CD. Ill), Complaint filed December 20, 2013; US Securities and Exchange Commission, \u0022SEC Charges Archer-Daniels-Midland Company With FCPA Violations,\u0022 December 20, 2013, at http:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370540535139","Documents":""},{"Case ID":"ST-408","Case Cluster ":"Archer Daniels Midland Company","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Ukraine","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unknown","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,338,387 ","Criminal Fine\/Penalty (US$) ":"$1,338,387 ","Criminal Fine \/ Penalty (Explanation)":"Noted in ACTI Hamburg Plea Agreement","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Na (VAT Fraud - Ukraine)","Summary":"According to the US Department of Justice, \u0022Alfred C. Toepfer International Ukraine Ltd. (ACTI Ukraine), a subsidiary of ADM, pleaded guilty in the Central District of Illinois to one count of conspiracy to violate the anti-bribery provisions of the FCPA and agreed to pay $17.8 million in criminal fines. The Department of Justice also entered into a non-prosecution agreement (NPA) with ADM in connection with the company\u2019s failure to implement an adequate system of internal financial controls to address the making of improper payments both in Ukraine and by an ADM joint venture in Venezuela. [ ] \r\n \r\n According to the charges, from 2002 to 2008, ACTI Ukraine, a trader and seller of commodities based in the Ukraine, together with Alfred C. Toepfer International G.m.b.H. (ACTI Hamburg), another subsidiary of ADM, paid third-party vendors to pass on bribes to Ukrainian government officials to obtain VAT refunds. The charges allege that, in total, ACTI Ukraine and ACTI Hamburg paid roughly $22 million to two vendors, nearly all of which was to be passed on to Ukrainian government officials to obtain over $100 million in VAT refunds, resulting in a benefit to ACTI Ukraine and ACTI Hamburg of roughly $41 million.\r\n \r\n According to the NPA with ADM, a number of concerns were expressed to ADM executives, including an e-mail calling into question potentially illegal \u201cdonations\u201d by ACTI Ukraine and ACTI Hamburg to recover the VAT refunds, yet nonetheless failed to implement sufficient anti-bribery compliance policies and procedures to prevent corrupt payments.\u0022 (Source: US DOJ Press Release, \u0022ADM Subsidiary Pleads Guilty to Conspiracy to Violate the Foreign Corrupt Practices Act,\u0022 December 20, 2013.)","Sources ":"US Department of Justice Press Release, \u0022ADM Subsidiary Pleads Guilty to Conspiracy to Violate the Foreign Corrupt Practices Act,\u0022 December 20, 2013, at https:\/\/www.justice.gov\/opa\/pr\/adm-subsidiary-pleads-guilty-conspiracy-violate-foreign-corrupt-practices-act and plea agreement","Documents":""},{"Case ID":"ST-409","Case Cluster ":"Archer Daniels Midland Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Ukraine","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"","Other Jurisdictions of Settlement":"Germany","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$17,800,000 ","Criminal Fine\/Penalty (US$) ":"$17,800,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"No (VAT Fraud - Ukraine)","Summary":"According to the US Department of Justice, \u0022Alfred C. Toepfer International Ukraine Ltd. (ACTI Ukraine), a subsidiary of ADM, pleaded guilty in the Central District of Illinois to one count of conspiracy to violate the anti-bribery provisions of the FCPA and agreed to pay $17.8 million in criminal fines. The Department of Justice also entered into a non-prosecution agreement (NPA) with ADM in connection with the company\u2019s failure to implement an adequate system of internal financial controls to address the making of improper payments both in Ukraine and by an ADM joint venture in Venezuela. [ ] \r\n \r\n According to the charges, from 2002 to 2008, ACTI Ukraine, a trader and seller of commodities based in the Ukraine, together with Alfred C. Toepfer International G.m.b.H. (ACTI Hamburg), another subsidiary of ADM, paid third-party vendors to pass on bribes to Ukrainian government officials to obtain VAT refunds. The charges allege that, in total, ACTI Ukraine and ACTI Hamburg paid roughly $22 million to two vendors, nearly all of which was to be passed on to Ukrainian government officials to obtain over $100 million in VAT refunds, resulting in a benefit to ACTI Ukraine and ACTI Hamburg of roughly $41 million.\r\n \r\n According to the NPA with ADM, a number of concerns were expressed to ADM executives, including an e-mail calling into question potentially illegal \u201cdonations\u201d by ACTI Ukraine and ACTI Hamburg to recover the VAT refunds, yet nonetheless failed to implement sufficient anti-bribery compliance policies and procedures to prevent corrupt payments.\u0022 (Source: US DOJ Press Release, \u0022ADM Subsidiary Pleads Guilty to Conspiracy to Violate the Foreign Corrupt Practices Act,\u0022 December 20, 2013.)","Sources ":"US v. Alfred C. Toepfer International (Ukraine) Ltd., Case No. 13-cr-20062 (CD. Ill), Information and Plea Agreement both filed December 20, 2013 at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-alfred-c-toepfer-international-ukraine-ltd-court-docket-number","Documents":""},{"Case ID":"ST-410","Case Cluster ":"Avon Products","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"12\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$67,648,000 ","Criminal Fine\/Penalty (US$) ":"$67,648,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"No (License)","Summary":"According to the US Department of Justice, referencing court documents filed in the case, \u0022from at least 2004 through 2008, Avon and Avon China conspired to falsify Avon\u2019s books and records by falsely describing the nature and purpose of certain Avon China transactions. \r\n \r\n Specifically, the companies sought to disguise over $8 million in gifts, cash and nonbusiness travel, meals and entertainment that Avon China executives and employees gave to government officials in China in order to obtain and retain business benefits for Avon China. Avon China attempted to disguise the payments and benefits through various means, including falsely describing the nature or purpose of, or participants associated with such expenses, and falsely recording payments to a third party intermediary as payments for legitimate consulting services.\r\n \r\n The companies also admitted that in late 2005 Avon learned that Avon China was routinely providing things of value to Chinese government officials and failing to properly document them. Instead of ensuring the practice was halted, fixing the false books and records, disciplining the culpable individuals, and implementing\r\n appropriate controls to address this problem, the companies took steps to conceal the conduct, despite knowing that Avon China\u2019s books and records, and ultimately Avon\u2019s books and records, would continue to be inaccurate.\u0022 (Source: US Department of Justice Press Release, Avon China Pleads Guilty to Violating the FCPA by Concealing More Than $8 Million in Gifts to Chinese Officials,\u0022 December 17, 2014.)","Sources ":"US v. Avon Products (China) Co. Ltd. Case No. 14-cr-828 (SDNY), Information and Plea Agreement, filed December 17, 2014; Department of Justice Press Release, Avon China Pleads Guilty to Violating the FCPA by Concealing More Than $8 Million in Gifts to Chinese Officials,\u0022 December 17, 2014, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-avon-products-china-co-ltd","Documents":""},{"Case ID":"ST-411","Case Cluster ":"Avon Products","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"12\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Accounting provisions of the FCPA","Offenses - Settled":"Accounting provisions of the FCPA","Public Procurement Contract \/ SOE Involved?":"No (License)","Summary":"According to the US Department of Justice, referencing court documents filed in the case, \u0022from at least 2004 through 2008, Avon and Avon China conspired to falsify Avon\u2019s books and records by falsely describing the nature and purpose of certain Avon China transactions. \r\n \r\n Specifically, the companies sought to disguise over $8 million in gifts, cash and nonbusiness travel, meals and entertainment that Avon China executives and employees gave to government officials in China in order to obtain and retain business benefits for Avon China. Avon China attempted to disguise the payments and benefits through various means, including falsely describing the nature or purpose of, or participants associated with such expenses, and falsely recording payments to a third party intermediary as payments for legitimate consulting services.\r\n \r\n The companies also admitted that in late 2005 Avon learned that Avon China was routinely providing things of value to Chinese government officials and failing to properly document them. Instead of ensuring the practice was halted, fixing the false books and records, disciplining the culpable individuals, and implementing\r\n appropriate controls to address this problem, the companies took steps to conceal the conduct, despite knowing that Avon China\u2019s books and records, and ultimately Avon\u2019s books and records, would continue to be inaccurate.\u0022 (Source: US Department of Justice Press Release, Avon China Pleads Guilty to Violating the FCPA by Concealing More Than $8 Million in Gifts to Chinese Officials,\u0022 December 17, 2014.)","Sources ":"US v. Avon Products (China) Co. Ltd. Case No. 14-cr-828 (SDNY), Information and Plea Agreement, filed December 17, 2014; Department of Justice Press Release, Avon China Pleads Guilty to Violating the FCPA by Concealing More Than $8 Million in Gifts to Chinese Officials,\u0022 December 17, 2014, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-avon-products-china-co-ltd","Documents":""},{"Case ID":"ST-412","Case Cluster ":"Avon Products","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"12\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit, Prejudgment Interest","Total Monetary Sanctions (US$)":"$67,365,013.13 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$52,850,000 ","Civil Prejudgment Interest (US$) ":"$14,515,013.13 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records; Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022The SEC alleges that Avon\u2019s subsidiary in China made $8 million worth of payments in cash, gifts, travel, and entertainment to gain access to Chinese officials implementing and overseeing direct selling regulations in China. Avon sought to be among the first allowed to test the regulations, and eventually received the first direct selling business license in China in March 2006. The improper payments also were made to avoid fines or negative news articles that could have impacted Avon\u2019s clean corporate image required to retain the license. Examples of improper payments alleged in the SEC\u2019s complaint include paid travel for Chinese government officials within China or to the U.S. or Europe as well as such gifts as Louis Vuitton merchandise, Gucci bags, Tiffany pens, and corporate box tickets to the China Open tennis tournament. [ ] \r\n  \r\n According to the SEC\u2019s complaint filed in U.S. District Court for the Southern District of New York, the improper payments occurred from 2004 to 2008. Avon management learned about potential FCPA problems at the subsidiary through an internal audit report in late 2005. Avon management consulted an outside law firm, directed that reforms be instituted at the subsidiary, and sent an internal audit team to follow up. Ultimately, however, no such reforms were instituted at the Chinese subsidiary. Avon finally began a full-blown internal investigation in 2008 after its CEO received a letter from a whistleblower.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Avon With FCPA Violations \/\r\n Avon Entities to Pay $135 Million to Settle SEC and Criminal Cases,\u0022 December 17, 2014.)","Sources ":"US SEC v. Avon Products, Inc., Case No. 14-cv-9956 (SDNY), Complaint filed December 17, 2014, at https:\/\/www.sec.gov\/litigation\/complaints\/2014\/comp-pr2014-285.pdf; SEC Press Release, \u0022SEC Charges Avon With FCPA Violations \/ Avon Entities to Pay $135 Million to Settle SEC and Criminal Cases,\u0022 December 17, 2014, at https:\/\/www.sec.gov\/news\/pressrelease\/2014-285.html","Documents":""},{"Case ID":"ST-413","Case Cluster ":"Bechtel \/ Power Generation Engineering and Services Company (PGESCo)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Egypt","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"3\/23","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$5,258,995 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$5,258,995 ","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Mail Fraud, Conspiracy to Commit Money Laundering, Interference with Administration of Internal Revenue (Tax) Laws in relation to an FCPA bribery scheme","Offenses - Settled":"Mail Fraud, Conspiracy to Commit Money Laundering, Interference with Administration of Internal Revenue (Tax) Laws in relation to an FCPA bribery scheme","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Asem Elgawhary [ ] pleaded guilty on Dec. 4, 2014, to mail fraud, conspiracy to commit money laundering, and obstruction and interference with the administration of the tax laws. In imposing sentence today [the Court] also ordered Elgawhary to forfeit $5.2 million.\r\n \r\n From 1996 to 2011, Elgawhary was assigned by Bechtel\u2014a U.S. corporation engaged in engineering, construction and project management\u2014to be the general manager at Power Generation Engineering and Services Company (PGESCo), a joint venture between Bechtel and Egypt\u2019s state-owned and state-controlled electricity company, known as EEHC. PGESCo assisted EEHC in identifying possible subcontractors, soliciting bids and awarding contracts to perform power projects for EEHC. According to his plea agreement, Elgawhary admitted to accepting a total of $5.2 million from three power companies, which they paid to secure a competitive and unfair advantage in the bidding process. One of the power companies, Alstom S.A., together with a Swiss subsidiary, pleaded guilty on Dec. 22, 2014, to violations of the Foreign Corrupt Practices Act (FCPA) in connection with a scheme to pay bribes to foreign officials, including Elgawhary, in various countries. \r\n \r\n As Elgawhary admitted in his plea agreement, he attempted to conceal the kickback scheme by routing the payments through various off-shore bank accounts, including Swiss bank accounts, under his control. Elgawhary also sent various documents and \u201cRepresentation Letters\u201d to Bechtel executives and members of the PGESCo Board of Directors, falsely certifying that he had no knowledge or suspicion of any fraud at PGESCo, and that there were no possible violations of law or regulations that should have been considered for disclosure in PGESCo\u2019s financial statements. Elgawhary also admitted that, in a further attempt to conceal the scheme, he made misrepresentations to counsel for Bechtel when he was interviewed in April 2011.\r\n \r\n Elgawhary further admitted to obstructing and interfering with tax laws by failing to report any of the kickback payments as income for the tax years 2008 through 2011 and providing false information about foreign bank accounts.\u0022 (Source: US Department of Justice Press Release, \u0022Former Bechtel Executive Sentenced to 42 Months in Prison and Ordered to Forfeit $5.2 Million in Connection with Kickback Scheme,\u0022 March 23, 2015.)","Sources ":"US v. Asem Elgawhary, Case No. 14-cr-68 (D. Md.), Criminal Complaint, filed (November 27, 2013), Indictment (February 20, 2014); Department of Justice Press Release, \u0022Former Bechtel Executive Sentenced to 42 Months in Prison and Ordered to Forfeit $5.2 Million in Connection with Kickback Scheme,\u0022 March 23, 2015, accessed at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-asem-m-elgawhary-court-docket-number-14-cr-00068-dkc; Consent Order of Forfeiture and Judgment, both filed March 23, 2015 accessed via PACER.","Documents":""},{"Case ID":"ST-414","Case Cluster ":"Berger Group Holdings Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"India, Indonesia, Kuwait, Vietnam","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"7\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$17,100,000 ","Criminal Fine\/Penalty (US$) ":"$17,100,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Louis Berger International, Inc. a New Jersey-based construction management company admitted to violations of the Foreign Corrupt Practices Act (FCPA) and agreed to pay a $17.1 million criminal penalty to resolve charges that it bribed foreign officials in India, Indonesia, Vietnam and Kuwait to secure government construction management contracts. Two of the company\u2019s former executives also pleaded guilty to conspiracy and FCPA charges in connection with the scheme. [ ] \r\n \r\n LBI entered into a deferred prosecution agreement (DPA) today and admitted its criminal conduct, including its conspiracy to violate the antibribery provisions of the FCPA. Pursuant to the DPA, LBI has agreed to pay a $17.1 million criminal penalty, to implement rigorous internal controls, to continue to cooperate fully with the department and to retain a compliance monitor for at least three years. \r\n \r\n Richard Hirsch [ ] and James McClung [ ], each pleaded guilty to one count of conspiracy to violate the FCPA and one substantive count of violating the FCPA. Hirsch previously served as the Senior Vice President responsible for the company\u2019s operations in Indonesia, Thailand, the Philippines and Vietnam. McClung previously served as the Senior Vice President responsible for the company\u2019s operations in India and, subsequent to Hirsch, in Vietnam. [As of April 18, 2016, the sentencing in Mr.Hirsch and Mr. McClung\u0027s cases had been set for May 12, 2016.]\r\n \r\n According to admissions in the DPA and statements in the charging documents, from 1998 through 2010, the company and its employees, including Hirsch and McClung, orchestrated $3.9 million in bribe payments to foreign officials in various countries in order to secure government contracts. To conceal the payments, the co-conspirators made payments under the guise of \u201ccommitment fees,\u201d \u201ccounterpart per diems,\u201d and other payments to third-party vendors. In reality, the payments were intended to fund bribes to foreign officials who had awarded contracts to LBI or who supervised LBI\u2019s work on contracts.\u0022 (Source:: US Department of Justice Press Release, \u0022Louis Berger International Resolves Foreign Bribery Charges,\u0022 July 17, 2015; US v. James McClung, Case No. 15-cr-00357 and US v. Richard Hirsch, Case No. 15-cr-00358 (D. NJ), Court Docket Report as of April 18, 2016.)","Sources ":"US v. Louis Berger international Inc., Case No. 15-mj-3624 (D. NJ), Criminal Complaint and Deferred prosecution Agreement filed July 7, 2015; Department of Justice Press Release, \u0022Louis Berger International Resolves Foreign Bribery Charges,\u0022 July 17, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/louis-berger-international; US v. Hirsch, Case No. 15-cr-00358 and US v. McClung, Case No. 15-cr-00357 (D. NJ), Court Docket Report as of April 18, 2016; and other related court documents at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/james-mcclung and https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/richard-hirsch","Documents":""},{"Case ID":"ST-415","Case Cluster ":"Besso Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Financial Conduct Authority","Jurisdiction of Foreign Public Official(s) ":"None specified","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"3\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Final Notice","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$524,261 ","Criminal Fine\/Penalty (US$) ":"NA","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"NA","Criminal Restitution \/ Reparation (US$)":"NA","Criminal Legal \/ Procedural Costs (US$)":"NA","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$524,261 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art. 16","OECD Anti-Bribery Convention Articles Implicated":"Art. 2, Art. 8","Offenses - Alleged":"Lack of Bribery Controls","Offenses - Settled":"Lack of Bribery Controls","Public Procurement Contract \/ SOE Involved?":"No","Summary":"According to the UK Financial Conduct Authority\u0027s Final Notice, \u00224.1. Besso is the broking subsidiary of Besso Insurance Group Limited. Besso is a medium-sized Lloyd\u2019s general insurance broker operating mainly in the commercial sector, specialising in marine, aviation, transport, property, casualty, international and liability insurance. Besso has been authorised by the Authority\n to carry out a number of regulated activities since 14 January 2005. This includes assisting in the administration and performance of contracts of insurance.\n 4.2. Insurance and reinsurance brokers such as Besso make payments to, and share commission with, Third Parties in a number of circumstances. For example, a broker may pay a co-broker who assists in the placement of insurance or reinsurance. In some cases, a broker may pay a broker who provides services (e.g., administrative and policy insurance services) in relation to the placement of\n insurance in countries where the principal broker does not have an office. In other cases, a broker may pay individuals or companies who have limited or no involvement in placement activities, but assist with client introductions and providing relevant market and other information.\n 4.3. Being a wholesale broker, Besso was heavily reliant upon Producing Brokers to bring business to it. The Producing Brokers would have the relationship with the insured and would handle all correspondence in relation to that insured. Besso would normally agree a split of commission between the Producing Broker and itself.\n 4.4. During the Relevant Period, Besso offered (and continues to offer) broking services for both insurance and reinsurance business across a wide range of industries and countries, which will have had a varying degree of perceived risk of bribery and corruption. In establishing and maintaining business relationships, Besso made use of, and paid commissions to, Third Parties (both overseas and in the UK). Accordingly, although it was not unusual or inappropriate for Besso to make payments to Third Parties, there was a risk, which was increased for higher risk industries and countries, that a proportion of the money paid to Third Parties might have been used by the Third Parties for inappropriate purposes. This could have included paying bribes to persons connected with the insured or public officials.\u0022 (Source: UK FCA FInal Notice, File Reference Number 309159, March 17, 2014.)","Sources ":"UK Financial Conduct Authority, Final Notice to Besso Limited, Firm Reference Number 309159, Maarch 17, 2014, at https:\/\/www.fca.org.uk\/your-fca\/documents\/final-notices\/2014\/besso-limited","Documents":""},{"Case ID":"ST-416","Case Cluster ":"BHP Billiton","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Burundi; other unnamed African and Asian countries","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"5\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$25,000,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$25,000,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, BHPB is a global resources company that is among the world\u2019s leading producers of major commodities, including iron ore, coal, oil and gas, copper, aluminum, manganese, uranium, nickel, and silver. \u0022This matter concerns BHPB\u2019s failure to devise and maintain sufficient internal controls over a global hospitality program that the company hosted in connection with its sponsorship of the 2008 Beijing Summer Olympic Games. BHPB invited approximately 176 government officials and employees of state-owned enterprises (collectively, \u201cgovernment officials\u201d) to attend the Olympics at BHPB\u2019s expense. The majority of these invitations were extended to government officials from countries in Africa and Asia that had well-known histories of corruption. The three to four day hospitality packages included event tickets, luxury hotel accommodations, meals, other hospitality, and, in many instances, offers of business-class airfare for government officials and their guests. BHPB informed its employees that \u201c[o]ne of the core objectives [of the Olympic sponsorship] is to maximize the commercial investment made in the Games through assisting [BHPB] to strengthen relationships with key local and global stakeholders, e.g.: Government Ministers, Suppliers and Customers,\u201d and that the hospitality program was \u201ca primary vehicle to ensure this goal is achieved.\u201d\r\n \r\n 2. BHPB recognized that inviting government officials to the Olympics created a heightened risk of violating anti-corruption laws and the company\u2019s own Guide to Business Conduct, but the internal controls it developed and relied upon in an effort to address this risk were insufficient. As a result, BHPB invited government officials who were directly involved in, or in a position to influence, pending contract negotiations, efforts to obtain access rights, regulatory actions, or business dealings affecting BHPB in multiple countries. In addition, BHPB\u2019s books and records, namely certain internal forms that employees prepared in order to invite a government official to the Olympics, did not, in reasonable detail, accurately and fairly reflect BHPB\u2019s pending\r\n negotiations or business dealings with the government official at the time of the invitation.\u0022 (Source: SEC Administrative Proceedings, File No. 3-16546, In the Matter of BHP Billiton Ltd. and BHP Billiton Plc, May 20, 2015.)","Sources ":"US Securities and Exchange Commission, Administrative Proceedings, File No. 3-16546, In the Matter of BHP Billiton Ltd. and BHP Billiton Plc, May 20, 2015, at https:\/\/www.sec.gov\/litigation\/admin\/2015\/34-74998.pdf","Documents":""},{"Case ID":"ST-417","Case Cluster ":"Bilfinger SE \/ Willbros","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"12\/9","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$32,000,000 ","Criminal Fine\/Penalty (US$) ":"$32,000,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe foreign officials","Offenses - Settled":"Conspiracy to Bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Bilfinger SE, an international engineering and services company based in Mannheim, Germany, has agreed to pay a $32 million penalty to resolve charges that it violated the Foreign Corrupt Practices Act (FCPA) by bribing government officials of the Federal Republic of Nigeria to obtain and retain contracts related to the Eastern Gas Gathering System (EGGS) project, which was valued at approximately $387 million. [ ] \r\n \r\n As part of the agreed resolution, the department today filed a three-count criminal information in U.S. District Court for the Southern District of Texas charging Bilfinger with violating and conspiring to violate the FCPA\u2019s anti-bribery provisions. [ ]\r\n \r\n According to court documents, from late 2003 through June 2005, Bilfinger conspired with Willbros Group Inc. and others to make corrupt payments totaling more than $6 million to Nigerian government officials to assist in obtaining and retaining contracts related to the EGGS project. Bilfinger and Willbros formed a joint venture to bid on the EGGS project and inflated the price of the joint venture\u2019s bid by 3 percent to cover the cost of paying bribes to Nigerian officials. As part of the conspiracy, Bilfinger employees bribed Nigerian officials with cash that Bilfinger employees sent from Germany to Nigeria. At another point in the conspiracy, when Willbros employees encountered difficulty obtaining enough money to make their share of the bribe payments, Bilfinger loaned them $1 million, with the express purpose of paying bribes to the Nigerian officials.\r\n \r\n Including today\u2019s action, the department has filed criminal charges in the Southern District of Texas against three institutions and four executives and consultants in connection with the EGGS bribery scheme:\r\n \r\n On Sept. 14, 2006, Jim Bob Brown, a former Willbros executive, pleaded guilty to one count of conspiracy to violate the FCPA in connection with his role in making corrupt payments to Nigerian government officials to obtain and retain the EGGS contract and in connection with his role in making corrupt payments in Ecuador. Brown was sentenced on Jan. 28, 2010, to serve 12 months and one day in prison, to be followed by two years of supervised release, and ordered to pay a $17,500 fine.\r\n \r\n On Nov. 5, 2007, Jason Steph, also a former Willbros executive, pleaded guilty to one count of conspiracy to violate the FCPA in connection with his role in making corrupt payments to Nigerian government officials to obtain and retain the EGGS contract. Steph was sentenced on Jan. 28, 2010, to serve 15 months in prison, to be followed by two years of supervised release, and ordered to pay a $2,000 fine.\r\n \r\n On May 14, 2008, Willbros Group Inc. and Willbros International Inc. entered into a deferred prosecution agreement and agreed to pay a $22 million criminal penalty in connection with the company\u2019s payment of bribes to government officials in Nigeria and Ecuador. On March 30, 2012, the government moved to dismiss the charges against Willbros on the grounds that Willbros had satisfied its obligations under the deferred prosecution agreement, and on April 2, 2012, the court granted the United States\u2019 motion.\r\n \r\n On Dec. 19, 2008, Kenneth Tillery, a former Willbros executive, was charged with conspiring to make and making bribe payments to Nigerian and Ecuadoran officials in connection with the EGGS project and pipeline projects in Ecuador and conspiring to launder the bribe payments. Tillery remains a fugitive. The charges against Tillery are merely accusations, and he is presumed innocent unless and until proven guilty.\r\n \r\n On Nov. 12, 2009, Paul Grayson Novak, a former Willbros consultant, pleaded guilty to one count of conspiracy to violate the FCPA and one substantive count of violating the FCPA in connection with his role in making corrupt payments to Nigerian government officials to obtain and retain the EGGS contract. Novak was sentenced on May 3, 2013, to serve 15 months in prison, to be followed by two years of supervised release, and ordered to pay a $1 million fine.\u0022 (Source: US Department of Justice Press Release, \u0022German Engineering Firm Bilfinger Resolves Foreign Corrupt Practices Act Charges and Agrees to Pay $32 Million Criminal Penalty,\u0022 December 11, 2013, at https:\/\/www.justice.gov\/opa\/pr\/german-engineering-firm-bilfinger-resolves-foreign-corrupt-practices-act-charges-and-agrees.)","Sources ":"US v. Bilfinger SE, Case No. 4:13-cr-745 (SD Tex.), Information and Deferred Prosecution Agreement filed December 9, 2013; USDOJ Press Release, \u0022German Engineering Firm Bilfinger Resolves Foreign Corrupt Practices Act Charges and Agrees to Pay $32 Million Criminal Penalty,\u0022 December 11, 2013, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-bilfinger-se-court-docket-number-413-cr-745","Documents":""},{"Case ID":"ST-418","Case Cluster ":"Bilfinger SE \/ Willbros","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"5\/8","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,000,000 ","Criminal Fine\/Penalty (US$) ":"$1,000,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to Bribe foreign officials; Assist in Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe foreign officials; Assist in Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Bilfinger SE, an international engineering and services company based in Mannheim, Germany, has agreed to pay a $32 million penalty to resolve charges that it violated the Foreign Corrupt Practices Act (FCPA) by bribing government officials of the Federal Republic of Nigeria to obtain and retain contracts related to the Eastern Gas Gathering System (EGGS) project, which was valued at approximately $387 million. [ ] \r\n \r\n As part of the agreed resolution, the department today filed a three-count criminal information in U.S. District Court for the Southern District of Texas charging Bilfinger with violating and conspiring to violate the FCPA\u2019s anti-bribery provisions. [ ]\r\n \r\n According to court documents, from late 2003 through June 2005, Bilfinger conspired with Willbros Group Inc. and others to make corrupt payments totaling more than $6 million to Nigerian government officials to assist in obtaining and retaining contracts related to the EGGS project. Bilfinger and Willbros formed a joint venture to bid on the EGGS project and inflated the price of the joint venture\u2019s bid by 3 percent to cover the cost of paying bribes to Nigerian officials. As part of the conspiracy, Bilfinger employees bribed Nigerian officials with cash that Bilfinger employees sent from Germany to Nigeria. At another point in the conspiracy, when Willbros employees encountered difficulty obtaining enough money to make their share of the bribe payments, Bilfinger loaned them $1 million, with the express purpose of paying bribes to the Nigerian officials.\r\n \r\n Including today\u2019s action, the department has filed criminal charges in the Southern District of Texas against three institutions and four executives and consultants in connection with the EGGS bribery scheme:\r\n \r\n On Sept. 14, 2006, Jim Bob Brown, a former Willbros executive, pleaded guilty to one count of conspiracy to violate the FCPA in connection with his role in making corrupt payments to Nigerian government officials to obtain and retain the EGGS contract and in connection with his role in making corrupt payments in Ecuador. Brown was sentenced on Jan. 28, 2010, to serve 12 months and one day in prison, to be followed by two years of supervised release, and ordered to pay a $17,500 fine.\r\n \r\n On Nov. 5, 2007, Jason Steph, also a former Willbros executive, pleaded guilty to one count of conspiracy to violate the FCPA in connection with his role in making corrupt payments to Nigerian government officials to obtain and retain the EGGS contract. Steph was sentenced on Jan. 28, 2010, to serve 15 months in prison, to be followed by two years of supervised release, and ordered to pay a $2,000 fine.\r\n \r\n On May 14, 2008, Willbros Group Inc. and Willbros International Inc. entered into a deferred prosecution agreement and agreed to pay a $22 million criminal penalty in connection with the company\u2019s payment of bribes to government officials in Nigeria and Ecuador. On March 30, 2012, the government moved to dismiss the charges against Willbros on the grounds that Willbros had satisfied its obligations under the deferred prosecution agreement, and on April 2, 2012, the court granted the United States\u2019 motion.\r\n \r\n On Dec. 19, 2008, Kenneth Tillery, a former Willbros executive, was charged with conspiring to make and making bribe payments to Nigerian and Ecuadoran officials in connection with the EGGS project and pipeline projects in Ecuador and conspiring to launder the bribe payments. Tillery remains a fugitive. The charges against Tillery are merely accusations, and he is presumed innocent unless and until proven guilty.\r\n \r\n On Nov. 12, 2009, Paul Grayson Novak, a former Willbros consultant, pleaded guilty to one count of conspiracy to violate the FCPA and one substantive count of violating the FCPA in connection with his role in making corrupt payments to Nigerian government officials to obtain and retain the EGGS contract. Novak was sentenced on May 3, 2013, to serve 15 months in prison, to be followed by two years of supervised release, and ordered to pay a $1 million fine.\u0022 (Source: US Department of Justice Press Release, \u0022German Engineering Firm Bilfinger Resolves Foreign Corrupt Practices Act Charges and Agrees to Pay $32 Million Criminal Penalty,\u0022 December 11, 2013, at https:\/\/www.justice.gov\/opa\/pr\/german-engineering-firm-bilfinger-resolves-foreign-corrupt-practices-act-charges-and-agrees.)","Sources ":"US v. Bilfinger SE, Case No. 4:13-cr-745 (SD Tex.), Information and Deferred Prosecution Agreement filed December 9, 2013; US Department of Justice Press Release, \u0022German Engineering Firm Bilfinger Resolves Foreign Corrupt Practices Act Charges and Agrees to Pay $32 Million Criminal Penalty,\u0022 December 11, 2013, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-bilfinger-se-court-docket-number-413-cr-745;\r\n \r\n US v. Paul Grayson Novak, Case No. 4:08-cr-22 (SD Tex.), Indictment filed November 11, 2009, Plea Agreement (November 12, 2009), Judgment (May 8, 2013), at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-paul-grayson-novak-2009-docket-no-408-cr-00022","Documents":""},{"Case ID":"ST-419","Case Cluster ":"Bio-Rad Laboratories","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Russia","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"11\/3","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$14,350,000 ","Criminal Fine\/Penalty (US$) ":"$14,350,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"Falsification of Books and Records; Internal Controls Violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022California-based medical diagnostics and life sciences manufacturing and sales company, Bio-Rad Laboratories Inc. (BioRad), has agreed to pay a $14.35 million penalty to resolve allegations that it violated the Foreign Corrupt Practices Act (FCPA) by falsifying its books and records and failing to implement adequate internal controls in connection with sales it made in Russia. [ ] According to the company\u2019s admissions in the agreement, Bio-Rad SNC, a Bio-Rad subsidiary located in France, retained and paid intermediary companies commissions of 15-30 percent purportedly in exchange for various services in connection with certain governmental sales in Russia. The intermediary companies, however, did not perform these services. Several high-level managers at Bio-Rad, responsible for overseeing\r\n Bio-Rad\u2019s business in Russia, reviewed and approved the commission payments to the intermediary companies despite knowing that the intermediary companies were not performing such services. These managers knowingly caused the payments to be falsely recorded on Bio-Rad SNC\u2019s and, ultimately, Bio-Rad\u2019s books. Bio-Rad, through several of its managers, also failed to implement adequate controls, as well as adequate compliance systems, with regard to its Russian operations while knowing that the failure to implement such controls allowed the intermediary companies to be paid significantly above-market commissions for little or no services.\u0022 (Source: Department of Justice Press Release, \u0022Bio-Rad Laboratories Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $14.35 Million Penalty,\u0022 November 3, 2014.)","Sources ":"US Department of Justice Non-Prosecution Agreement in re: Bio-Rad Laboratories, Inc., November 3, 2014, at https:\/\/www.justice.gov\/sites\/default\/files\/criminal-fraud\/legacy\/2014\/11\/03\/Bio-Rad-NPA-110314.pdf; Department of Justice Press Release, \u0022Bio-Rad Laboratories Resolves Foreign Corrupt Practices Act\r\n Investigation and Agrees to Pay $14.35 Million Penalty,\u0022 November 3, 2014.","Documents":""},{"Case ID":"ST-420","Case Cluster ":"Bizjet","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico, Panama","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"11\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$15,000 ","Criminal Fine\/Penalty (US$) ":"$15,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials, Conspiracy to Launder Monetary Instruments, Money Laundering","Offenses - Settled":"Conspiracy; Bribery of Foreign Officials - Aid and Abet","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Bernd Kowalewski, the former President and CEO of BizJet, pleaded guilty \u0022to conspiracy to violate the Foreign Corrupt Practices Act (FCPA) and a substantive violation of the FCPA in connection with a scheme to pay bribes to officials in Mexico and Panama in exchange for those officials\u2019 assistance in securing contracts for BizJet to perform aircraft maintenance, repair and overhaul services.\u0022 (Source: US DOJ Press Release, \u0022Former Chief Executive Officer of Lufthansa Subsidiary BizJet Pleads Guilty to Foreign Bribery Charges,\u0022 July 24, 2014.)\r\n \r\n According to the US Department of Justice, \u0022BizJet paid bribes to officials employed by the Mexican Policia Federal Preventiva, the Mexican Coordinacion General de Transportes Aereos Presidenciales, the air fleet for the Gobierno del Estado de Sinaloa, the air fleet for the Gobierno del Estado de Sonora and the Republica de Panama Autoridad Aeronautica Civil. In many instances, BizJet paid the bribes directly to the foreign officials. In other instances, BizJet funneled the bribes through a shell company owned and operated by a BizJet sales manager. BizJet executives orchestrated, authorized and approved the unlawful payments.\u0022 (Source: US Department of Justice Press Release, \u0022Bizjet International Sales and Support Inc., Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $11.8 Million Criminal Penalty,\u0022 March 14, 2012.) According to the Statement of Facts agreed to by the company as part of its Deferred Prosecution Agreement, \u0022Shell Company A\u0022 was owned by BizJet\u0027s Sales Manager and operated out of his personal residence in Van Nuys, California (para 7); Shell Company A \u0022operated under the pretense\u0022 of supplying aircraft maintenance, repair and overhaul services but in fact was used in the conspiracy by BizJet executives and sales manager to make unlawful payments to foreign officials via its bank account in California. (para 18) (Source: US v. BizJet International Sales and Support, Inc., Case No. 4:12-cr-00061 (N.D. Okla.), Deferred Prosecution Agreement and Statement of Facts filed March 14, 2012.)","Sources ":"US v. Kowalewski, Case No. 12-cr-07 (N.D. Okla), Judgment filed on November 18, 2014 and Court Docket Report as of April 19, 2016;\r\n \r\n Department of Justice Press Release, \u0022Former Chief Executive Officer of Lufthansa Subsidiary BizJet Pleads Guilty to Foreign Bribery Charges,\u0022 July 24, 2014, at https:\/\/www.justice.gov\/opa\/pr\/former-chief-executive-officer-lufthansa-subsidiary-bizjet-pleads-guilty-foreign-bribery\r\n \r\n US v. BizJet International Sales and Support, Inc., Case No. 4:12-cr-00061 (N.D. Okla.), Deferred Prosecution Agreement and Statement of Facts filed March 14, 2012, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-bizjet-international-sales-and-support-inc-court-docket-number","Documents":""},{"Case ID":"ST-421","Case Cluster ":"Bizjet","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico, Panama","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"4\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$10,000 ","Criminal Fine\/Penalty (US$) ":"$10,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Mr. Uhl was Controller or Vice President of Bizjet International Sales and Support Inc., the U.S.-based subsidiary of Lufthansa Technik AG, which provides aircraft maintenance, repair and overhaul (MRO) services. \u0022BizJet paid bribes to officials employed by the Mexican Policia Federal Preventiva, the Mexican Coordinacion General de Transportes Aereos Presidenciales, the air fleet for the Gobierno del Estado de Sinaloa, the air fleet for the Gobierno del Estado de Sonora and the Republica de Panama Autoridad Aeronautica Civil. In many instances, BizJet paid the bribes directly to the foreign officials. In other instances, BizJet funneled the bribes through a shell company owned and operated by a BizJet sales manager. BizJet executives orchestrated, authorized and approved the unlawful payments.\u0022 (Source: US Department of Justice Press Release, \u0022Bizjet International Sales and Support Inc., Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $11.8 Million Criminal Penalty,\u0022 March 14, 2012.) According to the Statement of Facts agreed to by the company as part of its Deferred Prosecution Agreement, \u0022Shell Company A\u0022 was owned by BizJet\u0027s Sales Manager and operated out of his personal residence in Van Nuys, California (para 7); Shell Company A \u0022operated under the pretense\u0022 of supplying aircraft maintenance, repair and overhaul services but in fact was used in the conspiracy by BizJet executives and sales manager to make unlawful payments to foreign officials via its bank account in California. (para 18) (Source: US v. BizJet International Sales and Support, Inc., Case No. 4:12-cr-00061 (N.D. Okla.), Deferred Prosecution Agreement and Statement of Facts filed March 14, 2012.)","Sources ":"US v. Uhl, Case No. 11-cr-184 (N.D. Okla), Information, Plea Agreement and Judgment, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-neal-uhl-court-docket-number-11-cr-184-gkf;\r\n \r\n Department of Justice Press Release, \u0022Former Chief Executive Officer of Lufthansa Subsidiary BizJet Pleads Guilty to Foreign Bribery Charges,\u0022 July 24, 2014, at https:\/\/www.justice.gov\/opa\/pr\/former-chief-executive-officer-lufthansa-subsidiary-bizjet-pleads-guilty-foreign-bribery\r\n \r\n US v. BizJet International Sales and Support, Inc., Case No. 4:12-cr-00061 (N.D. Okla.), Deferred Prosecution Agreement and Statement of Facts filed March 14, 2012, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-bizjet-international-sales-and-support-inc-court-docket-number","Documents":""},{"Case ID":"ST-422","Case Cluster ":"Bizjet","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico, Panama","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"4\/3","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials; Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials; Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Mr. Uhl was Vice President of Sales and Marketing of Bizjet International Sales and Support Inc., the U.S.-based subsidiary of Lufthansa Technik AG, which provides aircraft maintenance, repair and overhaul (MRO) services. \u0022BizJet paid bribes to officials employed by the Mexican Policia Federal Preventiva, the Mexican Coordinacion General de Transportes Aereos Presidenciales, the air fleet for the Gobierno del Estado de Sinaloa, the air fleet for the Gobierno del Estado de Sonora and the Republica de Panama Autoridad Aeronautica Civil. In many instances, BizJet paid the bribes directly to the foreign officials. In other instances, BizJet funneled the bribes through a shell company owned and operated by a BizJet sales manager. BizJet executives orchestrated, authorized and approved the unlawful payments.\u0022 (Source: US Department of Justice Press Release, \u0022Bizjet International Sales and Support Inc., Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $11.8 Million Criminal Penalty,\u0022 March 14, 2012.) According to the Statement of Facts agreed to by the company as part of its Deferred Prosecution Agreement, \u0022Shell Company A\u0022 was owned by BizJet\u0027s Sales Manager and operated out of his personal residence in Van Nuys, California (para 7); Shell Company A \u0022operated under the pretense\u0022 of supplying aircraft maintenance, repair and overhaul services but in fact was used in the conspiracy by BizJet executives and sales manager to make unlawful payments to foreign officials via its bank account in California. (para 18) (Source: US v. BizJet International Sales and Support, Inc., Case No. 4:12-cr-00061 (N.D. Okla.), Deferred Prosecution Agreement and Statement of Facts filed March 14, 2012.)","Sources ":"US v. Dubois, Case No. 11-cr-183 (N.D. Okla), Information, Plea Agreement and Judgment, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-peter-dubois-court-docket-number-11-cr-183-gkf; DOJ Press Release, \u0022Four Former Executives of Lufthansa Subsidiary Bizjet Charged with Foreign Bribery,\u0022 April 5, 2013, at https:\/\/www.justice.gov\/opa\/pr\/four-former-executives-lufthansa-subsidiary-bizjet-charged-foreign-bribery.","Documents":""},{"Case ID":"ST-423","Case Cluster ":"BNY Mellon","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Unidentified Middle East nation","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"8\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment interest, Civil Fine","Total Monetary Sanctions (US$)":"$14,800,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$8,300,000 ","Civil Prejudgment Interest (US$) ":"$1,500,000 ","Civil Fine \/ Penalty (US$)":"$5,000,000 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, Bank of New York Mellon \u0022has agreed to pay $14.8 million to settle charges that it violated the Foreign Corrupt Practices Act (FCPA) by providing valuable student internships to family members of foreign government officials affiliated with a Middle Eastern sovereign wealth fund. An SEC investigation found that BNY Mellon did not evaluate or hire the family members through its existing, highly competitive internship programs that have stringent hiring standards and require a minimum grade point average and multiple interviews. The family members did not meet the rigorous criteria yet were hired with the knowledge and approval of senior BNY Mellon employees in order to corruptly influence foreign officials and win or retain contracts to manage and service the assets of the sovereign wealth fund. According to the SEC\u2019s order instituting a settled administrative proceeding, the sovereign wealth fund officials requested that BNY Mellon provide their family members with internships, and they made numerous follow-up requests about the status, timing, and other details of the internships for their relatives.\u0022 (Source: SEC Press Release, \u0022SEC Charges BNY Mellon With FCPA Violations,\u0022 August 18, 2015.)","Sources ":"US Securities and Exchange Commission, In the Matter of The Bank of New York Mellon Corporation, Administrative Proceeding File No. 3-16762, August 18, 2015, at https:\/\/www.sec.gov\/litigation\/admin\/2015\/34-75720.pdf; SEC Press Release, \u0022SEC Charges BNY Mellon With FCPA Violations,\u0022 August 18, 2015, at https:\/\/www.sec.gov\/news\/pressrelease\/2015-170.html.","Documents":""},{"Case ID":"ST-424","Case Cluster ":"Bonny Island Nigeria","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"4\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$11,760,000 ","Criminal Fine\/Penalty (US$) ":"$11,760,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art.1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Department of Justice, \u0022Parker Drilling Company, a publicly listed drilling-services company, headquartered in Houston, has agreed to pay an $11.76 million penalty to resolve charges related to the Foreign Corrupt Practices Act (FCPA) for authorizing payment to an intermediary, knowing that the payment would be used to corruptly influence the decisions of a Nigerian government panel reviewing Parker Drilling\u2019s adherence to Nigerian customs and tax laws. [ ] \r\n \r\n The investigation of Parker Drilling stemmed from the Justice Department\u2019s Panalpina-related investigations, which previously yielded criminal resolutions with Panalpina and five oil and gas service companies and subsidiaries and resulted in more than $156 million in criminal penalties. [ ] \r\n  \r\n According to court documents, in 2001 and 2002, Panalpina World Transport (Nigeria) Limited, working on Parker Drilling\u2019s behalf, avoided certain costs associated with complying with Nigeria\u2019s customs laws by fraudulently claiming that Parker Drilling\u2019s rigs had been exported and then re-imported into Nigeria. In late 2002, Nigeria formed a government commission, commonly called the Temporary Import (TI) Panel, to examine whether Nigeria\u2019s Customs Service had collected certain duties and tariffs that Nigeria was due. In December 2002, the TI Panel commenced proceedings against Parker Drilling. The TI Panel later determined that Parker Drilling had violated Nigeria\u2019s customs laws and assessed a $3.8 million fine against Parker Drilling.\r\n \r\n According to court documents, rather than pay the assessed fine, Parker Drilling contracted indirectly with an intermediary agent to resolve its customs issues. From January to May 2004, Parker Drilling transferred $1.25 million to the agent, who reported spending a portion of the money on various things including entertaining government officials. Emails in which the agent requested additional money from Parker Drilling referenced the agent\u2019s interactions with Nigeria\u2019s Ministry of Finance, State Security Service, and a delegation from the president\u2019s office. Two senior executives within Parker Drilling at the time reviewed and approved the agent\u2019s invoices, knowing that the invoices arbitrarily attributed portions of the money that Parker Drilling transferred to the agent to various fees and expenses. The agent succeeded in reducing Parker Drilling\u2019s TI Panel fines from $3.8 million to just $750,000.\u0022 (Source: DOJ Press Release, \u0022Parker Drilling Company Resolves FCPA Investigation and Agrees to Pay $11.76 Million Penalty,\u0022 April 16, 2013.)","Sources ":"US v. Parker Drilling Company, Case No. 13-cr-176 (EDVA), Information and Deferred Prosecution Agreement filed April 16, 2013 and DOJ Press Release, \u0022Parker Drilling Company Resolves FCPA Investigation and Agrees to Pay $11.76 Million Penalty,\u0022 April 16, 2013, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-parker-drilling-company-court-docket-number-13-cr-176","Documents":""},{"Case ID":"ST-425","Case Cluster ":"Bonny Island Nigeria","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"4\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment interest","Total Monetary Sanctions (US$)":"$4,090,818 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$3,050,000 ","Civil Prejudgment Interest (US$) ":"$1,040,818 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"SOE","Summary":"According to the US Securities and Exchange Commission, Parker Drilling Company, a worldwide drilling services and project management firm was charged in April 2013, \u0022with violating the Foreign Corrupt Practices Act (FCPA) by authorizing improper payments to a third-party intermediary retained to assist the company in resolving customs disputes.\r\n \r\n The SEC\u0027s complaint, filed in federal district court in Alexandria, Virginia, alleges that in 2004 Parker Drilling authorized payments to a Nigerian agent totaling $1.25 million. The company did so despite former senior executives knowing that the agent intended to use the funds to \u0022entertain\u0022 Nigerian officials involved in resolving Parker Drilling\u0027s ongoing customs problems. Following the Nigerian agent\u0027s work, the company received an unexplained $3,050,000 reduction of a previously assessed customs fine, and the company was permitted to nationalize and sell its Nigerian rigs.\u0022 (Source: SEC Litigation Release No. 22672 \/ April 16, 2013, \u0022SEC Charges Parker Drilling Company with Violating the Foreign Corrupt Practices Act.\u0022)","Sources ":"US Securities and Exchange Commission v. Parker Drilling Company, Civil Action No. 13-cv-461 (E.D. Va.), Complaint filed April 16, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp22672.pdf; SEC Litigation Release No. 22672 \/ April 16, 2013, \u0022SEC Charges Parker Drilling Company with Violating the Foreign Corrupt Practices Act,\u0022 at https:\/\/www.sec.gov\/litigation\/litreleases\/2013\/lr22672.htm.","Documents":""},{"Case ID":"ST-426","Case Cluster ":"Bristol-Myers Squibb","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"10\/5","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment interest, Civil Fine","Total Monetary Sanctions (US$)":"$14,650,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$11,400,000 ","Civil Prejudgment Interest (US$) ":"$500,000 ","Civil Fine \/ Penalty (US$)":"$2,750,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations and Recordkeeping","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission\u2019s \u0022order instituting settled administrative proceedings, Bristol-Myers Squibb lacked effective internal controls over interactions with health care providers at BMS China, its majority-owned joint venture. Between 2009 and 2014, BMS China sales representatives sought to secure and increase business by providing health care providers in China with cash, jewelry and other gifts, meals, travel, entertainment, and sponsorships for conferences and meetings. BMS China inaccurately recorded the spending as legitimate business expenses in its books and records, which were then consolidated into the books and records of Bristol-Myers Squibb. [ ] The SEC\u2019s order finds that Bristol-Myers Squibb violated the FCPA\u2019s internal controls and recordkeeping provisions. Without admitting or denying the findings, Bristol-Myers Squibb consented to the order and agreed to return $11.4 million of profits plus prejudgment interest of $500,000 and pay a civil penalty of $2.75 million. Bristol-Myers Squibb also agreed to report to the SEC for a two-year period on the status of its remediation and implementation of FCPA and anti-corruption compliance measures.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Bristol-Myers Squibb With FCPA Violations,\u0022 October 5, 2015.)","Sources ":"US SEC Press Release, \u0022SEC Charges Bristol-Myers Squibb With FCPA Violations,\u0022 October 5, 2015, at https:\/\/www.sec.gov\/news\/pressrelease\/2015-229.html","Documents":""},{"Case ID":"ST-427","Case Cluster ":"Brucker Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"12\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment interest, Civil Fine","Total Monetary Sanctions (US$)":"$2,399,969 ","Criminal Fine\/Penalty (US$) ":"NA","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"NA","Criminal Restitution \/ Reparation (US$)":"NA","Criminal Legal \/ Procedural Costs (US$)":"NA","Civil Disgorgement of Profits (US$) ":"$1,714,852 ","Civil Prejudgment Interest (US$) ":"$310,117 ","Civil Fine \/ Penalty (US$)":"$375,000 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art. 16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations and Recordkeeping","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, Brucker Corporation, a Billerica, Mass.-based global manufacturer of scientific instruments was charged \u0022with violating the Foreign Corrupt Practices Act (FCPA) by providing non-business related travel and improper payments to various Chinese government officials in an effort to win business. \n \n An SEC investigation found that Bruker Corporation lacked sufficient internal controls to prevent and detect approximately $230,000 in improper payments out of its China-based offices that falsely recorded them in books and records as legitimate business and marketing expenses. The payments enabled Bruker to realize approximately $1.7 million in profits from sales contracts with state-owned entities in China whose officials received the improper payments. [ ] \n \n According to the SEC\u2019s order instituting a settled administrative proceeding, a Bruker office in China paid more than $111,000 to Chinese government officials under 12 suspicious collaboration agreements contingent on state-owned entities providing research on Bruker products or using Bruker products in demonstration laboratories. The collaboration agreements did not specify the work product that the state-owned entities had to provide in order to be paid, and no work product was actually provided to the Bruker office by the state-owned entities. Certain collaboration agreements were executed directly with a Chinese government official rather than the state-owned entity itself, and in some cases Bruker\u2019s office paid the official directly. \n \n According to the SEC\u2019s order, the other improper payments involved reimbursements to Chinese government officials for leisure travel to the United States, Czech Republic, Norway, Sweden, France, Germany, Switzerland, and Italy. These officials often were responsible for authorizing the purchase of Bruker products, and the leisure trips typically followed business-related travel for the officials funded by the company. For example, Bruker paid for the purported training expenses of a Chinese government official who signed the sales contract on behalf of a state-owned entity, but the payment actually was reimbursement for sightseeing, tour tickets, shopping, and other leisure activities in Frankfurt and Paris. Bruker also funded some trips for Chinese government officials that had no legitimate business component. For example, two Chinese government officials received paid travel to New York despite the lack of any Bruker facilities there, and also to Los Angeles where they engaged in sightseeing activities.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Massachusetts-Based Scientific Instruments Manufacturer with FCPA Violations,\u0022 December 15, 2014.)","Sources ":"US SEC Press Release, \u0022SEC Charges Massachusetts-Based Scientific Instruments Manufacturer with FCPA Violations,\u0022 December 15, 2014, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370543708934; Administrative Proceeding File No.","Documents":""},{"Case ID":"ST-428","Case Cluster ":"Control Components, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Multiple","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"11\/9","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Plea Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$20,000.00 ","Criminal Fine\/Penalty (US$) ":"$20,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On July 22, 2009, Control Components, Inc. (CCI), a Rancho Santa Margarita, California-based company, was charged in a three count criminal information with violations of the FCPA and the Travel Act, stemming from a decade-long scheme to secure contracts in approximately 36 countries by paying bribes to officials and employees of various foreign state-owned companies as well as foreign and domestic private companies. Previously, two former executives of CCI, Mario Covino and Richard Morlok, were each charged with one count of conspiracy to bribe foreign officials in violation of the FCPA (on December 17, 2008 and January 7, 2009, respectively). On April 9, 2009, a grand jury in the Central District of California returned an indictment against six additional former CCI executives for their alleged roles in this bribery scheme. According to court documents, from 2003 through 2007, CCI, a manufacturer of service control valves for use in the nuclear, oil and gas, and power generation industries, made approximately 236 corrupt payments to officers and employees of foreign state-owned and private companies in more than 30 countries. Sales from these corrupt payments resulted in net profits to the company of approximately $46.5 million.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Control Componets, Inc. Case Summary, at 64-65.)","Sources ":"US v. Hong Rose Carson, Case No, 09-cr-77 (C.D. Cal), Judgment filed November 5, 2012","Documents":""},{"Case ID":"ST-429","Case Cluster ":"Control Components, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Multiple","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"11\/7","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Plea Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$20,000.00 ","Criminal Fine\/Penalty (US$) ":"$20,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On July 22, 2009, Control Components, Inc. (CCI), a Rancho Santa Margarita, California-based company, was charged in a three count criminal information with violations of the FCPA and the Travel Act, stemming from a decade-long scheme to secure contracts in approximately 36 countries by paying bribes to officials and employees of various foreign state-owned companies as well as foreign and domestic private companies. Previously, two former executives of CCI, Mario Covino and Richard Morlok, were each charged with one count of conspiracy to bribe foreign officials in violation of the FCPA (on December 17, 2008 and January 7, 2009, respectively). On April 9, 2009, a grand jury in the Central District of California returned an indictment against six additional former CCI executives for their alleged roles in this bribery scheme. According to court documents, from 2003 through 2007, CCI, a manufacturer of service control valves for use in the nuclear, oil and gas, and power generation industries, made approximately 236 corrupt payments to officers and employees of foreign state-owned and private companies in more than 30 countries. Sales from these corrupt payments resulted in net profits to the company of approximately $46.5 million.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Control Componets, Inc. Case Summary, at 64-65.)","Sources ":"US v. Stuart Carson, Case No, 09-cr-77 (C.D. Cal), Judgment filed November 7, 2012","Documents":""},{"Case ID":"ST-430","Case Cluster ":"Dallas Airmotive","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Argentina, Brazil, Peru","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"12\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Penalty","Total Monetary Sanctions (US$)":"$14,000,000","Criminal Fine\/Penalty (US$) ":"$14,000,000 ","Criminal Fine \/ Penalty (Explanation)":"$0 ","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"Accordng to the US Department of Justice, \u0022Dallas Airmotive Inc., a provider of aircraft engine maintenance, repair and overhaul services based in Grapevine, Texas, has admitted to violations of the Foreign Corrupt Practices Act (FCPA) and agreed to pay a $14 million criminal penalty to resolve charges that it bribed Latin American government officials in order to secure lucrative government contracts. [ ] \r\n \r\n A criminal information, filed today in federal court in the Northern District of Texas as part of the deferred prosecution agreement, charges Dallas Airmotive with one count of conspiring to violate the FCPA and one count of violating the FCPA\u2019s antibribery provisions. According to Dallas Airmotive\u2019s detailed admissions in the statement of facts accompanying the deferred prosecution agreement, between 2008 and 2012, the company bribed officials of the Brazilian Air Force, the Peruvian Air Force, the Office of the Governor of the Brazilian State of Roraima, and the Office of the Governor of the San Juan Province in Argentina. Dallas Airmotive used various methods to convey the bribe payments, including by entering into agreements with front companies affiliated with foreign officials, making payments to third party representatives with the understanding that funds would be directed to foreign officials, and directly providing things of value, such as paid vacations, to foreign officials.\u0022 (Source: US DOJ Press Release, \u0022Dallas Airmotive Inc. Admits Foreign Corrupt Practices Act Violations and Agrees to Pay $14 Million Criminal Penalty,\u0022 December 10, 2014.)","Sources ":"US v. Airmotive, Inc., Case No. 14-cr-483 (NDTX), Information filed December 10, 2014; Deferred Prosecution and US DOJ Press Release, \u0022Dallas Airmotive Inc. Admits Foreign Corrupt Practices Act Violations and Agrees to Pay $14 Million Criminal Penalty,\u0022 December 10, 2014, all accessed at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-dallas-airmotive-2014-court-docket-no-3-14-cr-483-d.","Documents":""},{"Case ID":"ST-431","Case Cluster ":"Data Systems \u0026 Solutions LLC","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Lithuania","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"6\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Penalty","Total Monetary Sanctions (US$)":"$8,820,000.00 ","Criminal Fine\/Penalty (US$) ":"$8,820,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Data Systems \u0026 Solutions LLC (DS\u0026S), a company based in Reston, Va., that provides design, installation, maintenance and other services at nuclear and fossil fuel power plants, has agreed to pay an $8.82 million criminal penalty to resolve violations of the Foreign Corrupt Practices Act (FCPA) [ ] , \r\n \r\n The department filed a two-count criminal information today in the Eastern District of Virginia charging DS\u0026S with conspiring to violate, and violating, the FCPA\u2019s anti-bribery provisions.\r\n \r\n According to court documents, DS\u0026S paid bribes to officials employed by the Ignalina Nuclear Power Plant, a state-owned nuclear power plant in Lithuania, to secure contracts to perform services for the plant. To disguise the scheme, the bribes were funneled through several subcontractors located in the United States and abroad. The subcontractors, in turn, made repeated payments to high-level officials at Ignalina via check or wire transfer.\u0022 (Source: US DOJ Press Release, \u0022Data Systems \u0026 Solutions LLC Resolves Foreign Corrupt Practices Act Violations and Agrees to Pay $8.82 Million Criminal Penalty,\u0022 June 18, 2012.)","Sources ":"US v. Data Systems \u0026 Solutions LLC, Case No. 12-cr-262 (EDVA), Information and Deferred Prosecution Agreement filed June 18, 2012 and DOJ Press Release, \u0022Data Systems \u0026 Solutions LLC Resolves Foreign Corrupt Practices Act Violations and Agrees to Pay $8.82 Million Criminal Penalty,\u0022 June 18, 2012, accessed at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-data-systems-solutions-llc-court-docket-number-12-cr-262-lo.","Documents":""},{"Case ID":"ST-432","Case Cluster ":"Diebold Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China, Indonesia, Russia","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"10\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Penalty","Total Monetary Sanctions (US$)":"$25,920,000.00 ","Criminal Fine\/Penalty (US$) ":"$25,920,000.00 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials; Conspiracy Falsification of Books and Records","Offenses - Settled":"Conspiracy to Bribe Foreign Officials; Conspiracy Falsification of Books and Records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Diebold Inc. (Diebold), the Ohio-based provider of integrated self-service delivery and security systems, including automated teller machines (ATMs), has agreed to pay a $25.2 million penalty to resolve allegations that it violated the Foreign Corrupt Practices Act (FCPA) by bribing government officials in China and Indonesia and falsifying records in Russia in order to obtain and retain contracts to provide ATMs to state-owned and private banks in those countries. [ ] \r\n \r\n The department today filed in U.S. District Court for the Northern District of Ohio a criminal information and a deferred prosecution agreement. The two-count information charges Diebold with conspiring to violate the FCPA\u2019s anti-bribery and books and records provisions and violating the FCPA\u2019s books and records provisions. [ ] \r\n \r\n According to court documents, Diebold paid bribes and falsified documents in connection with the sale of ATMs to bank customers in China, Indonesia, and Russia. With respect to China and Indonesia, the court documents allege that from 2005 to 2010, in order to secure and retain business with bank customers, including state-owned and -controlled banks, Diebold repeatedly provided things of value, including payments, gifts, and non-business travel for employees of the banks, totaling approximately $1.75 million. Diebold attempted to disguise the payments and benefits through various means, including by making payments through third parties designated by the banks and by inaccurately recording leisure trips for bank employees as \u201ctraining.\u201d The court documents also allege that from 2005 to 2009, Diebold created and entered into false contracts with a distributor in Russia for services that the distributor was not performing. The distributor, in turn, used the money that Diebold paid to it, in part, to pay bribes to employees of Diebold\u2019s privately-owned bank customers in Russia in order to obtain and retain ATM-related contracts with those customers.\u0022 (Source: US DOJ Press Release, \u0022Diebold Incorporated Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $25.2 Million Criminal Penalty,\u0022 October 22, 2013.)","Sources ":"US v. Diebold Inc., Case No. 13-cr-464 (ND Ohio), Information and Deferred Prosecution Agreement both filed October 22, 2013; DOJ Press Release, \u0022Diebold Incorporated Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $25.2 Million Criminal Penalty,\u0022 October 22, 2013, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-diebold-inc-court-docket-number-13-cr-000464-so","Documents":""},{"Case ID":"ST-433","Case Cluster ":"Diebold Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, Indonesia, Russia","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"10\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$22,972,942.00 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$19,719,550 ","Civil Prejudgment Interest (US$) ":"$3,253,392 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, Diebold, the \u0022Ohio-based manufacturer of ATMs and bank security systems with violating the Foreign Corrupt Practices Act by bribing officials at government-owned banks with pleasure trips in order to illicitly win business.\r\n \r\n The SEC alleges that subsidiaries of Diebold Inc. in China and Indonesia spent approximately $1.8 million on travel, entertainment, and other improper gifts for senior officials with the ability to influence the banks\u2019 purchasing decisions. Government-owned bank officials in China and Indonesia were rewarded with free trips to popular tourist destinations in the U.S. and Europe, and Diebold\u2019s expenditures were falsely recorded in the company\u2019s books and records as legitimate training expenses. Diebold\u2019s subsidiary in China also provided dozens of government bank officials with annual cash gifts ranging from less than $100 to more than $600. The SEC further alleges that Diebold falsified books and records to hide approximately $1.2 million of bribes paid to employees at privately owned banks in Russia. [ ] \r\n \r\n According to the SEC\u2019s complaint filed in federal court in Washington D.C., Diebold\u2019s misconduct occurred from 2005 to 2010. Among the tourist destinations of U.S. trips were the Grand Canyon, Napa Valley, Disneyland, and Universal Studios as well as Las Vegas, New York City, Chicago, Washington D.C., and Hawaii. Officials also were treated to European vacations. For example, eight officials at a government-owned bank in China enjoyed a two-week trip at Diebold\u2019s expense that included stays in Paris, Brussels, Amsterdam, Cologne, Frankfurt, Munich, Salzburg, Vienna, Klagenfurt, Venice, Florence, and Rome. Destinations of leisure trips for other officials included Australia, New Zealand, and Bali. In total, Diebold spent approximately $1.6 million to bribe government-owned bank officials in China, and more than $147,000 to bribe officials at government banks in Indonesia. \r\n \r\n The SEC further alleges that from 2005 to 2008, Diebold\u2019s Russian subsidiary paid approximately $1.2 million in bribes in connection with the sale of ATMs to private banks in Russia. The bribes were funneled through a distributor in Russia using phony service contracts to hide and falsely record the payments as legitimate business expenses.\u0022 (Source: SEC Press Release, \u0022SEC Charges Diebold With FCPA Violations,\u0022 October 22, 2013.)","Sources ":"US Securities and Exchange Commission v. Diebold Inc., Case No. 1:13-cv-01609 (DDC), Complaint filed October 12, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-225.pdf; Final Judgment of November 5, 2013 accessed at PACER;\r\n \r\n SEC Press Release, \u0022SEC Charges Diebold With FCPA Violations,\u0022 October 22, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370539977273","Documents":""},{"Case ID":"ST-434","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"4\/6","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$0.00 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials; Securities Fraud","Offenses - Settled":"Bribery of Foreign Officials; Securities Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022the global markets group at broker-dealer Direct Access Partners (DAP) executed fixed income trades for customers in foreign sovereign debt. DAP Global generated more than $66 million in revenue for DAP from transaction fees - in the form of markups and markdowns - on riskless principal trade executions in Venezuelan sovereign or state-sponsored bonds for Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES). A portion of this revenue was illicitly paid to BANDES Vice President of Finance, Mar\u00eda de los \u00c1ngeles Gonz\u00e1lez de Hernandez, who authorized the fraudulent trades. [ ] \r\n \r\n The SEC\u0027s complaint charges the following individuals for the roles in the kickback scheme:\r\n \r\n Tomas Alberto Clarke Bethancourt, who lives in Miami and is an executive vice president at DAP. Known as \u0022Tomas Clarke,\u0022 he was responsible for executing the fraudulent trades and maintaining spreadsheets tracking the illicit markups and markdowns on those trades.\r\n Iuri Rodolfo Bethancourt, who lives in Panama and received more than $20 million in fraudulent proceeds from DAP via his Panamanian shell company, which then paid Gonzalez a portion of this amount.\r\n Jose Alejandro Hurtado, who lives in Miami and served as the intermediary between DAP and Gonzalez. Hurtado was paid more than $6 million in kickbacks disguised as salary payments from DAP, and he remitted some of that money to Gonzalez.\r\n Haydee Leticia Pabon, who is Hurtado\u0027s wife and received approximately $8 million in markups or markdowns on BANDES trades that were funneled to her from DAP in the form of sham finders\u0027 fees. [ ]\r\n \r\n According to the SEC\u0027s complaint, the scheme began in October 2008 and continued until at least June 2010. BANDES was a new customer to DAP brought in by DAP Global executives through their connections to Hurtado. As a result of the kickbacks to Gonzalez, DAP obtained BANDES\u0027 lucrative trading business and provided Gonzalez with the incentive to enter into trades with DAP at considerable markups or markdowns without regard to the prices paid by BANDES. Gonzalez used her senior role at the Caracas-based bank to ensure that its bond trades would continue to be steered to DAP. As the scheme evolved over time, the traders deceived DAP\u0027s clearing brokers, executed internal wash trades, inter-positioned another broker-dealer in the trades to conceal their role in the transactions, and engaged in massive roundtrip trades to pad their revenue.\r\n \r\n For example, the SEC alleges that in January 2010, the traders and Gonzalez arranged for two fraudulent roundtrip trades with BANDES as both buyer and seller. These trades - which lacked any legitimate business purpose - caused BANDES to pay DAP more than $10 million in fees, a portion of which was diverted to Gonzalez for authorizing the blatantly fraudulent trades.\r\n \r\n The SEC further alleges that, giving rise to the adage of no honor among thieves, Clarke and Hurtado frequently falsified the size of DAP\u0027s fees in their reports to Gonzalez, which enabled the traders to retain a greater share of the fraudulent profits.\u0022 (Source: US SEC Press Release,\u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013.) \r\n \r\n In April 2014, Benito Chinea and Joseph DeMeneses were added to the SEC\u0027s complaint. In 2016, seven defendants in the case were ordered to forfeit $42,506,171, which was deemed satisfied by the criminal judgments imposed against them. (Source: US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank.\u0022)","Sources ":"US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank,\u0022 at https:\/\/www.sec.gov\/litigation\/litreleases\/2016\/lr23513.htm; \r\n \r\n US Securities and Exchange Commission v. Clarke Bethancourt, Bethancourt, Hurtado and Pabon, Case No. 13-cv-3074 (SDNY), Complaint filed May 7, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-84.pdf; SEC Press Release, \u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171514248","Documents":""},{"Case ID":"ST-435","Case Cluster ":"","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"4\/6","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$0.00 ","Criminal Fine\/Penalty (US$) ":"NA","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"NA","Criminal Restitution \/ Reparation (US$)":"NA","Criminal Legal \/ Procedural Costs (US$)":"NA","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"$0 ","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art. 16,  Art. 23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials; Securities Fraud","Offenses - Settled":"Bribery of Foreign Officials; Securities Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022the global markets group at broker-dealer Direct Access Partners (DAP) executed fixed income trades for customers in foreign sovereign debt. DAP Global generated more than $66 million in revenue for DAP from transaction fees - in the form of markups and markdowns - on riskless principal trade executions in Venezuelan sovereign or state-sponsored bonds for Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES). A portion of this revenue was illicitly paid to BANDES Vice President of Finance, Mar\u00eda de los \u00c1ngeles Gonz\u00e1lez de Hernandez, who authorized the fraudulent trades. [ ] \n \n The SEC\u0027s complaint charges the following individuals for the roles in the kickback scheme:\n \n Tomas Alberto Clarke Bethancourt, who lives in Miami and is an executive vice president at DAP. Known as \u0022Tomas Clarke,\u0022 he was responsible for executing the fraudulent trades and maintaining spreadsheets tracking the illicit markups and markdowns on those trades.\n Iuri Rodolfo Bethancourt, who lives in Panama and received more than $20 million in fraudulent proceeds from DAP via his Panamanian shell company, which then paid Gonzalez a portion of this amount.\n Jose Alejandro Hurtado, who lives in Miami and served as the intermediary between DAP and Gonzalez. Hurtado was paid more than $6 million in kickbacks disguised as salary payments from DAP, and he remitted some of that money to Gonzalez.\n Haydee Leticia Pabon, who is Hurtado\u0027s wife and received approximately $8 million in markups or markdowns on BANDES trades that were funneled to her from DAP in the form of sham finders\u0027 fees. [ ]\n \n According to the SEC\u0027s complaint, the scheme began in October 2008 and continued until at least June 2010. BANDES was a new customer to DAP brought in by DAP Global executives through their connections to Hurtado. As a result of the kickbacks to Gonzalez, DAP obtained BANDES\u0027 lucrative trading business and provided Gonzalez with the incentive to enter into trades with DAP at considerable markups or markdowns without regard to the prices paid by BANDES. Gonzalez used her senior role at the Caracas-based bank to ensure that its bond trades would continue to be steered to DAP. As the scheme evolved over time, the traders deceived DAP\u0027s clearing brokers, executed internal wash trades, inter-positioned another broker-dealer in the trades to conceal their role in the transactions, and engaged in massive roundtrip trades to pad their revenue.\n \n For example, the SEC alleges that in January 2010, the traders and Gonzalez arranged for two fraudulent roundtrip trades with BANDES as both buyer and seller. These trades - which lacked any legitimate business purpose - caused BANDES to pay DAP more than $10 million in fees, a portion of which was diverted to Gonzalez for authorizing the blatantly fraudulent trades.\n \n The SEC further alleges that, giving rise to the adage of no honor among thieves, Clarke and Hurtado frequently falsified the size of DAP\u0027s fees in their reports to Gonzalez, which enabled the traders to retain a greater share of the fraudulent profits.\u0022 (Source: US SEC Press Release,\u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013.) \n \n In April 2014, Benito Chinea and Joseph DeMeneses were added to the SEC\u0027s complaint. In 2016, seven defendants in the case were ordered to forfeit $42,506,171, which was deemed satisfied by the criminal judgments imposed against them. (Source: US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank.\u0022)","Sources ":"US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank,\u0022 at https:\/\/www.sec.gov\/litigation\/litreleases\/2016\/lr23513.htm; \n \n US Securities and Exchange Commission v. Clarke Bethancourt, Bethancourt, Hurtado and Pabon, Case No. 13-cv-3074 (SDNY), Complaint filed May 7, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-84.pdf; SEC Press Release, \u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171514248","Documents":""},{"Case ID":"ST-436","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"4\/6","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$0.00 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials; Securities Fraud","Offenses - Settled":"Bribery of Foreign Officials; Securities Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022the global markets group at broker-dealer Direct Access Partners (DAP) executed fixed income trades for customers in foreign sovereign debt. DAP Global generated more than $66 million in revenue for DAP from transaction fees - in the form of markups and markdowns - on riskless principal trade executions in Venezuelan sovereign or state-sponsored bonds for Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES). A portion of this revenue was illicitly paid to BANDES Vice President of Finance, Mar\u00eda de los \u00c1ngeles Gonz\u00e1lez de Hernandez, who authorized the fraudulent trades. [ ] \r\n \r\n The SEC\u0027s complaint charges the following individuals for the roles in the kickback scheme:\r\n \r\n Tomas Alberto Clarke Bethancourt, who lives in Miami and is an executive vice president at DAP. Known as \u0022Tomas Clarke,\u0022 he was responsible for executing the fraudulent trades and maintaining spreadsheets tracking the illicit markups and markdowns on those trades.\r\n Iuri Rodolfo Bethancourt, who lives in Panama and received more than $20 million in fraudulent proceeds from DAP via his Panamanian shell company, which then paid Gonzalez a portion of this amount.\r\n Jose Alejandro Hurtado, who lives in Miami and served as the intermediary between DAP and Gonzalez. Hurtado was paid more than $6 million in kickbacks disguised as salary payments from DAP, and he remitted some of that money to Gonzalez.\r\n Haydee Leticia Pabon, who is Hurtado\u0027s wife and received approximately $8 million in markups or markdowns on BANDES trades that were funneled to her from DAP in the form of sham finders\u0027 fees. [ ]\r\n \r\n According to the SEC\u0027s complaint, the scheme began in October 2008 and continued until at least June 2010. BANDES was a new customer to DAP brought in by DAP Global executives through their connections to Hurtado. As a result of the kickbacks to Gonzalez, DAP obtained BANDES\u0027 lucrative trading business and provided Gonzalez with the incentive to enter into trades with DAP at considerable markups or markdowns without regard to the prices paid by BANDES. Gonzalez used her senior role at the Caracas-based bank to ensure that its bond trades would continue to be steered to DAP. As the scheme evolved over time, the traders deceived DAP\u0027s clearing brokers, executed internal wash trades, inter-positioned another broker-dealer in the trades to conceal their role in the transactions, and engaged in massive roundtrip trades to pad their revenue.\r\n \r\n For example, the SEC alleges that in January 2010, the traders and Gonzalez arranged for two fraudulent roundtrip trades with BANDES as both buyer and seller. These trades - which lacked any legitimate business purpose - caused BANDES to pay DAP more than $10 million in fees, a portion of which was diverted to Gonzalez for authorizing the blatantly fraudulent trades.\r\n \r\n The SEC further alleges that, giving rise to the adage of no honor among thieves, Clarke and Hurtado frequently falsified the size of DAP\u0027s fees in their reports to Gonzalez, which enabled the traders to retain a greater share of the fraudulent profits.\u0022 (Source: US SEC Press Release,\u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013.) \r\n \r\n In April 2014, Benito Chinea and Joseph DeMeneses were added to the SEC\u0027s complaint. In 2016, seven defendants in the case were ordered to forfeit $42,506,171, which was deemed satisfied by the criminal judgments imposed against them. (Source: US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank.\u0022)","Sources ":"US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank,\u0022 at https:\/\/www.sec.gov\/litigation\/litreleases\/2016\/lr23513.htm; \r\n \r\n US Securities and Exchange Commission v. Clarke Bethancourt, Bethancourt, Hurtado and Pabon, Case No. 13-cv-3074 (SDNY), Complaint filed May 7, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-84.pdf; SEC Press Release, \u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171514248","Documents":""},{"Case ID":"ST-437","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"4\/6","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$0","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials; Securities Fraud","Offenses - Settled":"Bribery of Foreign Officials; Securities Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022the global markets group at broker-dealer Direct Access Partners (DAP) executed fixed income trades for customers in foreign sovereign debt. DAP Global generated more than $66 million in revenue for DAP from transaction fees - in the form of markups and markdowns - on riskless principal trade executions in Venezuelan sovereign or state-sponsored bonds for Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES). A portion of this revenue was illicitly paid to BANDES Vice President of Finance, Mar\u00eda de los \u00c1ngeles Gonz\u00e1lez de Hernandez, who authorized the fraudulent trades. [ ] \r\n \r\n The SEC\u0027s complaint charges the following individuals for the roles in the kickback scheme:\r\n \r\n Tomas Alberto Clarke Bethancourt, who lives in Miami and is an executive vice president at DAP. Known as \u0022Tomas Clarke,\u0022 he was responsible for executing the fraudulent trades and maintaining spreadsheets tracking the illicit markups and markdowns on those trades.\r\n Iuri Rodolfo Bethancourt, who lives in Panama and received more than $20 million in fraudulent proceeds from DAP via his Panamanian shell company, which then paid Gonzalez a portion of this amount.\r\n Jose Alejandro Hurtado, who lives in Miami and served as the intermediary between DAP and Gonzalez. Hurtado was paid more than $6 million in kickbacks disguised as salary payments from DAP, and he remitted some of that money to Gonzalez.\r\n Haydee Leticia Pabon, who is Hurtado\u0027s wife and received approximately $8 million in markups or markdowns on BANDES trades that were funneled to her from DAP in the form of sham finders\u0027 fees. [ ]\r\n \r\n According to the SEC\u0027s complaint, the scheme began in October 2008 and continued until at least June 2010. BANDES was a new customer to DAP brought in by DAP Global executives through their connections to Hurtado. As a result of the kickbacks to Gonzalez, DAP obtained BANDES\u0027 lucrative trading business and provided Gonzalez with the incentive to enter into trades with DAP at considerable markups or markdowns without regard to the prices paid by BANDES. Gonzalez used her senior role at the Caracas-based bank to ensure that its bond trades would continue to be steered to DAP. As the scheme evolved over time, the traders deceived DAP\u0027s clearing brokers, executed internal wash trades, inter-positioned another broker-dealer in the trades to conceal their role in the transactions, and engaged in massive roundtrip trades to pad their revenue.\r\n \r\n For example, the SEC alleges that in January 2010, the traders and Gonzalez arranged for two fraudulent roundtrip trades with BANDES as both buyer and seller. These trades - which lacked any legitimate business purpose - caused BANDES to pay DAP more than $10 million in fees, a portion of which was diverted to Gonzalez for authorizing the blatantly fraudulent trades.\r\n \r\n The SEC further alleges that, giving rise to the adage of no honor among thieves, Clarke and Hurtado frequently falsified the size of DAP\u0027s fees in their reports to Gonzalez, which enabled the traders to retain a greater share of the fraudulent profits.\u0022 (Source: US SEC Press Release,\u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013.) \r\n \r\n In April 2014, Benito Chinea and Joseph DeMeneses were added to the SEC\u0027s complaint. In 2016, seven defendants in the case were ordered to forfeit $42,506,171, which was deemed satisfied by the criminal judgments imposed against them. (Source: US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank.\u0022)","Sources ":"US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank,\u0022 at https:\/\/www.sec.gov\/litigation\/litreleases\/2016\/lr23513.htm; \r\n \r\n US Securities and Exchange Commission v. Clarke Bethancourt, Bethancourt, Hurtado and Pabon, Case No. 13-cv-3074 (SDNY), Complaint filed May 7, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-84.pdf; SEC Press Release, \u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171514248","Documents":""},{"Case ID":"ST-438","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"4\/6","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$0","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"$0 ","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials; Securities Fraud","Offenses - Settled":"Bribery of Foreign Officials; Securities Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022the global markets group at broker-dealer Direct Access Partners (DAP) executed fixed income trades for customers in foreign sovereign debt. DAP Global generated more than $66 million in revenue for DAP from transaction fees - in the form of markups and markdowns - on riskless principal trade executions in Venezuelan sovereign or state-sponsored bonds for Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES). A portion of this revenue was illicitly paid to BANDES Vice President of Finance, Mar\u00eda de los \u00c1ngeles Gonz\u00e1lez de Hernandez, who authorized the fraudulent trades. [ ] \r\n \r\n The SEC\u0027s complaint charges the following individuals for the roles in the kickback scheme:\r\n \r\n Tomas Alberto Clarke Bethancourt, who lives in Miami and is an executive vice president at DAP. Known as \u0022Tomas Clarke,\u0022 he was responsible for executing the fraudulent trades and maintaining spreadsheets tracking the illicit markups and markdowns on those trades.\r\n Iuri Rodolfo Bethancourt, who lives in Panama and received more than $20 million in fraudulent proceeds from DAP via his Panamanian shell company, which then paid Gonzalez a portion of this amount.\r\n Jose Alejandro Hurtado, who lives in Miami and served as the intermediary between DAP and Gonzalez. Hurtado was paid more than $6 million in kickbacks disguised as salary payments from DAP, and he remitted some of that money to Gonzalez.\r\n Haydee Leticia Pabon, who is Hurtado\u0027s wife and received approximately $8 million in markups or markdowns on BANDES trades that were funneled to her from DAP in the form of sham finders\u0027 fees. [ ]\r\n \r\n According to the SEC\u0027s complaint, the scheme began in October 2008 and continued until at least June 2010. BANDES was a new customer to DAP brought in by DAP Global executives through their connections to Hurtado. As a result of the kickbacks to Gonzalez, DAP obtained BANDES\u0027 lucrative trading business and provided Gonzalez with the incentive to enter into trades with DAP at considerable markups or markdowns without regard to the prices paid by BANDES. Gonzalez used her senior role at the Caracas-based bank to ensure that its bond trades would continue to be steered to DAP. As the scheme evolved over time, the traders deceived DAP\u0027s clearing brokers, executed internal wash trades, inter-positioned another broker-dealer in the trades to conceal their role in the transactions, and engaged in massive roundtrip trades to pad their revenue.\r\n \r\n For example, the SEC alleges that in January 2010, the traders and Gonzalez arranged for two fraudulent roundtrip trades with BANDES as both buyer and seller. These trades - which lacked any legitimate business purpose - caused BANDES to pay DAP more than $10 million in fees, a portion of which was diverted to Gonzalez for authorizing the blatantly fraudulent trades.\r\n \r\n The SEC further alleges that, giving rise to the adage of no honor among thieves, Clarke and Hurtado frequently falsified the size of DAP\u0027s fees in their reports to Gonzalez, which enabled the traders to retain a greater share of the fraudulent profits.\u0022 (Source: US SEC Press Release,\u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013.) \r\n \r\n In April 2014, Benito Chinea and Joseph DeMeneses were added to the SEC\u0027s complaint. In 2016, seven defendants in the case were ordered to forfeit $42,506,171, which was deemed satisfied by the criminal judgments imposed against them. (Source: US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank.\u0022)","Sources ":"US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank,\u0022 at https:\/\/www.sec.gov\/litigation\/litreleases\/2016\/lr23513.htm; \r\n \r\n US Securities and Exchange Commission v. Clarke Bethancourt, Bethancourt, Hurtado and Pabon, Case No. 13-cv-3074 (SDNY), Complaint filed May 7, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-84.pdf; SEC Press Release, \u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171514248","Documents":""},{"Case ID":"ST-439","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"4\/6","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$0","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials; Securities Fraud","Offenses - Settled":"Bribery of Foreign Officials; Securities Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022the global markets group at broker-dealer Direct Access Partners (DAP) executed fixed income trades for customers in foreign sovereign debt. DAP Global generated more than $66 million in revenue for DAP from transaction fees - in the form of markups and markdowns - on riskless principal trade executions in Venezuelan sovereign or state-sponsored bonds for Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES). A portion of this revenue was illicitly paid to BANDES Vice President of Finance, Mar\u00eda de los \u00c1ngeles Gonz\u00e1lez de Hernandez, who authorized the fraudulent trades. [ ] \r\n \r\n The SEC\u0027s complaint charges the following individuals for the roles in the kickback scheme:\r\n \r\n Tomas Alberto Clarke Bethancourt, who lives in Miami and is an executive vice president at DAP. Known as \u0022Tomas Clarke,\u0022 he was responsible for executing the fraudulent trades and maintaining spreadsheets tracking the illicit markups and markdowns on those trades.\r\n Iuri Rodolfo Bethancourt, who lives in Panama and received more than $20 million in fraudulent proceeds from DAP via his Panamanian shell company, which then paid Gonzalez a portion of this amount.\r\n Jose Alejandro Hurtado, who lives in Miami and served as the intermediary between DAP and Gonzalez. Hurtado was paid more than $6 million in kickbacks disguised as salary payments from DAP, and he remitted some of that money to Gonzalez.\r\n Haydee Leticia Pabon, who is Hurtado\u0027s wife and received approximately $8 million in markups or markdowns on BANDES trades that were funneled to her from DAP in the form of sham finders\u0027 fees. [ ]\r\n \r\n According to the SEC\u0027s complaint, the scheme began in October 2008 and continued until at least June 2010. BANDES was a new customer to DAP brought in by DAP Global executives through their connections to Hurtado. As a result of the kickbacks to Gonzalez, DAP obtained BANDES\u0027 lucrative trading business and provided Gonzalez with the incentive to enter into trades with DAP at considerable markups or markdowns without regard to the prices paid by BANDES. Gonzalez used her senior role at the Caracas-based bank to ensure that its bond trades would continue to be steered to DAP. As the scheme evolved over time, the traders deceived DAP\u0027s clearing brokers, executed internal wash trades, inter-positioned another broker-dealer in the trades to conceal their role in the transactions, and engaged in massive roundtrip trades to pad their revenue.\r\n \r\n For example, the SEC alleges that in January 2010, the traders and Gonzalez arranged for two fraudulent roundtrip trades with BANDES as both buyer and seller. These trades - which lacked any legitimate business purpose - caused BANDES to pay DAP more than $10 million in fees, a portion of which was diverted to Gonzalez for authorizing the blatantly fraudulent trades.\r\n \r\n The SEC further alleges that, giving rise to the adage of no honor among thieves, Clarke and Hurtado frequently falsified the size of DAP\u0027s fees in their reports to Gonzalez, which enabled the traders to retain a greater share of the fraudulent profits.\u0022 (Source: US SEC Press Release,\u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013.) \r\n \r\n In April 2014, Benito Chinea and Joseph DeMeneses were added to the SEC\u0027s complaint. In 2016, seven defendants in the case were ordered to forfeit $42,506,171, which was deemed satisfied by the criminal judgments imposed against them. (Source: US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank.\u0022)","Sources ":"US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank,\u0022 at https:\/\/www.sec.gov\/litigation\/litreleases\/2016\/lr23513.htm; \r\n \r\n US Securities and Exchange Commission v. Clarke Bethancourt, Bethancourt, Hurtado and Pabon, Case No. 13-cv-3074 (SDNY), Complaint filed May 7, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-84.pdf; SEC Press Release, \u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171514248","Documents":""},{"Case ID":"ST-440","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"11\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$8,347,849.00 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$8,347,849 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Violation of Travel Act; Money Laundering; Conspiring to violate the Travel Act and to commit money laundering","Offenses - Settled":"Violation of Travel Act; Money Laundering; Conspiring to violate the Travel Act and to commit money laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice press release of November 18, 2013, \u0022Maria De Los Angeles Gonzalez De Hernandez [ ] pleaded guilty [ ] to conspiring to violate the Travel Act and to commit money laundering, as well as substantive counts of these offenses. [ ] At all times relevant to the charges, Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES) was a state-run economic development bank in Venezuela. The Venezuelan government had a majority ownership interest in BANDES and provided it with substantial funding. \r\n  \r\n According to court records, Gonzalez was an official at BANDES and oversaw the development bank\u2019s overseas trading activity. At her direction, BANDES conducted substantial trading through the Broker-Dealer. Most of the trades executed by the Broker-Dealer on behalf of BANDES involved fixed income investments for which the Broker-Dealer charged the bank a mark-up on purchases and a mark-down on sales.\r\n \r\n  From early 2009 through 2012, Gonzalez participated in a bribery scheme in which she directed trading business she controlled at BANDES to the Broker-Dealer and, in return, agents and employees of the Broker-Dealer shared the revenue the Broker-Dealer generated from this trading business with Gonzalez. During this time period, the Broker-Dealer generated over $60 million in mark-ups and mark-downs from trades with BANDES. Agents and employees of the Broker-Dealer devised a split with Gonzalez of the commissions paid by BANDES to the Broker-Dealer. Emails, account records, and other documents collected from the Broker-Dealer and other sources reveal that Gonzalez received a substantial share of the revenue generated by the Broker-Dealer for BANDES-related trades. Specifically, Gonzalez received millions in bribe payments from Broker-Dealer agents and employees.\r\n \r\n  Additionally, Gonzalez paid a portion of the bribe payments she received to another BANDES employee who was also involved in the scheme. \r\n \r\n To further conceal the scheme, the kickbacks to Gonzalez were often paid using intermediary corporations and offshore accounts that Gonzalez and others held in Switzerland, among other places.\u0022 (Source: US Department of Justice Press Release, \u0022High-Ranking Bank Official at Venezuelan State Development Bank Pleads Guilty to Participating in Bribery Scheme,\u0022 November 18, 2013.)\r\n \r\n According to the Final Order of Forfeiture, Ms. De los Angeles Gonzalez de Hernandez was ordered to forfeit $8,347,849, in assetsheld held at Bank Hapoalim in the name of Maria de los Angeles Gonzalez and Jorge Hernandez and accounts held at Rahn \u0026 Bobmer and Banque Prevee BCP in the name of Wersen Group Ltd. (Source: US v. De los Angeles Gonzalez de Hernandez, Case No. 13-cr-901 (SDNY), FInal Order of Forfeiture filed April 1, 2016.)","Sources ":"US v. De Los Angeles Gonzalez de Hernandez, Case No. 13-cr-901 (SDNY), Final Order of Forfeiture filed April 1, 2016, accessed at Pacer; other court documents and Department of Justice Press Release, \u0022High-Ranking Bank Official at Venezuelan State Development Bank Pleads Guilty to Participating in Bribery Scheme,\u0022 November 18, 2013, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-maria-de-los-angeles-gonzalez-de-hernandez-court-docket-number","Documents":""},{"Case ID":"ST-441","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"8\/30","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$18,514,560 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$18,514,560 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials; Conspiracy to Bribe Foreign Officials, Violate Travel Act, Commit Money Laundering","Offenses - Settled":"Bribery of Foreign Officials; Conspiracy to Bribe Foreign Officials, Violate Travel Act, Commit Money Laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Ernesto Lujan, Jose Alejandro Hurtado and Tomas Alberto Clarke Bethancourt pleaded guilty in New York federal court to conspiring to violate the Foreign Corrupt Practices Act (FCPA), to violate the Travel Act and to commit money laundering, as well as substantive counts of these offenses. These charges relate to a scheme to bribe a foreign official named Maria de los Angeles Gonzalez de Hernandez at Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES), a state economic development bank in Venezuela, in exchange for receiving trading business from BANDES. Lujan, Hurtado and Clarke each also pleaded guilty to an additional charge of conspiring to violate the FCPA in connection with a similar scheme to bribe a foreign official employed by Banfoandes (the \u201cBanfoandes Foreign Official\u201d), another state economic development bank in Venezuela, and to conspiring to obstruct an examination by the U.S. Securities and Exchange Commission (SEC) of the New York-based broker-dealer (the \u201cBroker-Dealer\u201d) where all three defendants had worked, to conceal the true facts of the Broker-Dealer\u2019s relationship with BANDES. [ ] \r\n \r\n Lujan, Clarke and Hurtado worked or were associated with the Broker-Dealer, principally through its Miami offices. In 2008, the Broker-Dealer established a group called the Global Markets Group, which included Lujan, Clarke and Hurtado, and which offered fixed income trading services to institutional clients. \r\n \r\n One of the Broker-Dealer\u2019s clients was BANDES, which operated under the direction of the Venezuelan Ministry of Finance. The Venezuelan government had a majority ownership interest in BANDES and provided it with substantial funding. Gonzalez was an official at BANDES and oversaw the development bank\u2019s overseas trading activity. At her direction, BANDES conducted substantial trading through the Broker-Dealer. Most of the trades executed by the Broker-Dealer on behalf of BANDES involved fixed-income investments for which the Broker-Dealer charged the bank a mark-up on purchases and a mark-down on sales. \r\n \r\n The Broker-Dealer also conducted business with Banfoandes, another state development bank in Venezuela that, along with its 2009 successor Banco Bicentenario, operated under the direction of the Venezuelan Ministry of Finance. Banfoandes acted as a financial agent of the Venezuelan government in order to promote economic and social development by, among other things, offering credit to low-income Venezuelans. The Banfoandes Foreign Official was responsible for some of Banfoandes\u2019s foreign investments.\r\n \r\n Court records state that from early 2009 through 2012, Lujan, Clarke and Hurtado participated in a bribery scheme in which Gonzalez allegedly directed trading business she controlled at BANDES to the Broker-Dealer, and in return, agents and employees of the Broker-Dealer split the revenue the Broker-Dealer generated from this trading business with Gonzalez. During this time period, the Broker-Dealer generated over $60 million in mark-ups and mark-downs from trades with BANDES. Agents and employees of the Broker-Dealer, including Lujan, Clarke and Hurtado, devised a split with Gonzalez of the commissions paid by BANDES to the Broker-Dealer. Emails, account records and other documents collected from the Broker-Dealer and other sources reveal that Gonzalez allegedly received a substantial share of the revenue generated by the Broker-Dealer for BANDES-related trades. Specifically, Gonzalez allegedly received kickbacks and payments from Broker-Dealer agents and employees that were frequently in six-figure amounts.\r\n \r\n To further conceal the scheme, the kickbacks to Gonzalez were often paid using intermediary corporations and offshore accounts that she held in Switzerland, among other places. For instance, Lujan, Clarke and Hurtado used accounts they controlled in Switzerland to transfer funds to an account Gonzalez allegedly controlled in Switzerland. Additionally, Hurtado and his spouse received substantial compensation from the Broker-Dealer, portions of which Hurtado transferred to an account allegedly held by Gonzalez in Miami and to an account held by an associate of Gonzalez in Switzerland. Hurtado also sought and allegedly received reimbursement from Gonzalez for the U.S. income taxes he had paid on money that he used to make kickback payments to Gonzalez. Lujan and Clarke also derived substantial profit from their roles in the bribery scheme.\r\n  \r\n According to court records, beginning in or about November 2010, the SEC commenced a periodic examination of the Broker-Dealer, and from November 2010 through March 2011 the SEC\u2019s examination staff made several visits to the Broker-Dealer\u2019s offices in Manhattan. In early 2011, Lujan, Clarke and Hurtado discussed their concern that the SEC was examining the Broker-Dealer\u2019s relationship with BANDES and asking questions regarding certain emails and other information that the SEC examination staff had discovered. Lujan, Clarke and Hurtado agreed that they would take steps to conceal the true facts of the Broker-Dealer\u2019s relationship with BANDES, including deleting emails. Lujan, Clarke and Hurtado then, in fact, deleted emails. Additionally as part of this effort to obstruct the SEC examination, Clarke lied to SEC examination staff in response to an interview question about his relationship to an individual who had received purported foreign associate payments relating to BANDES. \r\n \r\n In a related scheme, from 2008 through mid-2009, Lujan, Clarke and Hurtado paid bribes to the Banfoandes Foreign Official, who, in exchange, directed Banfoandes trading business to the Broker-Dealer.\u0022 (Source: DOJ Press Release, \u0022Three Former Broker-dealer Employees Plead Guilty in Manhattan Federal Court to Bribery of Foreign Officials, Money Laundering and Conspiracy to Obstruct Justice, August 30, 2013.)","Sources ":"US v. Lujan, Case No. 13-cr-671 (SDNY), Final Order of Forfeiture (February 10, 2016) and Judgment (December 7, 2015), Court Docket Report as of April 19, 2016, accessed at PACER; DOJ Press Release, \u0022Three Former Broker-dealer Employees Plead Guilty in Manhattan Federal Court to Bribery of Foreign Officials, Money Laundering and Conspiracy to Obstruct Justice, August 30, 2013 and other related court documents at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-jose-alejandro-hurtado-court-docket-number-13-crim-673.","Documents":""},{"Case ID":"ST-442","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"8\/30","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$11,896,743 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$11,896,743 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials, Conspiracy to Commit Money Laundering, Money Laundering, Conspiracy to Obstruct Justice, Violation of Travel Act","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials, Conspiracy to Commit Money Laundering, Money Laundering, Conspiracy to Obstruct Justice, Violation of Travel Act","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Ernesto Lujan, Jose Alejandro Hurtado and Tomas Alberto Clarke Bethancourt pleaded guilty in New York federal court to conspiring to violate the Foreign Corrupt Practices Act (FCPA), to violate the Travel Act and to commit money laundering, as well as substantive counts of these offenses. These charges relate to a scheme to bribe a foreign official named Maria de los Angeles Gonzalez de Hernandez at Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES), a state economic development bank in Venezuela, in exchange for receiving trading business from BANDES. Lujan, Hurtado and Clarke each also pleaded guilty to an additional charge of conspiring to violate the FCPA in connection with a similar scheme to bribe a foreign official employed by Banfoandes (the \u201cBanfoandes Foreign Official\u201d), another state economic development bank in Venezuela, and to conspiring to obstruct an examination by the U.S. Securities and Exchange Commission (SEC) of the New York-based broker-dealer (the \u201cBroker-Dealer\u201d) where all three defendants had worked, to conceal the true facts of the Broker-Dealer\u2019s relationship with BANDES. [ ] \r\n \r\n Lujan, Clarke and Hurtado worked or were associated with the Broker-Dealer, principally through its Miami offices. In 2008, the Broker-Dealer established a group called the Global Markets Group, which included Lujan, Clarke and Hurtado, and which offered fixed income trading services to institutional clients. \r\n \r\n One of the Broker-Dealer\u2019s clients was BANDES, which operated under the direction of the Venezuelan Ministry of Finance. The Venezuelan government had a majority ownership interest in BANDES and provided it with substantial funding. Gonzalez was an official at BANDES and oversaw the development bank\u2019s overseas trading activity. At her direction, BANDES conducted substantial trading through the Broker-Dealer. Most of the trades executed by the Broker-Dealer on behalf of BANDES involved fixed-income investments for which the Broker-Dealer charged the bank a mark-up on purchases and a mark-down on sales. \r\n \r\n The Broker-Dealer also conducted business with Banfoandes, another state development bank in Venezuela that, along with its 2009 successor Banco Bicentenario, operated under the direction of the Venezuelan Ministry of Finance. Banfoandes acted as a financial agent of the Venezuelan government in order to promote economic and social development by, among other things, offering credit to low-income Venezuelans. The Banfoandes Foreign Official was responsible for some of Banfoandes\u2019s foreign investments.\r\n \r\n Court records state that from early 2009 through 2012, Lujan, Clarke and Hurtado participated in a bribery scheme in which Gonzalez allegedly directed trading business she controlled at BANDES to the Broker-Dealer, and in return, agents and employees of the Broker-Dealer split the revenue the Broker-Dealer generated from this trading business with Gonzalez. During this time period, the Broker-Dealer generated over $60 million in mark-ups and mark-downs from trades with BANDES. Agents and employees of the Broker-Dealer, including Lujan, Clarke and Hurtado, devised a split with Gonzalez of the commissions paid by BANDES to the Broker-Dealer. Emails, account records and other documents collected from the Broker-Dealer and other sources reveal that Gonzalez allegedly received a substantial share of the revenue generated by the Broker-Dealer for BANDES-related trades. Specifically, Gonzalez allegedly received kickbacks and payments from Broker-Dealer agents and employees that were frequently in six-figure amounts.\r\n \r\n To further conceal the scheme, the kickbacks to Gonzalez were often paid using intermediary corporations and offshore accounts that she held in Switzerland, among other places. For instance, Lujan, Clarke and Hurtado used accounts they controlled in Switzerland to transfer funds to an account Gonzalez allegedly controlled in Switzerland. Additionally, Hurtado and his spouse received substantial compensation from the Broker-Dealer, portions of which Hurtado transferred to an account allegedly held by Gonzalez in Miami and to an account held by an associate of Gonzalez in Switzerland. Hurtado also sought and allegedly received reimbursement from Gonzalez for the U.S. income taxes he had paid on money that he used to make kickback payments to Gonzalez. Lujan and Clarke also derived substantial profit from their roles in the bribery scheme.\r\n  \r\n According to court records, beginning in or about November 2010, the SEC commenced a periodic examination of the Broker-Dealer, and from November 2010 through March 2011 the SEC\u2019s examination staff made several visits to the Broker-Dealer\u2019s offices in Manhattan. In early 2011, Lujan, Clarke and Hurtado discussed their concern that the SEC was examining the Broker-Dealer\u2019s relationship with BANDES and asking questions regarding certain emails and other information that the SEC examination staff had discovered. Lujan, Clarke and Hurtado agreed that they would take steps to conceal the true facts of the Broker-Dealer\u2019s relationship with BANDES, including deleting emails. Lujan, Clarke and Hurtado then, in fact, deleted emails. Additionally as part of this effort to obstruct the SEC examination, Clarke lied to SEC examination staff in response to an interview question about his relationship to an individual who had received purported foreign associate payments relating to BANDES. \r\n \r\n In a related scheme, from 2008 through mid-2009, Lujan, Clarke and Hurtado paid bribes to the Banfoandes Foreign Official, who, in exchange, directed Banfoandes trading business to the Broker-Dealer.\u0022 (Source: DOJ Press Release, \u0022Three Former Broker-dealer Employees Plead Guilty in Manhattan Federal Court to Bribery of Foreign Officials, Money Laundering and Conspiracy to Obstruct Justice, August 30, 2013.)","Sources ":"US v. Hurtado, Case No. 13-cr-673 (SDNY), Amended Judgment filed January 22, 2016 and Preliminary Consent Order of Forfeiture filed December 15, 2015 and Orer of Forfeiture, filed March 21, 2016, accessed at PACER; DOJ Press Release, \u0022Three Former Broker-dealer Employees Plead Guilty in Manhattan Federal Court to Bribery of Foreign Officials, Money Laundering and Conspiracy to Obstruct Justice, August 30, 2013 and other related court documents at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-jose-alejandro-hurtado-court-docket-number-13-crim-673.","Documents":""},{"Case ID":"ST-443","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"3\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$2,670,612 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$2,670,612 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Travel Act","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Travel Act","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Benito Chinea, former chief executive officer and joseph DeMeneses, former managing director of a U.S. broker dealer Direct Access Partners Global [\u0022Broker Dealer\u0022]were sentenced in 2015 \u0022for their roles in a scheme to pay bribes to a senior official in Venezuela\u2019s state economic development bank, Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (Bandes), in return for trading business that generated more than $60 million in commissions. [ ] [Chinea and DeMeneses] were each sentenced to four years in prison. They were also ordered to pay $3,636,432 and $2,670,612 in forfeiture, respectively, which amounts represent their earnings from the bribery scheme. On Dec. 17, 2014, both defendants pleaded guilty to one count of conspiracy to violate the Foreign Corrupt Practices Act and the Travel Act.\u0022 According to the press release, it was alleged in the court documents that Chinea and DeMeneses, together with three Miami based employees participated in a bribery scheme that ran from late 2008 through 2012, in which Maria de los Angeles Gonzalez, a BANDES Vice President of Finance directed trading business to Direct Access Partners, and in return, agents and employees of DAP split the revenue that DAP generated from this trading business with Gonzalez. During this time period, DAP generated over $60 million in commissions from trades with BANDES. As further alleged in court documents, in order to conceal the scheme, payments to Gonzalez, frequently in six figure amounts, were routed through third parties posing as \u201cforeign finders\u201d and into offshore bank accounts. In several instances, Chinea personally signed checks worth millions of dollars that were made payable to one of these purported \u201cforeign finders\u201d and later deposited in a Swiss bank account. Chinea and DeMeneses admitted that they agreed to use DAP funds to reimburse DeMeneses and Clarke for the approximately $1.5 million from their personal funds they used to bribe Gonzalez. To conceal their true nature, Chinea and DeMeneses agreed to hide these reimbursements in DAP\u2019s books as sham loans from DAP to DeMeneses and Clarke. (Source: US DOJ Press Release, \u0022CEO and Managing Director Of US BrokerDealer Sentenced for\r\n International Bribery Scheme,\u0022 March 27, 2015.) Please note that the date of Mr. Chinea and Mr. DeMeneses\u0027 sentencing is used as the settlement date in this entry.","Sources ":"US v. Benito Chinea and Joseph DeMeneses, Case No. 14-cr-240, Indictment filed April 10, 2014 and DOJ Press Release, \u0022CEO and Managing Director Of US BrokerDealer Sentenced for International Bribery Scheme,\u0022 March 27, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-joseph-demeneses-court-docket-number-14-cr-240-dlc.","Documents":""},{"Case ID":"ST-444","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"8\/30","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$5,787,824 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$5,787,824 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Violate Travel Act, Commit Money Laundering; Bribery of Foreign Officials; Violation of Travel Act, Money Laundering, Conspiracy to Obstruct Justice","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Violate Travel Act, Commit Money Laundering; Bribery of Foreign Officials; Violation of Travel Act, Money Laundering, Conspiracy to Obstruct Justice","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Ernesto Lujan, Jose Alejandro Hurtado and Tomas Alberto Clarke Bethancourt pleaded guilty in New York federal court to conspiring to violate the Foreign Corrupt Practices Act (FCPA), to violate the Travel Act and to commit money laundering, as well as substantive counts of these offenses. These charges relate to a scheme to bribe a foreign official named Maria de los Angeles Gonzalez de Hernandez at Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES), a state economic development bank in Venezuela, in exchange for receiving trading business from BANDES. Lujan, Hurtado and Clarke each also pleaded guilty to an additional charge of conspiring to violate the FCPA in connection with a similar scheme to bribe a foreign official employed by Banfoandes (the \u201cBanfoandes Foreign Official\u201d), another state economic development bank in Venezuela, and to conspiring to obstruct an examination by the U.S. Securities and Exchange Commission (SEC) of the New York-based broker-dealer (the \u201cBroker-Dealer\u201d) where all three defendants had worked, to conceal the true facts of the Broker-Dealer\u2019s relationship with BANDES. [ ] In a related scheme, from 2008 through mid-2009, Lujan, Clarke and Hurtado paid bribes to the Banfoandes Foreign Official, who, in exchange, directed Banfoandes trading business to the Broker-Dealer.\u0022 (Source: US Department of Justice Press Release, \u0022Three Former Broker-dealer Employees Plead Guilty in Manhattan Federal Court to Bribery of Foreign Officials, Money Laundering and Conspiracy to Obstruct Justice,\u0022 August 30, 2013, at https:\/\/www.justice.gov\/opa\/pr\/three-former-broker-dealer-employees-plead-guilty-manhattan-federal-court-bribery-foreign.)\r\n \r\n As part of his plea agreement, Mr. Clarke Bethancourt agreed and was ordered to forfeit: 1) real property at 485 Brickell Avenue, 2) $48,334.34 and $264,000 in cash, 3) all assets held by ETC Investments at accounts in Mirabaud \u0026 Cie in Switzerland, 4) any and all assets on deposit at Banco General SA in Panama, 5) any and all assets held at CBH Compagnie Bancaire Helvetique SA in Switzerland, and 5) all assets up to $1,247,057.50. (Source: US v. Clarke Bethancourt, Case No. 13-cr-670 (SDNY), Consent Preliminary Order of Forfeiture filed December 8, 2015.)","Sources ":"US v. Clarke Bethancourt, Case No. 13-cr-670 (SDNY), Consent Preliminary Order of Forfeiture filed December 8, 2015, accessed at Pacer; otehr related court documents at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-tomas-alberto-clarke-bethancourt-court-docket-number-13-crim-670","Documents":""},{"Case ID":"ST-445","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"https:\/\/www.sec.gov\/litigation\/litreleases\/2016\/lr23513.htm","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$3,636,432 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$3,636,432 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Travel Act","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Travel Act","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Benito Chinea, former chief executive officer and joseph DeMeneses, former managing director of a U.S. broker dealer Direct Access Partners Global [\u0022Broker Dealer\u0022]were sentenced in 2015 \u0022for their roles in a scheme to pay bribes to a senior official in Venezuela\u2019s state economic development bank, Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (Bandes), in return for trading business that generated more than $60 million in commissions. [ ] [Chinea and DeMeneses] were each sentenced to four years in prison. They were also ordered to pay $3,636,432 and $2,670,612 in forfeiture, respectively, which amounts represent their earnings from the bribery scheme. On Dec. 17, 2014, both defendants pleaded guilty to one count of conspiracy to violate the Foreign Corrupt Practices Act and the Travel Act.\u0022 According to the press release, it was alleged in the court documents that Chinea and DeMeneses, together with three Miami based employees participated in a bribery scheme that ran from late 2008 through 2012, in which Maria de los Angeles Gonzalez, a BANDES Vice President of Finance directed trading business to Direct Access Partners, and in return, agents and employees of DAP split the revenue that DAP generated from this trading business with Gonzalez. During this time period, DAP generated over $60 million in commissions from trades with BANDES. As further alleged in court documents, in order to conceal the scheme, payments to Gonzalez, frequently in six figure amounts, were routed through third parties posing as \u201cforeign finders\u201d and into offshore bank accounts. In several instances, Chinea personally signed checks worth millions of dollars that were made payable to one of these purported \u201cforeign finders\u201d and later deposited in a Swiss bank account. Chinea and DeMeneses admitted that they agreed to use DAP funds to reimburse DeMeneses and Clarke for the approximately $1.5 million from their personal funds they used to bribe Gonzalez. To conceal their true nature, Chinea and DeMeneses agreed to hide these reimbursements in DAP\u2019s books as sham loans from DAP to DeMeneses and Clarke. (Source: US DOJ Press Release, \u0022CEO and Managing Director Of US BrokerDealer Sentenced for\r\n International Bribery Scheme,\u0022 March 27, 2015.) Please note that the date of Mr. Chinea and Mr. DeMeneses\u0027 sentencing is used as the settlement date in this entry.","Sources ":"US v. Benito Chinea and Joseph DeMeneses, Case No. 14-cr-240, Indictment filed April 10, 2014 and DOJ Press Release, \u0022CEO and Managing Director Of US BrokerDealer Sentenced for International Bribery Scheme,\u0022 March 27, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-benito-chinea-court-docket-number-14-cr-240-dlc","Documents":""},{"Case ID":"ST-446","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"$0 ","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of Foreign Officials; Securities Fraud","Offenses - Settled":"Bribery of Foreign Officials; Securities Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022the global markets group at broker-dealer Direct Access Partners (DAP) executed fixed income trades for customers in foreign sovereign debt. DAP Global generated more than $66 million in revenue for DAP from transaction fees - in the form of markups and markdowns - on riskless principal trade executions in Venezuelan sovereign or state-sponsored bonds for Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES). A portion of this revenue was illicitly paid to BANDES Vice President of Finance, Mar\u00eda de los \u00c1ngeles Gonz\u00e1lez de Hernandez, who authorized the fraudulent trades. [ ] \r\n \r\n The SEC\u0027s complaint charges the following individuals for the roles in the kickback scheme:\r\n \r\n Tomas Alberto Clarke Bethancourt, who lives in Miami and is an executive vice president at DAP. Known as \u0022Tomas Clarke,\u0022 he was responsible for executing the fraudulent trades and maintaining spreadsheets tracking the illicit markups and markdowns on those trades.\r\n Iuri Rodolfo Bethancourt, who lives in Panama and received more than $20 million in fraudulent proceeds from DAP via his Panamanian shell company, which then paid Gonzalez a portion of this amount.\r\n Jose Alejandro Hurtado, who lives in Miami and served as the intermediary between DAP and Gonzalez. Hurtado was paid more than $6 million in kickbacks disguised as salary payments from DAP, and he remitted some of that money to Gonzalez.\r\n Haydee Leticia Pabon, who is Hurtado\u0027s wife and received approximately $8 million in markups or markdowns on BANDES trades that were funneled to her from DAP in the form of sham finders\u0027 fees. [ ]\r\n \r\n According to the SEC\u0027s complaint, the scheme began in October 2008 and continued until at least June 2010. BANDES was a new customer to DAP brought in by DAP Global executives through their connections to Hurtado. As a result of the kickbacks to Gonzalez, DAP obtained BANDES\u0027 lucrative trading business and provided Gonzalez with the incentive to enter into trades with DAP at considerable markups or markdowns without regard to the prices paid by BANDES. Gonzalez used her senior role at the Caracas-based bank to ensure that its bond trades would continue to be steered to DAP. As the scheme evolved over time, the traders deceived DAP\u0027s clearing brokers, executed internal wash trades, inter-positioned another broker-dealer in the trades to conceal their role in the transactions, and engaged in massive roundtrip trades to pad their revenue.\r\n \r\n For example, the SEC alleges that in January 2010, the traders and Gonzalez arranged for two fraudulent roundtrip trades with BANDES as both buyer and seller. These trades - which lacked any legitimate business purpose - caused BANDES to pay DAP more than $10 million in fees, a portion of which was diverted to Gonzalez for authorizing the blatantly fraudulent trades.\r\n \r\n The SEC further alleges that, giving rise to the adage of no honor among thieves, Clarke and Hurtado frequently falsified the size of DAP\u0027s fees in their reports to Gonzalez, which enabled the traders to retain a greater share of the fraudulent profits.\u0022 (Source: US SEC Press Release,\u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013.) \r\n \r\n In April 2014, Benito Chinea and Joseph DeMeneses were added to the SEC\u0027s complaint. In 2016, seven defendants in the case were ordered to forfeit $42,506,171, which was deemed satisfied by the criminal judgments imposed against them. (Source: US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank.\u0022)","Sources ":"US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank,\u0022 at https:\/\/www.sec.gov\/litigation\/litreleases\/2016\/lr23513.htm; US Securities and Exchange Commission v. Clarke Bethancourt, Bethancourt, Hurtado and Pabon, Case No. 13-cv-3074 (SDNY), Complaint filed May 7, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-84.pdf; SEC Press Release, \u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171514248","Documents":""},{"Case ID":"ST-260","Case Cluster ":"Lucent Technologies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"12\/21","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$1,500,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$1,500,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Lucent Technologies, Inc. at 68-69, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf:  DOJ - $1 million fine; SEC - $1.5 million civil penalties; Misconduct in China, 2000-2003, company spent over $1.3 million in travel and other things of value for senior level government officials, including heads of state-owned telecommunications companies in Beijing and leaders of provincial telecommunications subsidiaries.  Resulting Criminal Enforcement Action: In Re Lucent Technologies inc. (December 21, 2007); Civil action: SEC v. Lucent Technologies Inc. (D.D.C., December 21, 2007). According to the Statement of Facts attached to the non-prosecution agreement by the US Department of Justice and Lucent, from at least 2000 to 2003, Lucent provided approximately 315 trips for Chinese government officials which were primarily for sightseeing, entertainment, and leisure in Boston, Las Vegas, the Grand Canyon and Hawaii; an April 2001 personal visit to San Francisco by a director of a regional, state-owned broadband provider and her guest; a January 2003 travel to Hong Kong and Thailand for a seven-day vacation by the deputy manager of a subsidiary of a large state-owned telecommunications service provider in China, his wife and daughter and other pre- and post-sales trips and paying for educational (MBA) costs, paid internship for a daughter of a Chinese government official working at the Chinese embassy in the U.S. (Source: Non-Prosecution Agreement, Appendix A: Statement of Facts, In Re Lucent Technologies, Inc. dated November 14, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/lucent-tech\/11-14-07lucent-agree.pdf.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Lucent Technologies, Inc. at 68-69, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-apppx-c.pdf; US Department of Justice Press Release, \u0022Lucent Technologies Inc. Agrees to Pay $1 Million Fine to Resolve FCPA Allegations,\u0022 December 21, 2007, accessed at http:\/\/www.justice.gov\/opa\/pr\/2007\/December\/07_crm_1028.html (accessed September 15, 2011); In Re Lucent Technologies, Inc., Department of Justice Non-Prosecution Agreement and Appendix A: Statement of Facts (dated November 14, 2007), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/lucent-tech\/11-14-07lucent-agree.pdf; SEC v. Lucent Technologies, Case No. 1:07-cv-02301-RBW (D.D.C.), Complaint filed December 21, 2007, accessed at http:\/\/fcpa.shearman.com\/files\/2df\/2df2c9377360116808a51bd869d91227.pdf?i=d127b5a5143e9fa5206999c01419e264; Securities and Exchange Commission Litigation Release No. 20414 \/ December 21, 2007, accessed at http:\/\/fcpa.shearman.com\/files\/22b\/22bad0eccb9eefdb54f168bafc03db0d.pdf?i=359c3469ccf281e16e805da3d9dce8f6.","Documents":""},{"Case ID":"ST-259","Case Cluster ":"Lucent Technologies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"12\/21","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,000,000.00","Criminal Fine\/Penalty (US$) ":"$1,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Lucent Technologies, Inc. at 68-69, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf:  DOJ - $1 million fine; SEC - $1.5 million civil penalties; Misconduct in China, 2000-2003, company spent over $1.3 million in travel and other things of value for senior level government officials, including heads of state-owned telecommunications companies in Beijing and leaders of provincial telecommunications subsidiaries.  Resulting Criminal Enforcement Action: In Re Lucent Technologies inc. (December 21, 2007); Civil action: SEC v. Lucent Technologies Inc. (D.D.C., December 21, 2007). According to the Statement of Facts attached to the non-prosecution agreement by the US Department of Justice and Lucent, from at least 2000 to 2003, Lucent provided approximately 315 trips for Chinese government officials which were primarily for sightseeing, entertainment, and leisure in Boston, Las Vegas, the Grand Canyon and Hawaii; an April 2001 personal visit to San Francisco by a director of a regional, state-owned broadband provider and her guest; a January 2003 travel to Hong Kong and Thailand for a seven-day vacation by the deputy manager of a subsidiary of a large state-owned telecommunications service provider in China, his wife and daughter and other pre- and post-sales trips and paying for educational (MBA) costs, paid internship for a daughter of a Chinese government official working at the Chinese embassy in the U.S. (Source: Non-Prosecution Agreement, Appendix A: Statement of Facts, In Re Lucent Technologies, Inc. dated November 14, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/lucent-tech\/11-14-07lucent-agree.pdf.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Lucent Technologies, Inc. at 68-69, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-apppx-c.pdf; US Department of Justice Press Release, \u0022Lucent Technologies Inc. Agrees to Pay $1 Million Fine to Resolve FCPA Allegations,\u0022 December 21, 2007, accessed at http:\/\/www.justice.gov\/opa\/pr\/2007\/December\/07_crm_1028.html (accessed September 15, 2011); In Re Lucent Technologies, Inc., Department of Justice Non-Prosecution Agreement and Appendix A: Statement of Facts (dated November 14, 2007), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/lucent-tech\/11-14-07lucent-agree.pdf; SEC v. Lucent Technologies, Case No. 1:07-cv-02301-RBW (D.D.C.), Complaint filed December 21, 2007, accessed at http:\/\/fcpa.shearman.com\/files\/2df\/2df2c9377360116808a51bd869d91227.pdf?i=d127b5a5143e9fa5206999c01419e264; Securities and Exchange Commission Litigation Release No. 20414 \/ December 21, 2007, in same case, accessed at http:\/\/fcpa.shearman.com\/files\/22b\/22bad0eccb9eefdb54f168bafc03db0d.pdf?i=359c3469ccf281e16e805da3d9dce8f6.","Documents":""},{"Case ID":"ST-299","Case Cluster ":"Pacific Consolidated Industries LP","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"United Kingdom","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"09\/03","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$7,500.00","Criminal Fine\/Penalty (US$) ":"$7,500","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering, Bribery of Foreign Officials, International Money Laundering, False Statement in a Tax Return","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering, Bribery of Foreign Officials, International Money Laundering, False Statement in a Tax Return","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Pacific Consolidated Industries LP, at 63-64, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: Time period of misconduct in United Kingdom, 1993-2003; Martin Eric Self and Leo Winston Smith, two executives of Pacific Consolidated Industries (which later went defunct) caused PCI to enter into a marketing agreement with  a person they understood to be a relative of the UK-MOD official\/project manager directly involved in the procurement of Air Separation Units (which PCI manufactured) on behalf of the UK-Ministry of Defence.  The ASU and related contracts awarded to PCI were valued at over $11 million. The executives were charged with participating in a scheme to make more than $370,000 in illicit payments, and Smith was also charged with failing to report nearly $500,000 in commissions from PCI on his tax returns.  Self pleaded guilty and was ordered to pay $7,500 criminal fine; Smith also pleaded guilty and was ordered to pay $20,000 in criminal fine. PCI was a private company. The UK-MOD official pleaded guilty in the UK to accepting more than $300,000 in bribes from PCI and was sentenced to two years in prison.  According to the United Kingdom\u0027s \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 Ministry of Defence official, Michael Hale, was convicted in April 2007, on nine counts of accepting bribes totalling \u00a3217,000. (Source:  United Kingdom\u0027s \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 September 2008, accessed at www.dfid.gov.uk\/documents).  The UK\u0027s MailOnline (and other media) reported on April 16, 2007 that Michael Hale, a senior military official, had plead guilty in Southwark Crown Court to charges of receiving bribes from Pacific Consolidated Industries. (Source: MailOnline, \u0022Senior MoD jailed for taking bribes from US arms dealer,\u0022 April 16, 2007, accessed at http:\/\/www.dailymail.co.uk\/news\/article-448968\/Senior-MoD-jailed-taking-bribes-US-arms-dealer.html.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Pacific Consolidated Industries LP, at 63-64, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf:  US Department of Justice Press Release, \u0022Former Pacific Consolidated Industries LP Executive [Martin Eric Self] Pleads Guilty in Connection with Bribes Paid to U.K. Ministry of Defence Official,\u0022 May 8, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/May\/08-crm-394.html; US Department of Justice Press Release, \u0022Former Pacific Consolidated Industries LP Executive [Leo Winston Smith] Pleads Guilty in Connection with Bribes Paid to U.K. Ministry of Defense Official,\u0022 September 3, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/September\/09-crm-928.html;  US v. Leo Winston Smith, Case No. 8:07-cr-00069-AG (C.D.Ca.),  Amended Judgment filed January 11, 2011, accessed at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/smithl\/01-11-11smith-leo-amended.pdf; US v. Martin Eric Self, Case No. 8:08-cr-00110-AG (C.D. Ca.), Judgment filed November 17, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/selfm\/11-17-08self-judgment.pdf; United Kingdom\u0027s \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 September 2008, accessed at www.dfid.gov.uk\/documents; MailOnline, \u0022Senior MoD jailed for taking bribes from US arms dealer,\u0022 April 16, 2007, accessed at http:\/\/www.dailymail.co.uk\/news\/article-448968\/Senior-MoD-jailed-taking-bribes-US-arms-dealer.html.","Documents":""},{"Case ID":"ST-322","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Munich Public Prosecution Office","Jurisdiction of Foreign Public Official(s) ":"Various","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"12\/15","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Art. 30 Administrative Code-OWiG","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$528,585,548.00","Criminal Fine\/Penalty (US$) ":"$334,548","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$528,251,000","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Sections 130 and 30 AdministrativeCode-OWiG (Breach of Directors Duties)","Offenses - Settled":"Sections 130 and 30 Administrative Code-OWiG (Breach of Directors Duties)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the March 2011 Report by the Organisation for Economic Co-Operation and Development (OECD) on Germany\u0027s Enforcement of the Anti-Bribery Convention, Germany prosecuted two Siemens-related cases, and cited as sources: \u0022i) Decision of the Munich I Regional Court of 4 October 2007 pursuant to section 30 OWiG in conjunction with section 334 CC - against the telecommunication unit of Siemens \u2013 fine of EUR 201 million (see also Annual reports 2006-2007 and 2007-2008 Bavaria (i) and Germany\u2019s reply to Phase 3 questionnaires), hereinafter Case \u201cTelecommunications Unit of Siemens\u201d; ii) Decision of the Munich I Public Prosecution office of 15 December 2008 pursuant to sections 130 and 30 OWiG - against Siemens \u2013 Fine of EUR 395 million (see all Annual reports, about a \u00ab Hesse based Company \u00bb and related decision of the Federal Court of Justice of 28 August 2008 - Ref. Supra.), hereinafter Case \u201cSiemens (except Telecommunications Unit)\u201d  (Source: Organisation for Economic Co-operation and Development, \u0022Germany: Phase 3, Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Transactions, approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011.\u0022)","Sources ":"Organisation for Economic Co-operation and Development, \u0022Germany: Phase 3, Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Transactions, approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011,\u0022 accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf. US Department of Justice Press Release, \u0022Siemens AG and Three Subsidiaries Plead Guilty to Foreign Corrupt Practices Act Violations and Agree to Pay $450 million in Combined Criminal Fines,\u0022 December 15, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/December\/08-crm-1105.html; ","Documents":""},{"Case ID":"ST-329","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Munich Public Prosecution Office","Jurisdiction of Foreign Public Official(s) ":"Libya, Nigeria, Russia","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"10\/04","Other Jurisdictions of Settlement":"United States, The World Bank","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Art. 30 Administrative Code-OWiG","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$284,585,850.00","Criminal Fine\/Penalty (US$) ":"$1,415,850","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$283,170,000","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Breach of Trust (section 266(1) Criminal Code)","Offenses - Settled":"Breach of Trust (section 266(1) Criminal Code)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the March 2011 Report by the Organisation for Economic Co-Operation and Development (OECD) on Germany\u0027s Enforcement of the Anti-Bribery Convention, Germany prosecuted two Siemens-related cases, and cited as sources: \u0022i) Decision of the Munich I Regional Court of 4 October 2007 pursuant to section 30 OWiG in conjunction with section 334 CC - against the telecommunication unit of Siemens \u2013 fine of EUR 201 million (see also Annual reports 2006-2007 and 2007-2008 Bavaria (i) and Germany\u2019s reply to Phase 3 questionnaires), hereinafter Case \u201cTelecommunications Unit of Siemens\u201d; ii) Decision of the Munich I Public Prosecution office of 15 December 2008 pursuant to sections 130 and 30 OWiG - against Siemens \u2013 Fine of EUR 395 million (see all Annual reports, about a \u00ab Hesse based Company \u00bb and related decision of the Federal Court of Justice of 28 August 2008 - Ref. Supra.), hereinafter Case \u201cSiemens (except Telecommunications Unit)\u201d  (Source: Organisation for Economic Co-operation and Development, \u0022Germany: Phase 3, Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Transactions, approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011.\u0022)","Sources ":"Organisation for Economic Co-operation and Development, \u0022Germany: Phase 3, Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Transactions, approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011,\u0022 accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf. replace with: http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Germanyphase3reportEN.pdf  US Department of Justice Press Release, \u0022Siemens AG and Three Subsidiaries Plead Guilty to Foreign Corrupt Practices Act Violations and Agree to Pay $450 million in Combined Criminal Fines,\u0022 December 15, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/December\/08-crm-1105.html.","Documents":""},{"Case ID":"ST-242","Case Cluster ":"Johnson \u0026 Johnson","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Greece","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"04\/08","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Civil  Recovery Order (Proceeds of Crime Act)","Monetary Sanctions  (Types)":"Civil  Recovery Order ","Total Monetary Sanctions (US$)":"$7,877,400.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$7,877,400","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Unlawful Conduct - payments made by DePuy International Limited to intermediaries for the purpose of making corrupt payments to Greek medical professionals working in the Greek public health system","Offenses - Settled":"Unlawful Conduct - payments made by DePuy International Limited to intermediaries for the purpose of making corrupt payments to Greek medical professionals working in the Greek public health system","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a UK Serious Fraud Office Press Release, on April 8, 2011, the SFO obtained a Civil Recovery Order for GBP 4.829 million and prosecution costs against DePuy International Limited (a UK subsidiary of the US parent company Johnson \u0026 Johnson), \u0022in recognition of unlawful conduct relating to the sale of orthopaedic products in Greece between 1998 and 2006.\u0022  The SFO launched its investigation following a referral from the US Department of Justice in October 2007 and worked closely with the US DOJ and the Securities and Exchange Commission.  \u0022The unlawful conduct consisted of payments made by DePuy International Limited to intermediaries for the purpose of making corrupt payments to Greek medical professionals working in the Greek public health system. Payments to the intermediaries amounted to twenty percent of the price, at which the orthopaedic product was ultimately sold. These payments covered the commission for the intermediary and were available to be used to pay inducements or rewards for the use of orthopaedic products sold by DePuy International Limited. [  ] The corporate benefit sought by DePuy International Limited, as a result of the payments to intermediaries, was retention and enhancement of market position. The Greek government paid DePuy International Limited\u0027s intermediaries approximately \u00a333.5 million for orthopaedic products between 1998 and 2007.  [  ] On the facts of this case, criminal sanction of the Greek conduct has been achieved by the conclusion of a Deferred Prosecution Agreement with DePuy International Limited\u0027s parent company and the DOJ.  The Director of the Serious Fraud Office has concluded that a prosecution was therefore prevented in this jurisdiction by the principles of double jeopardy. The underlying purpose of the rule against double jeopardy is to stop a defendant from being prosecuted twice for the same offence in different jurisdictions. The DOJ Deferred Prosecution Agreement has the legal character of a formally concluded prosecution and punishes the same conduct in Greece that had formed the basis of the Serious Fraud Office investigation.  Combined criminal and civil sanctions have therefore been imposed in the United States in respect of Depuy International Limited\u0027s parent and assets have been frozen in the ongoing Greek investigation, all relating to the same conduct in Greece. Consequently the Serious Fraud office is satisfied that the most appropriate sanction is a Civil Recovery Order, under the Proceeds of Crime Act 2002.  As has been described approximately \u00a333.5 million represents the sales, tainted by the unlawful conduct, made to public hospitals by DePuy International Limited\u0027s Greek intermediaries. Approximately \u00a314.8 million of this passed from the Greek intermediary to DePuy International Limited in respect of orthopaedic products for use in the public health care system. Consequently \u00a314.8 million can be said to represent unlawfully obtained property.  In the context of a global resolution, the Serious Fraud Office has taken particular note of the fact of disgorgement and recovery in more than one jurisdiction for the same underlying unlawful conduct. The Serious Fraud Office has also taken into account asset tracing difficulties.\u0022 (Source:  UK Serious Fraud Office Press Release, \u0022DePuy International Limited ordered to pay 4.829 million pounds in Civil Recovery Order,\u0022 April 8, 2011.)","Sources ":"UK Serious Fraud Office Press Release, \u0022DePuy International Limited ordered to pay 4.829 million pounds in Civil Recovery Order,\u0022 April 8, 2011, accessed at: http:\/\/www.sfo.gov.uk\/press-room\/press-release-archive\/press-releases-2011\/depuy-international-limited-ordered-to-pay-4829-million-in-civil-recovery-order.aspx;  See also, UK Serious Fraud Office Press Release, \u0022British executive jailed for part in Greek healthcare corruption,\u0022 April 14, 2010, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2010\/british-executive-jailed-for-part-in-greek-healthcare-corruption.aspx.","Documents":""},{"Case ID":"ST-292","Case Cluster ":"Oil States International, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"04\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD, \u0022From 2003 through 2004, Oil States International, Inc. (Oil States), through certain employees of one of its subsidiaries, Hydraulic Well Control LLC (HWC), provided approximately $348,350 in improper payments to employees of Petr\u00f3leos de Venezuela, S.A. (PdVSA), an energy company owned by the government of Venezuela. Previously, HWC had hired a consultant to help it secure business from PdVSA. In December 2003, three PdVSA employees approached HWC\u2018s consultant and asked the consultant to submit inflated bills to HWC for his services and pay these excess funds to the PdVSA employees in the form of kickbacks. These employees also threatened to undermine or undo HWC\u2018s contracts with PdVSA if the company refused to pay the requested kickbacks. In turn, the consultant told three HWC employees about the scheme, and the employees agreed to accept inflated invoices. Ultimately, from December 2003 through November 2004, HWC approximately $348,350 in illicit payments to the consultant, knowing that some or all of this money would be transferred to foreign government officials for the purpose of obtaining or retaining business for HWC and Oil States. HWC then improperly recorded the payments in its accounting books and records as ordinary business expenses, which were subsequently incorporated into the books and records of its parent company.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Oil States International, Inc. Case Summary at 118.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Oil States International, Inc. Case Summary at 118, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Administrative Proceeding File No. 3-12280, Order Instituting Cease and Desist Proceedings, In the Matter of Oil States International, Inc. (April 27, 2006), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2006\/34-53732.pdf","Documents":""},{"Case ID":"ST-301","Case Cluster ":"Pacific Consolidated Industries LP","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Crown Prosecution Service","Jurisdiction of Foreign Public Official(s) ":"United Kingdom","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"04\/09","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Unknown if ordered","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unspecified","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Accepting Bribe Payment","Offenses - Settled":"Accepting Bribe Payment","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United Kingdom\u0027s \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 Ministry of Defence official, Michael Hale, was convicted in April 2007, on nine counts of accepting bribes totalling \u00a3217,000.\u0022 (Source:  United Kingdom\u0027s \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 September 2008, accessed at www.dfid.gov.uk\/documents).  The UK\u0027s MailOnline (and other media) reported on April 16, 2007 that Michael Hale, a senior military official, had plead guilty in Southwark Crown Court to charges of receiving bribes from Pacific Consolidated Industries. (Source: MailOnline, \u0022Senior MoD jailed for taking bribes from US arms dealer,\u0022 April 16, 2007, accessed at http:\/\/www.dailymail.co.uk\/news\/article-448968\/Senior-MoD-jailed-taking-bribes-US-arms-dealer.html.) According to the June 2011 United States Report to the OECD, \u0022the UK-MOD official pleaded guilty in the UK to accepting more than $300,000 in bribes from PCI and was sentenced to two years in prison.\u0022 (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Pacific Consolidated Industries, LP Case Summary at 81-82, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.)","Sources ":"United Kingdom\u0027s \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 September 2008, accessed at www.dfid.gov.uk\/documents; MailOnline, \u0022Senior MoD jailed for taking bribes from US arms dealer,\u0022 April 16, 2007, accessed at http:\/\/www.dailymail.co.uk\/news\/article-448968\/Senior-MoD-jailed-taking-bribes-US-arms-dealer.html; US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Pacific Consolidated Industries LP Case Summary at 81-82, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-324","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"[tax authorities]","Jurisdiction of Foreign Public Official(s) ":"Various","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"10\/04","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Tax Settlement (\u0022tatsthliche VerstUdigung\u0022) ","Monetary Sanctions  (Types)":"Tax Settlement (tatsthliche VerstUdigung) ","Total Monetary Sanctions (US$)":"$253,446,100.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"$253,446,100","Other Civil Monetary Sanctions (Explanation)":"Taxes Owed","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$253,446,100","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Taxes Owed","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":" Tax violations (liability relating to payments in connection with BCAs, other sales-related agreements with third-party intermediaries and other payments relating to the former Com Group at Siemens AG)","Offenses - Settled":" Tax violations (liability relating to payments in connection with BCAs, other sales-related agreements with third-party intermediaries and other payments relating to the former Com Group at Siemens AG)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"From Siemens Annual Report 2007 Incl. Consolidated Financial Statements of Siemens AG at 170-171 (30 Nov 2007): \u0022The Company has accounted for income tax-related charges with respect to fiscal 2000-2006 and adjusted comparative amounts for fiscal 2005 and 2006 as summarized below: In October 2007, the Company reached a final settlement (tats\u00e4chliche Verst\u00e4ndigung) with the German tax authorities regarding the deductibility for tax purposes of certain payments at the former Com Group at Siemens AG with respect to fiscal 2000-2006. Pursuant to the settlement, the Company\u2019s income tax obligation relating to payments in connection with BCAs [Business Consultant Agreements], other sales-related agreements with third-party intermediaries and other payments relating to the former Com Group at Siemens AG was determined to be \u20ac179 million. Payments of approximately \u20ac449 million were determined to be non-deductible for tax purposes. The Company also recorded interest charges of \u20ac12 million related to the tax obligations.\u0022  (Source: Siemens Annual Report 2007, at 170.","Sources ":"Siemens AG, Annual Report 2007, accessed at http:\/\/www.siemens.com\/annual\/07\/pool\/download\/pdf\/e07_00_gb2007.pdf, replace with http:\/\/www.siemens.com\/investor\/pool\/en\/investor_relations\/financial_publications\/annual_reports\/2007\/e07_00_gb2007.pdf","Documents":""},{"Case ID":"ST-300","Case Cluster ":"Pacific Consolidated Industries LP","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"United Kingdom","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"03\/08","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$20,000.00","Criminal Fine\/Penalty (US$) ":"$20,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Pacific Consolidated Industries LP, at 63-64, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: Time period of misconduct in United Kingdom, 1993-2003; Martin Eric Self and Leo Winston Smith, two executives of Pacific Consolidated Industries (which later went defunct) caused PCI to enter into a marketing agreement with  a person they understood to be a relative of the UK-MOD official\/project manager directly involved in the procurement of Air Separation Units (which PCI manufactured) on behalf of the UK-Ministry of Defence.  The ASU and related contracts awarded to PCI were valued at over $11 million. The executives were charged with participating in a scheme to make more than $370,000 in illicit payments, and Smith was also charged with failing to report nearly $500,000 in commissions from PCI on his tax returns.  Self pleaded guilty and was ordered to pay $7,500 criminal fine; Smith also pleaded guilty and was ordered to pay $20,000 in criminal fine. PCI was a private company. The UK-MOD official pleaded guilty in the UK to accepting more than $300,000 in bribes from PCI and was sentenced to two years in prison.  According to the United Kingdom\u0027s \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 Ministry of Defence official, Michael Hale, was convicted in April 2007, on nine counts of accepting bribes totalling ?17,000. (Source:  United Kingdom\u0027s \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 September 2008, accessed at www.dfid.gov.uk\/documents).  The UK\u0027s MailOnline (and other media) reported on April 16, 2007 that Michael Hale, a senior military official, had plead guilty in Southwark Crown Court to charges of receiving bribes from Pacific Consolidated Industries. (Source: MailOnline, \u0022Senior MoD jailed for taking bribes from US arms dealer,\u0022 April 16, 2007, accessed at http:\/\/www.dailymail.co.uk\/news\/article-448968\/Senior-MoD-jailed-taking-bribes-US-arms-dealer.html.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Pacific Consolidated Industries LP, at 63-64, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf:  US Department of Justice Press Release, \u0022Former Pacific Consolidated Industries LP Executive [Martin Eric Self] Pleads Guilty in Connection with Bribes Paid to U.K. Ministry of Defence Official,\u0022 May 8, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/May\/08-crm-394.html; US Department of Justice Press Release, \u0022Former Pacific Consolidated Industries LP Executive [Leo Winston Smith] Pleads Guilty in Connection with Bribes Paid to U.K. Ministry of Defense Official,\u0022 September 3, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/September\/09-crm-928.html;  US v. Leo Winston Smith, Case No. 8:07-cr-00069-AG (C.D.Ca.),  Amended Judgment filed January 11, 2011, accessed at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/smithl\/01-11-11smith-leo-amended.pdf; US v. Martin Eric Self, Case No. 8:08-cr-00110-AG (C.D. Ca.), Judgment filed November 17, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/selfm\/11-17-08self-judgment.pdf; United Kingdom\u0027s \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 September 2008, accessed at www.dfid.gov.uk\/documents; MailOnline, \u0022Senior MoD jailed for taking bribes from US arms dealer,\u0022 April 16, 2007, accessed at http:\/\/www.dailymail.co.uk\/news\/article-448968\/Senior-MoD-jailed-taking-bribes-US-arms-dealer.html.","Documents":""},{"Case ID":"ST-297","Case Cluster ":"Oxford University Press","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Unspecified sub-Saharan African countries (acts by Kenyan and Tanzanian subsidiaries whose geographical region included Kenya, Burundi, Malawi, Rwanda, Sudan, Uganda, Tanzania, Zanzibar archipelago)","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"07\/03","Other Jurisdictions of Settlement":"World Bank","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Civil Recovery Order (Proceeds of Crime Act)","Monetary Sanctions  (Types)":"Civil Recovery Order, Legal Costs, Voluntary Payment","Total Monetary Sanctions (US$)":"$6,126,115.10","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$2,971,300 ","Other Civil Monetary Sanctions (US$)":"$3,154,815","Other Civil Monetary Sanctions (Explanation)":"Investigation costs of $19,595.10 and $3,135,220 in voluntary unilateral payment to non-profit organizations","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$3,135,220 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Voluntary payment to non-profit organizations","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Irregularities in tender bidding; revenues derived from unlawful conduct (bribery and\/or corruption)","Offenses - Settled":"Irregularities in tender bidding; revenues derived from unlawful conduct (bribery and\/or corruption)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office press release, \u0022OPL is a wholly owned subsidiary of Oxford University Press (OUP), which pursues its mission through five publishing divisions, including the International Division.  [ ]  Oxford University Press East Africa (OUPEA) is based in Kenya but covers a geographical region which includes Kenya, Burundi, Malawi, Rwanda, Sudan and Uganda.  Oxford University Press Tanzania (OUPT) is based in mainland Tanzania but also has responsibility for the semi-autonomous Zanzibar archipelago.  Both OUPT and OUPEA are wholly owned subsidiaries of OPL and part of the International Division of OUP. [ ]  In 2011, OUP became aware of the possibility of irregular tendering practices involving its education business in East Africa.  OUP acted immediately to investigate the matter, instructing independent lawyers and forensic accountants to undertake a detailed investigation. As a result of the investigation, in November 2011 OUP voluntarily reported certain concerns in relation to contracts arising from a number of tenders which its Kenyan and Tanzanian subsidiaries, OUPEA and OUPT, entered into between the years 2007 and 2010.  [ ] The product of [the company\u0027s self investigation] led the SFO and the World Bank to believe that OUPEA and OUPT had offered and made payments, directly and through agents, intended to induce the recipients to award competitive tenders and\/or publishing contracts for schoolbooks to OUPEA and OUPT.  [ ] The value of the Order made by the High Court is \u00a31,895,435 [ ]. OPL will also pay the SFO costs of pursuing the order which amount to \u00a312,500. [ ] In addition to the property recovered under the civil recovery order, OUP unilaterally offered to contribute \u00a31,000,000 to not-for-profit organisations for teacher training and other educational purposes in sub-Saharan Africa.  This was a reflection of the seriousness with which OUP views the course of events that were subject to the investigation and a wish to acknowledge that the conduct of OUPEA and OUPT fell short of that expected within its wider organisation.  The contribution would benefit the people within the affected region and be consistent with the overall mission of OUP.  The offer also confirmed that the funds would not be used so as to provide OUP with a commercial advantage.  Although the benefits to the people of the affected region are acknowledged by the SFO, the SFO decided that the offer should not be included in the terms of the court order as the SFO considers it is not its function to become involved in voluntary payments of this kind.   However, the SFO welcomes OUP\u0027s commitment to make this contribution and to work with a range of not-for-profit organisations in sub-Saharan Africa to achieve the above objectives.\u0022  (Source: UK Serious Fraud Office press release, \u0022Oxford Publishing Ltd to pay almost ?.9 million as settlement after admitting unlawful conduct in its East African operations,\u0022 July 3, 2012.) ","Sources ":"UK Serious Fraud Office press release, \u0022Oxford Publishing Ltd to pay almost \u00a31.9 million as settlement after admitting unlawful conduct in its East African operations,\u0022 July 3, 2012, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2012\/oxford-publishing-ltd-to-pay-almost-19-million-as-settlement-after-admitting-unlawful-conduct-in-its-east-african-operations.aspx; Consent Order (July 2, 2012), accessed at http:\/\/www.sfo.gov.uk\/media\/215466\/sealed_consent_order.pdf; Claim Form, accessed at http:\/\/www.sfo.gov.uk\/media\/215458\/part_8_claim_form_n208.pdf; Application Notice Form, accessed at http:\/\/www.sfo.gov.uk\/media\/215462\/application_notice_form_n244.pdf","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Oxford_Univ_Press_Settlement_SFO_Press_Release_Jul_3_2012.pdf"},{"Case ID":"ST-381","Case Cluster ":"Weir Group plc","Jurisdiction of Settlement":"","Jurisdiction of Settlement \/ Enforcement Agency":"Crown Office (Scotland); Procurator Fiscal Service (Scotland)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea, Confiscation Order (Proceeds of Crime Act 2002 and Proceeds of Crime Act (Scotland) Act 1995)","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$26,767,500.00","Criminal Fine\/Penalty (US$) ":"$4,751,800","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$22,015,700","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$2,375,790","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Kick-back payments","Offenses - Settled":"Kick-back payments","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Crown Office and Procurator Fiscal Service news release dated December 15, 2010, \u0022The Crown Office has secured \u00a313.9 million under Proceeds of Crime legislation after a Scottish engineering company pled guilty to paying \u2018kickbacks\u2019 in return for contracts from Saddam Hussein\u2019s government. The confiscation order, made against Glasgow-based Weir Group Plc, is the biggest ever made by a Scottish court.  At the High Court in Edinburgh today, the company was also fined \u00a33 million after pleading guilty to paying more than \u00a33m in \u2018kickbacks\u2019, in contravention of UN sanctions against Iraq, through a Swiss bank account.  The Weir Group also admitted facilitating the payment of kickbacks by paying a fee of more than \u00a31.4 m to their agent, an Iraqi national, to the same Swiss bank account. The agent made the payments to the Iraqi government on behalf of Weir.  The kickbacks were paid to the Iraqi Government from funds in the UN\u2019s Oil for Food Programme, which should have been used for humanitarian purposes. An Independent Inquiry Committee set up by the UN has estimated that, in total, about US $1.5 billion that could have been used to ease the suffering of the Iraqi people was paid as kickbacks to Saddam Hussein\u0027s government. The Lord Advocate, the Right Honourable Elish Angiolini QC, said: \u0027This case represents the biggest single confiscation order made so far in Scotland using the Proceeds of Crime legislation. It is the result of a highly successful collaboration between National Casework Division of the Crown Office and Procurator Fiscal Service, Strathclyde Police and the Serious Fraud Office. In this year alone we have recovered over \u00a324 million, a record amount under the Proceeds of Crime legislation.\u0027\u0022  The news release added that in notes to editors: \u0022Weir Group companies secured 16 contracts for which they were paid \u00a334,340,204 by paying kickbacks of \u00a33,104,527. The confiscation order has been granted for \u00a313,945,962.\u0022 This includes Weir\u2019s gross profit of \u00a39, 414,283 from the contracts - plus the kickback of \u00a33,104,527 and the fee of \u00a31,427,152 paid to Weir\u2019s agent in Iraq.(Source:  The Crown Office and Procurator Fiscal Service news release, \u0022CROWN SECURES RECORD \u00a313.9M AS WEIR GROUP CONVICTED OF PAYING KICKBACKS FOR IRAQ CONTRACTS,\u0022 December 15, 2010.)  According to a February 13, 2011 press statement by the Government of Scotland, GBP1.5 million of the GBP 13.9 million seized under the Proceeds of Crime Act will support water development in Iraq and humanitarian programmes in Iraq and Afghanistan. Specifically, GBP1.4 million were to go towards projects in Iraq and GBP 100,000 to a Scottish charity for humanitarian work in Afghanistan. The remainder, GBP 12.4 million \u0022will be used to fund community projects in Scotland.\u0022  (Source: The Scottish Government, \u0022Seized cash returned to Iraq,\u0022 February 13, 2011.)","Sources ":"Crown Office and Procurator Fiscal Service Press Release, \u0022Crown Secures record \u00a313.9 million as Weir Group convicted of paying kickbacks for Iraq contracts,\u0022 December 15, 2010, accessed at http:\/\/www.copfs.gov.uk\/News\/Releases\/2010\/12\/Crown-Secures-record-%C2%A3139-million-Weir-Group-convicted-paying-kickbacks-Iraq-contracts; The Scottish Government, \u0022Seized cash returned to Iraq,\u0022 February 13, 2011, at http:\/\/www.scotland.gov.uk\/News\/Releases\/2011\/02\/14085030.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Weir_Group_COPFS_Settlement_Dec_15_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Weir_Group_Scotland_PR_Feb_14_2011.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Scotland_Crown_Office_POCA_Record_News_Release_June_2011.pdf"},{"Case ID":"ST-394","Case Cluster ":"Willis Ltd.","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Financial Services Authority","Jurisdiction of Foreign Public Official(s) ":"Egypt, Russia","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"07\/21","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Final Notice (of Penalty)","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$11,120,800.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$11,120,800","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Breaches of Principle 3 of the FSA\u0027s Principles for Businesses and Rule SYSC 3.2.6 R of the FSA?s Senior Management Arrangements, Systems and Controls Handbook (\u0022failings in its anti-bribery and corruption systems and controls\u0022)","Offenses - Settled":"Breaches of Principle 3 of the FSA\u0027s Principles for Businesses and Rule SYSC 3.2.6 R of the FSA\u0027s Senior Management Arrangements, Systems and Controls Handbook (\u0022failings in its anti-bribery and corruption systems and controls\u0022)","Public Procurement Contract \/ SOE Involved?":"No","Summary":"According to a July 21, 2011 press release by the UK Financial Services Authority (FSA\/PN\/066\/2011), the FSA \u0022has today fined Willis Limited \u00a36.895 million [US $11,120,800] for failings in its anti-bribery and corruption systems and controls. These failings created an unacceptable risk that payments made by Willis Limited to overseas third parties could be used for corrupt purposes. This is the biggest fine imposed by the FSA in relation to financial crime systems and controls to date.  Between January 2005 and December 2009, Willis Limited made payments to overseas third parties who assisted it in winning and retaining business from overseas clients, particularly in high risk jurisdictions. These payments totalled \u00a327 million. The FSA investigation found that, up until August 2008, Willis Limited failed to: \u2022ensure that it established and recorded an adequate commercial rationale to support its payments to overseas third parties; \u2022ensure that adequate due diligence was carried out on overseas third parties to evaluate the risk involved in doing business with them; and \u2022adequately review its relationships on a regular basis to confirm whether it was still necessary and appropriate for Willis Limited to continue with the relationship.\u0022  The press release also noted that Willis Ltd. agreed to settle at an early stage and was therefore given a 30% (stage 1) discount, without which the fine would have been GBP 9.85 million [US$15,886,900]. (Source: UK Financial Services Authority Press Release, \u0022FSA fines Willis Limited \u00a36.895 million for anti-bribery and corruption systems and controls failings,\u0022 FSA\/PN\/066\/2011,\u0022 July 21, 2011.)  According to the penalty notice issued to Willis Limited, \u0022One of the Overseas Third Parties engaged by Willis provided consultancy services in respect of a company based in Russia during the Relevant Period. This Overseas Third Party had a complex operational structure. The company was registered as a foreign company in Liberia, had a bank account in Switzerland and was controlled by a Trust Company in the Isle of Man.\u0022 (para 4.19); Willis Limited is a wholly-owned subsidiary of the Willis group of companies, whose ultimate parent is the Willis Group Holdings Plc, incorporated in Dublin, Ireland. (Source: UK Financial Services Authority, Final Notice to Willis Limited, July 21, 2011, accessed at   http:\/\/www.fsa.gov.uk\/pubs\/final\/willis_ltd.pdf.);  According to the FSA website, \u0022Facts and figures\u0022: Who pays for the FSA?  Our budget is met from a levy on the firms we regulate. We receive no funding from the taxpayer. The amount each firm pays is determined according to its size and the types of business it undertakes. When financial penalties are imposed on firms or individuals, the proceeds are used to reduce fees in the following financial year.\u0022 Link at http:\/\/www.fsa.gov.uk\/Pages\/About\/Media\/Facts\/index.shtml.","Sources ":"UK Financial Services Authority Press Release, \u0022FSA fines Willis Limited \u00a36.895 million for anti-bribery and corruption systems and controls failings,\u0022 FSA\/PN\/066\/2011,\u0022 July 21, 2011, accessed at http:\/\/www.fsa.gov.uk\/pages\/Library\/Communication\/PR\/2011\/066.shtml; UK Financial Services Authority, Final Notice to Willis Limited, July 21, 2011, accessed at http:\/\/www.fsa.gov.uk\/pubs\/final\/willis_ltd.pdf; United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf","Documents":""},{"Case ID":"ST-24","Case Cluster ":"Alcatel-Lucent S.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Costa Rica, Honduras, Malaysia, Taiwan","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/27","Other Jurisdictions of Settlement":"Costa Rica","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit","Total Monetary Sanctions (US$)":"$45,372,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$45,372,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, the Commission filed a complaint which \u0022alleges that Alcatel\u0027s bribes went to government officials in Costa Rica, Honduras, Malaysia, and Taiwan between December 2001 and June 2006.  An Alcatel subsidiary provided at least $14.5 million to consulting firms through sham consulting agreements for use in the bribery scheme in Costa Rica.  Various high-level government officials in Costa Rica received at least $7 million of the $14.5 million to ensure Alcatel obtained or retained three contracts to provide telephone services in Costa Rica.  The SEC alleges that the same Alcatel subsidiary bribed officials in the government of Honduras to obtain or retain five telecommunications contracts.  Another Alcatel subsidiary made bribery payments to Malaysian government officials in order to procure a telecommunications contract.  An Alcatel subsidiary also made illegal payments to various officials in the government of Taiwan to win a contract to supply railway axle counters to the Taiwan Railway Administration. According to the SEC\u0027s complaint, all of the bribery payments were undocumented or improperly recorded as consulting fees in the books of Alcatel\u0027s subsidiaries and then consolidated into Alcatel\u0027s financial statements.  The leaders of several Alcatel subsidiaries and geographical regions, including some who reported directly to Alcatel\u0027s executive committee, either knew or were severely reckless in not knowing about the misconduct. [ ]  The SEC acknowledges the assistance of  [ ] the Office of the Attorney General in Costa Rica; the Fiscalia de Delitos Econ\u0026oacute;icos, Corrupci\u0026oacute; Tributarios in Costa Rica; and the Service Central de Preion de la Corruption in France.\u0022  (Source:  US Securities and Exchange Commission Litigation Release No. 21795\/ December 27, 2010, SEC v. Alcatel-Lucent, S.A., Civil Action No. 1:10-CV-24620-GRAHAM (S.D. FL.) (December 27, 2010), \u0022SEC Files Settled Foreign Corrupt Practices Act Charges Against Alcatel-Lucent, S.A. With Total Disgorgement and Criminal Fines of Over $137 Million.\u0022)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Alcatel-Lucent S.A. (Matter #11) Case Summary at 27-29, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 21795\/ December 27, 2010, SEC v. Alcatel-Lucent, S.A., Civil Action No. 1:10-CV-24620-GRAHAM (S.D. FL.) (December 27, 2010), \u0022SEC Files Settled Foreign Corrupt Practices Act Charges Against Alcatel-Lucent, S.A. With Total Disgorgement and Criminal Fines of Over $137 Million,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21795.htm; Complaint filed December 27, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21795.pdf.","Documents":""},{"Case ID":"ST-52","Case Cluster ":"BAE Systems plc","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Tanzania","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/21","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea  ","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Reparation, Legal Costs","Total Monetary Sanctions (US$)":"$46,914,016.00","Criminal Fine\/Penalty (US$) ":"$776,080","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$45,788,700","Criminal Legal \/ Procedural Costs (US$)":"$349,236 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$45,788,700 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Ex Gratia Payment to Tanzania","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Failure to Keep Accounting Records contravening section 221(5) of the Companies Act 1985","Offenses - Settled":"Failure to Keep Accounting Records contravening section 221(5) of the Companies Act 1985","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office Press Release, \u0022Today at Southwark Crown Court BAE Systems Plc was fined \u00a3500,000 after admitting it had failed to keep adequate accounting records in relation to a defence contract for the supply of an air traffic control system to the Government of Tanzania.  This outcome follows a settlement by BAE as part of a global agreement it reached earlier this year with the Serious Fraud Office and the US Department of Justice concerning contracts in a number of countries. The settlement with the SFO relates to the Tanzania contract whereby BAE agreed to pay an ex-gratia payment for the benefit of the people of Tanzania of \u00a340 million less any fine imposed by the Crown Court.  Additionally, BAE was ordered to pay \u00a3225,000 costs to the SFO.  [  ] A contract for the supply of a radar defence system for Dar-es-Salaam International Airport was agreed in 1999 between British Aerospace Defence Systems Ltd and the government of Tanzania. (This followed negotiations that had been conducted since 1992 initially by Siemens Plessey Systems which was acquired by BAE in 1998). The value of the contract was US $39.97 million. BAE\u0027s practice was to engage advisers to help with its marketing. These advisers were either classified by BAE as \u0027overt\u0027 (i.e. that is they operated openly as BAE\u0027s in-country representatives), or \u0027covert\u0027. The latter operated in circumstances where there was a need for confidentiality. In order to maximise confidentiality with regard to its use of covert advisers and the making of payments to them, BAE set up Red Diamond Trading Company, incorporated in the British Virgin Islands. In Tanzania a local businessman, Shailesh Vithlani, was recruited at an early stage (initially by Siemens) to advise BAE on its negotiations with the government on the radar contract. Shortly before the contract was signed two new adviser arrangements with Vithlani were concluded. One was made between Red Diamond and a Vithlani-controlled Panama-incorporated company, Envers Trading Corporation. This was a \u0027covert\u0027 arrangement where the fee for Vithlani\u0027s services was to be not more than 30.025% of the radar contract price. The other arrangement was \u0027overt\u0027 and was for services direct to BAE by a Vithlani-controlled business, Merlin International, registered in the B.V.I. It did not involve Red Diamond and the fee was 1% of the radar contract value.  Between January 2000 and December 2005 around $12.4 million was paid to Vithlani\u0027s two companies. BAE has accepted that there was a high probability that part of this sum would be used to favour it in the contract negotiations.  The payments were not subject to proper and adequate scrutiny or review.  Furthermore, it was not possible for any person auditing the accounts to investigate and determine whether the payments were properly accounted for or were lawful. In sentencing BAE, the Judge said that he took the view that BAE were concealing from the auditors and ultimately the public the fact that they were making payments to Vithlani; 97% of them via two offshore companies, with the intention that he should have free rein to make such payments to such people as he thought fit in order to secure the radar contract for BAE but that BAE did not want to know the details.  The Judge took into account in sentencing BAE that the group had committed itself to a process of change following the Report of Lord Woolf and that BAE would be making a payment for the benefit of the people of Tanzania of \u00a340 million less the fine. The Judge said that the people of Tanzania were the real victims. The Judge decided in these circumstances to impose a fine of \u00a3500,000.\u0022 (Source:  UK Serious Fraud Office Press Release, \u0022BAE fined in Tanzania defence contract case,\u0022 December 21, 2010, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2010\/bae-fined-in-tanzania-defence-contract-case.aspx.)","Sources ":"United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf; UK Serious Fraud Office Press Release, \u0022BAE fined in Tanzania defence contract case,\u0022 December 21, 2010, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2010\/bae-fined-in-tanzania-defence-contract-case.aspx; Between: R - and - BAE SYSTEMS PLC, Case No. Case No: S2010565 (Southwark Crown Court), December 21, 2010, accessed at http:\/\/www.judiciary.gov.uk\/Resources\/JCO\/Documents\/Judgments\/r-v-bae-sentencing-remarks.pdf; Prosecution Note for Opening, accessed at http:\/\/www.sfo.gov.uk\/media\/133543\/bae%20opening%20statement%2020.12.10.pdf; Settlement Agreement between the Serious Fraud Office and BAE Systems plc, February 2010, accessed at http:\/\/www.sfo.gov.uk\/media\/133535\/bae%20-%20settlement%20agreement%20and%20basis%20of%20plea.pdf; Charge, accessed at http:\/\/www.sfo.gov.uk\/media\/133535\/bae%20-%20settlement%20agreement%20and%20basis%20of%20plea.pdf.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/BAE_UK_SFO_Court_Sentencing_Remarks_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/BAE_UK_Settlement_Tanzania_SFO_PR_Feb_5_2010.pdf"},{"Case ID":"ST-74","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"02\/11","Other Jurisdictions of Settlement":"Nigeria, United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Civil Recovery Order (Proceeds of Crime Act) ","Monetary Sanctions  (Types)":"Civil Recovery Order","Total Monetary Sanctions (US$)":"$11,303,600.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$11,303,600","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Proceeds of Unlawful Conduct (Bribery by a Third Party)","Offenses - Settled":"Proceeds of Unlawful Conduct","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office Press Release, \u0022The Serious Fraud Office (SFO) has taken action in the High Court today which has resulted in an Order for the company, M.W. Kellogg Limited (MWKL), to pay just over \u00a37 million in recognition of sums it is due to receive which were generated through the criminal activity of third parties. The High Court made the Order under Part 5 of the Proceeds of Crime Act 2002. The SFO recognised that MWKL took no part in the criminal activity which generated the funds. The funds due to MWKL are share dividends payable from profits and revenues generated by contracts obtained by bribery and corruption undertaken by MWKL\u0027s parent company and others.  The agreement will lead to the payment of \u00a37,028,077 within fourteen days in full and final settlement of the case.  This sum represents the share dividends due and the interest which has accrued on these sums.The contracts were awarded to a company partly owned by MWKL on behalf of its US parent company.  MWKL reported concerns to the SFO under the \u0022self referral\u0022 scheme and fully co-operated with the subsequent investigation. The SFO, working in partnership with the US Department of Justice, reviewed the conduct of MWKL and decided that the most appropriate approach was to remove the funds which will become due to the company through the unlawful conduct. This reflects the finding that MWKL was used by the parent company and was not a willing participant in the corruption.\u0022 (Source: UK Serious Fraud Office, \u0022MW Kellogg Ltd to pay 7 million pounds in SFO High Court action,\u0022 February 16, 2011.)","Sources ":"UK Serious Fraud Office Press Release, \u0022MW Kellogg Ltd to pay 7 million pounds in SFO High Court action,\u0022 February 16, 2011, http:\/\/www.sfo.gov.uk\/press-room\/press-release-archive\/press-releases-2011\/mw-kellogg-ltd-to-pay-7-million-in-sfo-high-court-action.aspx; United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf","Documents":""},{"Case ID":"ST-110","Case Cluster ":"Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Haiti","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"05\/19","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Restitution, Criminal Forfeiture","Total Monetary Sanctions (US$)":"$3,302,675.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$1,028,851","Criminal Restitution \/ Reparation (US$)":"$2,273,824","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$73,824","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Haiti (unconfirmed as to $2.2m)","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 4, 2009, two former executives of a Florida-based telecommunications company, the president of a Florida-based intermediary company, and two former Haitian government officials were charged in an indictment for their alleged roles in a foreign bribery, wire fraud, and money laundering scheme that lasted from at least November 2001 through March 2005. Joel Esquenazi, the former president of the telecommunications company; Carlos Rodriguez, the former executive vice-president of the telecommunications company; Marguerite Grandison, the former president of Telecom Consulting Services Corp.; Robert Antoine, a former director of international relations at the Republic of Haiti\u0027s state-owned national telecommunications company, Telecommunications D\u0027Haiti (Haiti Teleco); and Jean Rene Duperval, another former director of international relations at Haiti Teleco, were charged in connection with a scheme whereby the telecommunications company paid more than $800,000 to shell companies, including Grandison\u0027s Telecom Consulting Services Corp., to be used for bribes to foreign officials of Haiti Teleco. The purpose of these bribes was to obtain various business advantages from the Haitian officials for the telecommunications company, including issuing preferred telecommunications rates, reducing the number of minutes for which payment was owed, and giving a variety of credits toward owed sums, as well as to defraud the Republic of Haiti of revenue.Previously, on April 22, 2009, Juan Diaz, the president of J.D. Locator Services Inc., a Florida-based intermediary, and Antonio Perez, the former controller of the Florida-based telecommunications company, were charged in connection with their roles in the alleged foreign bribery scheme. According to court documents, from 1998 to 2003, Diaz and Perez conspired to make \u0022side payments\u0022 totaling $1 million to the Haitian government officials through a shell company belonging to Diaz, all on behalf of the Florida-based telecommunications company.On February 1, 2010, Jean Fourcand, the president of Fourcand Enterprises, Inc., another intermediary company, was charged in a one-count criminal information with engaging in monetary transactions involving property derived from the scheme to bribe the former Haitian government officials. Specifically, between November 2001 and August 2002, Fourcand received funds originating from this and other U.S. telecommunications companies for the benefit of Robert Antoine. A portion of these funds came in the form of a check from J.D. Locator Services Inc., and a portion of these funds were used to engage in a real estate transaction that benefitted Antoine.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco) Case Summary at 51-52.)  Diaz\u0027s Information included the following Notice of Forfeiture: \u0022the defendant shall forfeit to the United States any property, real or personal, which constitutes proceeds traceable to the Title 18, United States Code, Section 371 conspiracy to commit a violation of the Foreign Corrupt Practices Act, Title 15, United States Code, Section 78dd-2, a specified unlawful activity as defined in Title 18, United States Code, Section 1956(c)(7), which is $1,028,851.95 in United States currency.\u0022 (Source:  US v. Diaz, Case No. 1:09-cr-20346-JEM (S.D. Fla.), Information filed April 22, 2009, at p. 10.) According to the Sentencing Hearing Transcript, the victim recipient of the restitution is the Government of Haiti. (Source: US v. Diaz, Case No. 1:09-cr-20346-JEM (S.D. Fla.), Sentencing Hearing (July 30, 2010) Transcript filed August 5, 2010, accessed via Pacer.)  According to the Amended Judgment in US v. Esquenazi, Esquenazi, Rodriguez, Perez, Fourcand and Antoine were ordered joint and severally liable for $2.2 million in restitution.  (Source: US v. Esquenazi, Case No. 1:09-cr-20210-JEM (S.D. Fla.), Amended Judgment filed November 3, 2011, accessed via Pacer.)  Esquenazi and Rodriguez were sentenced following their convictions; hence there is no entry on their cases and the restitution sum is noted only in this entry as to avoid double counting of the sum. According to the US Department of Justice Press Release, \u0022The Department of Justice is grateful to the government of Haiti for providing substantial assistance in gathering evidence during this investigation. In particular, Haiti\u0027s financial intelligence unit, the Unite de Renseignements Financiers, the Bureau des Affaires Financierses et Economiques, which is a specialized component of the Haitian National Police, and the Ministry of Justice and Public Security provided significant cooperation and coordination in this ongoing investigation.\u0022 (Source:  US Department of Justice Press Release, \u0022Florida Businessman Sentenced to 57 Months in Prison for Role in Foreign Bribery Scheme,\u0022 July 30, 2010.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco) Case Summary at 51-52, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Diaz, Case No. 1:09-cr-20346-JEM (S.D. Fla.), Information filed April 22, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/diazj\/04-22-09diaz-info.pdf; Plea Agreement filed May 18, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/diazj\/05-18-09diaz-plea-agree.pdf; Factual Agreement filed May 18, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/diazj\/05-18-09diaz-fatual-agree.pdf; Judgment filed August 5, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/diazj\/08-05-10diaz-judgment.pdf; and Sentencing Hearing (July 30, 2010) Transcript filed August 5, 2010, accessed via Pacer.  US Department of Justice Press Release, \u0022Florida Businessman Sentenced to 57 Months in Prison for Role in Foreign Bribery Scheme,\u0022 July 30, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/July\/10-crm-883.html.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Haiti_Teleco_Diaz_Sentencing_Hearing_Transcript_Aug_2010.pdf"},{"Case ID":"ST-114","Case Cluster ":"CBRN Ltd.","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Crown Prosecution Service","Jurisdiction of Foreign Public Official(s) ":"Uganda","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"09\/21","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Restitution","Total Monetary Sanctions (US$)":"$96,682.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$96,682","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$73,242","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Uganda","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Receipt of corrupt funds; money laundering","Offenses - Settled":"Receipt of Bribery","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK\u0027s Self-Assessment related to the United Nations Convention against Corruption, \u0022R v Tumokunde \u0026 Tobiasen - Tumukunde, from Uganda advised his government on science and technology.  In May 2007 he signed a contract worth \u00a3210,000 with British company CBRN Ltd, for CBRN to supply services to the government for a forthcoming Commonwealth visit by heads of state. Following the agreement, Tumukunde approached CBRN Managing Director, Niels Tobiasen, claiming that he would need to make additional payments via Tumukunde to meet a local tax of 10%.  Tobiasen agreed and a total of six payments worth over \u00a383,000 were made to both Tumukunde and another Ugandan, Rusoke Tagaswire between 1 June 2007 and 1 February 2008. Tumukunde and Tagaswire recorded the money as being paid to them as agents of the Ugandan government working on the contract, when in fact they were inducements going directly into two bank accounts Tumukunde had opened in his own name in the UK.  Tumukunde was charged with four counts of money laundering and sentenced to 12 months in prison on 22nd September 2008.  Niels Tobiasen pleaded guilty to making corrupt payments and given a suspended sentence after cooperating fully with police enquiries. It is currently estimated that up to \u00a340,000 of the monies will be repatriated to the Government of Uganda.\u0022  (Source:  United Kingdom, \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 September 2008, at www.dfid.gov.uk.)  According to the Norton Rose law firm Case Study cited in the July 13, 2011 United Kingdom\u0027s UNCAC Self-Assessment Report, the London Police received information of Tumukunde\u0027s plans to travel to the UK and Tumukunde was arrested by Scotland Yard at Heathrow Airport. (Tobiasen later pleaded guilty to making corrupt payments to Tobiasen. On September 22, 2008, Tumukunde pleaded guilty, before His Honour Judge Wadsworth in the Southwark Crown Court to accepting corrupt payments and was sentenced to 12 months\u0027 imprisonment; he also signed a disclaimer releasing the GBP 52,800 from his bank account into the custody of the City of London Police for restitution. (Sources: Norton Rose (law firm), \u0022Case Study: CBRN Team Ltd (non-FCPA)\u0022; City of London Police Statement, \u0022Guilty plea to bribery sets legal landmark,\u0022 July 27, 2010.) Source:Vhttp:\/\/www.nortonrose.com\/expertise\/business-ethics-and-anti-corruption\/business-ethics-and-anti-corruption-case-study-cbrn-team-ltd-non-fcpa-18410.as","Sources ":"United Kingdom, \u0022Self-assessment checklist on the implementation ofthe United Nations Convention against Corruption,\u0022 September 2008, at www.dfid.gov.uk; Paul Lewis and Rob Evans, \u0022Ugandan is jailed in UK bribery crackdown,\u0022 The Guardian, September 22, 2008, accessed at http:\/\/www.guardian.co.uk\/uk\/2008\/sep\/23\/ukcrime.law; United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf","Documents":""},{"Case ID":"ST-202","Case Cluster ":"Hydro Kleen Systems Inc.","Jurisdiction of Settlement":"Canada","Jurisdiction of Settlement \/ Enforcement Agency":"Crown Prosecutors (Alberta)","Jurisdiction of Foreign Public Official(s) ":"Canada, United States","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"01\/10","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$20,279.00","Criminal Fine\/Penalty (US$) ":"$20,279","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign official [subparagraph 426(1)(a)(i) of the Criminal Code (secret commissions) and paragraph 3(1)(a) of the Corruption of Foreign Public Officials Act (CFPOA)]","Offenses - Settled":"Bribery of foreign official (Corruption of Foreign Public Officials Act)","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to Canada\u0027s Phase 3 Report by the OECD (March 2011), \u0022At the time of the Phase 2 on-site visit to Canada in 2003, proceedings were ongoing in respect of charges against Hydro Kleen Group Inc., an Alberta-based company, and two individuals, concerning the bribes of approximately CAD 30 000 paid to a US Immigration official contrary to subparagraph 426(1)(a)(i) of the Criminal Code (secret commissions) and paragraph 3(1)(a) of the Corruption of Foreign Public Officials Act (CFPOA).  In January 2005, Hydro Kleen admitted guilt to one count under the CFPOA as part of a plea agreement. The company was fined CAD 25 000. The two other charges, against a director and an officer of the company, were stayed as part of the plea agreement.\u0022  (Source:  Canada Report to the OECD: Phase 3 - Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, 18 March 2011.) According to the Sentencing hearing transcripts in R. v. Watts, et al [2005] A.J. No. 568, \u0022Between the 1st day of August, 2000, and the 1st day of December, 2001, at or near Red Deer and elsewhere in the Province of Alberta, in order to obtain or retain an advantage in the course of business directly or indirectly gave, offered, or agreed to give or offer a loan, reward, advantage or benefit, to wit: the sum of $28,299.88 more or less to a foreign public official, to wit: Hector Ramirez Garcia for the benefit of Hector Ramirez Garcia as consideration for an act or omission by Hector Ramirez Garcia in connection with the performance of his duties or functions on behalf of the United States of America, United States Department of Justice, Immigration and Naturalization Service, contrary to section 3(1)(a) of the Corruption of Foreign Public Officials Act SC 1998, C34.\u0022 (Source: R. v. Watts [2005] A.J. No. 568, Oral Judgment and Sentencing Hearing, January 10, 2005).  Please note that during sentencing a victim, the competitor company - Innovative Coke Expulsion Inc. - that lost the contract due to the bribery by Hydro Kleen, read a \u0022victim impact statement\u0022 pursuant to section 722 of the Criminal Code.  (Source: Ibid.)   The three individuals were charged with violations of Canada\u0027s Corruption of Foreign Public 2002 Year in Review: Developments in U.S. and International Efforts to Combat Transnational Commercial Bribery Officials Act and of the Criminal Code of Canada. Mr. Garcia pleaded guilty and served a six-month jail sentence. Upon his release in February 2003, Mr. Garcia was deported tothe United States where he faces prosecution by the DOJ. [ ]  A related civil lawsuit was filed in Canada by another refinery cleaning company, Innovative Coke Expulsion Inc. (\u0022ICE\u0022 on the grounds that Garcia accepted bribes to deny its employees entry into the United States. ICE also filed a civil RICO suit against Hydro Kleen, which has a U.S. subsidiary, in the United States. In May 2002, Hydro Kleen paid ICE $300,000 in settlement.\u0022  (Source: American Bar Association, \u00222002 Year in Review: Developments in U.S. and International Efforts to Combat Transnational Commercial Bribery.\u0022)","Sources ":"Canada Report to the OECD: Phase 3 - Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (18 March 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/55\/25\/47438413.pdf; R. v. Watts, et al [2005] A.J. No. 568, Oral Judgment and Sentencing Hearing, January 10, 2005, accessed at http:\/\/www.cba.org\/cba\/dublin2009\/pdf\/Gowlings_Appendix%20A%20-%20R%20v.%20Watts.pdf  (Hydro Kleen sentencing); American Bar Association, \u00222002 Year in Review: Developments in U.S. and International Efforts to Combat Transnational Commercial Bribery,\u0022 accessed at http:\/\/apps.americanbar.org\/intlaw\/committees\/special_projects\/corrupt_practices\/yir_corrupt.pdf.","Documents":""},{"Case ID":"ST-261","Case Cluster ":"Mabey \u0026 Johnson Ltd.","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Ghana, Jamaica, Iraq (UN Oil-for-Food)","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"09\/25","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Restitution, Criminal Confiscation, Legal  Costs, Monitoring Costs","Total Monetary Sanctions (US$)":"$10,733,697.45","Criminal Fine\/Penalty (US$) ":"$5,679,205","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$1,784,893","Criminal Restitution \/ Reparation (US$)":"$2,296,021","Criminal Legal \/ Procedural Costs (US$)":"$973,578 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$2,296,021","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Ghana, Iraq via Development Fund for Iraq, Jamaica","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials, Breach of UN Sanctions","Offenses - Settled":"Bribery of foreign officials, Breach of UN Sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office Press Release of September 25, 2009, \u0022Mabey \u0026 Johnson Ltd appeared at Southwark Crown Court today for sentence in relation to admitted offences of overseas corruption and breaching UN sanctions. The company is to pay  \u00a3.6M. This is the first prosecution brought in the UK against a  company for these offences. The company, which is a supplier of steel bridging and is based in Twyford, Berkshire, had already indicated at a magistrates\u0027 court hearing on 10 July 2009 that it would plead guilty to these offences. \/ Corruption - The prosecution for corruption arises from the company\u0027s voluntary disclosure to the SFO of evidence to indicate that the company had sought to influence decision-makers in public contracts in Jamaica and Ghana between 1993 and 2001. The decision to voluntarily disclose the corruption offences to the SFO was taken by the management of Mabey \u0026 Johnson\u0027s holding company in February 2008 whereupon an investigation was opened. \/ Breach of UN sanctions - The prosecution for breach of UN sanctions during 2001\/02, as they applied to contracts in the Iraq \u0022Oil-for-food\u0022 programme, arises from an investigation commenced in January 2007.  The details of the sentence today are:  Fines: Ghana  \u00a3750,000; Jamaica  \u00a3750,000; Iraq  \u00a32 million; Confiscation order  \u00a31.1million; Reparations: Ghana  \u00a3658,000; Jamaica  \u00a3139,000; Iraq  \u00a3618,000. Costs to the SFO  \u00a3350,000First year monitoring cost up to  \u00a3250,000.\u0022  (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd Sentencing,\u0022 September 25, 2009.)  According to a UK Parliamentary Report, \u0022In respect of Jamaica and Ghana the company undertook to offer the sums described above to its customers in Jamaica and Ghana. The undertaking by the company included a provision dealing with the possibility that the company would be unable to reach an agreement with its customers within six years or if it became evident at a prior date that no such agreement was likely to be reached. In those circumstances the payment would be made to the SFO or any successor body. The SFO\u0027s understanding is that the reparation payment has been made to the customer in Jamaica. The company has been unsuccessful, however, in its attempts to reach agreement with its Ghanaian customer. It is understood that the issue here concerns the reluctance of the Ghanaian authorities to accept that any corruption was involved. A different scheme is in operation relating to Iraq. A Development Fund for Iraq was set up internationally and payments in Oil for Food cases are made to that fund. There is therefore an international mechanism for compensation.\u0022 (Source: UK House of Commons, International Development Financial Crime and Development, Eleventh Report of Session 2010?12, Volume I (November 30, 2011), Appendix B, \u0022Notes on Other Cases by the Serious Fraud Office.\u0022) ","Sources ":"United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf; UK Serious Fraud Office, \u0022Mabey \u0026 Johnson Ltd Sentencing,\u0022 September 25, 2009, accessed at http:\/\/www.sfo.gov.uk\/press-room\/press-release-archive\/press-releases-2009\/mabey--johnson-ltd-sentencing-.aspx;  UK House of Commons, International Development Financial Crime and Development, Eleventh Report of Session 2010?12, Volume I (November 30, 2011), Appendix B, \u0022Notes on Other Cases by the Serious Fraud Office,\u0022 accessed at http:\/\/www.publications.parliament.uk\/pa\/cm201012\/cmselect\/cmintdev\/847\/84702.htm","Documents":""},{"Case ID":"ST-243","Case Cluster ":"Johnson \u0026 Johnson","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Greece","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"04\/14","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to make corrupt payments (section 1 of the Prevention of Corruption Act 1906)","Offenses - Settled":"Conspiracy to make corrupt payments (section 1 of the Prevention of Corruption Act 1906)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the August 2011 Report by the United Kingdom to the OECD, \u0022Former DePuy executive Robert John Dougall pleaded guilty after admitting his involvement in making \u00a34.5 million of corrupt payments to medical professionals within the Greek state healthcare system. He was originally sentenced to 12 months imprisonment. Recognising the important public interest issues raised in this case, Mr. Dougall was granted leave to appeal. On appeal the sentence was suspended. The Court of Appeal emphasised [sic] that where a defendant entered a guilty plea and provided full co-operation with the authorities investigating a major crime involving fraud or corruption and the level of criminality and mitigation meant that the sentence of imprisonment would be 12 months or less, then -- the argument that the sentence should be suspended is very powerful and that --  this result will normally follow.\u0022 (Source:  United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, Information as of 16 August 2011).  There is no mention of a monetary penalty ordered in this case in the UK Serious Fraud Office\u0027s Press Release on his case. (Source: US Serious Fraud Office Press Release, \u0022British executive jailed for part in Greek healthcare corruption,\u0022 April 14, 2010.)","Sources ":"United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf;  US Serious Fraud Office Press Release, \u0022British executive jailed for part in Greek healthcare corruption,\u0022 April 14, 2010, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2010\/british-executive-jailed-for-part-in-greek-healthcare-corruption.aspx; R. v. Dougall, Case No: 2010\/02063\/A3,  [2010] EWCA Crim 1048 (May 13, 2010), accessed at http:\/\/openmedicineeu.blogactiv.eu\/files\/2011\/06\/JJ-DOUGALL-Appeal-Judgement.pdf","Documents":""},{"Case ID":"ST-262","Case Cluster ":"Mabey \u0026 Johnson Ltd.","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"02\/23","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None ","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"\u0022Sanctions Offenses\u0022","Offenses - Settled":"\u0022Sanctions Offenses\u0022","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office Press Release, on February 23, 2011, \u0022Two former directors and a sales manager of engineering firm Mabey \u0026 Johnson Ltd have been sentenced today for providing kickbacks to the Iraqi government of Saddam Hussein. Charles Forsyth, David Mabey and Richard Gledhill inflated the contract price for the supply of steel bridges and disguised illegal payments that were channelled through Jordanian banks.The sentences are: *Richard Charles Edward Forsyth, 63, former managing director was sentenced to 21 months imprisonment, disqualified from acting as a company director for five years and was ordered to pay prosecution costs of   \u00a375,000. *David Mabey, 49, former sales director, to eight months imprisonment, disqualified from acting as a company director for two years and was ordered to pay prosecution costs of  \u00a3125,000. *Richard Gledhill, 64, former sales manager, to eight months imprisonment, suspended for two years.  On 10 February 2011, a Southwark Crown Court jury found Charles Forsyth and David Mabey guilty of making illegal payments to Iraq during 2001\/02 in breach of United Nations sanctions. Richard Gledhill, who was sales manager for contracts in Iraq, pleaded guilty to sanctions offences at an earlier hearing and gave evidence for the Prosecution.  The company, Mabey \u0026 Johnson Ltd, of Twyford, Berkshire, had entered into a contract under the UN Oil-For-Food Programme to supply 13 steel modular bridges.  The illegal payments of over \u20ac420,000 that secured the contract with the Iraqi government represented 10% of the total contract value.\u0022  (Source:  UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd: Former executives jailed for helping finance Saddam Hussein\u0027s government,\u0022 February 23, 2011.  For background on the case, see UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson directors made illegal payments to Sadam Hussein\u0027s Iraq to gain contract,\u0022 February 10, 2011.)","Sources ":"UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd: Former executives jailed for helping finance Saddam Hussein\u0027s government,\u0022 February 23, 2011, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2011\/mabey--johnson-ltd-former-executives-jailed-for-helping-finance-saddam-hussein\u0027s-government.aspx; UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson directors made illegal payments to Sadam Hussein\u0027s Iraq to gain contract,\u0022 February 10, 2011, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2011\/mabey--johnson-directors-made-illegal-payments-to-sadam-hussein\u0027s-iraq-to-gain-contract.aspx","Documents":""},{"Case ID":"ST-263","Case Cluster ":"Mabey \u0026 Johnson Ltd.","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"01\/13","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Civil Recovery Order (Proceeds of Crime Act)","Monetary Sanctions  (Types)":"Civil Recovery Order, Legal Costs","Total Monetary Sanctions (US$)":"$204,835.86","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"$3,739.86 ","Civil Disgorgement of Profits (US$) ":"$201,096","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Share Dividends Received from Contracts Won through Unlawful Conduct","Offenses - Settled":"Share Dividends Received from Contracts Won through Unlawful Conduct","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Press Release by the UK Serious Fraud Office, \u0022The Director of the Serious Fraud Office (SFO) has taken action in the High Court, which has resulted in an Order for the company, Mabey Engineering (Holdings) Ltd, to pay over \u00a3130,000 in recognition of sums it received through share dividends derived from contracts won through unlawful conduct. Mabey Engineering (Holdings) Ltd is the parent company of modular bridge manufacturers Mabey and Johnson Ltd and part of the Mabey Holdings group. Mabey and Johnson (M\u0026J) has been working with the SFO since the beginning of 2008 when it approached the authorities to highlight irregularities it had identified as a result of an internal investigation. Following the self-referral and subsequent co-operation with the SFO\u0027s investigations M\u0026J pleaded guilty to charges of corruption and breaches of United Nations sanctions and was convicted at Southwark Crown Court in September 2009. [ ]  The settlement will see the shareholder of M\u0026J pay \u00a3131,201 under Part 5 of the Proceeds of Crime Act 2002.  The action, which represents the conclusion of all matters related to the self-referral, arises from the successful prosecution in February 2011 of former M\u0026J company officers; David Mabey and Charles Forsyth and the earlier conviction of M\u0026J employee Richard Gledhill for their part in breaching UN Sanctions with Iraq.  The sum represents the dividends which the parent company collected from the contracts at the centre of the UN Sanctions prosecutions.  The company will also pay costs of \u00a32,440.\u0022  (Source: UK Serious Fraud Office Press Release, \u0022Shareholder agrees civil recovery by SFO in Mabey \u0026 Johnson,\u0022 January 13, 2012.)\r\n","Sources ":"UK Serious Fraud Office Press Release, \u0022Shareholder agrees civil recovery by SFO in Mabey \u0026 Johnson,\u0022 January 13, 2012, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2012\/shareholder-agrees-civil-recovery-by-sfo-in-mabey--johnson.aspx","Documents":""},{"Case ID":"ST-355","Case Cluster ":"Tenaris, S.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Uzbekistan","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"05\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$3,500,000.00","Criminal Fine\/Penalty (US$) ":"$3,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, on May 17, 2011, Tenaris S.A., a publicly traded corporation headquartered in Luxembourg agreed to pay $3.5 million in criminal penalties for violation of the Foreign Corrupt Practices Act and entered into a Non-Prosecution Agreement with the Department of Justice. (Source: US Department of Justice Press Release, \u0022Tenaris S.A. Agrees to Pay $3.5 Million Criminal Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 May 17, 2011.)   The NPA included a provision which states \u0022It is understood that Tenaris admits, accepts, and acknowledges responsibility for the conduct of its employees, agents, and subsidiaries set forth in Appendix A [Statement of Facts],\u0022 namely that employees and agents of Tenaris offered and made improper payments to officials of OJSC O\u0027ztashqineftgaz, an Uzbekistan state-controlled oil and gas production company, and failed to record such payments in Tenaris\u0027s books and records.  (Source: In Re Tenaris, Department of Justice Non-Prosecution Agreement dated March 14, 2011.)  According to the United States June 2011 \u0022Steps taken to implement and enforce the OECD Convention on Combatting Bribery of Foreign Public Officials in International Business Transactions,\u0022 Report to the OECD, \u0022This enforcement action marked the first-ever use of a DPA [Deferred Prosecution Agreement] to facilitate and reward cooperation in a SEC investigation.\u0022 (at 11)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 June 2011, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf;  In Re Tenaris, S.A., DOJ Non-Prosecution Agreement dated March 14, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tenaris-sa\/2011-03-14-tenaris.pdf and Press Release of May 17, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/May\/11-crm-629.html.","Documents":""},{"Case ID":"ST-356","Case Cluster ":"Tenaris, S.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Uzbekistan","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"05\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Deferred Prosecution Agreement ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$5,428,338.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$4,786,438","Civil Prejudgment Interest (US$) ":"$641,900","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States June 2011 \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Report to the OECD, \u0022This enforcement action marked the first-ever use of a DPA [Deferred Prosecution Agreement] to facilitate and reward cooperation in a SEC investigation.\u0022 (at 11)  Please note that the Tenaris DPA with the SEC includes a \u0022Statement of Facts,\u0022 but as noted in the document, Tenaris agreed to the settlement \u0022without admitting or denying the allegations\u0022 made against it by the SEC. (Source: In Re Tenaris, S.A., SEC Deferred Prosecution Agreement, May 17, 2011.)  According to the DPA, \u0022Between in or around April 2006 through May 2007, Tenaris bid on a series of contracts with OJSC O\u0027ztashqineftgaz (\u0022OAO\u0022), to supply OAO with pipeline for use in the development and production of oil and natural gas in Uzbekistan. OAO was a subsidiary ofUzbekneftegaz, the state-owned holding company of Uzbekistan\u0027s oil and gas industry.\u0022  The SEC had alleged that Tenaris retained an agent in connection with those contract bids and made commission payments to the agent, and that \u0022Tenaris\u0027s then-regional sales personnel understood that a portion of the commission Tenaris paid to the Agent for services related to contracts M-07-53, M-0770, M-07-71 and M-07-72 would be used to pay OAO officials for opening competitors\u0027 bids, providing confidential bid information to Tenaris, and replacing Tenaris\u0027s original bids with its revised bids.\u0022 (at para 6n)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 June 2011, Tenaris Case Summary, at 11-12, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   In Re Tenaris, S.A., SEC Deferred Prosecution Agreement, May 17, 2011, accessed at  http:\/\/www.sec.gov\/news\/press\/2011\/2011-112-dpa.pdf.","Documents":""},{"Case ID":"ST-357","Case Cluster ":"Textron Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Egypt, India, Indonesia, Iraq (UN Oil-for-Food), United Arab Emirates ","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"08\/23","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,150,000.00","Criminal Fine\/Penalty (US$) ":"$1,150,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records","Offenses - Settled":"Bribery of Foreign Officials, Falsification of Books and Records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On August 23, 2007, Textron, Inc., a Rhode Island-based industrial equipment company, settled allegations with the Department of Justice and the SEC relating to kickbacks paid to the former Government of Iraq under the United Nations Oil for Food Program (OFFP). As part of a consent agreement with the SEC and a non-prosecution agreement with the Department, Textron acknowledged responsibility for kickbacks paid to the Iraqi government by its David Brown French subsidiaries in exchange for contracts worth $1,936,936 to provide industrial pumps, gears, and other equipment to Iraqi ministries under the OFFP. According to settlement documents, the subsidiaries in Textron\u0027s Fluid and Power Business Unit paid a total of more than $650,000 in kickbacks by inflating the price of contracts by 10 percent before submitting the contracts to the U.N. for approval. These kickback payments, which bypassed the U.N. escrow account, were paid by third parties to Iraqi government-controlled accounts. During the course of its own internal investigation, Textron also uncovered an additional 36 illicit payments totaling almost $115,000 that were made to officials of state-owned companies in countries other than Iraq, including the United Arab Emirates, Bangladesh, Indonesia, Egypt, and India, in order to obtain similar contracts.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 June 2011, Textron inc. Case Summary, at 99-100.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 June 2011, Textron inc. Case Summary, at 99-100, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  In re: Textron, Inc., Non-Prosecution Agreement and Statement of Facts (August 23, 2007), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/textron-inc\/08-21-07textron-agree.pdf and US Department of Justice Press Release, \u0022Textron Inc. Agrees to $1.15 Million Fine in Connection with Payment of $600,000 in Kickbacks by its French Subsidiaries under the United Nations Oil for Food Program,\u0022 August 23, 2007, accessed at http:\/\/fcpa.shearman.com\/files\/04e\/04e42ef825608000bc64d754b81f7093.pdf?i=92fe69b0c1a0458c55646f7fc899da95 (also available at http:\/\/www.justice.gov\/opa\/pr\/2007\/August\/07_crm_646.html); SEC v. Textron, Inc. (D.D.C.), Complaint filed on August 23, 2007 and Final Judgment filed August 31, 2007, accessed at http:\/\/fcpa.shearman.com\/files\/479\/479ab232d795496347543f9673c118e3.pdf?i=b403e47bd0a0e0e148a9d284811430d3 and http:\/\/fcpa.shearman.com\/files\/2a9\/2a95205e0169f1db9e04408b41e6ddc6.pdf?i=7c4b4d50118071cab831985af973acff, respectively.","Documents":""},{"Case ID":"ST-358","Case Cluster ":"Textron Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Bangladesh, Egypt, India, Indonesia, Iraq (UN Oil-for-Food), United Arab Emirates ","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"08\/23","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$3,535,040.68","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$2,284,579","Civil Prejudgment Interest (US$) ":"$450,462","Civil Fine \/ Penalty (US$)":"$800,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On August 23, 2007, Textron, Inc., a Rhode Island-based industrial equipment company, settled allegations with the Department of Justice and the SEC relating to kickbacks paid to the former Government of Iraq under the United Nations Oil for Food Program (OFFP). As part of a consent agreement with the SEC and a non-prosecution agreement with the Department, Textron acknowledged responsibility for kickbacks paid to the Iraqi government by its David Brown French subsidiaries in exchange for contracts worth $1,936,936 to provide industrial pumps, gears, and other equipment to Iraqi ministries under the OFFP. According to settlement documents, the subsidiaries in Textron\u0027s Fluid and Power Business Unit paid a total of more than $650,000 in kickbacks by inflating the price of contracts by 10 percent before submitting the contracts to the U.N. for approval. These kickback payments, which bypassed the U.N. escrow account, were paid by third parties to Iraqi government-controlled accounts. During the course of its own internal investigation, Textron also uncovered an additional 36 illicit payments totaling almost $115,000 that were made to officials of state-owned companies in countries other than Iraq, including the United Arab Emirates, Bangladesh, Indonesia, Egypt, and India, in order to obtain similar contracts.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 June 2011, Textron inc. Case Summary, at 99-100.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 June 2011, Textron inc. Case Summary, at 99-100, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  SEC v. Textron, Inc. (D.D.C.), Complaint filed on August 23, 2007 and Final Judgment filed August 31, 2007, accessed at http:\/\/fcpa.shearman.com\/files\/479\/479ab232d795496347543f9673c118e3.pdf?i=b403e47bd0a0e0e148a9d284811430d3 and http:\/\/fcpa.shearman.com\/files\/2a9\/2a95205e0169f1db9e04408b41e6ddc6.pdf?i=7c4b4d50118071cab831985af973acff, respectively. SEC press release accessed at; http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20251.htm","Documents":""},{"Case ID":"ST-359","Case Cluster ":"Titan Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Benin","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"03\/01","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$15,479,195.47","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$12,620,000","Civil Prejudgment Interest (US$) ":"$2,859,195","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States June 2011 Report to the OECD, \u0022Titan Corporation (Titan), a Delaware Corporation headquartered in San Diego, CA, is a global provider of military intelligence and communications solutions. In October 1998, Titan established a joint venture with Afronetwork, a Benin telecommunications company, to build a satellite-based telephone system in Benin. In a November meeting between Titan and Afronetwork, Titan was introduced to a \u0022business advisor\u0022 to the president of Benin. Titan subsequently hired the \u0022advisor\u0022 to assist with the contract in exchange for 5% of the value of all equipment installed in Benin. Revenues from the contract were close to $100 million, and Titan subsequently made over $2.3 million in payments to the agent, including via offshore accounts in Monaco. Titan recorded the payments as \u0022consulting services\u0022 in its corporate books and records and broke the payments into smaller increments to make them appear more reasonable.\u0022  (Source: Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Titan Corporation Case Summary at 116-117.)   According to the SEC Litigation Release, to settle the SEC\u0027s civil charges, Titan agreed to pay $12.62 million in disgorgement along with $2,859,195.47 million in prejudgment interest. In addition, Titan was ordered to pay a civil penalty of $13 million, which was deemed satisfied by payment of the same amount in criminal fines. (Source: US Securities and Exchange Commission Litigation Release No. 19107 \\ March 1, 2005, Securities and Exchange Commission v. The Titan Corporation, Case No. 05-0411 (D.D.C.) (JR) (filed March 1, 2005), \u0022SEC Sues The Titan Corporation for Payments to Campaign of Benin President.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Titan Corporation Case Summary at 116-117, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 19107 \\ March 1, 2005, Securities and Exchange Commission v. The Titan Corporation, Case No. 05-0411 (D.D.C.) (JR) (filed March 1, 2005), \u0022SEC Sues The Titan Corporation for Payments to Campaign of Benin President,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr19107.htm; Complaint filed March 1, 2005, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/comp19107.pdf; Investigation Report, Release No. 51283 \/ March 1, 2005, accessed at http:\/\/www.sec.gov\/litigation\/investreport\/34-51238.htm","Documents":""},{"Case ID":"ST-360","Case Cluster ":"Titan Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Benin","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"03\/01","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$13,000,000.00","Criminal Fine\/Penalty (US$) ":"$13,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Filing a false tax return","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records, Filing a false tax return","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States June 2011 Report to the OECD, \u0022Titan Corporation (Titan), a Delaware Corporation headquartered in San Diego, CA, is a global provider of military intelligence and communications solutions. In October 1998, Titan established a joint venture with Afronetwork, a Benin telecommunications company, to build a satellite-based telephone system in Benin. In a November meeting between Titan and Afronetwork, Titan was introduced to a \u0022business advisor\u0022 to the president of Benin. Titan subsequently hired the \u0022advisor\u0022 to assist with the contract in exchange for 5% of the value of all equipment installed in Benin. Revenues from the contract were close to $100 million, and Titan subsequently made over $2.3 million in payments to the agent, including via offshore accounts in Monaco. Titan recorded the payments as \u0022consulting services\u0022 in its corporate books and records and broke the payments into smaller increments to make them appear more reasonable.\u0022  (Source: Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Titan Corporation Case Summary at 116-117.)   See also, US v. Titan Corporation, Case No. 05-cr-0314 (S.D. Cal.) documents listed in Sources field.","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Titan Corporation Case Summary at 116-117, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Titan Corporation, Case No. 05-cr-314 (S.D. Cal.), Information filed on March 1, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/titan-corp\/03-01-05titan-info.pdf; Plea Agreement filed March 1, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/titan-corp\/03-01-05titan-plea.pdf; Office of the United States Attorney for the Southern District of California, News Release March 1, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/titan-corp\/03-01-05titan-pr-plea.pdf; Judgment filed March 21, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/titan-corp\/03-21-05titan-judgment.pdf; Amended Judgment filed April 13, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/titan-corp\/04-13-05titan-judgment.pdf","Documents":""},{"Case ID":"ST-361","Case Cluster ":"Titan Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Benin","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"06\/23","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$5,000.00","Criminal Fine\/Penalty (US$) ":"$5,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Falsification of books and records","Offenses - Settled":"Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States June 2011 Report to the OECD, \u0022Titan Corporation (Titan), a Delaware Corporation headquartered in San Diego, CA, is a global provider of military intelligence and communications solutions. In October 1998, Titan established a joint venture with Afronetwork, a Benin telecommunications company, to build a satellite-based telephone system in Benin. In a November meeting between Titan and Afronetwork, Titan was introduced to a \u0022business advisor\u0022 to the president of Benin. Titan subsequently hired the \u0022advisor\u0022 to assist with the contract in exchange for 5% of the value of all equipment installed in Benin. Revenues from the contract were close to $100 million, and Titan subsequently made over $2.3 million in payments to the agent, including via offshore accounts in Monaco. Titan recorded the payments as \u0022consulting services\u0022 in its corporate books and records and broke the payments into smaller increments to make them appear more reasonable.\u0022  The Report also noted that Steven Lynwood Head, Chief Executive Officer of Titan Africa, Inc. also pleaded guilty to charge of falsification of books and records and was fined $5,000.  (Source: Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Titan Corporation Case Summary at 116-117.)   See also, US v. Steven Lynwood Head, Case No. 06-cr-1380-BEN (S.D. Cal.) documents listed in source column.  ","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Titan Corporation Case Summary at 116-117, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Steven Lynwood Head, Case No. 3:06-cr-1380-BEN (S.D. Cal.), Information filed June 23, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/heads\/06-27-06head-info.pdf; Plea Agreement filed June 26, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/heads\/06-23-6head-plea.pdf; Government\u0027s Motion for Downward Departure in Sentencing filed September 21, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/heads\/09-21-07headgovt5k1-depart.pdf; Judgment filed October 4, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/heads\/10-04-07head-judgment.pdf","Documents":""},{"Case ID":"ST-362","Case Cluster ":"Tyco International Ltd.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Brazil, South Korea","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"04\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Civil Penalty ","Total Monetary Sanctions (US$)":"$50,000,001.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$50,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations. Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the SEC Litigation Release in SEC v. Tyco International, Ltd., the company settled a civil injunctive action in the U.S. District Court for the Southern District of New York.  The SEC\u0027s complaint alleged that, from 1996 through 2002, Tyco violated federal securities laws including inflating operating income, failure to disclose executive compensation, and violated antibribery provisions of the Foreign Corrupt Practices Act when employees or agents of its Earth Tech Brasil Ltds. subsidiary made payments to Brazilian officials for the purpose of obtaining or retaining business for Tyco. The final judgment also orders Tyco to pay $1 in disgorgement and a $50 million civil penalty. (Source: Securities and Exchange Commission Litigation Release No. 19657 (April 17, 2006) in SEC v. Tyco International Ltd., Case No. 2:06-cv-2942 (S.D.N.Y. 2006).  Pleae note that as part of the settlement, a Final Judgment was entered against Tyco International without the company admitting or denying the allegations of the Complaint (except as to jurisdiction).  (Source: SEC v. Tyco International Ltd., Case No. 2:06-cv-2942 (S.D.N.Y.), Final Judgment filed April 27, 2006.) [The US June 2011 Report to the OECD, Tyco case summary noted that $1 million in disgorgement had been ordered.]","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Tyco Internatonal Ltd., at 107; Securities and Exchange Commission Litigation Release No. 19657 (April 17, 2006) in SEC v. Tyco International Ltd., Case No. 2:06-cv-2942 (S.D.N.Y.), Complaint filed April 17, 2006.  Litigation Release accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2006\/lr19657.htm and Complaint at http:\/\/www.sec.gov\/litigation\/complaints\/2006\/comp19657.pdf; Final Judgment filed April 27, 2006 at http:\/\/fcpa.shearman.com\/files\/274\/27418a1c06809e1f95673bd0d7a0921f.pdf?i=82ab60c8ea2f89f59d46535a2094a129.","Documents":""},{"Case ID":"ST-363","Case Cluster ":"Tyson Foods, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"02\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$4,000,000.00","Criminal Fine\/Penalty (US$) ":"$4,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"No (Inspectors)","Summary":"According to the US Department of Justice Press Release, \u0022As part of a deferred prosecution agreement with the department, Tyson acknowledged responsibility for the actions of its subsidiaries, employees and agents who made improper payments to government-employed veterinarians who inspected two of its chicken processing plants in Gomez Palacio, Mexico.  [  ] According to documents filed in court, Tyson\u0027s Mexican subsidiary, Tyson de Mexico, paid approximately $90,000 between 2004 and 2006, to two publicly-employed veterinarians who inspected its Mexican plants, resulting in profits of approximately $880,000.  The payments were made both directly to the veterinarians and indirectly through their wives, who Tyson de Mexico listed on its payroll, although neither performed any services for Tyson.  According to court documents, the bribe payments were made to keep the veterinarians from disrupting the operations of the meat-production facilities.  When payments to the spouses were terminated in 2004, Tyson representatives agreed to increase the amount paid to the veterinarians to match the amount previously paid to their spouses.\u0022 (Source: US Department of Justice Press Release, \u0022Tyson Foods Inc. Agrees to Pay $4 Million Criminal Penalty to Resolve Foreign Bribery Allegations,\u0022 February 10, 2011.)","Sources ":"US Department of Justice Press Release, \u0022Tyson Foods Inc. Agrees to Pay $4 Million Criminal Penalty to Resolve Foreign Bribery Allegations,\u0022 February 10, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/February\/11-crm-171.html;  US v. Tyson Foods, Inc., Case No. 1:11-cr-00037 (D.D.C.), Information filed February 10, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tyson-foods\/02-10-11tyson_foods_info.pdf; and Deferred Prosecution Agreement dated February 4, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tyson-foods\/02-10-11tyson_foods_dpa.pdf.","Documents":""},{"Case ID":"ST-364","Case Cluster ":"Tyson Foods, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Mexico","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"02\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest ","Total Monetary Sanctions (US$)":"$1,214,477.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$880,786","Civil Prejudgment Interest (US$) ":"$333,691","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art.1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"NO (INSPECTORS)","Summary":"According to the US Department of Justice Press Release, \u0022As part of a deferred prosecution agreement with the department, Tyson acknowledged responsibility for the actions of its subsidiaries, employees and agents who made improper payments to government-employed veterinarians who inspected two of its chicken processing plants in Gomez Palacio, Mexico.  [  ] According to documents filed in court, Tyson\u0027s Mexican subsidiary, Tyson de Mexico, paid approximately $90,000 between 2004 and 2006, to two publicly-employed veterinarians who inspected its Mexican plants, resulting in profits of approximately $880,000.  The payments were made both directly to the veterinarians and indirectly through their wives, who Tyson de Mexico listed on its payroll, although neither performed any services for Tyson.  According to court documents, the bribe payments were made to keep the veterinarians from disrupting the operations of the meat-production facilities.  When payments to the spouses were terminated in 2004, Tyson representatives agreed to increase the amount paid to the veterinarians to match the amount previously paid to their spouses.\u0022 (Source: US Department of Justice Press Release, \u0022Tyson Foods Inc. Agrees to Pay $4 Million Criminal Penalty to Resolve Foreign Bribery Allegations,\u0022 February 10, 2011.)   The US Securities and Exchange Commission made the same allegations and also alleged that the company failed to keep accurate books and records and to implement a system of effective internal controls to prevent improper payments.  (Source: SEC v. Tyson Foods, Inc., Case No. 1:11-cv-00350 (D.D.C.), Complaint filed February 10, 2011.)  Without admitting or denying the SEC\u0027s allegations, Tyson Foods consented to the entry of a final judgment ordering disgorgement of profits and prejudgment interest and enjoining the company from future FCPA violations. (Source: SEC v. Tyson Foods, Inc., Case No. 1:11-cv-00350 (D.D.C.), Final Judgment filed February 15, 2011.)","Sources ":"U.S. Securities and Exchange Commission, Litigation Release No. 21851 \/ February 10, 2011, \u0022SEC Charges Tyson Foods With FCPA Violations; Tyson Foods to Pay Disgorgement Plus Pre-judgment Interest of More Than $1.2 million; Tyson Foods to Pay Criminal Penalty of $4 Million,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr21851.htm; SEC v. Tyson Foods, Inc., Case No. 1:11-cv-00350 (D.D.C.), Complaint filed February 10, 2011, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp21851.pdf and Final Judgment filed February 15, 2011 (accessed via Pacer).  DOJ:  US Department of Justice Press Release, \u0022Tyson Foods Inc. Agrees to Pay $4 Million Criminal Penalty to Resolve Foreign Bribery Allegations,\u0022 February 10, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/February\/11-crm-171.html;  US v. Tyson Foods, Inc., Case No. 1:11-cr-00037 (D.D.C.), Information filed February 10, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tyson-foods\/02-10-11tyson_foods_info.pdf; and Deferred Prosecution Agreement dated February 4, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tyson-foods\/02-10-11tyson_foods_dpa.pdf.","Documents":""},{"Case ID":"ST-365","Case Cluster ":"UNC \/ Lear Services Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2000","Month\/Day of Settlement (or Notes)":"03\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Restitution, Special Assessment","Total Monetary Sanctions (US$)":"$844,200.00","Criminal Fine\/Penalty (US$) ":"$75,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$768,000","Criminal Legal \/ Procedural Costs (US$)":"$1,200 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Falsification of books and records, Mail fraud, Making a false statement","Offenses - Settled":"Falsification of books and records,Mail fraud, Making a false statement","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 UNC\/Lear Services, Inc. at 122: Misconduct took place in Saudi Arabia between 1993 and 1995; the US Department of Justice charged UNC\/Lear Services on February 17, 2000; the charges arose from the company\u0027s efforts to conceal $140,000 in illicit payments which were made to a Kentucky corporation for the benefit of a Saudi Arabian consultant; the payments were descibed in the company\u0027s books and records as \u0022fees for engineering services\u0022 and the consultant provided UNC\/Lear with false invoices to support the payments.   The Court Docket report in US v. UNC\/Lear Services, Case No. 3:00-cr-00031-EHJ (W.D. Ky.) noted that on September 10, 2000, UNC\/Lear pleaded guilty to all charges on March 6, 2000, and was sentenced to pay SPA $1200, $75,000 criminal fine, and $768,000 in restitution; the documents in the case were unavailable via Pacer.  The Docket Report does not indicate the recipient of the restitution ordered.","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 UNC\/Lear Services Inc.,  at 122, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US v. UNC\/Lear Services, Case No. 3:00-cr-00031-EHJ (W.D. Ky.), Court Docket Report accessed via Pacer on October 24, 2011.  See also, US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, UNC\/Lear Services Inc. Case Summary at 132, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-366","Case Cluster ":"United Industrial Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Egypt","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"05\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$337,679.42","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$267,571","Civil Prejudgment Interest (US$) ":"$70,108.42","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On May 29, 2009, the SEC filed a settled enforcement action in the U.S. District Court for the District of Columbia against Thomas Wurzel, the former President of ACL Technologies, Inc. (ACL), formerly a subsidiary of United Industrial Corporation (UIC), which provided aerospace and defense systems. In a related action, the SEC also instituted, on May 29, 2009, a settled administrative proceeding against UIC.The Commission\u0027s complaint against Wurzel alleged that he authorized illicit payments to an Egyptian-based agent while he knew or consciously disregarded the high probability that the agent would offer, provide, or promise at least a portion of such payments to Egyptian Air Force officials for the purpose of influencing these officials to award business related to a military aircraft depot in Cairo, Egypt to UIC. In relation to this misconduct, the Commission charged Wurzel with violations of the anti-bribery, books and records and internal controls provisions of the FCPA, and with aiding and abetting UIC\u0027s violations of the anti-bribery and books and records provisions of the FCPA.The Commission\u0027s complaint alleges that from late 2001 through 2002, Wurzel authorized three forms of illicit payments to the agent: (1) payments to the agent ostensibly for labor subcontracting work; (2) a $100,000 advance payment to the agent in June 2002 for \u0022equipment and materials;\u0022 and (3) a $50,000 payment to the agent in November 2002 for \u0022marketing services.\u0022 Furthermore, Wurzel later directed his subordinates to create false invoices to conceal the fact that the $100,000 \u0022advance payment\u0022 in June 2002 was never repaid. As a result, UIC, through ACL, was awarded a contract with gross revenues and net profits of approximately $5.3 million and $267,000, respectively.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, United Industrial Corporation Case Summary at 65-66.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, United Industrial Corporation Case Summary at 65-66, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, In the Matter of United Industrial Corporation, Administrative Proceedings File No. 3-13495, Corrected Order Instituting Cease and Desist Proceedings, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2009\/34-60005.pdf","Documents":""},{"Case ID":"ST-367","Case Cluster ":"United Industrial Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Egypt","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"05\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$35,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$35,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"False accounting, Aiding and Abetting UIC\u0027s Bribery of Foreign Officials, Aiding adn Abetting UIC\u0027s Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On May 29, 2009, the SEC filed a settled enforcement action in the U.S. District Court for the District of Columbia against Thomas Wurzel, the former President of ACL Technologies, Inc. (ACL), formerly a subsidiary of United Industrial Corporation (UIC), which provided aerospace and defense systems. In a related action, the SEC also instituted, on May 29, 2009, a settled administrative proceeding against UIC.The Commission\u0027s complaint against Wurzel alleged that he authorized illicit payments to an Egyptian-based agent while he knew or consciously disregarded the high probability that the agent would offer, provide, or promise at least a portion of such payments to Egyptian Air Force officials for the purpose of influencing these officials to award business related to a military aircraft depot in Cairo, Egypt to UIC. In relation to this misconduct, the Commission charged Wurzel with violations of the anti-bribery, books and records and internal controls provisions of the FCPA, and with aiding and abetting UIC\u0027s violations of the anti-bribery and books and records provisions of the FCPA.The Commission\u0027s complaint alleges that from late 2001 through 2002, Wurzel authorized three forms of illicit payments to the agent: (1) payments to the agent ostensibly for labor subcontracting work; (2) a $100,000 advance payment to the agent in June 2002 for \u0022equipment and materials;\u0022 and (3) a $50,000 payment to the agent in November 2002 for \u0022marketing services.\u0022 Furthermore, Wurzel later directed his subordinates to create false invoices to conceal the fact that the $100,000 \u0022advance payment\u0022 in June 2002 was never repaid. As a result, UIC, through ACL, was awarded a contract with gross revenues and net profits of approximately $5.3 million and $267,000, respectively.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, United Industrial Corporation Case Summary at 65-66.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, United Industrial Corporation Case Summary at 65-66, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  SEC v. Thomas Wurzel, Case No. 1:09-cv-01005 (D.D.C.), Complaint filed May 29, 2009, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp21063.pdf and SEC Litigation Release No. 21063 in SEC v. Wurzel, accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21063.htm; and In the Matter of United Industrial Corporation, Administrative Proceeding File No. 3-13495, Corrected Order Instituting Cease-and-Desist Proceedings Pursuant to Section 21C of the Securities and Exchange Act of 1934, Making Findings and Imposing a Cease-and-Desist Order, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2009\/34-60005.pdf.","Documents":""},{"Case ID":"ST-368","Case Cluster ":"Universal Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Malawi, Mozambique, Thailand","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine (if subsidiary does not make payment)","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Conspiracy to Falsify Books and Records, Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Conspiracy to Falsify Books and Records, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, On August 6, 2010, \u0022Universal Leaf Tabacos Ltda. (Universal Brazil), the Brazilian subsidiary of Universal Corporation (Universal), was charged in the Eastern District of Virginia with conspiring to violate the anti-bribery and books and records provisions of the FCPA, and with violating the anti-bribery provisions of the FCPA. On the same date, the SEC filed a settled civil action against Universal in the District of Columbia, charging the parent company with violations of the anti-bribery, books and records, and internal controls provisions of the FCPA. The criminal and civil charges against Universal and its subsidiary stem from schemes to bribe foreign officials in Thailand, Mozambique, and Malawi.  From 2000 to 2004, Universal Brazil and two of its competitors, Dimon Incorporated and Standard Commercial Corporation, sold Brazilian-grown tobacco to the Thailand Tobacco Monopoly (TTM). Each of these three companies retained sales agents in Thailand, and collaborated through those agents to apportion tobacco sales to the TTM among themselves, coordinate their sales prices, and pay kickbacks to officials of the Thailand Tobacco Monopoly in order to ensure that each company would share in the Thai tobacco market. These companies made annual sales to the TTM, and in order to secure these sales contracts, each company paid kickbacks to certain TTM representatives based on the number of kilograms of tobacco they sold to the TTM. To obtain these contracts, Universal Brazil paid approximately $697,000 in bribes to TTM officials during this period. In addition, Universal Brazil employees then falsely characterized the corrupt payments on the company\u0027s books and records as \u0022commissions\u0022 paid to the company\u0027s sales agents.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Universal Corporation Case Summary at 44-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.)  According to the Universal Corporation\u0027s Non-Prosecution Agreement with the Department of Justice, \u0022It is understood that [Universal Corporation\u0027s subsidiary] Universal Brazil has agreed to pay a monetary penalty in the amount of $4,400,000. Universal agrees to pay this monetary penalty to the United States Treasury on behalf of Universal Brazil if for any reason Universal Brazil has not paid this amount within ten days of the sentencing of Universal Brazil.\u0022  (Source: In Re: Universal Corporation, Department of Justice Non-Prosecution Agreement and Statement of Facts, August 6, 2010.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Universal Corporation Case Summary at 44-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  In Re: Universal Corporation, Department of Justice Non-Prosecution Agreement and Statement of Facts, August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/universal-corp.html and US Department of Justice Press Release, \u0022Alliance One International Inc. and Universal Corporation Resolve Related FCPA Matters Involving Bribes Paid to Foreign Government Officials,\u0022 August 6, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/August\/10-crm-903.html.  US Department of Justice Press Release, \u0022Alliance One International Inc. and Universal Corporation Resolve Related FCPA Matters Involving Bribes Paid to Foreign Government Officials,\u0022 August 6, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/August\/10-crm-903.html","Documents":""},{"Case ID":"ST-369","Case Cluster ":"Universal Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Thailand, Malawi, Mozambique","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit","Total Monetary Sanctions (US$)":"$4,581,276.51","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$4,581,276.51","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records, Internal Controls Violations ","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, on August 6, 2010, the Commission charged Universal Corporation with violations of the FCPA, namely \u0022According to the SEC\u0027s complaint, between 2000 and 2004, Universal, in coordination with two of its competitors, Dimon, Inc. (\u0022Dimon\u0022) and Standard Commercial Corporation (\u0022Standard\u0022), paid approximately $800,000 to bribe officials of the government-owned Thailand Tobacco Monopoly (\u0022TTM\u0022) in exchange for securing approximately $11.5 million in sales contracts for its subsidiaries in Brazil and Europe. From 2004 through 2007, Universal also made a series of payments in excess of $165,000 to government officials in Mozambique through corporate subsidiaries in Belgium and Africa. Universal made these payments, among other things, to secure an exclusive right to purchase tobacco from regional growers and to procure legislation beneficial to the company\u0027s business. Between 2002 and 2003, Universal subsidiaries paid a total of $850,000 to high-ranking Malawian government officials. Universal did not accurately record these payments in its books and records.\u0022 (Source:  US Securities and Exchange Commission Litigation Release No. 21618 \/ August 6, 2010, Securities and Exchange Commission v. Universal Corporation Inc., Civil Action No. 01:10-cv-01318 (RWR) (D.D.C.) (filed August 6, 2010), Securities and Exchange Commission v. Alliance One International, Inc., Civil Action No. 01:10-cv-01319 (RMU) (D.D.C.) (filed August 6, 2010), \u0022SEC Files Anti-Bribery Charges Against Two Global Tobacco Companies.\u0022)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Universal Corporation Case Summary at 44-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 21618 \/ August 6, 2010, Securities and Exchange Commission v. Universal Corporation Inc., Civil Action No. 01:10-cv-01318 (RWR) (D.D.C.) (filed August 6, 2010), Securities and Exchange Commission v. Alliance One International, Inc., Civil Action No. 01:10-cv-01319 (RMU) (D.D.C.) (filed August 6, 2010), \u0022SEC Files Anti-Bribery Charges Against Two Global Tobacco Companies,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21618.htm; Complaint filed August 6, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21618-universal.pdf","Documents":""},{"Case ID":"ST-370","Case Cluster ":"Universal Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Malawi, Mozambique, Thailand","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$4,400,000.00","Criminal Fine\/Penalty (US$) ":"$4,400,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Conspiracy to Falsify Books and Records, Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Conspiracy to Falsify Books and Records, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, On August 6, 2010, \u0022Universal Leaf Tabacos Ltda. (Universal Brazil), the Brazilian subsidiary of Universal Corporation (Universal), was charged in the Eastern District of Virginia with conspiring to violate the anti-bribery and books and records provisions of the FCPA, and with violating the anti-bribery provisions of the FCPA. On the same date, the SEC filed a settled civil action against Universal in the District of Columbia, charging the parent company with violations of the anti-bribery, books and records, and internal controls provisions of the FCPA. The criminal and civil charges against Universal and its subsidiary stem from schemes to bribe foreign officials in Thailand, Mozambique, and Malawi.  From 2000 to 2004, Universal Brazil and two of its competitors, Dimon Incorporated and Standard Commercial Corporation, sold Brazilian-grown tobacco to the Thailand Tobacco Monopoly (TTM). Each of these three companies retained sales agents in Thailand, and collaborated through those agents to apportion tobacco sales to the TTM among themselves, coordinate their sales prices, and pay kickbacks to officials of the Thailand Tobacco Monopoly in order to ensure that each company would share in the Thai tobacco market. These companies made annual sales to the TTM, and in order to secure these sales contracts, each company paid kickbacks to certain TTM representatives based on the number of kilograms of tobacco they sold to the TTM. To obtain these contracts, Universal Brazil paid approximately $697,000 in bribes to TTM officials during this period. In addition, Universal Brazil employees then falsely characterized the corrupt payments on the company\u0027s books and records as \u0022commissions\u0022 paid to the company?s sales agents.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Universal Corporation Case Summary at 44-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.)  According to the Universal Corporation\u0027s Non-Prosecution Agreement with the Department of Justice, \u0022It is understood that [Universal Corporation\u0027s subsidiary] Universal Brazil has agreed to pay a monetary penalty in the amount of $4,400,000. Universal agrees to pay this monetary penalty to the United States Treasury on behalf of Universal Brazil if for any reason Universal Brazil has not paid this amount within ten days of the sentencing of Universal Brazil.\u0022  (Source: In Re: Universal Corporation, Department of Justice Non-Prosecution Agreement and Statement of Facts, August 6, 2010.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Universal Corporation Case Summary at 44-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Universal Leaf Tabacos Ltda., Case No. 3:10-cr-225-REP (E.D. Va.), Information filed August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/universal-leaf\/08-06-10universal-leaf-info.pdf; Plea Agreement filed August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/universal-leaf\/08-06-10universal-leaf-plea-agmt.pdf; Agreed Sentencing Memorandum filed August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/universal-leaf\/08-06-10universal-leaf-sentencing-memo.pdf; Judgment filed August 31, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/universal-leaf\/08-31-universal-leaf-judgment.pdf.  US Department of Justice Press Release, \u0022Alliance One International Inc. and Universal Corporation Resolve Related FCPA Matters Involving Bribes Paid to Foreign Government Officials,\u0022 August 6, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/August\/10-crm-903.html","Documents":""},{"Case ID":"ST-371","Case Cluster ":"UTStarcom, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"12\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine  ","Total Monetary Sanctions (US$)":"$1,500,000.00","Criminal Fine\/Penalty (US$) ":"$1,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 31, 2009, UTStarcom, Inc. (UTSI), a global telecommunications company that designs, manufactures, and sells network equipment and handsets, entered into a non-prosecution agreement with the Department of Justice regarding the improper provision of travel and other things of value to employees at state-owned telecommunications firms in the People\u0027s Republic of China, in violation of the FCPA. On the same date, the SEC filed a settled civil complaint against UTSI in relation to this conduct.  As part of these agreements, UTSI acknowledged responsibility for the actions of its wholly-owned subsidiary, UTStarcom China Co. Ltd. (UTS-China), and its employees and agents, who arranged and paid for employees of Chinese state-owned telecommunications companies to travel to popular tourist destinations in the United States, including Hawaii, Las Vegas, and New York City. The trips were purportedly for individuals to participate in training at UTSI facilities. In fact, UTSI had no facilities in those locations and conducted no training. UTS-China then falsely recorded these trips as \u0022training\u0022 expenses, while the true purpose for providing these trips was to obtain and retain lucrative telecommunications contracts. The civil complaint filed by the SEC also stated that UTSI had arranged for expensive gifts and all-expense paid trips for officials from government customers in Thailand. In addition, the SEC stated that UTSI made sham payments to a Mongolian consulting company for the purpose of bribing a Mongolian government official to help UTSI obtain a favorable ruling in a license dispute.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, UTStarcom Inc. Case Summary at 56-57.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, UTStarcom Inc. Case Summary at 56-57, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   In Re UTStarcom Inc., Non-Prosecution Agreement filed December 31, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/utstarcom-inc\/12-31-09utstarcom-agree.pdf; US Department of Justice Press Release, \u0022UTStarcom Inc. Agrees to Pay $1.5 Million Penalty for Acts of Foreign Bribery in China,\u0022 December 31, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/December\/09-crm-1390.html","Documents":""},{"Case ID":"ST-372","Case Cluster ":"UTStarcom, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"12\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$1,500,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$1,500,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"$0","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 31, 2009, UTStarcom, Inc. (UTSI), a global telecommunications company that designs, manufactures, and sells network equipment and handsets, entered into a non-prosecution agreement with the Department of Justice regarding the improper provision of travel and other things of value to employees at state-owned telecommunications firms in the People\u0027s Republic of China, in violation of the FCPA. On the same date, the SEC filed a settled civil complaint against UTSI in relation to this conduct.  As part of these agreements, UTSI acknowledged responsibility for the actions of its wholly-owned subsidiary, UTStarcom China Co. Ltd. (UTS-China), and its employees and agents, who arranged and paid for employees of Chinese state-owned telecommunications companies to travel to popular tourist destinations in the United States, including Hawaii, Las Vegas, and New York City. The trips were purportedly for individuals to participate in training at UTSI facilities. In fact, UTSI had no facilities in those locations and conducted no training. UTS-China then falsely recorded these trips as \u0022training\u0022 expenses, while the true purpose for providing these trips was to obtain and retain lucrative telecommunications contracts. The civil complaint filed by the SEC also stated that UTSI had arranged for expensive gifts and all-expense paid trips for officials from government customers in Thailand. In addition, the SEC stated that UTSI made sham payments to a Mongolian consulting company for the purpose of bribing a Mongolian government official to help UTSI obtain a favorable ruling in a license dispute.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, UTStarcom Inc. Case Summary at 56-57.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, UTStarcom Inc. Case Summary at 56-57, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 21357 \/ December 31, 2009, Securities and Exchange Commission v. UTStarcom, Inc., Case No. CV-09-6094 (JSW) (N.D. Cal. filed Dec. 31, 2009), \u0022SEC Charges California Telecom Company with Bribery and Other FCPA Violations,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21357.htm; Complaint filed December 31, 2009, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp21357.pdf","Documents":""},{"Case ID":"ST-373","Case Cluster ":"Veraz Networks, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, Vietnam","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"06\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$300,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$300,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"$0","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On June 29, 2010, the SEC filed a settled civil complaint against Veraz Networks, Inc. (\u0022Veraz\u0022), a San Jose, California-based telecommunications company. The SEC alleged that Veraz violated the books and records and internal controls provisions of the FCPA in connection with improper payments to foreign officials in China and Vietnam. These payments took place after the company went public in 2007.  Specifically, the SEC alleged that Veraz engaged a consultant in China who in 2007 and 2008 gave gifts and offered improper payments together valued at approximately $40,000 to officials at a government controlled telecommunications company in China in an attempt to win business for Veraz. A Veraz supervisor who approved the gifts described them in an internal Veraz email as the \u0022gift scheme.\u0022 Similarly, the SEC alleged that in 2007 and 2008, a Veraz employee made improper payments to the CEO of a government controlled telecommunications company in Vietnam in order to win business for Veraz.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Veraz Networks Inc. Case Summary at 48-49.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Veraz Networks Inc. Case Summary at 48-49, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21581 \/ June 29, 2010, Securities and Exchange Commission v. Veraz Networks, Inc., Case No. CV-10-2849 (PVT) (N.D. Cal. filed June 29, 2010), \u0022SEC Charges California Telecommunications Company with FCPA Violations,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21581.htm; Complaint filed June 29, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21581.pdf","Documents":""},{"Case ID":"ST-374","Case Cluster ":"Vetco International Ltd.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"11\/21","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$4,200,000.00","Criminal Fine\/Penalty (US$) ":"$4,200,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"$0","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the June 2011 United States Report to the OECD, \u0022On January 5, 2007, three wholly-owned subsidiaries of Vetco International, Ltd., a global supplier of products and services for oil drilling production, were charged in the Southern District of Texas with conspiring to violate the FCPA and violating the anti-bribery provisions of the FCPA in connection with the corrupt payment of approximately $2.1 million to Nigerian government officials. According to court documents, beginning in February 2001, Vetco International, and its predecessor and several related companies, began providing engineering and procurement services, as well as subsea construction equipment, for Nigeria\u0027s first deepwater oil drilling operation, known as the Bonga Project. From at least September 2002 to at least April 2005, in connection with their business in Nigeria, these subsidiaries made at least 378 corrupt payments through a major international freight forwarding and customs clearance company to employees of the Nigerian Customs Service, and these payments were intended to assist Vetco in avoiding paying customs duties. On the same date, Aibel Group, Ltd. (Aibel Group), another wholly owned subsidiary of Vetco International, entered into a deferred prosecution agreement regarding the same bribery scheme. Subsequently, on November 12, 2008, Aibel Group, a United Kingdom corporation, was charged in a two-count superseding information charging the company with a conspiracy to violate the FCPA and a substantive violation of the FCPA.\u0022 (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Vetco International Ltd. Case Summary at 110-111.) ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Vetco International Ltd. Case Summary at 110-111, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Aibel Group Ltd., Case No. 4:07-cr-00005 (S.D. Tex.), Deferred Prosecution Agreement filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/aibelgrp\/02-06-07aibelgrp-agree.pdf; Order of Dismissal of Information and Deferred Prosecution Agreement filed November 21, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/aibelgrp\/11-21-08aibelgrp-dismiss.pdf; Superseding Information filed November 12, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/aibelgrp\/11-12-08aibelgrp-info.pdf; Plea Agreement filed November 12, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/aibelgrp\/11-21-08aibelgrp-plea.pdf; Judgment filed December 10, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/aibelgrp\/12-10-08aibelgrp-judgment.pdf","Documents":""},{"Case ID":"ST-375","Case Cluster ":"Vetco International Ltd.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"02\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$8,000,000.00","Criminal Fine\/Penalty (US$) ":"$8,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"$0","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the June 2011 United States Report to the OECD, \u0022On January 5, 2007, three wholly-owned subsidiaries of Vetco International, Ltd., a global supplier of products and services for oil drilling production, were charged in the Southern District of Texas with conspiring to violate the FCPA and violating the anti-bribery provisions of the FCPA in connection with the corrupt payment of approximately $2.1 million to Nigerian government officials. According to court documents, beginning in February 2001, Vetco International, and its predecessor and several related companies, began providing engineering and procurement services, as well as subsea construction equipment, for Nigeria\u0027s first deepwater oil drilling operation, known as the Bonga Project. From at least September 2002 to at least April 2005, in connection with their business in Nigeria, these subsidiaries made at least 378 corrupt payments through a major international freight forwarding and customs clearance company to employees of the Nigerian Customs Service, and these payments were intended to assist Vetco in avoiding paying customs duties.  On the same date, Aibel Group, Ltd. (Aibel Group), another wholly owned subsidiary of Vetco International, entered into a deferred prosecution agreement regarding the same bribery scheme. Subsequently, on November 12, 2008, Aibel Group, a United Kingdom corporation, was charged in a two-count superseding information charging the company with a conspiracy to violate the FCPA and a substantive violation of the FCPA.\u0022 (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Vetco International Ltd. Case Summary at 110-111.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Vetco International Ltd. Case Summary at 110-111, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Vetco Gray Controls, Inc., Vetco Gray UK Limited and Vetco Gray Controls Limited, Case No. 4:07-cr-00004 (S.D. Tex.), Information filed January 5, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-info.pdf; Plea Agreement (as to Vetco Gray Controls Inc.), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-inc-plea.pdf; Plea Agreement (as to Vetco Gray Controls Limited), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-plea.pdf; Plea Agreement (as to Vetco Gray UK Ltd.); Judgment (as to Vetco Gray Controls, Inc.), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-judgment.pdf; Judgment (as to Vetco Gray UK Limited) filed February 17, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-17-07vetcogray-uk-judgement.pdf; Judgment (as to Vetco Gray Controls Limited), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-limited-judgment.pdf","Documents":""},{"Case ID":"ST-376","Case Cluster ":"Vetco International Ltd.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"02\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$6,000,000.00","Criminal Fine\/Penalty (US$) ":"$6,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"$0","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the June 2011 United States Report to the OECD, \u0022On January 5, 2007, three wholly-owned subsidiaries of Vetco International, Ltd., a global supplier of products and services for oil drilling production, were charged in the Southern District of Texas with conspiring to violate the FCPA and violating the anti-bribery provisions of the FCPA in connection with the corrupt payment of approximately $2.1 million to Nigerian government officials. According to court documents, beginning in February 2001, Vetco International, and its predecessor and several related companies, began providing engineering and procurement services, as well as subsea construction equipment, for Nigeria\u0027s first deepwater oil drilling operation, known as the Bonga Project. From at least September 2002 to at least April 2005, in connection with their business in Nigeria, these subsidiaries made at least 378 corrupt payments through a major international freight forwarding and customs clearance company to employees of the Nigerian Customs Service, and these payments were intended to assist Vetco in avoiding paying customs duties.  On the same date, Aibel Group, Ltd. (Aibel Group), another wholly owned subsidiary of Vetco International, entered into a deferred prosecution agreement regarding the same bribery scheme. Subsequently, on November 12, 2008, Aibel Group, a United Kingdom corporation, was charged in a two-count superseding information charging the company with a conspiracy to violate the FCPA and a substantive violation of the FCPA.\u0022 (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Vetco International Ltd. Case Summary at 110-111.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Vetco International Ltd. Case Summary at 110-111, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Vetco Gray Controls, Inc., Vetco Gray UK Limited and Vetco Gray Controls Limited, Case No. 4:07-cr-00004 (S.D. Tex.), Information filed January 5, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-info.pdf; Plea Agreement (as to Vetco Gray Controls Inc.), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-inc-plea.pdf; Plea Agreement (as to Vetco Gray Controls Limited), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-plea.pdf; Plea Agreement (as to Vetco Gray UK Ltd.); Judgment (as to Vetco Gray Controls, Inc.), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-judgment.pdf; Judgment (as to Vetco Gray UK Limited) filed February 17, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-17-07vetcogray-uk-judgement.pdf; Judgment (as to Vetco Gray Controls Limited), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-limited-judgment.pdf","Documents":""},{"Case ID":"ST-377","Case Cluster ":"Vetco International Ltd.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"02\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$12,000,000.00","Criminal Fine\/Penalty (US$) ":"$12,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"$0","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the June 2011 United States Report to the OECD, \u0022On January 5, 2007, three wholly-owned subsidiaries of Vetco International, Ltd., a global supplier of products and services for oil drilling production, were charged in the Southern District of Texas with conspiring to violate the FCPA and violating the anti-bribery provisions of the FCPA in connection with the corrupt payment of approximately $2.1 million to Nigerian government officials. According to court documents, beginning in February 2001, Vetco International, and its predecessor and several related companies, began providing engineering and procurement services, as well as subsea construction equipment, for Nigeria\u0027s first deepwater oil drilling operation, known as the Bonga Project. From at least September 2002 to at least April 2005, in connection with their business in Nigeria, these subsidiaries made at least 378 corrupt payments through a major international freight forwarding and customs clearance company to employees of the Nigerian Customs Service, and these payments were intended to assist Vetco in avoiding paying customs duties.  On the same date, Aibel Group, Ltd. (Aibel Group), another wholly owned subsidiary of Vetco International, entered into a deferred prosecution agreement regarding the same bribery scheme. Subsequently, on November 12, 2008, Aibel Group, a United Kingdom corporation, was charged in a two-count superseding information charging the company with a conspiracy to violate the FCPA and a substantive violation of the FCPA.\u0022 (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Vetco International Ltd. Case Summary at 110-111.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Vetco International Ltd. Case Summary at 110-111, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Vetco Gray Controls, Inc., Vetco Gray UK Limited and Vetco Gray Controls Limited, Case No. 4:07-cr-00004 (S.D. Tex.), Information filed January 5, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-info.pdf; Plea Agreement (as to Vetco Gray Controls Inc.), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-inc-plea.pdf; Plea Agreement (as to Vetco Gray Controls Limited), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-plea.pdf; Plea Agreement (as to Vetco Gray UK Ltd.); Judgment (as to Vetco Gray Controls, Inc.), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-judgment.pdf; Judgment (as to Vetco Gray UK Limited) filed February 17, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-17-07vetcogray-uk-judgement.pdf; Judgment (as to Vetco Gray Controls Limited), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-limited-judgment.pdf","Documents":""},{"Case ID":"ST-378","Case Cluster ":"Vitol SA","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"New York County District Attorney\u0027s Office","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"11\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Restitution; Legal Costs","Total Monetary Sanctions (US$)":"$17,500,000.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$13,000,000","Criminal Legal \/ Procedural Costs (US$)":"$4,500,000 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$13,000,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Iraq via Development Fund for Iraq","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Grand Larceny","Offenses - Settled":"Grand Larceny","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the New York County District Attorney\u0027s Office Press Release, on November 20, 2007, \u0022Manhattan District Attorney Robert M. Morgenthau announced today the guilty plea of a Switzerland-based oil trading company for its involvement in a scheme to pay kickbacks to Iraq in connection with oil purchases made under the United Nations Oil-for-Food Programme. VITOL, S.A. (VITOL) pleaded guilty today in New York State Court to Grand Larceny in the First Degree in connection with the scheme.  According to the plea, VITOL paid $13 million in kickbacks to Iraqi officials in connection with oil purchases but allowed false representations to be made to the United Nations that no kickbacks were paid.  Relying on those false representations, United Nations officials approved the contracts and authorized millions of dollars in payments for the benefit of Iraq from the Oil-for-Food Programme.  Instead of halting these transactions, United Nations officials were duped into allowing the Oil-for-Food Programme to continue unchanged. As a result of its guilty plea, VITOL will pay restitution of $13 million to the Iraqi people through the Development Fund for Iraq and a payment of $4.5 million in lieu of fines, forfeiture and to cover the cost of prosecution.  The plea by VITOL is part of a continuing investigation by the Manhattan District Attorney\u0027s Office into the Oil-for-Food Programme.  This investigation began as a result of this office\u0027s cooperation with the Independent Inquiry Committee into the United Nations Oil-for-Food Programme, headed by Paul Volcker. Mr. Morgenthau said, \u0027The Oil for Food Programme was established by the United Nations with the noble goal of providing for the humanitarian needs of the Iraqi people.  One outcome of this investigation, and last week\u0027s joint investigation involving Chevron, is to insure that illegal funds that were paid to Saddam Hussein\u0027s government are redirected to benefit the Iraqi people.\u0027  Through its representative, duly appointed by Vitol\u0027s Board of Directors, VITOL admitted in court today that while the United Nations Oil-for-Food Programme was in effect, VITOL purchased Iraqi crude oil first as a direct purchaser and later from third-parties.  In June 2001, after an OPEC meeting, an agent of VITOL was told by Iraqi officials that surcharges had to be paid in order for Iraqi crude oil to be lifted.  Over the next year, VITOL paid or caused surcharges to be paid on certain oil purchases in two ways.   In direct purchases, VITOL had an associated entity called Vitol Bahrain send the surcharge monies to accounts controlled by the Iraqi regime.  In indirect purchases, VITOL financed the purchase of oil through third-parties who then paid the surcharge to the Iraqi regime.  VITOL did not inform the UN about the surcharge payments.  During the period from June 2001 through September 2002, approximately $13,000,000 in surcharge monies were paid directly to the Iraqi regime in connection with crude oil purchased directly or indirectly by VITOL.  The investigation into the United Nations? Oil-for-Food Programme has resulted into two other actions against oil companies.  Last week, there was a settlement with the  Chevron Oil Company in which Chevron paid $27 million, of which $20 million was paid as restitution for the benefit of the Iraqi people.  In October 2005, Midway Trading pleaded guilty for paying kickbacks to Iraq for oil purchases.\u0022  Mr. Morgenthau thanked the Independent Inquiry Committee into the United Nations Oil-for-Food Programme and Paul Volcker who heads the Committee. (Source: New York County District Attorney\u0027s Office, News Release on Vitol SA Plea, November 20, 2007.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Vitol S.A. Case Summary at 90-91, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  New York County District Attorney\u0027s Office, News Release on Vitol SA Plea, November 20, 2007, accessed at http:\/\/manhattanda.client.tagonline.com\/whatsnew\/press\/2007-11-20.shtml","Documents":""},{"Case ID":"ST-379","Case Cluster ":"Watts Water Technologies, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"10\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profit, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$3,776,606.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$2,755,815","Civil Prejudgment Interest (US$) ":"$820,791","Civil Fine \/ Penalty (US$)":"$200,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Failure to Maintain Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the finding of facts in US Securities and Exchange Commission\u0027s Cease and Desist Order, which the company and Chang neither admitted or denied as part of their settlement, the violations of FCPA books and records and internal controls provisions took place at Watts Valve Changsha Co., Ltd. (\u0022CWV\u0022) a wholly owned Chinese subsidiary established in 2005 by Watts to purchase the assets and businesses of Changsha Valve Works (\u0022Changsha Valve\u0022). CWV acquired Changsha Valve in April 2006 and Watts sold CWV in January 2010.  CWV produced and supplied large valve products for infrastructure projects in China which are mostly developed, constructed and owned by state-owned entities. These entities routinely retain state-owned design institutes to assist in the design and construction of these projects.  CWV employees made improper payments to employees at certain design institutes, thereby generating profits for Watts of more than $2.7 million. Chang is a former interim general manager of CWV and vice president of sales for Watts\u0027 management subsidiary in China, and approved many of hte payments to the design institutes which were improperly recorded on Watts\u0027 books as commission.  Specifically, the CWV Sales policy provided that all sales-related expenses, including travel, meals and entertainment and payment of \u0022consultant fees\u0022 to design institutes would be borne by the CWV sales employees\u0027 commissions. The typical commission was 7 to 7-1\/2 percent of the contract price with the Sales Policy expressly providing that sales personnel could use their commissions to make payments to design institutes of up to 3% of the total contract amount.   (Source: In the Matter of Watts Water Technologies, Inc. and Lessen Chang (October 13, 2011), Administrative Proceeding File No. 3-14585, Order Instituting Cease-and-Desist Proceedings Pursuant to Section 21C of the Securities Exchange Act of 1934, Making Findings, and Imposing Cease-and-Desist Orders and Civil Penalties.)","Sources ":"In the Matter of Watts Water Technologies, Inc. and Lessen Chang (October 13, 2011), Administrative Proceeding File No. 3-14585, Order Instituting Cease-and-Desist Proceedings Pursuant to Section 21C of the Securities Exchange Act of 1934, Making Findings, and Imposing Cease-and-Desist Orders and Civil Penalties, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2011\/34-65555.pdf.","Documents":""},{"Case ID":"ST-380","Case Cluster ":"Watts Water Technologies, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"10\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$25,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"$25,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Failure to Maintain Books and Records ","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the finding of facts in US Securities and Exchange Commission\u0027s Cease and Desist Order, which the company and Chang neither admitted or denied as part of their settlement, the violations of FCPA books and records and internal controls provisions took place at Watts Valve Changsha Co., Ltd. (\u0022CWV\u0022) a wholly owned Chinese subsidiary established in 2005 by Watts to purchase the assets and businesses of Changsha Valve Works (\u0022Changsha Valve\u0022). CWV acquired Changsha Valve in April 2006 and Watts sold CWV in January 2010.  CWV produced and supplied large valve products for infrastructure projects in China which are mostly developed, constructed and owned by state-owned entities. These entities routinely retain state-owned design institutes to assist in the design and construction of these projects.  CWV employees made improper payments to employees at certain design institutes, thereby generating profits for Watts of more than $2.7 million. Chang is a former interim general manager of CWV and vice president of sales for Watts\u0027 management subsidiary in China, and approved many of hte payments to the design institutes which were improperly recorded on Watts\u0027 books as commission.  Specifically, the CWV Sales policy provided that all sales-related expenses, including travel, meals and entertainment and payment of \u0022consultant fees\u0022 to design institutes would be borne by the CWV sales employees\u0027 commissions. The typical commission was 7 to 7-1\/2 percent of the contract price with the Sales Policy expressly providing that sales personnel could use their commissions to make payments to design institutes of up to 3% of the total contract amount.   (Source: In the Matter of Watts Water Technologies, Inc. and Lessen Chang (October 13, 2011), Administrative Proceeding File No. 3-14585, Order Instituting Cease-and-Desist Proceedings Pursuant to Section 21C of the Securities Exchange Act of 1934, Making Findings, and Imposing Cease-and-Desist Orders and Civil Penalties.)","Sources ":"In the Matter of Watts Water Technologies, Inc. and Lessen Chang (October 13, 2011), Administrative Proceeding File No. 3-14585, Order Instituting Cease-and-Desist Proceedings Pursuant to Section 21C of the Securities Exchange Act of 1934, Making Findings, and Imposing Cease-and-Desist Orders and Civil Penalties, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2011\/34-65555.pdf.","Documents":""},{"Case ID":"ST-382","Case Cluster ":"Westinghouse Air Brake Technologies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"India","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"02\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$300,000.00","Criminal Fine\/Penalty (US$) ":"$300,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Westinghouse Air Brake Technologies Corporation, at 67-68, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: time period of misconduct in India is 2001-2005; Westinghouse\u0027s Indian subsidiary Pioneer Friction Limited (Pioneer) made over $137,400 in improper cash payments to officials of the Indian Railways Board, a government agency which is part of India\u0027s Ministry of Railroads. The payments were made in order to: (a) assist Pioneer in obtaining and retaining business with the IRB; (b) schedule pre-shipping product inspections; (c) obtain issuance of product delivery certificates; and (d) curb what Pioneer considered to be excessive tax audits. ","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Westinghouse Air Brake Technologies Corporation, at 67-68, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf;  US Department of Justice Press Release, \u0022Westinghouse Air Brake Technologies Corporation Agrees to Pay $300,000 Penalty to Resolve Foreign Bribery Violations in India,\u0022 February 14, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/February\/08_crm_116.html (accessed on September 15, 2011).","Documents":""},{"Case ID":"ST-383","Case Cluster ":"Westinghouse Air Brake Technologies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"India","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"02\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$288,351.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$259,000","Civil Prejudgment Interest (US$) ":"$29,351","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US Securities and Exchange Commission Litigation Release, \u0022On February 14, 2008, the Securities and Exchange Commission filed two settled enforcement proceedings charging Westinghouse Air Brake Technologies Corporation (\u0022Wabtec\u0022), which is headquartered in western Pennsylvania, with violations of the Foreign Corrupt Practices Act (\u0022FCPA\u0022) in connection with certain improper payments that Wabtec\u0027s Indian subsidiary, Pioneer Friction Limited (\u0022Pioneer\u0022), made to employees of the government of India in order to obtain or retain business from the Indian national railway system. Wabtec manufactures, among other things, brake subsystems and related products for locomotives, freight cars and passenger vehicles. The Commission filed a civil action in the United States District Court for the Eastern District of Pennsylvania charging Wabtec with violating the anti-bribery, books-and-records and internal controls provisions of the FCPA and seeking a civil penalty. The Commission also issued an administrative order finding that Wabtec violated the same provisions of the FCPA. In the administrative proceeding, the Commission ordered Wabtec to cease and desist from such violations, and to disgorge $259,000, together with $29,351 in prejudgment interest. The Commission also required Wabtec to retain an independent consultant to review and make recommendations concerning the company\u0027s FCPA compliance policies and procedures. In the federal civil action, Wabtec agreed to the entry of a final judgment requiring it to pay a civil penalty in the amount of $87,000.Pioneer, incorporated and headquartered in India, manufactures low and high friction brake blocks for rail operations. Pioneer\u0027s financial results are reported on a consolidated basis as part of Wabtec\u0027s consolidated financial statements. In both its administrative order and federal court complaint, the Commission charged that, from at least 2001 through 2005, Pioneer made over $137,400 in improper cash payments to employees of the Indian government in order to have its competitive bids for government business granted or considered. As a result of being awarded contracts in 2005, Pioneer realized profits of $259,000. In connection with the improper payments, Wabtec failed to keep accurate books and records, and failed to devise and maintain effective internal accounting controls.\u0022 (Source: US Securities and Exchange Commission Litigation Release No. 20457 \/ February 14, 2008, SEC v. Westinghouse Air Brake Technologies Corporation, Civil Action No. 08-CV-706 (E.D.Pa.), \u0022SEC Sanctions Westinghouse Air Brake Technologies Corporation for Improper Payments to Indian Government Employees.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Westinghouse Air Brake Technologies Corporation Case Summary at 85-86, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20457 \/ February 14, 2008, SEC v. Westinghouse Air Brake Technologies Corporation, Civil Action No. 08-CV-706 (E.D.Pa.), \u0022SEC Sanctions Westinghouse Air Brake Technologies Corporation for Improper Payments to Indian Government Employees,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20457.htm; Complaint filed February 14, 2008, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20457.pdf","Documents":""},{"Case ID":"ST-384","Case Cluster ":"Westinghouse Air Brake Technologies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"India","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"2\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$87,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"$87,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US Securities and Exchange Commission Litigation Release, \u0022On February 14, 2008, the Securities and Exchange Commission filed two settled enforcement proceedings charging Westinghouse Air Brake Technologies Corporation (\u0022Wabtec\u0022), which is headquartered in western Pennsylvania, with violations of the Foreign Corrupt Practices Act (\u0022FCPA\u0022) in connection with certain improper payments that Wabtec\u0027s Indian subsidiary, Pioneer Friction Limited (\u0022Pioneer\u0022), made to employees of the government of India in order to obtain or retain business from the Indian national railway system. Wabtec manufactures, among other things, brake subsystems and related products for locomotives, freight cars and passenger vehicles. The Commission filed a civil action in the United States District Court for the Eastern District of Pennsylvania charging Wabtec with violating the anti-bribery, books-and-records and internal controls provisions of the FCPA and seeking a civil penalty. The Commission also issued an administrative order finding that Wabtec violated the same provisions of the FCPA. In the administrative proceeding, the Commission ordered Wabtec to cease and desist from such violations, and to disgorge $259,000, together with $29,351 in prejudgment interest. The Commission also required Wabtec to retain an independent consultant to review and make recommendations concerning the company\u0027s FCPA compliance policies and procedures. In the federal civil action, Wabtec agreed to the entry of a final judgment requiring it to pay a civil penalty in the amount of $87,000.Pioneer, incorporated and headquartered in India, manufactures low and high friction brake blocks for rail operations. Pioneer\u0027s financial results are reported on a consolidated basis as part of Wabtec\u0027s consolidated financial statements. In both its administrative order and federal court complaint, the Commission charged that, from at least 2001 through 2005, Pioneer made over $137,400 in improper cash payments to employees of the Indian government in order to have its competitive bids for government business granted or considered. As a result of being awarded contracts in 2005, Pioneer realized profits of $259,000. In connection with the improper payments, Wabtec failed to keep accurate books and records, and failed to devise and maintain effective internal accounting controls.\u0022 (Source: US Securities and Exchange Commission Litigation Release No. 20457 \/ February 14, 2008, SEC v. Westinghouse Air Brake Technologies Corporation, Civil Action No. 08-CV-706 (E.D.Pa.), \u0022SEC Sanctions Westinghouse Air Brake Technologies Corporation for Improper Payments to Indian Government Employees.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Westinghouse Air Brake Technologies Corporation Case Summary at 85-86, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20457 \/ February 14, 2008, SEC v. Westinghouse Air Brake Technologies Corporation, Civil Action No. 08-CV-706 (E.D.Pa.), \u0022SEC Sanctions Westinghouse Air Brake Technologies Corporation for Improper Payments to Indian Government Employees,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20457.htm; Complaint filed February 14, 2008, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20457.pdf; and final judgment in Eastern District of Pennsylvania case, accessed at http:\/\/fcpa.shearman.com\/files\/89b\/89b0f8ade28e8c6cb474081e1fdb3499.pdf?i=abde6828feb586da522341a4724e2f79.","Documents":""},{"Case ID":"ST-385","Case Cluster ":"Willbros Group Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Bolivia","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"05\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$35,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$35,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"False Accounting Violations, Aiding and Abetting Willbros\u0027 Bribery of Foreign Officials, Aiding and Abetting Willbros\u0027 Internal Controls Violations, Aiding and Abetting Willbros\u0027 Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States Securities and Exchange Commission Litigation Release, on May 14, 2008, the Commission \u0022filed a settled civil action against Willbros Group, Inc. and several former employees alleging that they violated, among other things, the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA) and the antifraud provisions of the federal securities laws. The complaint also names Jason Steph, a former supervisory employee in Nigeria, Gerald Jansen, a former administrative supervisor in Nigeria, Lloyd Biggers, a former employee in Nigeria and Carlos Galvez, a former accounting employee in Bolivia. According to the complaint, the company also violated the reporting, books and records and internal controls provisions of the Securities Exchange Act. Willbros Group, Steph, Jansen, Biggers and Galvez have agreed to settle the charges against them, without admitting or denying the Commission\u0027s allegations. The Commission alleges in its complaint that Willbros Group, through the actions of others acting on its behalf, engaged in multiple schemes to bribe foreign officials. First, the complaint alleges that, beginning by at least 2003, Willbros Group, through the conduct of a former executive officer, Steph and others, engaged in a scheme to pay over $6 million in bribes to Nigerian government officials and to employees of an operator of a joint venture majority-owned by the Nigerian government in order to obtain a significant contract. A similar scheme was used to help obtain a second significant contract. Together, these contracts resulted in net profits of approximately $8,900,000. In 2005, according to the complaint, Steph assisted in the payment of $850,000 to satisfy a portion of these earlier commitments. The complaint further alleges that Willbros Group, through acts by a former executive officer, Steph, Jansen, Biggers and others, employed a long-running scheme using fabricated invoices to procure cash from the company\u0027s administrative headquarters in Houston to, among other things, bribe Nigerian tax and court officials. This fraudulent cash abuse was also used to fund in part the bribes paid in 2005.  Second, Willbros Group, through the conduct of the same former executive officer and others schemed to pay a $300,000 bribe to officials of an oil and gas company owned by the Ecuador government in order to obtain a $3 million contract. Finally, Willbros Group, through the actions of the same former executive officer, an outside consultant and Galvez implemented a fraudulent tax avoidance scheme in Bolivia. This fraudulent scheme resulted in material misstatements in Willbros Group\u0027s financial statements.\u0022  (Source:  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20571.htm; Complaint in SEC v. Willbros et al. [Willbros Group, Inc, Jason Steph, Gerald Jansen, Lloyd Biggers, Carlos Galvez], Case No. 4:08-cv-01494 (S.D. Tex.) filed May 14, 2008, accessed at www.sec.gov\/litigation\/complaints\/2008\/comp20571.pdf","Documents":""},{"Case ID":"ST-386","Case Cluster ":"Willbros Group Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"05\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$30,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$30,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"False Accounting Violations, Aiding and Abetting Willbros\u0027 Bribery of Foreign Officials, Aiding and Abetting Willbros\u0027 Internal Controls Violations, Aiding and Abetting Willbros\u0027 Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States Securities and Exchange Commission Litigation Release, on May 14, 2008, the Commission \u0022filed a settled civil action against Willbros Group, Inc. and several former employees alleging that they violated, among other things, the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA) and the antifraud provisions of the federal securities laws. The complaint also names Jason Steph, a former supervisory employee in Nigeria, Gerald Jansen, a former administrative supervisor in Nigeria, Lloyd Biggers, a former employee in Nigeria and Carlos Galvez, a former accounting employee in Bolivia. According to the complaint, the company also violated the reporting, books and records and internal controls provisions of the Securities Exchange Act. Willbros Group, Steph, Jansen, Biggers and Galvez have agreed to settle the charges against them, without admitting or denying the Commission\u0027s allegations. The Commission alleges in its complaint that Willbros Group, through the actions of others acting on its behalf, engaged in multiple schemes to bribe foreign officials. First, the complaint alleges that, beginning by at least 2003, Willbros Group, through the conduct of a former executive officer, Steph and others, engaged in a scheme to pay over $6 million in bribes to Nigerian government officials and to employees of an operator of a joint venture majority-owned by the Nigerian government in order to obtain a significant contract. A similar scheme was used to help obtain a second significant contract. Together, these contracts resulted in net profits of approximately $8,900,000. In 2005, according to the complaint, Steph assisted in the payment of $850,000 to satisfy a portion of these earlier commitments. The complaint further alleges that Willbros Group, through acts by a former executive officer, Steph, Jansen, Biggers and others, employed a long-running scheme using fabricated invoices to procure cash from the company\u0027s administrative headquarters in Houston to, among other things, bribe Nigerian tax and court officials. This fraudulent cash abuse was also used to fund in part the bribes paid in 2005.  Second, Willbros Group, through the conduct of the same former executive officer and others schemed to pay a $300,000 bribe to officials of an oil and gas company owned by the Ecuador government in order to obtain a $3 million contract. Finally, Willbros Group, through the actions of the same former executive officer, an outside consultant and Galvez implemented a fraudulent tax avoidance scheme in Bolivia. This fraudulent scheme resulted in material misstatements in Willbros Group\u0027s financial statements.\u0022  (Source:  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20571.htm; Complaint in SEC v. Willbros et al. [Willbros Group, Inc, Jason Steph, Gerald Jansen, Lloyd Biggers, Carlos Galvez], Case No. 4:08-cv-01494 (S.D. Tex.) filed May 14, 2008, accessed at www.sec.gov\/litigation\/complaints\/2008\/comp20571.pdf","Documents":""},{"Case ID":"ST-387","Case Cluster ":"Willbros Group Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"11\/05","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,000.00","Criminal Fine\/Penalty (US$) ":"$2,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"","OECD Anti-Bribery Convention Articles Implicated":"Art. 1  ","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering, International Money Laundering","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States Report to the OECD, \u0022On May 14, 2008, Willbros Group Inc. (WGI), a publicly-traded company that provides construction, engineering and other services in the oil and gas industry, and Willbros International Inc. (WII), the wholly owned subsidiary through which it conducts international operations, were charged in a six-count criminal information with one count of conspiring to make bribe payments to Nigerian and Ecuadoran officials, two counts of violating the anti-bribery provisions of the FCPA, and three counts of violating the books and records provisions of the FCPA. These charges stemmed from a bribery scheme involving senior officials of WII, which involved the corrupt payment of more than $6.3 million to Nigerian officials in connection with a gas pipeline construction project and $300,000 to Ecuadorian officials in connection with a gas pipeline rehabilitation project.From late 2003 through March 2005, WII employees agreed to make corrupt payments totaling more than $6.3 million to officials of the Nigerian National Petroleum Corporation (NNPC), the state-owned oil company in Nigeria; NNPC\u0027s subsidiary, the National Petroleum Investment Management Services (NAPIMS); a senior official in the executive branch of the Nigerian federal government; officials of a multinational oil company; and a Nigerian political party. These bribes were paid to Nigerian government officials to assist in obtaining and retaining a $387 million contract for work on a major engineering, procurement and construction gas pipeline project known as the Eastern Gas Gathering System (EGGS). In addition, in 2004, various WII employees paid at least $300,000 to officials of the Ecuadorian state-owned oil company in order to obtain a gas pipeline rehabilitation contract. [ ] Jason Edward Steph, WII\u0027s General Manager-Onshore in Nigeria, was indicted July 19, 2007. Steph\u0027s charges stemmed from his role in causing a series of corrupt payments totaling more than $6 million to be made to various Nigerian officials in order to assist WII in obtaining and retaining the EGGS deal. According to court documents, in early 2005, as a senior WII executive, Steph authorized and arranged for the payment of $1.8 million in cash to the Nigerian officials to further the conspiracy.\u0022  On November 5, 2007, Steph pleaded guilty to participating in a conspiracy to violate the FCPA. (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81.) ","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Jason Edward Steph: Docket Number: 07-CR-307 (S.D. Tex.), Indictment filed July 19, 2007, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/stephj\/07-19-07steph-indict.pdf;  Plea Agreement filed November 5, 2007; Judgment filed February 1, 2010, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/stephj\/02-01-10steph-judgment.pdf","Documents":""},{"Case ID":"ST-388","Case Cluster ":"Willbros Group Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"05\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, False Accounting Violations, Aiding and Abetting Willbros\u0027 Bribery of Foreign Officials, Aiding and Abetting Willbros\u0027 Internal Controls Violations, Aiding and Abetting Willbros\u0027 Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States Securities and Exchange Commission Litigation Release, on May 14, 2008, the Commission \u0022filed a settled civil action against Willbros Group, Inc. and several former employees alleging that they violated, among other things, the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA) and the antifraud provisions of the federal securities laws. The complaint also names Jason Steph, a former supervisory employee in Nigeria, Gerald Jansen, a former administrative supervisor in Nigeria, Lloyd Biggers, a former employee in Nigeria and Carlos Galvez, a former accounting employee in Bolivia. According to the complaint, the company also violated the reporting, books and records and internal controls provisions of the Securities Exchange Act. Willbros Group, Steph, Jansen, Biggers and Galvez have agreed to settle the charges against them, without admitting or denying the Commission\u0027s allegations. The Commission alleges in its complaint that Willbros Group, through the actions of others acting on its behalf, engaged in multiple schemes to bribe foreign officials. First, the complaint alleges that, beginning by at least 2003, Willbros Group, through the conduct of a former executive officer, Steph and others, engaged in a scheme to pay over $6 million in bribes to Nigerian government officials and to employees of an operator of a joint venture majority-owned by the Nigerian government in order to obtain a significant contract. A similar scheme was used to help obtain a second significant contract. Together, these contracts resulted in net profits of approximately $8,900,000. In 2005, according to the complaint, Steph assisted in the payment of $850,000 to satisfy a portion of these earlier commitments. The complaint further alleges that Willbros Group, through acts by a former executive officer, Steph, Jansen, Biggers and others, employed a long-running scheme using fabricated invoices to procure cash from the company\u0027s administrative headquarters in Houston to, among other things, bribe Nigerian tax and court officials. This fraudulent cash abuse was also used to fund in part the bribes paid in 2005.  Second, Willbros Group, through the conduct of the same former executive officer and others schemed to pay a $300,000 bribe to officials of an oil and gas company owned by the Ecuador government in order to obtain a $3 million contract. Finally, Willbros Group, through the actions of the same former executive officer, an outside consultant and Galvez implemented a fraudulent tax avoidance scheme in Bolivia. This fraudulent scheme resulted in material misstatements in Willbros Group\u0027s financial statements.\u0022  (Source:  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees.) According to the Agreed Judgment in Steph\u0027s case, there was no monetary penalty ordered. (Source: US v. Willbros Group Inc. Case No. 4:08-cv-1494 (S.D. Tex.), Agreed Judgment as to Jason Stephs dated May 27, 2008, accessed at http:\/\/fcpa.shearman.com\/files\/7d4\/7d4bde190ba89e2405d4d9a1a1d20f03.pdf?i=11ae1adbca1d3c212c85c0df61982ced.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20571.htm; Complaint in SEC v. Willbros et al. [Willbros Group, Inc, Jason Steph, Gerald Jansen, Lloyd Biggers, Carlos Galvez], Case No. 4:08-cv-01494 (S.D. Tex.) filed May 14, 2008, accessed at www.sec.gov\/litigation\/complaints\/2008\/comp20571.pdf; Agreed Judgment as to Jason Stephs dated May 27, 2008","Documents":""},{"Case ID":"ST-389","Case Cluster ":"Willbros Group Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Ecuador","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"09\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$17,500.00","Criminal Fine\/Penalty (US$) ":"$17,500","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States Report to the OECD, \u0022On May 14, 2008, Willbros Group Inc. (WGI), a publicly-traded company that provides construction, engineering and other services in the oil and gas industry, and Willbros International Inc. (WII), the wholly owned subsidiary through which it conducts international operations, were charged in a six-count criminal information with one count of conspiring to make bribe payments to Nigerian and Ecuadoran officials, two counts of violating the anti-bribery provisions of the FCPA, and three counts of violating the books and records provisions of the FCPA. These charges stemmed from a bribery scheme involving senior officials of WII, which involved the corrupt payment of more than $6.3 million to Nigerian officials in connection with a gas pipeline construction project and $300,000 to Ecuadorian officials in connection with a gas pipeline rehabilitation project.From late 2003 through March 2005, WII employees agreed to make corrupt payments totaling more than $6.3 million to officials of the Nigerian National Petroleum Corporation (NNPC), the state-owned oil company in Nigeria; NNPC\u0027s subsidiary, the National Petroleum Investment Management Services (NAPIMS); a senior official in the executive branch of the Nigerian federal government; officials of a multinational oil company; and a Nigerian political party. These bribes were paid to Nigerian government officials to assist in obtaining and retaining a $387 million contract for work on a major engineering, procurement and construction gas pipeline project known as the Eastern Gas Gathering System (EGGS). In addition, in 2004, various WII employees paid at least $300,000 to officials of the Ecuadorian state-owned oil company in order to obtain a gas pipeline rehabilitation contract. [ ]  Jim Bob Brown, WII\u0027s Managing Director (Nigeria and Ecuador), was charged September 11, 2006. Brown was charged in connection with conspiring with other WII executives to pay approximately $1.5 million in cash to Nigerian officials and $300,000 to Ecuadorian officials. According to court documents, from 1996 through 2005, Brown also conspired with other WII executives to approve a scheme in which WII\u0027s Nigerian operations submitted fictitious invoices for payment by WGI. These funds were used, in part, to make corrupt payments to officials of the Nigerian revenue agencies and courts in order to lower taxes that would have otherwise been assessed, and to influence favorably litigation in Nigeria affecting the business of WGI.\u0022  In September 2006, Brown pleaded guilty and was sentenced in January 2010. (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81.) ","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Jim Bob Brown, Case No. 4:06-cr-316 (S.D. Tex.), Indictment filed September 11, 2006, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/brownj\/09-11-06brown-info.pdf; Plea Agreement filed September 14, 2006, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/brownj\/09-14-09brown-plea-agree.pdf; Judgment filed January 29, 2010, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/brownj\/01-29-10brown-judgment.pdf","Documents":""},{"Case ID":"ST-390","Case Cluster ":"Willbros Group Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Ecuador, Nigeria","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"09\/14","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Aiding and Abetting Willbros\u0027 Bribery of Foreign Officials, Aiding and Abetting Willbros\u0027 Internal Controls Violations, Aiding and Abetting Willbros\u0027 Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, on September 14, 2006, the Commission \u0022filed a civil action against Jim Bob \u0022J.B.\u0022 Brown, a former employee of a subsidiary of Willbros Group, Inc. [  ] The Commission alleges in its complaint that Brown, a former supervisory employee in Willbros\u0027s Nigerian and Latin American operations, participated in three separate schemes to bribe foreign officials. First, the complaint alleges that, in February and March 2005, Brown procured $1 million on behalf of a Willbros affiliate and delivered that money as partial payment of previously-made commitments to Nigerian government officials and to employees of the operator of a joint venture majority owned by an arm of the Nigerian government. He also assisted, according to the complaint, in the payment of an additional $550,000 that was also used to satisfy the earlier commitments. Second, Brown, in return for the granting to Willbros of a $3 million contract, knowingly assisted a scheme to pay a $300,000 bribe to officials of an oil and gas company owned by the government of Ecuador and its subsidiary. Finally, Brown knowingly assisted a long-running scheme in which employees of Willbros affiliates used fabricated invoices to procure cash from the company\u0027s administrative headquarters in Houston that was used to, among other things, bribe Nigerian tax and court officials.\u0022 (Source:  US Securities and Exchange Commission, Litigation Release No. 19832 \/ September 14, 2006, SEC v. Jim Bob Brown, Civil Action No. 06-CV-2919, U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Charges Former Employee of A Willbros Group, Inc. Subsidiary With FCPA Violations.\u0022)  According  to the Final Judgment against Brown, there was no monetary penalty assessed as part of his civil case.  (Source: US v. Jim Bob Brown, Case No. 4:06-cv-2919 (S.D. Tex.), Final Judgment filed May 10, 2010.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 19832 \/ September 14, 2006, SEC v. Jim Bob Brown, Civil Action No. 06-CV-2919, U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Charges Former Employee of A Willbros Group, Inc. Subsidiary With FCPA Violations,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2006\/lr19832.htm; Complaint filed September 14, 2006, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2006\/comp19832.pdf; Final Judgment filed May 10, 2010, accessed at http:\/\/fcpa.shearman.com\/files\/898\/898e03234c3a08fb6e835438e886a801.pdf?i=7196cb3d3c4105606f49eaf41e4dab95","Documents":""},{"Case ID":"ST-391","Case Cluster ":"Willbros Group Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"05\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"False Accounting Violations, Aiding and Abetting Willbros\u0027 Bribery of Foreign Officials, Aiding and Abetting Willbros\u0027 Internal Controls Violations, Aiding and Abetting Willbros\u0027 Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States Securities and Exchange Commission Litigation Release, on May 14, 2008, the Commission \u0022filed a settled civil action against Willbros Group, Inc. and several former employees alleging that they violated, among other things, the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA) and the antifraud provisions of the federal securities laws. The complaint also names Jason Steph, a former supervisory employee in Nigeria, Gerald Jansen, a former administrative supervisor in Nigeria, Lloyd Biggers, a former employee in Nigeria and Carlos Galvez, a former accounting employee in Bolivia. According to the complaint, the company also violated the reporting, books and records and internal controls provisions of the Securities Exchange Act. Willbros Group, Steph, Jansen, Biggers and Galvez have agreed to settle the charges against them, without admitting or denying the Commission\u0027s allegations. The Commission alleges in its complaint that Willbros Group, through the actions of others acting on its behalf, engaged in multiple schemes to bribe foreign officials. First, the complaint alleges that, beginning by at least 2003, Willbros Group, through the conduct of a former executive officer, Steph and others, engaged in a scheme to pay over $6 million in bribes to Nigerian government officials and to employees of an operator of a joint venture majority-owned by the Nigerian government in order to obtain a significant contract. A similar scheme was used to help obtain a second significant contract. Together, these contracts resulted in net profits of approximately $8,900,000. In 2005, according to the complaint, Steph assisted in the payment of $850,000 to satisfy a portion of these earlier commitments. The complaint further alleges that Willbros Group, through acts by a former executive officer, Steph, Jansen, Biggers and others, employed a long-running scheme using fabricated invoices to procure cash from the company\u0027s administrative headquarters in Houston to, among other things, bribe Nigerian tax and court officials. This fraudulent cash abuse was also used to fund in part the bribes paid in 2005.  Second, Willbros Group, through the conduct of the same former executive officer and others schemed to pay a $300,000 bribe to officials of an oil and gas company owned by the Ecuador government in order to obtain a $3 million contract. Finally, Willbros Group, through the actions of the same former executive officer, an outside consultant and Galvez implemented a fraudulent tax avoidance scheme in Bolivia. This fraudulent scheme resulted in material misstatements in Willbros Group\u0027s financial statements.\u0022  (Source:  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20571.htm; Complaint in SEC v. Willbros et al. [Willbros Group, Inc, Jason Steph, Gerald Jansen, Lloyd Biggers, Carlos Galvez], Case No. 4:08-cv-01494 (S.D. Tex.) filed May 14, 2008, accessed at www.sec.gov\/litigation\/complaints\/2008\/comp20571.pdf","Documents":""},{"Case ID":"ST-392","Case Cluster ":"Willbros Group Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Ecuador","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"05\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$22,000,000.00","Criminal Fine\/Penalty (US$) ":"$22,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States Report to the OECD, \u0022On May 14, 2008, Willbros Group Inc. (WGI), a publicly-traded company that provides construction, engineering and other services in the oil and gas industry, and Willbros International Inc. (WII), the wholly owned subsidiary through which it conducts international operations, were charged in a six-count criminal information with one count of conspiring to make bribe payments to Nigerian and Ecuadoran officials, two counts of violating the anti-bribery provisions of the FCPA, and three counts of violating the books and records provisions of the FCPA. These charges stemmed from a bribery scheme involving senior officials of WII, which involved the corrupt payment of more than $6.3 million to Nigerian officials in connection with a gas pipeline construction project and $300,000 to Ecuadorian officials in connection with a gas pipeline rehabilitation project.From late 2003 through March 2005, WII employees agreed to make corrupt payments totaling more than $6.3 million to officials of the Nigerian National Petroleum Corporation (NNPC), the state-owned oil company in Nigeria; NNPC\u0027s subsidiary, the National Petroleum Investment Management Services (NAPIMS); a senior official in the executive branch of the Nigerian federal government; officials of a multinational oil company; and a Nigerian political party. These bribes were paid to Nigerian government officials to assist in obtaining and retaining a $387 million contract for work on a major engineering, procurement and construction gas pipeline project known as the Eastern Gas Gathering System (EGGS). In addition, in 2004, various WII employees paid at least $300,000 to officials of the Ecuadorian state-owned oil company in order to obtain a gas pipeline rehabilitation contract.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Willbros Group, Inc., et al, Case No. 4:08-cr-287 (S.D. Tex.), ,Information filed May 14, 2008, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/willbros-group\/05-14-08willbros-info.pdf; Deferred Prosecution Agreement filed May 14, 2007, accessed at  www.justice.gov\/criminal\/fraud\/fcpa\/cases\/willbros-group\/05-14-08willbros-deferred.pdf.  US Department of Justice Press Release, \u0022Willbros Group Inc. Enters Deferred Prosecution Agreement and Agrees to Pay $22 Million Penalty for FCPA Violations,\u0022 May 14, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/May\/08-crm-417.html","Documents":""},{"Case ID":"ST-393","Case Cluster ":"Willbros Group Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Ecuador, Bolivia","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"05\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit, Prejudgment Interest","Total Monetary Sanctions (US$)":"$10,300,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$8,900,000","Civil Prejudgment Interest (US$) ":"$1,400,000","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Fraud in Connection with the Purchase and Sale of Securities, Disclosure Violations, Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States Securities and Exchange Commission Litigation Release, on May 14, 2008, the Commission \u0022filed a settled civil action against Willbros Group, Inc. and several former employees alleging that they violated, among other things, the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA) and the antifraud provisions of the federal securities laws. The complaint also names Jason Steph, a former supervisory employee in Nigeria, Gerald Jansen, a former administrative supervisor in Nigeria, Lloyd Biggers, a former employee in Nigeria and Carlos Galvez, a former accounting employee in Bolivia. According to the complaint, the company also violated the reporting, books and records and internal controls provisions of the Securities Exchange Act. Willbros Group, Steph, Jansen, Biggers and Galvez have agreed to settle the charges against them, without admitting or denying the Commission\u0027s allegations. The Commission alleges in its complaint that Willbros Group, through the actions of others acting on its behalf, engaged in multiple schemes to bribe foreign officials. First, the complaint alleges that, beginning by at least 2003, Willbros Group, through the conduct of a former executive officer, Steph and others, engaged in a scheme to pay over $6 million in bribes to Nigerian government officials and to employees of an operator of a joint venture majority-owned by the Nigerian government in order to obtain a significant contract. A similar scheme was used to help obtain a second significant contract. Together, these contracts resulted in net profits of approximately $8,900,000. In 2005, according to the complaint, Steph assisted in the payment of $850,000 to satisfy a portion of these earlier commitments. The complaint further alleges that Willbros Group, through acts by a former executive officer, Steph, Jansen, Biggers and others, employed a long-running scheme using fabricated invoices to procure cash from the company\u0027s administrative headquarters in Houston to, among other things, bribe Nigerian tax and court officials. This fraudulent cash abuse was also used to fund in part the bribes paid in 2005.  Second, Willbros Group, through the conduct of the same former executive officer and others schemed to pay a $300,000 bribe to officials of an oil and gas company owned by the Ecuador government in order to obtain a $3 million contract. Finally, Willbros Group, through the actions of the same former executive officer, an outside consultant and Galvez implemented a fraudulent tax avoidance scheme in Bolivia. This fraudulent scheme resulted in material misstatements in Willbros Group\u0027s financial statements.\u0022  (Source:  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20571.htm; Complaint in SEC v. Willbros et al. [Willbros Group, Inc, Jason Steph, Gerald Jansen, Lloyd Biggers, Carlos Galvez], Case No. 4:08-cv-01494 (S.D. Tex.) filed May 14, 2008, accessed at www.sec.gov\/litigation\/complaints\/2008\/comp20571.pdf","Documents":""},{"Case ID":"ST-395","Case Cluster ":"York International Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food), United Arab Emirates","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"10\/01","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$10,000,000.00","Criminal Fine\/Penalty (US$) ":"$10,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud, Falsification of books and records, Wire fraud","Offenses - Settled":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud, Falsification of books and records, Wire fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 York International Corporation, at 47-48, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: the charges against York stemmed in part from the actions of its Dubai-headquartered subsidiary, York Air Conditioning and Refrigeration FZE (\u0022York FZE\u0022), whose employees and agents paid approximately $647,110 in kickbacks to Iraqi government officials from 2000 to 2003 in order to obtain contracts to provide air conditioning, ventilation and refrigeration equipment and services to Iraq under the UN Oil-for-Food program.  (York FZE was a subsidiary of York Air Conditioning and Refrigeration Inc., a Delaware formed subsidiary of York International, whose branch office in Dubai served as headquarters of York\u0027s Middle East operations.)  According to the Statement of Facts, approximately $7 milion in Iraqi contracts were obtained as a result; all contracts through the UN Oil-for-Food program. Additionally, from 1999 to 2005, employees of YACR and York FZE paid kickbacks and bribes to employees of government customers and contractors of government customers in order to obtain and retain approximately $42 million in contracts on government projects in UAE, Egypt, Babrain, Turkey, and India.  In the UAE, during 2003-20004, YACR and York FZE secured contractss worth $3.7 million related to a luxury hotel and convention complex in Abu Dhabi; the subsidiaries made 13 payments totalling $550,000 to an intermediary  in circumstances that make it likely that the intermediary made corrupt payments to members of the hotel and convention complex\u0027s executive committee, which was established by UAE government decree and which represented the UAE\u0027s Ministry of Finance and Industry in managing the construction of the complex. (para 41)  (Source:  US v. York International Corporation, Case No. 1:07-cr-00253-RJL (D.D.C.), Deferred Prosecution Agreement and Statement of Facts, filed October 15, 2007).  No additional details were given in the Statement of Facts with regard to the misconduct in the other jurisdictions noted in the Securities and Exchange Commission complaint.","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 York International Corporation, at 76-77, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.  US v. York International Corporation, Case No. 1:07-cr-00253-RJL (D.D.C.), Information filed October 1, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/york\/10-01-07york-info.pdf; Deferred Prosecution Agreement and Statement of Facts filed October 15, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/york\/10-15-07york-agree.pdf;  Department of Justice Press Release, \u0022Justice Department Agrees to Defer Prosecution of York International Corporation in Connection With Payment of Kickbacks Under the U.N. Oil For Food Program,\u0022 October 1, 2007, accessed at http:\/\/www.justice.gov\/opa\/pr\/2007\/October\/07_crm_783.html.","Documents":""},{"Case ID":"ST-396","Case Cluster ":"York International Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food), Bahrain, Egypt, India, Turkey, UAE, Nigeria, China and various other European and Middle Eastern countries 1999-2006","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"10\/01","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit, Prejudgment Interest, Civil Penalty ","Total Monetary Sanctions (US$)":"$12,032,880.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$8,949,132","Civil Prejudgment Interest (US$) ":"$1,083,748","Civil Fine \/ Penalty (US$)":"$2,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, on October 1, 2007, the Commission \u0022filed anti-bribery, internal controls, and books and records charges under the Foreign Corrupt Practices Act against York International Corporation (\u0022York International\u0022) in the U.S. District Court for the District of Columbia. York International, a global provider of heating, ventilation, air conditioning, and refrigeration products and services, was acquired by Johnson Controls, Inc. in 2005. The Commission\u0027s complaint alleges that York International\u0027s Delaware subsidiary paid approximately $522,500 to an intermediary while knowing that most of the money was intended to bribe United Arab Emirate officials; York International\u0027s Dubai subsidiary authorized and made approximately $647,110 in kickback payments under the U.N. Oil for Food Program; and that York International\u0027s subsidiaries devised elaborate schemes to conceal kickback payments of over $7.5 million made to secure orders on certain commercial and government projects in the Middle East, India, China, Nigeria and Europe.\u0022 (Source:  US Securitites and Exchange Commission, Litigation Release No. 20319 \/ October 1, 2007, Securities and Exchange Commission v. York International Corporation, 07 CV 01750 (D.D.C.)(RCL), \u0022SEC Files Settled Foreign Corrupt Practices Act Charges Against York International Corporation For Improper Payments to UAE Officials, to Iraq Under the U.N. Oil for Food Program, and to Others - - Company Agrees to Pay Over $12 Million and to Retain an Independent Compliance Monitor.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 York International Corporation, at 76-77, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.  US Securitites and Exchange Commission, Litigation Release No. 20319 \/ October 1, 2007, Securities and Exchange Commission v. York International Corporation, 07 CV 01750 (D.D.C.)(RCL), \u0022SEC Files Settled Foreign Corrupt Practices Act Charges Against York International Corporation For Improper Payments to UAE Officials, to Iraq Under the U.N. Oil for Food Program, and to Others - - Company Agrees to Pay Over $12 Million and to Retain an Independent Compliance Monitor,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20319.htm; Complaint filed October 1, 2007, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2007\/comp20319.pdf.","Documents":""},{"Case ID":"ST-302","Case Cluster ":"Paradigm, B.V.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China, Indonesia, Kazakhstan, Mexico, Nigeria","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"09\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,000,000.00","Criminal Fine\/Penalty (US$) ":"$1,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Paradigm BV, at 82-83, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: Misconduct involved corrupt payments to employees of state-owned oil and gas companies in China (2006), Indonesia (2003), Kazakhstan (2005-2006), Latvia [dates not given], Mexico (2004-2005), and Nigeria (2003-2005). Resulting criminal enforcement action: In Re Paradigm B.V. (November 24, 2007). Settlement amount: Criminal fine of $1 million. The involved misconduct is detailed in the Statement of Facts attached to the Non-prosecution agreement, which also noted that Paradigm is a Dutch Limited Liability Company, which moved its principal place of business in 2005 to Houston.  (Source: In Re Paradigm BV, Non-prosecution agrement and statement of facts (September 21, 2007).  According to the June 2011 United States Report to the OECD, \u0022In one instance, the company paid $22,250 into the Latvian bank account of a British West Indies company recommended as a consultant by an official of KazMunaiGas, Kazakhstan\u0027s national oil company, to secure a tender for geological software. [ ] Paradigm also used an agent in China to make commission payments to representatives of a subsidiary of the China National Offshore Company in connection with the sale of a software [  ] Paradigm also admitted to similar conduct in dealings in Mexico, Indonesia, and Nigeria.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Paradigm B.V. Case Summary at 98-99.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Paradigm B.V. at 82-83, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf;  In Re Paradigm BV, Non-Prosecution Agreement and Statement of Facts (September 21, 2007), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/paradigm\/09-21-07paradigm-agree.pdf; US Department of Justice Press Release, \u0022Paradigm B.V. Agrees to Pay $1 Million Penalty to Resolve Foreign Bribery Issues in Multiple Countries,\u0022 September 24, 2007, accessed at http:\/\/www.justice.gov\/opa\/pr\/2007\/September\/07_crm_751.html. US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Paradigm B.V. Case Summary at 98-99, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. ","Documents":""},{"Case ID":"ST-303","Case Cluster ":"Ports Engineering Consultants Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Panama","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"04\/19","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$15,000.00","Criminal Fine\/Penalty (US$) ":"$15,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art.1, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials, Making a False Statement","Offenses - Settled":"Bribery of Foreign Officials, Making a False Statement","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On November 10, 2009 and December 15, 2009, respectively, Charles Paul Edward Jumet and John W. Warwick were charged in connection with a conspiracy to make corrupt payments to Panamanian government officials in exchange for certain maritime contracts. Jumet was charged in a two-count criminal information with conspiracy to bribe foreign officials in violation of the FCPA and with making a false statement to the FBI. Warwick, the former president of Ports Engineering Consultants Corporation (PECC), was indicted on one-count of conspiracy to authorize and cause corrupt payments to be made to foreign government officials for the purpose of securing business for PECC, in violation of the FCPA. According to court documents, from 1997 through approximately July 2003, Warwick, Jumet, and others conspired to authorize and cause corrupt payments totaling more than $200,000 to be made to the former administrator and deputy administrator of the Panama Maritime Ports Authority, as well as to a former, high-ranking elected executive official of the Republic of Panama. These corrupt payments were made so that the Panamanian officials would award contracts to maintain lighthouses and buoys along Panama\u0027s waterways to PECC, a company incorporated under the laws of Panama and affiliated with Overman Associates, an engineering firm based in Virginia. In 1997, the Panamanian government awarded PECC a no-bid 20-year concession to perform these duties. As a result of these contracts, PECC earned approximately $18 million in revenue from 1997 to 2000. In 2000, Panama?s Comptroller General Office suspended the contract while it investigated the government\u0027s decision to award PECC a contract without soliciting a bid from any other entities. In 2003, the Panamanian government resumed making payments to PECC.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011.)  According to the US Government\u0027s Sentencing Memorandum in co-defendant Warwick\u0027s case, \u0022Defendant Warwick is a United States citizen who was President of Ports Engineering Consultants Corporation (PECC), Overman Associates, and Overman de Panama during this conspiracy. He, Charles Jumet, and others authorized and caused corrupt payments to be made to Panamanian government officials, through shell corporations -- Warmspell Holding Corporation and Soderville Corporation -- and through the issuance of checks made payable to the \u0027bearer.\u0027\u0022  (Source: US v. Warwick, Case No. 3:09-cr-449-HEH (E.D. Va.), US Government Sentencing Memorandum filed June 14, 2010.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  Ports Engineering Consultants Corporation Case Summary at 57-58.  US v. Charles Paul Edward Jumet, Case No. 3:09-cr-397 (E.D.Va.), Information filed November 10, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/jumetc\/11-10-09jumet-info.pdf; Plea Agreement filed November 13, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/jumetc\/11-13-09jumet-plea-agree.pdf; Statement of Facts filed November 13, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/jumetc\/11-12-09jumet-statement-facts.pdf; Judgment filed April 22, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/jumetc\/04-22-10jumet-judgment.pdf.  US Department of Justice Press Release, \u0022Virginia Resident Sentenced to 87 Months in Prison for Bribing Foreign Government Officials, Longest Prison Sentence Ever Imposed Related to Foreign Corrupt Practices Act (FCPA) Violations,\u0022 April 22, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/April\/10-crm-442.html","Documents":""},{"Case ID":"ST-304","Case Cluster ":"Ports Engineering Consultants Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Panama","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"02\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$331,000.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$331,000","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On November 10, 2009 and December 15, 2009, respectively, Charles Paul Edward Jumet and John W. Warwick were charged in connection with a conspiracy to make corrupt payments to Panamanian government officials in exchange for certain maritime contracts. Jumet was charged in a two-count criminal information with conspiracy to bribe foreign officials in violation of the FCPA and with making a false statement to the FBI. Warwick, the former president of Ports Engineering Consultants Corporation (PECC), was indicted on one-count of conspiracy to authorize and cause corrupt payments to be made to foreign government officials for the purpose of securing business for PECC, in violation of the FCPA.  According to court documents, from 1997 through approximately July 2003, Warwick, Jumet, and others conspired to authorize and cause corrupt payments totaling more than $200,000 to be made to the former administrator and deputy administrator of the Panama Maritime Ports Authority, as well as to a former, high-ranking elected executive official of the Republic of Panama. These corrupt payments were made so that the Panamanian officials would award contracts to maintain lighthouses and buoys along Panama\u0027s waterways to PECC, a company incorporated under the laws of Panama and affiliated with Overman Associates, an engineering firm based in Virginia. In 1997, the Panamanian government awarded PECC a no-bid 20-year concession to perform these duties. As a result of these contracts, PECC earned approximately $18 million in revenue from 1997 to 2000. In 2000, Panama\u0027s Comptroller General Office suspended the contract while it investigated the government\u0027s decision to award PECC a contract without soliciting a bid from any other entities. In 2003, the Panamanian government resumed making payments to PECC.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011.)  According to the US Government\u0027s Sentencing Memorandum, \u0022Defendant Warwick is a United States citizen who was President of Ports Engineering Consultants Corporation (PECC), Overman Associates, and Overman de Panama during this conspiracy. He, Charles Jumet, and others authorized and caused corrupt payments to be made to Panamanian government officials, through shell corporations -- Warmspell Holding Corporation and Soderville Corporation -- and through the issuance of checks made payable to the \u0027bearer.\u0027\u0022  (Source: US v. Warwick, Case No. 3:09-cr-449-HEH (E.D. Va.), US Government Sentencing Memorandum filed June 14, 2010.)  Forfeiture Agreement contained in Warwick\u0027s Plea Agreement filed February 10, 2010.","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Ports Engineering Consultants Corporation Case Summary at 57-58, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. John W. Warwick, Case No. 3:09-cr-449-HEH (E.D. Va.), Indictment filed December 15, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/warwickj\/12-15-09warwick-indict.pdf; Plea Agreement filed February 10, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/warwickj\/02-10-10warwick-plea-agree.pdf; Statement of Facts filed February 10, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/warwickj\/02-10-10warwick-statement-facts.pdf;  US Government Sentencing Memorandum filed June 14, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/warwickj\/06-14-10warwick-senten-memo.pdf.  See also, US Department of Justice Press Release, \u0022Virginia Resident Sentenced to 37 Months in Prison for Bribing Foreign Government Officials,\u0022 June 25, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/June\/10-crm-750.html","Documents":""},{"Case ID":"ST-305","Case Cluster ":"Prodetra bv, Wadinxveen","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Rijksrecherche (Dutch Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Out of court settlement","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$158,168.10","Criminal Fine\/Penalty (US$) ":"$103,203","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$54,965.10","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"","Offenses - Settled":"Sanctions legislation by paying kickbacks when implementing UN Oil-for-Food Programme","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Netherlands Phase 2 Report of the OECD Anti-Bribery Working Group (December 17, 2008): \u0022As of October 2008, no foreign bribery cases had been brought before the Dutch courts. Nevertheless, the prosecution authorities have concluded out-of-court transactions with seven companies for paying kickbacks in the context of the Oil-for-Food Programme in Iraq, although the offence charged was the violation of sanctions legislation and not the foreign bribery offence.\u0022 (para 2); \u0022 the Prosecution Department reports that it has concluded financial transactions (out of court settlements) with 7 companies for violating sanction legislation by paying kickbacks when implementing the Oil for Food Programme. Criminal gains have also been confiscated. In July 2008 a press release has been issued about these settlements. Together with the names of the companies (Alfasan International B.V., N.V. Organon, Flowserve B.V. , OPW Fluid Transfer Group Europe B.V., Prodetra B.V. Solvochem Holland B.V., Stet Holland B.V.) the settlements have been made public. For the following Oil-for-food transactions out-of-court settlements have been reached: 1. Alfasan International BV Woerden, fine: \u20ac 31.800,-- and confiscation \u20ac 10.183,55 2. NV Organon Oss, fine: \u20ac 381.602 3. Flowerserve bv te Etten-Leur, fine: \u20ac 76.274 and confiscation \u20ac180.260 4. OPW Fluid Transfer Group Europe BV, Nieuw Vennep, fine \u20ac 57.204 and confiscation \u20ac 24.600 5. Prodetra bv,Wadinxveen, fine: 64.751 and confiscation \u20ac 34.485,95 6. Solvochem Holland bv, Rotterdam, fine \u20ac 136.000 and confiscation \u20ac 144.592 7. Stet Holland bv,Emmeloord, fine \u20ac 119.712 and confiscation \u20ac 54.458.\u0022 (Source: Ibid., at 14.)","Sources ":"OECD Anti-Bribery Working Group, The Netherlands Phase 2 Report (December 17, 2008), accessed at http:\/\/www.oecd.org\/dataoecd\/61\/59\/41919004.pdf; Melissa Lipman, \u0022Cos. Settle Dutch Probe Into Oil-For-Food For ?1.3M,\u0022 Law 360, July 16, 2008, accessed at http:\/\/www.law360.com\/articles\/62486\/cos-settle-dutch-probe-into-oil-for-food-for-1-3m (partial article, gives date of Dutch Public Prosecution Service press release.)","Documents":""},{"Case ID":"ST-306","Case Cluster ":"RAE Systems, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,700,000.00","Criminal Fine\/Penalty (US$) ":"$1,700,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"Falsification of books and records, Internal controls violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 10, 2010, RAE Systems, Inc. entered into a non-prosecution agreement with the Department of Justice regarding alleged violations of the books and records and internal controls provisions of the FCPA. On the same date, the SEC filed a settled civil complaint against RAE Systems in the U.S. District Court for the District of Columbia, charging the company with violations of the anti-bribery, books and records, and internal controls provisions of the FCPA.  [  ] According to court records, from 2005 to 2008, the company had significant operations in the People\u0027s Republic of China (PRC), and sold its products and services primarily through two subsidiaries organized as joint ventures with local Chinese entities: RAE-KLH (Beijing) Co. Limited (RAE-KLH) and RAE Coal Mine Safety Instruments (Fushun) Co. Ltd. (RAE Fushun). A significant number of RAE-KLH\u0027s and RAE Fushun\u0027s customers were PRC government departments and bureaus, and large state-owned agencies and instrumentalities, including regional fire departments, emergency response departments and entities under the supervision of the provincial environmental agency.  As described in the agreement [with the Department of Justice], RAE Systems accepted responsibility for violating the internal controls and books and records provisions of the FCPA arising from and related to improper benefits corruptly paid by employees of RAE-KLH and RAE Fushun to foreign officials in the PRC. As a result of due diligence conducted by RAE Systems before acquiring the majority of the joint venture that became known as RAE-KLH, RAE Systems was aware of improper commissions, kickbacks and \u0022under table greasing to get deals\u0022 by employees.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, RAE Systems, Inc. Case Summary at 30-32.) ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, RAE Systems, Inc. Case Summary at 30-32, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  In Re: RAE Systems, Inc., Non-Prosecution Agreement and Statement of Facts, December 10, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/rae-systems\/12-10-10rae-systems.pdf;  US Department of Justice Press Release, \u0022RAE Systems Agrees to Pay $1.7 Million Criminal Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 December 10, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/December\/10-crm-1428.html.","Documents":""},{"Case ID":"ST-307","Case Cluster ":"RAE Systems, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$1,257,012.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,147,800","Civil Prejudgment Interest (US$) ":"$109,212","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 10, 2010, RAE Systems, Inc. entered into a non-prosecution agreement with the Department of Justice regarding alleged violations of the books and records and internal controls provisions of the FCPA. On the same date, the SEC filed a settled civil complaint against RAE Systems in the U.S. District Court for the District of Columbia, charging the company with violations of the anti-bribery, books and records, and internal controls provisions of the FCPA.  [  ] According to court records, from 2005 to 2008, the company had significant operations in the People\u0027s Republic of China (PRC), and sold its products and services primarily through two subsidiaries organized as joint ventures with local Chinese entities: RAE-KLH (Beijing) Co. Limited (RAE-KLH) and RAE Coal Mine Safety Instruments (Fushun) Co. Ltd. (RAE Fushun). A significant number of RAE-KLH\u0027s and RAE Fushun\u0027s customers were PRC government departments and bureaus, and large state-owned agencies and instrumentalities, including regional fire departments, emergency response departments and entities under the supervision of the provincial environmental agency.  As described in the agreement [with the Department of Justice], RAE Systems accepted responsibility for violating the internal controls and books and records provisions of the FCPA arising from and related to improper benefits corruptly paid by employees of RAE-KLH and RAE Fushun to foreign officials in the PRC. As a result of due diligence conducted by RAE Systems before acquiring the majority of the joint venture that became known as RAE-KLH, RAE Systems was aware of improper commissions, kickbacks and \u0022under table greasing to get deals\u0022 by employees.\u0022  The SEC complaint alleged that \u0022employees of RAE-KLH and RAW Fushun paid approximately $400,000 to Chinese government officials in violation of the FCPA\u0027s anti-bribery provisions.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, RAE Systems, Inc. Case Summary at 30-32.) ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, RAE Systems, Inc. Case Summary at 30-32, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission v. RAE Systems, Inc., Case No. 1:10-cv-2093 (D.D.C.), Complaint filed December 10, 2010,  accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21770.pdf and SEC Litigation Release No. 21770 (December 10, 2010), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21770.htm.","Documents":""},{"Case ID":"ST-308","Case Cluster ":"Rockwell Automation Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"05\/03","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$2,761,091.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,771,000","Civil Prejudgment Interest (US$) ":"$590,091","Civil Fine \/ Penalty (US$)":"$400,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Books and records, internal controls failure","Offenses - Settled":"No admission of SEC findings","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Law.com, citing Alexandra Wrage of Trace International as source, this case was unusual in that the Department of Justice chose not to bring charges against the company (termed \u0022split decision\u0022 by SEC and DOJ).  (Source: Brian Zabcik, \u0022Reasonable Minds Can Disagree: SEC, DOJ Part Ways on Rockwell Payments,\u0022 Law.com, May 5, 2011, accessed at http:\/\/www.law.com\/jsp\/cc\/PubArticleCC.jsp?id=1202492959767).  The SEC Cease-and-Desist Order made the following findings of misconduct (which Rockwell did not admit or deny as part of the settlement agreement):  (1) from 2003 to 2006, payment of $615,000 by certain employees of Rockwell\u0027s former subsidiary in China, China Rockwell Automation Power Systems (Shangai) Ltd. to Design Institutes, which were typically state-owned enterprises and (2) approximately $450,000 to fund sightseeing and other non-business trips for employees of Design Institutes and other state-owned companies. Rockwell realized approximately $1.7 million in net profits on sales contracts with end-user Chinese government-owned companies that were associated with payments to the Design Institutes. (Source: In the Matter of Rockwell Automation, Inc., Order Instituting Cease and Desist Order, SEC Administrative Proceeding File No. 3-14364 (May 3, 2011). ","Sources ":"In the Matter of Rockwell Automation, Inc., Administrative Proceeding, File No. 3-14364, Order Instituting Cease-and_Desist Proceedings (May 3, 2011), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2011\/34-64380.pdf; Brian Zabcik, \u0022Reasonable Minds Can Disagree: SEC, DOJ Part Ways on Rockwell Payments,\u0022 Law.com, May 5, 2011, accessed at http:\/\/www.law.com\/jsp\/cc\/PubArticleCC.jsp?id=1202492959767.","Documents":""},{"Case ID":"ST-309","Case Cluster ":"Samir A. Vincent","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"01\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to Defraud the United States, Impersonating Agents of Foreign Governments, Violation of the International Emergency Economic Powers Act, Fraud and False Statements","Offenses - Settled":"Conspiracy to Defraud the United States, Impersonating Agents of Foreign Governments, Violation of the International Emergency Economic Powers Act, Fraud and False Statements","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Press Release by the United States Attorney for the Southern District, among that Office\u0027s UN Oil-for-Food investigations were \u0022on January 18, 2005, SAMIR A. VINCENT, an Iraqi-American businessman, pleaded guilty before JudgeCHIN to, among other things, conspiring to serve in the United States as an unregistered agent of the Hussein regime.\u0022 (Source: United States Attorney for the Southern District of New York Press Release, \u0022Texas Oil Executive and Two Corporations Sentenced on Charges Involving a Scheme to Pay Secret Kickbacks to the Former Government of Saddam Hussein,\u0022 March 7, 2008.)  According to the Court Docket Report in his case, Vincent was not assessed monetary penalties. (Source:  US v. Vincent et al, Case No. 1:05-cr-00059-DC (SDNY), Court Docket Report  (accessed on October 26, 2011 via Pacer).","Sources ":"United States Attorney for the Southern District of New York Press Release, \u0022Texas Oil Executive and Two Corporations Sentenced on Charges Involving a Scheme to Pay Secret Kickbacks to the Former Government of Saddam Hussein,\u0022 March 7, 2008, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/March08\/chalmersetalsentencingpr.pdf; US v. Vincent et al, Case No. 1:05-cr-00059-DC (SDNY), Court Docket Report  (accessed on October 26, 2011 via Pacer).","Documents":""},{"Case ID":"ST-310","Case Cluster ":"Saybolt Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Panama","Year of Settlement":"1998","Month\/Day of Settlement (or Notes)":"12\/03","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,500,000.00","Criminal Fine\/Penalty (US$) ":"$1,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD, \u0022In April 1998, a grand jury sitting in Trenton, New Jersey, returned an indictment charging Frerik Pluimers, a Dutch national, and David Mead, a British national, both of whom were officers of an American company, Saybolt Inc., with conspiracy and violations of the FCPA and the Travel Act in connection with a $50,000 bribe paid to Panamanian officials. The bribe was paid to secure a lease for Saybolt Panama to move into the Panama canal free zone, which would reduce the company\u0027s tax liability. The bribe was discussed and approved at a board meeting of Saybolt Inc. in New Jersey, but the bribe itself was paid from the company\u0027s Dutch parent, Saybolt N.A., with the authorization of Pluimers. \/ Criminal Disposition:  On December 3, 1998, Saybolt Inc. and its subsidiary, Saybolt North America, pled guilty to violating the FCPA and paid a $1.5 million fine. In a related case, Saybolt Inc. was sentenced to pay a $3.4 million fine and required to retain a compliance monitor in relation to charges that it had falsified environmental tests of certain of its products.  [  ] Mr. Mead was convicted at trial in October 1998 and sentenced to four months in prison and a $20,000 fine. The United States requested that the Netherlands extradite Mr. Pluimers in March 2000. Despite extended litigation, including a decision of the Dutch Supreme Court authorizing the extradition, the Dutch authorities have refused and rejected the U.S. request for Mr. Pluimers? extradition. The United States is still seeking Mr. Pluimers return to the United States to stand trial.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Saybolt Inc. Case Summary at 134-35.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Saybolt Inc. Case Summary at 134-35, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Saybolt North America, Inc. and Saybolt Inc., Case No. 98-cr-10266-WGY (D. Mass.), Information filed August 10, 1998, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/saybolt\/08-10-98saybolt-info.pdf; Plea Agreement dated August 18, 1998, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/saybolt\/08-18-98saybolt-plea-agree.pdf; Judgment (as to Saybolt North America, Inc.), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/saybolt\/01-26-99saybolt-northamerica-judg.pdf; Judgment (as to Saybolt Inc.), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/saybolt\/01-26-99saybolt-inc-judgment.pdf","Documents":""},{"Case ID":"ST-311","Case Cluster ":"Schering-Plough Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Poland","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"06\/09","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order ","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$500,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$500,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission\u0027s litigation release, \u0022The Commission\u0027s complaint alleges that, between February 1999 and March 2002, one of Schering-Plough\u0027s foreign subsidiaries, Schering-Plough Poland, made improper payments to a charitable organization called the Chudow Castle Foundation. The Foundation was headed by an individual who was the Director of the Silesian Health Fund during the relevant time. The health fund was a Polish governmental body that, among other things, provided money for the purchase of pharmaceutical products and influenced the purchase of those products by other entities, such as hospitals, through the allocation of health fund resources. According to the complaint, Schering-Plough Poland paid 315,800 zlotys (approximately $76,000) to the Chudow Castle Foundation to induce the Director to influence the health fund\u0027s purchase of Schering-Plough\u0027s pharmaceutical products. The complaint alleges that none of the payments made by Schering-Plough Poland to the Foundation was accurately reflected on the subsidiary\u0027s books and records. The complaint also alleges that the company\u0027s system of internal accounting controls was inadequate to prevent or detect the improper payments. Without admitting or denying the allegations in the complaint, Schering-Plough consented to pay a $500,000 civil penalty.\u0022   In a related enforcement matter, Schering-Plough, without admitting or denying the allegations in the SEC complaint, consented to a cease and desist order enjoining the company from FCPA violations and other conditions. Schering-Plough Poland was a subsidiary of Schering-Plough Central East AG, a wholly owned Swiss subsidiary of Plough-Schering with headquarters in Lucerne, Switzerland.  (Source:  US Securities and Exchange Commission, Litigation Release No. 18740, June 9, 2004, Securities and Exchange Commission v. Schering-Plough Corporation, United States District Court for the District of Columbia, Civil Action No. 1:04CV00945 (PLF), \u0022SEC FILES SETTLED ENFORCEMENT ACTION AGAINST SCHERING-PLOUGH CORPORATION FOR FOREIGN CORRUPT PRACTICES ACT VIOLATIONS,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr18740.htm, and June 9, 2004 Complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/comp18740.pdf.","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Schering-Plough Corporation Case Summary at 133,  accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Securities and Exchange Commission, Litigation Release No. 18740, June 9, 2004, Securities and Exchange Commission v. Schering-Plough Corporation, United States District Court for the District of Columbia, Civil Action No. 1:04CV00945 (PLF), \u0022SEC Files Settled Enforcement Action against Schering-Plough Corporation for Foreign Corrupt Practices Act Violations,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr18740.htm, and June 9, 2004 Complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/comp18740.pdf.","Documents":""},{"Case ID":"ST-312","Case Cluster ":"Schnitzer Steel Industries, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China, South Korea","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"10\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"None","Offenses - Settled":"None","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On October 10, 2006, SSI International Far East Ltd. (SSI Korea), a wholly-owned subsidiary of Schnitzer Steel Industries Inc. (SSI), was charged with conspiracy, bribery in violation of the FCPA, wire fraud, and aiding and abetting the making of false entries in SSI\u0027s books and records. These charges stemmed from a decade-long scheme to bribe foreign officials in China and South Korea in order to obtain and retain business for SSI Korea and its Oregon-based parent company.  [  ]  SSI entered into a three-year deferred prosecution agreement with the Department [of Justice] and agreed to appoint an independent compliance monitor.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Schnitzer Steel Industries Inc. Case Summary at 88-90.)  According to SSI\u0027s Deferred Prosecution Agreement with the Department of Justice, SSI agreed that its subsidiary SSI Korea would pay $7.5 million in fines to the U.S.  (Source: Schnitzer Steel Industries, Inc. Deferred Prosecution Agreement Octobet 16, 2006.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Schnitzer Steel Industries Inc. Case Summary at 88-90,  accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  Schnitzer Steel Industries, Inc. Deferred Prosecution Agreement Octobet 16, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/ssi-intl\/10-16-06schnitzer-agree.pdf","Documents":""},{"Case ID":"ST-313","Case Cluster ":"Schnitzer Steel Industries, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, South Korea","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"10\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$7,725,201.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$6,279,095","Civil Prejudgment Interest (US$) ":"$1,446,106","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Internal Controls Violatons, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On October 10, 2006, SSI International Far East Ltd. (SSI Korea), a wholly-owned subsidiary of Schnitzer Steel Industries Inc. (SSI), was charged with conspiracy, bribery in violation of the FCPA, wire fraud, and aiding and abetting the making of false entries in SSI\u0027s books and records. These charges stemmed from a decade-long scheme to bribe foreign officials in China and South Korea in order to obtain and retain business for SSI Korea and its Oregon-based parent company.[ ] In a related action, on December 13, 2007, the SEC filed a settled civil complaint charging former Chairman and CEO of SSI, Robert W. Philip, with violating the anti-bribery provisions of the FCPA and with aiding and abetting SSI\u0027s anti-bribery, books and records, and internal controls violations. According to the SEC\u0027s complaint, from 1999 to 2004, Philip authorized the payment of more than $200,000 to managers of government-owned steel mills in China in order to induce them to purchase scrap metal from SSI. In addition, the complaint charged Philip with authorizing more than $1.7 million in payments to managers of privately-owned steel mills in both China and South Korea. SSI later described these payments as \u0022sales commissions,\u0022 \u0022commissions to the customer,\u0022 \u0022refunds,\u0022 or \u0022rebates\u0022 in its books and records, in violation of the FCPA.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Schnitzer Steel Industries Inc. Case Summary at 88-90,  accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Schnitzer Steel Industries Inc. Case Summary at 88-90,  accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  In the Matter of Schnitzer Steel Industries, Inc., US Securities and Exchange Commission (October 16, 2006), Administrative Proceeding File No. 3-12456, Order Instituting Cease-and-Desist Proceedings, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2006\/34-54606.pdf","Documents":""},{"Case ID":"ST-314","Case Cluster ":"Schnitzer Steel Industries, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, South Korea","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"12\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment","Monetary Sanctions  (Types)":"Disgorgement of Bonuses, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$261,400.42","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$169,864","Civil Prejudgment Interest (US$) ":"$16,536.63","Civil Fine \/ Penalty (US$)":"$75,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Aiding and Abetting Schnitzer Steel Industries\u0027 Bribery of Foreign Officials; Aiding and Abetting Schnitzer Steel Industries\u0027 Internal Controls Violatons, Aiding and Abetting Schnitzer Steel Industries\u0027 Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, on December 13, 2007, the Commssion \u0022charged the former Chairman and CEO of Schnitzer Steel Industries, Inc., with violating anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA) by approving cash payments and other gifts to officials at Chinese  government-owned steel mills to entice their business. [  ] The Commission\u0027s complaint, filed in U.S. district court in Portland, Ore., alleges that from at least 1999 through 2004, Philip authorized payment of more than $200,000 in cash bribes and other gifts to managers at government-owned steel mills in China to induce them to purchase scrap metal from Portland-based Schnitzer. The Commission alleges that Schnitzer generated more than $96 million in revenue, and more than $6.2 million in profits, from sales to customers who had received the improper payments. The complaint further alleges that Philip authorized more than $1.7 million in payments to managers of privately owned steel mills in both China and South Korea, generating more than $500 million in additional revenue for the company.\u0022  (Source: US Securities and Exchange Commission Litigation Release No. 20397 \/ December 13, 2007, Securities and Exchange Commission v. Robert W. Philip, Case No. CV 07-1836 (MO) (D. Or. filed December 13, 2007), \u0022SEC Charges Former Chairman\/CEO of Schnitzer Steel for Authorizing Cash Bribes to Foreign Officials.\u0022)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Schnitzer Steel Industries Inc. Case Summary at 88-90,  accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20397 \/ December 13, 2007, Securities and Exchange Commission v. Robert W. Philip, Case No. CV 07-1836 (MO) (D. Or. filed December 13, 2007), \u0022SEC Charges Former Chairman\/CEO of Schnitzer Steel for Authorizing Cash Bribes to Foreign Officials,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20397.htm; Complaint filed December 13, 2007, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2007\/comp20397.pdf","Documents":""},{"Case ID":"ST-315","Case Cluster ":"Schnitzer Steel Industries, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, South Korea","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"06\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Bonuses, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$41,131.90","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$14,819","Civil Prejudgment Interest (US$) ":"$1,312.52 ","Civil Fine \/ Penalty (US$)":"$25,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Aiding and Abetting Schnitzer Steel Industries\u0027 Bribery of Foreign Officials; Aiding and Abetting Schnitzer Steel Industries\u0027 Internal Controls Violatons, Aiding and Abetting Schnitzer Steel Industries\u0027 Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, on June 29, 2007, the Commission \u0022announced charges against a former executive of Portland, Oregon-based Schnitzer Steel Industries, Inc., for violating the anti-bribery provisions of the Foreign Corrupt Practices Act (\u0022FCPA\u0022). Without admitting or denying the allegations, Si Chan Wooh of Tacoma, Washington, the former Executive Vice President and head of a Schnitzer subsidiary, agreed to pay approximately $40,000 in disgorgement, interest and penalties.  The Commission\u0027s complaint, filed in federal district court in Portland, Oregon, alleges that from at least 1999 through 2004, Wooh paid over $200,000 in cash bribes and other gifts to managers of government-owned steel mills in China to induce them to purchase scrap metal from Schnitzer. According to the Commission, Schnitzer realized over $6.2 million in profits from sales to customers procured through these illicit payments. The Complaint further alleges that during the same period, Wooh made or authorized similar payments totaling over $1.7 million to managers of privately owned steel mills in both China and South Korea.\u0022 (Source: US Securities and Exchange Commission Litigation Release No. 20174 \/ June 29, 2007, SEC v. Si Chan Wooh, Case No. CV-07-957 ST. (D. Or. filed June 29, 2007), \u0022SEC Settles Charges Against Former Portland Steel Executive for Anti-Bribery Statute Violations.\u0022)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Schnitzer Steel Industries Inc. Case Summary at 88-90,  accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20174 \/ June 29, 2007, SEC v. Si Chan Wooh, Case No. CV-07-957 ST. (D. Or. filed June 29, 2007), \u0022SEC Settles Charges Against Former Portland Steel Executive for Anti-Bribery Statute Violations,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20174.htm; Complaint filed June 29, 2007, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2007\/comp20174.pdf","Documents":""},{"Case ID":"ST-316","Case Cluster ":"Schnitzer Steel Industries, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China, South Korea","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"10\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$7,500,000.00","Criminal Fine\/Penalty (US$) ":"$7,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Freign Oficials, Conspiracy to Falsify Books and Records, Conspiracy to Commit Wire Fraud, Bribery of Foreign Officials, Falsification of Books and Records, Wire Fraud, Aiding and Abetting Schnitzer Steel Industries\u0027 Falsification of Books and Records ","Offenses - Settled":"Conspiracy to Bribe Freign Oficials, Conspiracy to Falsify Books and Records, Conspiracy to Commit Wire Fraud, Bribery of Foreign Officials, Falsification of Books and Records, Wire Fraud, Aiding and Abetting Schnitzer Steel Industries\u0027 Falsification of Books and Records ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to United States Report to the OECD, \u0022On October 10, 2006, SSI International Far East Ltd. (SSI Korea), a wholly-owned subsidiary of Schnitzer Steel Industries Inc. (SSI), was charged with conspiracy, bribery in violation of the FCPA, wire fraud, and aiding and abetting the making of false entries in SSI\u0027s books and records. These charges stemmed from a decade-long scheme to bribe foreign officials in China and South Korea in order to obtain and retain business for SSI Korea and its Oregon-based parent company. In June 2007, Si Chan Wooh, a former senior executive officer of SSI, was charged by both the DOJ and SEC in connection with his role in the bribery scheme.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Schnitzer Steel Industries Inc. Case Summary at 88-90,  accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.)   According to court documents, on October 14, 2011, the Department dropped its charges against Wooh.  (Sources:  US v. Si Chan Wooh, Case No. 3:07-cr-244 (D. Or.), Government\u0027s Unopposed Motion to Dismiss Information, filed October 14, 2011; Court Docket Entry indicating Order to Dismiss signed October 17, 2011.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Schnitzer Steel Industries Inc. Case Summary at 88-90,  accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  SSI International Far East Ltd., Case No. 06-cr-398-KI (D. Or.), Information filed October 10, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/ssi-intl\/10-10-06ssi-information.pdf; Plea Agreement filed October 10, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/ssi-intl\/10-10-06ssi-fareast-plea.pdf; Judgment dated October 17, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/ssi-intl\/10-17-06ssi-fareast-judg.pdf.  US v. Si Chan Wooh, Case No. 3:07-cr-244 (D. Or.), Government\u0027s Unopposed Motion to Dismiss Information, filed October 14, 2011; Court Docket Entry indicating Order to Dismiss signed October 17, 2011 (Both accessed via Pacer.)","Documents":""},{"Case ID":"ST-317","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"Nigeria","Jurisdiction of Settlement \/ Enforcement Agency":"Economic and Financial Crimes Commission; Attorney General","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"11\/22","Other Jurisdictions of Settlement":"Germany, United States, World Bank","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine, Disgorgement","Total Monetary Sanctions (US$)":"$46,000,000.00","Criminal Fine\/Penalty (US$) ":"$46,000,000","Criminal Fine \/ Penalty (Explanation)":"Please note that the December 22, 2010 press briefing by the Nigerian Attorney General noted that $170.8 million had been paid in total by companies and individuals; no specific figure was given as to each company.  The press statement noted that the sums had been paid by the companies as fines and disgorgement but no breakdown was given. ","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$46,000,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction (Amount from secondary sources)","UNCAC Articles(s) Implicated":"","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Unknown","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the May 4, 2011 Siemens Company Statement on Legal Proceedings against it around the world, the criminal charges filed against it by the Nigerian Economic and Financial Crimes Commission (EFCC) was dismissed in November 2010, pursuant to a settlement agreement between Siemens and the Nigerian authorities. (Source: Siemens, \u0022Legal Proceedings,\u0022 May 4, 2011.)  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.  However, on December 22, 2010, the Nigerian Attorney General and Minister of Justice stated at a media briefing that the total sum of $170.8 million had been paid by foreign companies to settle bribery charges and\/or allegations and that the sums represented fines and disgorgement of profits.  (Source: 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010.)","Sources ":"2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010, provided to the study by the Nigerian Economic and Financial Crimes Commission; Marcus Cohen, David Elesinmogun \u0026 Obumneme Egwuatu, \u0022Will Nigeria Take Another Bite?,\u0022 FCPA Blog, August 4, 2011, accessed at http:\/\/www.fcpablog.com\/blog\/tag\/shell; Siemens, \u0022Legal Proceedings,\u0022 May 4, 2011, accessed at http:\/\/www.siemens.com\/press\/pool\/de\/events\/2011\/corporate\/2011-q2\/2011-q2-legal-proceedings-e.pdf; US v. Siemens A.G., Case No. 08-cr-367-RJL (D.D.C.), Plea Agreement and Statement of Offense, both filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens-aktiengesellschaft.html.","Documents":""},{"Case ID":"ST-318","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Argentina, Bangladesh, Iraq (UN Oil-for-Food), Venezuela","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"12\/15","Other Jurisdictions of Settlement":"Germany, World Bank ","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$448,500,000.00","Criminal Fine\/Penalty (US$) ":"$448,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Falsification of Books and Records","Offenses - Settled":"Falsification of Books and Records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 11, 2008, Siemens Aktiengesellschaft (Siemens AG), a German corporation, and three of its subsidiaries were charged in separate criminal informations filed in the U.S. District Court for the District of Columbia for their roles in a scheme to bribe foreign officials in several countries. Siemens AG was charged with two counts of violating the internal controls and books and records provisions of the FCPA, while Siemens S.A. - Argentina was charged with conspiracy to violate the books and records provisions. In addition, Siemens Bangladesh Limited (Siemens Bangladesh) and Siemens S.A. - Venezuela (Siemens Venezuela) were each charged with one count of conspiracy to violate the anti-bribery and books and records provisions of the FCPA.  According to court documents filed in these criminal cases, beginning in the mid-1990s, Siemens AG engaged in systematic efforts to falsify its corporate books and records and knowingly failed to implement existing internal controls. As a result of Siemens AG\u0027s knowing failures in and circumvention of internal controls, from the time of its listing on the New York Stock Exchange on March 12, 2001, through approximately 2007, Siemens AG made payments totaling approximately $1.36 billion through various mechanisms. Of this amount, approximately $554.5 million was paid for unknown purposes, including approximately $341 million in direct payments to business consultants for unknown purposes. The remaining $805.5 million of this amount was intended in whole or in part as corrupt payments to foreign officials in Asia, Africa, Europe, the Middle East and the Americas, which were to be paid through various mechanisms, including cash desks and slush funds. The criminal charges against Siemens AG and its three subsidiaries stem from bribery schemes and related accounting misconduct involving its operations in Iraq, Argentina, Venezuela, and Bangladesh.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Siemens Aktiengesellschaft (Siemens AG) Case Summary at 70-73.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Siemens Aktiengesellschaft (Siemens AG) Case Summary at 70-73, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Siemens AG, Case No. 1:08-cr-367-RJL (D.D.C.), Information filed December 12, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-12-08siemensakt-info.pdf; Plea Agreement filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-15-08siemensakt-plea.pdf; Statement of Offense filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-15-08siemens-statement.pdf; Government Sentencing Memorandum filed December 12, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-12-08siemensvenez-sent.pdf; Judgment filed January 6, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/01-06-09siemensakt-judgment.pdf.  US Department of Justice Press Release, \u0022Siemens AG and Three Subsidiaries Plead Guilty to Foreign Corrupt Practices Act Violations and Agree to Pay $450 Million in Combined Criminal Fines,\u0022 December 15, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/December\/08-crm-1105.html","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_AG_DOJ_Information_Dec_12_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_AG_DOJ_Statement_of_Offense_December_15_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_AG_DOJ_Judgment_Jan_6_2009.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_AG_DOJ_Govt_Sentencing_Memorandum_Dec_12_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_AG_DOJ_Plea_Transcript_Press_Conference_Dec_15_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_AG_DOJ_Plea_PR_Dec_15_2008.pdf"},{"Case ID":"ST-319","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"Milan Prosecutors Office","Jurisdiction of Foreign Public Official(s) ":"Italy","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"07\/25","Other Jurisdictions of Settlement":"Germany, United States, World Bank","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Fine, Disgorgement of Profits","Total Monetary Sanctions (US$)":"$8,373,905.00","Criminal Fine\/Penalty (US$) ":"$632,375","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$7,741,530","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Legislative Decree No. 231 of 8 June 2001 - Administrative Liability of Legal Persons ","Offenses - Settled":"Legislative Decree No. 231 of 8 June 2001 - Administrative Liability of Legal Persons ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the July 2006 Sentence ordered by the Milan Tribunal, Siemens entered into a plea agreement regarding the bribery by its executives of officials at state owned-Enelpower.  According to the Sentence, the executives made bribery payments to the CEO of  EnelProduzione and CEO of Enelpower in order to obtain secret information related to the bids.  The bribe payments passed from bank accounts in Liechtenstein or via the Emirates Bank International (subsidiary of a British Virgin Island company) to different accounts of which the Enel executives were beneficiaries, via accounts of a foreign established company (the MEEISCO LLC), which was under the control of an intermediary. (Source: Sentence against Siemens AG and individual defendants issued by the Il Tribunale Ordinario di Milano (25 July 2006)).  ","Sources ":"Sentence against Siemens AG and individual defendants issued by the Il Tribunale Ordinario di Milano (25 July 2006), accessed at http:\/\/www.penalecontemporaneo.it\/upload\/Trib.%20Milano,%2025.7.2006%20_sent._,%20GUP%20Varanelli%20_Confisca_.pdf; text of Legislative Decree No. 231 of 8 June 2001 -- Administrative Liability of Legal Persons excerpted in Phase 3 Report on Implementing the OECD Anti Bribery Convention in Italy (December 2011), accessed at  http:\/\/www.oecd.org\/dataoecd\/59\/47\/49377261.pdf repalce with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Trib.%20Milano%2C%2025.7.2006%20_sent._%2C%20GUP%20Varanelli%20_Confisca_it.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/OECD_Italy_Phase_3_Report_Dec_2011.pdf"},{"Case ID":"ST-320","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina, Bangladesh, China, Iraq (UN Oil-for-Food), Israel, Mexico, Nigeria, Russia, Venezuela, Vietnam","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"12\/15","Other Jurisdictions of Settlement":"Germany, World Bank ","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits","Total Monetary Sanctions (US$)":"$350,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$350,000,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, on December 12, 2008, the Commission filed a settled civil complaint which alleged that \u0022Between March 12, 2001 and September 30, 2007, Siemens violated the FCPA by engaging in a widespread and systematic practice of paying bribes to foreign government officials to obtain business. Siemens created elaborate payment schemes to conceal the nature of its corrupt payments, and the company\u0027s inadequate internal controls allowed the conduct to flourish. The misconduct involved employees at all levels, including former senior management, and revealed a corporate culture long at odds with the FCPA. During this period, Siemens made thousands of payments to third parties in ways that obscured the purpose for, and the ultimate recipients of, the money. At least 4,283 of those payments, totaling approximately $1.4 billion, were used to bribe government officials in return for business to Siemens around the world. Among others, Siemens paid bribes on transactions to design and build metro transit lines in Venezuela; metro trains and signaling devices in China; power plants in Israel; high voltage transmission lines in China; mobile telephone networks in Bangladesh; telecommunications projects in Nigeria; national identity cards in Argentina; medical devices in Vietnam, China, and Russia; traffic control systems in Russia; refineries in Mexico; and mobile communications networks in Vietnam. Siemens also paid kickbacks to Iraqi ministries in connection with sales of power stations and equipment to Iraq under the United Nations Oil for Food Program. Siemens earned over $1.1 billion in profits on these transactions.   An additional approximately 1,185 separate payments to third parties totaling approximately $391 million were not properly controlled and were used, at least in part, for illicit purposes, including commercial bribery and embezzlement.\u0022  The Litigation Release also noted that Siemens consented to the SEC \u0022ordering it to pay $350 million in disgorgement of wrongful profits, which does not include profits factored into Munich\u0027s fine.\u0022  The Litigation Release also noted that assistance was provided to the SEC investigation by the Office of the Prosecutor General in Munich, Germany; the U.K. Financial Services Authority; and the Hong Kong Securities and Futures Commission. (Source:  US Securities and Exchange Commission Litigation Release No. 20829 \/ December 15, 2008, Securities and Exchange Commission v. Siemens Aktiengesellschaft, Civil Action No. 08 CV 02167 (D.D.C.), \u0022SEC Files Settled Foreign Corrupt Practices Act Charges Against Siemens AG for Engaging in Worldwide Bribery With Total Disgorgement and Criminal Fines of Over $1.6 Billion.\u0022)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Siemens Aktiengesellschaft (Siemens AG) Case Summary at 70-73, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20829 \/ December 15, 2008, Securities and Exchange Commission v. Siemens Aktiengesellschaft, Civil Action No. 08 CV 02167 (D.D.C.), \u0022SEC Files Settled Foreign Corrupt Practices Act Charges Against Siemens AG for Engaging in Worldwide Bribery With Total Disgorgement and Criminal Fines of Over $1.6 Billion,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20829.htm; Complaint filed December 12, 2008, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20829.pdf","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_SEC_Amended_Complaint.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_SEC_Litigation_Release_Settlement_Dec_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_SEC_Litigation_Release.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_SEC_DDC_Docket_Report.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_SEC_Final_Judgment.pdf"},{"Case ID":"ST-321","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"","Jurisdiction of Settlement \/ Enforcement Agency":"Integrity Vice Presidency","Jurisdiction of Foreign Public Official(s) ":"Various","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"7\/2","Other Jurisdictions of Settlement":"Germany, United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Establishment of Special Fund, Debarment,  \u0022Voluntary restraint\u0022 from bidding on World Bank projects for two years","Monetary Sanctions  (Types)":"Special Fund","Total Monetary Sanctions (US$)":"$100,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"$100,000,000","Other Civil Monetary Sanctions (Explanation)":"Special Fund","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$100,000,000","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Integrity initiative fund","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Corruption in a project in Russia involving a subsidiary","Offenses - Settled":"Corruption in a project in Russia involving a subsidiary","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the World Bank Press Release, \u0022The World Bank Group today announced a comprehensive settlement with Siemens AG in the wake of the company\u0027s acknowledged past misconduct in its global business and a World Bank investigation into corruption in a project in Russia involving a Siemens subsidiary. The settlement includes a commitment by Siemens to pay $100 million over the next 15 years to support anti-corruption work, an agreement of up to a four-year debarment for Siemens\u0027 Russian subsidiary, and a voluntary two-year shut-out from bidding on Bank business for Siemens AG and all of its consolidated subsidiaries and affiliates. [  ]  Siemens\u0027 commitment to pay $100 million to support global efforts to fight fraud and corruption would include providing funds to organizations and projects aimed at combating corruption through collective action, training, education. The money will also be directed to helping governments to recover assets stolen by corrupt leaders, and strengthening efforts to identify and crack-down on corrupt practices.  The World Bank Group will have audit rights over the use of these funds and veto rights over the selection of anticorruption groups or programs receiving funds.\u0022 (Source:  The World Bank, \u0022Siemens to pay $100m to fight corruption as part of World Bank Group settlement,\u0022 Press Release No:2009\/001\/EXT, July 2, 2009.)","Sources ":"World Bank Group -  Siemens Settlement Agreement, \u0022FACT SHEET,\u0022 accessed at http:\/\/siteresources.worldbank.org\/INTDOII\/Resources\/Siemens_Fact_Sheet_Nov_11.pdf; The World Bank, \u0022Siemens to pay $100m to fight corruption as part of World Bank Group settlement,\u0022 Press Release No:2009\/001\/EXT, July 2, 2009, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,contentMDK:22234573~pagePK:34370~piPK:34424~theSitePK:4607,00.html;  Siemens and The World Bank, \u0022Siemens selects initial projects for US$100 million Integrity Initiative,\u0022 December 9, 2010, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/TOPICS\/EXTLAWJUSTICE\/0,,contentMDK:22786119~menuPK:2643814~pagePK:64020865~piPK:149114~theSitePK:445634,00.html.  Additional information on Integrity Initiative at http:\/\/www.siemens.com\/sustainability\/en\/core-topics\/collective-action\/integrity-initiative\/index.php","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_World_Bank_Settlement_Press_Release_2009.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_Fact_Sheet_Nov_11_World_Bank_Settlement.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_World_Bank_2010_Initiative_Recipients_PR_Dec_2010.pdf"},{"Case ID":"ST-323","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"12\/13","Other Jurisdictions of Settlement":"Germany","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Aiding and Abetting Siemens\u0027 Bribery of Foreign Officials; Falsification of Books and Records; Aiding and Abetting Siemens\u0027 Failure to Maintain Internal Controls; Aiding and Abetting Siemens\u0027 Failure to Maintain Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Litigation Release, \u0022From approximately 1996 until early 2007, senior executives at Siemens and its regional company in Argentina, Siemens S.A. (\u0022Siemens Argentina\u0022), paid bribes to senior Argentine government officials -- including two Presidents, and Cabinet Ministers in two Presidential administrations. The bribes were initially paid to secure a $1 billion government contract (the \u0022DNI Contract\u0022) to produce national identity cards, or Documentos Nacionales de Identidad, for every Argentine citizen. Later, after a change in Argentine political administrations resulted in the DNI Contract being suspended and then canceled, Siemens paid additional bribes in a failed effort to bring the DNI Contract back into force. Still later, after the company instituted an arbitration proceeding to recover its costs and expected profits from the canceled DNI Contract, Siemens paid additional bribes to suppress evidence that the DNI Contract had originally been obtained through corruption. Over the course of the bribery scheme, over $100 million in bribes were paid, approximately $31.3 million of which were made after March 12, 2001, when Siemens became a U.S. issuer subject to U.S. securities laws. As a result of the bribe payments it made, Siemens received an arbitration award in 2007 against the government of Argentina of over $217 million plus interest for the DNI Contract. In August 2009, after settling bribery charges with the U.S. and Germany, Siemens waived the arbitration award.  During the relevant 2001 to 2007 time period, defendants Uriel Sharef, Ulrich Bock, Carlos Sergi, Stephan Signer, Herbert Steffen, Andres Truppel, and Bernd Regendantz each had a role in authorizing, negotiating, facilitating, or concealing bribe payments in connection with the DNI Contract. Siemens employed a group of consultants, designated the Project Group and led by defendant Sergi, to serve as payment intermediaries between the company and the Argentine government officials.\u0022  Without admitting or denying the SEC\u0027s allegations, defendant Bernd Regendantz has consented to the entry of a final judgment that permanently enjoins him from future violations and orders him to pay a civil penalty of $40,000, deemed satisfied by Regendantz\u0027 payment of a ?30,000 administrative fine ordered by the Public Prosecutor General in Munich, Germany. (Source: Securities and Exchange Commission Litigation Release No. 22190 \/ December 13, 2011, \u0022Securities and Exchange Commission v. Uriel Sharef, Ulrich Bock, Carlos Sergi, Stephan Signer, Herbert Steffen, Andres Truppel and Bernd Regendantz, Civil Action No. 11 civ 9073 (Judge Scheidlin\/Pitman) (S.D.N.Y.) \/ SEC Charges Seven Former Siemens Executives with Bribing Leaders in Argentina.\u0022)","Sources ":"US Securities and Exchange Commission v. Sharef, et al, Case No. 1:11-cv-9073 (S.D.N.Y.), Complaint filed December 13, 2011, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp22190.pdf; Securities and Exchange Commission Litigation Release No. 22190 \/ December 13, 2011, \u0022Securities and Exchange Commission v. Uriel Sharef, Ulrich Bock, Carlos Sergi, Stephan Signer, Herbert Steffen, Andres Truppel and Bernd Regendantz, Civil Action No. 11 civ 9073 (Judge Scheidlin\/Pitman) (S.D.N.Y.) \/ SEC Charges Seven Former Siemens Executives with Bribing Leaders in Argentina,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr22190.htm","Documents":""},{"Case ID":"ST-325","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice ","Jurisdiction of Foreign Public Official(s) ":"Bangladesh","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"12\/15","Other Jurisdictions of Settlement":"Germany, World Bank ","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$500,000.00","Criminal Fine\/Penalty (US$) ":"$500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 11, 2008, Siemens Aktiengesellschaft (Siemens AG), a German corporation, and three of its subsidiaries were charged in separate criminal informations filed in the U.S. District Court for the District of Columbia for their roles in a scheme to bribe foreign officials in several countries.  [  ] Bangladesh: From 2001 through 2006, Siemens Bangladesh caused corrupt payments of at least $5,319,839 to be made through purported business consultants to various Bangladeshi officials in exchange for favorable treatment during the bidding process on a mobile telephone project. At least one payment to each of these purported consultants was paid from a U.S. bank account.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Siemens Aktiengesellschaft (Siemens AG) Case Summary at 70-73.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Siemens Aktiengesellschaft (Siemens AG) Case Summary at 70-73, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Siemens Bangladesh Limited, Case No. 1:08-cr-369-RJL (D.D.C.), Information filed December 12, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-12-08siemensbangla-info.pdf; Plea Agreement filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-15-08siemensbangla-plea.pdf; Statement of Facts filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-15-08siemensbangla-statement.pdf; Judgment filed January 6, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/01-06-09siemensbangla-judgment.pdf","Documents":""},{"Case ID":"ST-326","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"Greece","Jurisdiction of Settlement \/ Enforcement Agency":"Parliament","Jurisdiction of Foreign Public Official(s) ":"Greece","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"04\/05","Other Jurisdictions of Settlement":"Italy, Nigeria, United States, World Bank","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Other","Legal Form of Settlement":"Parliamentary Decree","Monetary Sanctions  (Types)":"Other (Waiver of EUR80 million in obligations owed by Greek Government to Siemens; Payment of EUR90 million to finance anti-corruption platform; Investment of EUR 100 million to Siemens\u0027 activities within Greece)","Total Monetary Sanctions (US$)":"$355,703,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"$355,703,000","Other Civil Monetary Sanctions (Explanation)":"various; please see case summary","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$355,703,000","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the April 5, 2012 press release by Siemens, \u0022Today, the Hellenic Parliament ratified the settlement agreement between Siemens and the Greek State. This marks the beginning of a new chapter in Siemens\u0027 long history in Greece. The Greek Government\u0027s commitment to foster growth was one of the pillars on which this agreement was based. This agreement will allow Siemens to continue to be a real supporter. To this end, Siemens will explore actual and substantial areas of investment in Greece, with special emphasis to sectors which increase employment and support the economy. In total, this settlement will reach approximately 270 million Euro. In this context, Siemens waives claims of ?80 million that concern implemented projects and the delivery of equipment to the Greek State. Siemens will dispense up to the amount of 90 million Euro for transparency initiatives and anti-corruption programs, as well as for academic and research programs that aim at enhancing Greece\u0027s competitiveness. Finally, Siemens will spend over ?100 million, in order to enhance its activities in Greece and preserve a significant number of jobs in the local market.\u0022 (Source: Siemens AG Company Press Release, \u0022Siemens and the Hellenic Republic reach a settlement agreement and mark a new beginning,\u0022 April 5, 2012.)","Sources ":"Siemens AG Company Press Release, \u0022Siemens and the Hellenic Republic reach a settlement agreement and mark a new beginning,\u0022 April 5, 2012, accessed at http:\/\/www.siemens.com\/press\/pool\/de\/pressemitteilungen\/2012\/corporate\/AXX20120420e.pdf; Organisation for Economic Co-operation and Development, \u0022PHASE 3 REPORT ON IMPLEMENTING THE OECD ANTI-BRIBERY CONVENTION IN GREECE, JUNE 2012,\u0022 accessed at http:\/\/www.oecd.org\/dataoecd\/21\/2\/50633313.pdf","Documents":""},{"Case ID":"ST-327","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"12\/15","Other Jurisdictions of Settlement":"Germany, World Bank ","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$500,000.00","Criminal Fine\/Penalty (US$) ":"$500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to Falsifiy Books and Records","Offenses - Settled":"Conspiracy to Falsify Books and Records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 11, 2008, Siemens Aktiengesellschaft (Siemens AG), a German corporation, and three of its subsidiaries were charged in separate criminal informations filed in the U.S. District Court for the District of Columbia for their roles in a scheme to bribe foreign officials in several countries.  [  ]   From 1998 through 2007, Siemens Argentina made and caused to be made significant payments to various Argentine officials, both directly and indirectly, in exchange for favorable business treatment in connection with a $1 billion national identity card project. From March 2001 through January 2007, Siemens Argentina paid approximately $31,263,000 in corrupt payments to various Argentine officials through purported consultants and other conduit entities, and improperly characterized those corrupt payments in its books and records as legitimate payments for \u0022consulting fees\u0022 or \u0022legal fees.\u0022  Siemens Argentina\u0027s books and records were subsequently incorporated into the books and records of Siemens AG.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Siemens Aktiengesellschaft (Siemens AG) Case Summary at 70-73.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Siemens Aktiengesellschaft (Siemens AG) Case Summary at 70-73, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Siemens Argentina S.A., Case No. 1:08-cr368-RJL (D.D.C.), Information filed December 12, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-12-08siemensargen-info.pdf; Plea Agreement filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-15-08siemensargen-plea.pdf; Statement of Offense filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-15-08siemensargen-statement.pdf; Judgment filed January 6, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/01-06-09siemensarg-judgment.pdf.","Documents":""},{"Case ID":"ST-328","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"12\/15","Other Jurisdictions of Settlement":"Germany, The World Bank","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$500,000.00","Criminal Fine\/Penalty (US$) ":"$500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 11, 2008, Siemens Aktiengesellschaft (Siemens AG), a German corporation, and three of its subsidiaries were charged in separate criminal informations filed in the U.S. District Court for the District of Columbia for their roles in a scheme to bribe foreign officials in several countries.  [  ]  From 2001 through 2007, Siemens Venezuela made and caused to be made corrupt payments of at least $18,782,965 to various Venezuelan officials, indirectly through purported business consultants, in exchange for favorable business treatment in connection with two major metropolitan mass transit projects called Metro Valencia and Metro Maracaibo. Some of those payments were made using U.S. bank accounts controlled by the purported business consultants.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Siemens Aktiengesellschaft (Siemens AG) Case Summary at 70-73.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Siemens Aktiengesellschaft (Siemens AG) Case Summary at 70-73, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US v. Siemens S.A. (Venezuela), Case No. 1:08-cr-370-RJL (D.D.C.), Information filed December 12, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-12-08siemensvenez-info.pdf; Plea Agreement filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-15-08siemensvenez-plea.pdf; Statement of Offense filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-15-08siemensvenez-statement.pdf; Judgment filed January 6, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-15-08siemensvenez-statement.pdf","Documents":""},{"Case ID":"ST-330","Case Cluster ":"SINTEF Petroleum Research","Jurisdiction of Settlement":"Norway","Jurisdiction of Settlement \/ Enforcement Agency":"\u00d8kokrim","Jurisdiction of Foreign Public Official(s) ":"Iran","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"11\/02","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Penalty Notice","Monetary Sanctions  (Types)":"Criminal Penalty","Total Monetary Sanctions (US$)":"$370,782.00","Criminal Fine\/Penalty (US$) ":"$370,782","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Aggravated Bribery (criminal law, section 276b)","Offenses - Settled":"[Aggravated Bribery] - unclear from sources what was agreed to","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a SINTEF Petroleum Research\u0027s statement posted on its website: \u0022The Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime (\u00d8kokrim) has fined SINTEF Petroleum Research (SPR) NOK 2 million in connection with a consulting contract signed with an Iranian company in 2002. \u201cWe accept the fine\u201d, says SPR President May Britt Myhr. \u201cSINTEF has prioritised upgrading its routines from the day we became aware of this matter, so we are pleased that \u00d8kokrim acknowledges that we have implemented a number of measures to prevent such incidents from happening again. We will certainly use this experience in our continued development of SINTEF into an internationally leading research company\u201d, states SINTEF President Unni Steinsmo. [  ] \u00d8kokrim has concluded that a consulting contract SPR signed with an Iranian company in 2002 broke the law. \u00d8kokrim launched an investigation of SPR in August 2005 after the NOPEF trade union had reported the company to the authorities. \u00d8kokrim believes that the contract was in breach of criminal law. It has therefore fined SPR and has charged the former President of SPR with serious corruption (General Civil Penal Code, \u00a7276a, see \u00a7276b).\u0022  (Source:  SINTEF Press Release, \u0022SINTEF Petroleum Research Accepts Fine,\u0022 Published November 2, 2007.).  The second case concerns bribery by a research and consulting company (\u201cthe Research Company case\u201d). According to Norway\u0027s June 2011 OECD Phase 3 Report on the enforcement of the Anti-Bribery Convention, \u0022\u00d8kokrim charged a senior executive of that company with serious corruption, and issued a penalty notice to the company in connection with a consulting contract signed with a foreign company in 2002. \u00d8kokrim launched an investigation on the company in 2005, following an internal whistleblower report. \u00d8kokrim believed that the contract was in breach of criminal law, section 276b (aggravated bribery). The company\u201fs fine was in the amount of NOK 2 million, which was accepted. In May 2007, the senior executive was acquitted by the Court of First Instance, who found there was insufficient evidence to convict.\u0022 (Source: Norway Phase-3 Report at para 16.)  The case summary on \u00d8kokrim\u0027s website states that SINTEF\u0027s contract involved an Iranian entity, as well as payments to Hinson Engineering Limited, which was registered in the British Virgin Islands and held a bank account in Switzerland (\u0022Hinson Agreement\u0022) (Source: \u00d8kokrim, \u0022Korrupsjon - SINTEF Petroleumsforskning AS,\u0022 updated April 22, 2009.)","Sources ":"SINTEF Press Release, \u0022SINTEF Petroleum Research Accepts Fine,\u0022 Published November 2, 2007, accessed at http:\/\/www.sintef.no\/home\/Press-Room\/Press-Releases\/SINTEF-Petroleum-Research-accepts-fine\/; Organisation for Economic Co-operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Norway, June 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/38\/59\/48286802.pdf;  replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Norwayphase3reportEN.pdf;  \u00d8kokrim, \u0022SINTEF Petroleumsforskning AS,\u0022 updated April 22, 2009, accessed at http:\/\/www.okokrim.no\/artikler\/sak-sintef","Documents":""},{"Case ID":"ST-331","Case Cluster ":"Smith \u0026 Nephew plc","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Greece","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"02\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$5,426,799.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$4,028,000","Civil Prejudgment Interest (US$) ":"$1,398,799","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, \u0022Smith \u0026 Nephew PLC, headquartered in London, England, is a global medical device company with operations around the world. The SEC alleges that, from 1997 to June 2008, two of Smith \u0026Nephew PLC\u0027s subsidiaries, including its U.S. subsidiary, Smith \u0026 Nephew Inc., used a distributor to create a slush fund to make illicit payments to public doctors employed by government hospitals or agencies in Greece. [  ] The SEC\u0027s complaint alleges that, starting in 1997, Smith \u0026 Nephew PLC\u0027s subsidiaries developed a scheme to create an offshore fund to pay Greek public doctors to purchase products from two Smith \u0026 Nephew PLC subsidiaries, Smith \u0026 Nephew Inc. and Smith \u0026 Nephew GmbH. According to the complaint, Smith \u0026 Nephew PLC\u0027s subsidiaries made payments to a total of three shell entities in the United Kingdom controlled by the distributor that were used to pay bribes. The complaint alleges that on paper, it appeared as if Smith \u0026 Nephew PLC\u0027s subsidiaries were paying for marketing services, but no services were actually performed. The complaint also alleges that Smith \u0026 Nephew PLC failed to act on numerous red flags of bribery and that employees at Smith \u0026 Nephew PLC and its subsidiaries were aware of the payments.\u0022 (Source: US Securities and Exchange Commission Litigation Release, Litigation Release 22252 \/ February 6, 2012, Securities and Exchange Commission v. Smith \u0026 Nephew PLC, Civil Action No. 1: 12-CV-00187 (D.D.C.)(GK) (February, 6, 2012).","Sources ":"US Securities and Exchange Commission Litigation Release, Litigation Release 22252 \/ February 6, 2012, Securities and Exchange Commission v. Smith \u0026 Nephew PLC, Civil Action No. 1: 12-CV-00187 (D.D.C.)(GK) (February, 6, 2012), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2012\/lr22252.htm; complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp22252.pdf","Documents":""},{"Case ID":"ST-332","Case Cluster ":"Smith \u0026 Nephew plc","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Greece","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"02\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$16,800,000.00","Criminal Fine\/Penalty (US$) ":"$16,800,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022Smith \u0026 Nephew Inc. has entered into a deferred prosecution agreement with the Department of Justice to resolve improper payments by the company and certain affiliates in violation of the Foreign Corrupt Practices Act (FCPA) [ ].  Smith \u0026 Nephew, a Delaware corporation, is headquartered in Memphis, Tenn., and is a wholly-owned subsidiary of Smith \u0026 Nephew plc, an English company traded on the New York Stock Exchange.  The company manufactures and sells medical devices worldwide.  Smith \u0026 Nephew acknowledged responsibility for the actions of its affiliates, subsidiaries, employees and agents who made various improper payments to publicly-employed health care providers in Greece from 1998 until 2008 to secure lucrative business.  According to the criminal information filed today in U.S. District Court in the District of Columbia in connection with the agreement, Smith \u0026 Nephew, through certain executives, employees and affiliates, agreed to sell products at full list price to a Greek distributor based in Athens, and then pay the amount of the distributor discount to an off-shore shell company controlled by the distributor. These off-the-books funds were then used by the distributor to pay cash incentives and other things of value to publicly-employed Greek health care providers to induce the purchase of Smith \u0026 Nephew products. In total, from 1998 to 2008, Smith \u0026 Nephew, its affiliates and employees authorized the payment of approximately $9.4 million to the distributor\u0027s shell companies, some or all of which was passed on to physicians to corruptly induce them to purchase medical devices manufactured by Smith \u0026 Nephew. [  ] The Justice Department acknowledges and expresses its appreciation for the assistance provided by the authorities of the 8th Ordinary Interrogation Department of the Athens Court of First Instance and the Athens Economic Crime Squad in Greece.\u0022  (Source: US Department of Justice Press Release, \u0022Medical Device Company Smith \u0026 Nephew Resolves Foreign Corrupt Practices Act Investigation,\u0022 February 6, 2012.)","Sources ":"US Department of Justice Press Release, \u0022Medical Device Company Smith \u0026 Nephew Resolves Foreign Corrupt Practices Act Investigation,\u0022 February 6, 2012, accessed at http:\/\/www.justice.gov\/opa\/pr\/2012\/February\/12-crm-166.html.","Documents":""},{"Case ID":"ST-333","Case Cluster ":"Solvochem Holland BV","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Rijksrecherche (Dutch Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Out of court settlement","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$447,219.00","Criminal Fine\/Penalty (US$) ":"$216,762","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$230,457","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"","Offenses - Settled":"Sanctions legislation by paying kickbacks when implementing UN Oil-for-Food Programme","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Netherlands Phase 2 Report of the OECD Anti-Bribery Working Group (December 17, 2008): \u0022As of October 2008, no foreign bribery cases had been brought before the Dutch courts. Nevertheless, the prosecution authorities have concluded out-of-court transactions with seven companies for paying kickbacks in the context of the Oil-for-Food Programme in Iraq, although the offence charged was the violation of sanctions legislation and not the foreign bribery offence.\u0022 (para 2); \u0022 the Prosecution Department reports that it has concluded financial transactions (out of court settlements) with 7 companies for violating sanction legislation by paying kickbacks when implementing the Oil for Food Programme. Criminal gains have also been confiscated. In July 2008 a press release has been issued about these settlements. Together with the names of the companies (Alfasan International B.V., N.V. Organon, Flowserve B.V. , OPW Fluid Transfer Group Europe B.V., Prodetra B.V. Solvochem Holland B.V., Stet Holland B.V.) the settlements have been made public. For the following Oil-for-food transactions out-of-court settlements have been reached: 1. Alfasan International BV Woerden, fine: \u20ac 31.800,-- and confiscation \u20ac 10.183,55 2. NV Organon Oss, fine: \u20ac 381.602 3. Flowerserve bv te Etten-Leur, fine: \u20ac 76.274 and confiscation \u20ac180.260 4. OPW Fluid Transfer Group Europe BV, Nieuw Vennep, fine \u20ac 57.204 and confiscation \u20ac 24.600 5. Prodetra bv,Wadinxveen, fine: 64.751 and confiscation \u20ac 34.485,95 6. Solvochem Holland bv, Rotterdam, fine \u20ac 136.000 and confiscation \u20ac 144.592 7. Stet Holland bv,Emmeloord, fine \u20ac 119.712 and confiscation \u20ac 54.458.\u0022 (Source: Ibid., at 14.)","Sources ":"Organisation for Economic Co-Operation and Development Anti-Bribery Working Group, The Netherlands Phase 2 Report (December 17, 2008), accessed at http:\/\/www.oecd.org\/dataoecd\/61\/59\/41919004.pdf; Melissa Lipman, \u0022Cos. Settle Dutch Probe Into Oil-For-Food For \u20ac1.3M,\u0022 Law 360, July 16, 2008, accessed at http:\/\/www.law360.com\/articles\/62486\/cos-settle-dutch-probe-into-oil-for-food-for-1-3m (partial article, gives date of Dutch Public Prosecution Service press release which is July 15, 2008.)","Documents":""},{"Case ID":"ST-334","Case Cluster ":"Statoil ASA","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iran","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"10\/13","Other Jurisdictions of Settlement":"Norway","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$10,500,000.00","Criminal Fine\/Penalty (US$) ":"$10,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022In 2001 and 2002, Statoil sought to expand its business internationally, and focused specifically on Iran as a country in which to secure oil and gas development rights. At the time, Iran was awarding contracts for the development of the South Pars field, one of the largest natural gas fields in the world. In 2001, Statoil developed contacts with an Iranian government official who was believed to have influence over the award of oil and gas contracts in Iran. Following a series of negotiations with the Iranian official in 2001 and 2002, Statoil entered into a -- consulting contract\u2016 with an offshore intermediary company. The purpose of that consulting contract -- which called for the payment of more than $15 million over 11 years -- was to induce the Iranian official to use his influence to assist Statoil in obtaining a contract to develop portions of the South Pars field and to open doors to additional Iranian oil and gas projects in the future. Two bribe payments totaling more than $5 million were actually made by wire transfer through a New York bank account, and Statoil was awarded a South Pars development contract that was expected to yield millions of dollars in profit.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Statoil ASA Case Summary at 112-113.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Statoil ASA Case Summary at 112-113, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Statoil ASA, Case No. 1:06-cv-00960-RJH-1 (SDNY), Information filed October 13, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/statoil-asa-inc\/10-13-09statoil-information.pdf; Deferred Prosecution Agreement accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/statoil-asa-inc\/10-09-06statoil-agree.pdf.  See also, US Dept. of Justice Press Release, \u0022U.S. Resolves Probe against Oil Company that Bribed Iranian Official,\u0022 October 13, 2006, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/October06\/statoildeferredprosecutionagreementpr.pdf.","Documents":""},{"Case ID":"ST-335","Case Cluster ":"Statoil ASA","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iran","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"10\/13","Other Jurisdictions of Settlement":"Norway","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits","Total Monetary Sanctions (US$)":"$10,500,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$10,500,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, False Accounting Violations, Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022In 2001 and 2002, Statoil sought to expand its business internationally, and focused specifically on Iran as a country in which to secure oil and gas development rights. At the time, Iran was awarding contracts for the development of the South Pars field, one of the largest natural gas fields in the world. In 2001, Statoil developed contacts with an Iranian government official who was believed to have influence over the award of oil and gas contracts in Iran. Following a series of negotiations with the Iranian official in 2001 and 2002, Statoil entered into a -- consulting contract\u2016 with an offshore intermediary company. The purpose of that consulting contract -- which called for the payment of more than $15 million over 11 years -- was to induce the Iranian official to use his influence to assist Statoil in obtaining a contract to develop portions of the South Pars field and to open doors to additional Iranian oil and gas projects in the future. Two bribe payments totaling more than $5 million were actually made by wire transfer through a New York bank account, and Statoil was awarded a South Pars development contract that was expected to yield millions of dollars in profit.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Statoil ASA Case Summary at 112-113.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Statoil ASA Case Summary at 112-113.  US Securities and Exchange Commission, In the Matter of Statoil ASA, Administrative Proceeding File No. 3-12453, Order Instituting Cease-and-Desist Proceedings, October 13, 2006, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2006\/34-54599.pdf","Documents":""},{"Case ID":"ST-336","Case Cluster ":"Statoil ASA","Jurisdiction of Settlement":"Norway","Jurisdiction of Settlement \/ Enforcement Agency":"\u00d8kokrim","Jurisdiction of Foreign Public Official(s) ":"Iran","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"06\/29","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Penalty Notice ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$3,000,000.00","Criminal Fine\/Penalty (US$) ":"$3,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Breach of trading influence (section 276c of the General Civil Penal Code); Bribery of Foreign Officials","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 OECD Phase 3 Report on Norway: \u0022A first case (\u201cthe Oil Company case\u201d) had been initiated at the time of the Phase 2 evaluation of Norway in 2004. \u00d8kokrim issued penalty notices to a large state-owned oil company, and a senior executive of the company. On 28 June 2004, \u00d8kokrim issued penalty notices to the oil company and the company\u201fs former executive Vice President. The Vice President had negotiated an agreement with a company registered in an off-shore jurisdiction, according to which the latter was to perform various consulting services for the oil company for an 11 year period. The oil company was to pay a total fee of USD 15.2 million for these alleged services. Payments were made to a foreign bank account in the name of a third company. In September 2003, following exposure by a Norwegian newspaper, the agreement was terminated. The real purpose of the agreement was to channel funds to a foreign citizen in return for his or others influencing individuals who were involved in decision-making relevant to the company\u201fs commercial activities in the foreign jurisdiction, including administrative acts concerning the awarding of contracts in the oil and gas sector. The advantage to be conferred according to the agreement was improper, notably because of the amount of the remuneration, and because the true purpose of the agreement was concealed. This consultancy contract was entered into in breach of the oil company\u201fs internal guidelines. The penalty notice stated that the senior executive failed to arrange for the termination of the agreement as soon as possible after the entering into force of the new Norwegian corruption legislation on 4 July 2003. The penalty notices describe the offences as a breach of the trading of influence statute (section 276c of the General Civil Penal Code) [ ]  The company\u201fs fine was in the amount of NOK 20 million (EUR 2.4 million; USD 3 million), and the vice president\u201fs NOK 200 000 (EUR 24 000). Both fines were accepted.15 As the oil company was listed on the New York Stock Exchange, it was also fined, in a deferred prosecution agreement, USD 10.5 million by the Department of Justice (out of which the USD 3 million already paid to Norway was deducted); the Securities and Exchange Commission further required the company to disgorge USD 10.5 million.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Norway,\u0022 June 2011, at 7-8.)","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Norway,\u0022 June 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/38\/59\/48286802.pdf, replace with  http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Norwayphase3reportEN.pdf ; Staoil Company Press Release, \u0022Statoil accepts \u00d8kokrim penalty in the Horton case,\u0022 October 14, 2004, accessed at http:\/\/www.statoil.com\/en\/NewsAndMedia\/News\/2004\/Pages\/StatoilAcceptsOkokrimPenaltyInTheHortonCase.aspx","Documents":""},{"Case ID":"ST-337","Case Cluster ":"Statoil ASA","Jurisdiction of Settlement":"Norway","Jurisdiction of Settlement \/ Enforcement Agency":"\u00d8kokrim","Jurisdiction of Foreign Public Official(s) ":"Iran","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"06\/29","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Penalty Notice ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$29,225.70","Criminal Fine\/Penalty (US$) ":"$29,225.70","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Breach of trading influence (section 276c of the General Civil Penal Code)","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 OECD Phase 3 Report on Norway: \u0022A first case (\u0022the Oil Company case\u0022) had been initiated at the time of the Phase 2 evaluation of Norway in 2004. \u00d8kokrim issued penalty notices to a large state-owned oil company, and a senior executive of the company. On 28 June 2004, \u00d8kokrim issued penalty notices to the oil company and the company\u0027s former executive Vice President. The Vice President had negotiated an agreement with a company registered in an off-shore jurisdiction, according to which the latter was to perform various consulting services for the oil company for an 11 year period. The oil company was to pay a total fee of USD 15.2 million for these alleged services. Payments were made to a foreign bank account in the name of a third company. In September 2003, following exposure by a Norwegian newspaper, the agreement was terminated. The real purpose of the agreement was to channel funds to a foreign citizen in return for his or others influencing individuals who were involved in decision-making relevant to the company\u0027s commercial activities in the foreign jurisdiction, including administrative acts concerning the awarding of contracts in the oil and gas sector. The advantage to be conferred according to the agreement was improper, notably because of the amount of the remuneration, and because the true purpose of the agreement was concealed. This consultancy contract was entered into in breach of the oil company\u0027s internal guidelines. The penalty notice stated that the senior executive failed to arrange for the termination of the agreement as soon as possible after the entering into force of the new Norwegian corruption legislation on 4 July 2003. The penalty notices describe the offences as a breach of the trading of influence statute (section 276c of the General Civil Penal Code) [ ]  The company\u0027s fine was in the amount of NOK 20 million (EUR 2.4 million; USD 3 million), and the vice president\u0027s NOK 200 000 (EUR 24 000). Both fines were accepted. [  ]  As the oil company was listed on the New York Stock Exchange, it was also fined, in a deferred prosecution agreement, USD 10.5 million by the Department of Justice (out of which the USD 3 million already paid to Norway was deducted); the Securities and Exchange Commission further required the company to disgorge USD 10.5 million.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Norway,\u0022 June 2011, at 7-8.)","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Norway,\u0022 June 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/38\/59\/48286802.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Norwayphase3reportEN.pdf; Staoil Company Press Release, \u0022Statoil accepts \u00d8kokrim penalty in the Horton case,\u0022 October 14, 2004, accessed at http:\/\/www.statoil.com\/en\/NewsAndMedia\/News\/2004\/Pages\/StatoilAcceptsOkokrimPenaltyInTheHortonCase.aspx","Documents":""},{"Case ID":"ST-338","Case Cluster ":"Stet Holland bv Emmeloord","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Rijksrecherche (Dutch Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Out of court settlement","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$277,599.30","Criminal Fine\/Penalty (US$) ":"$190,802","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$86,797","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Sanctions legislation by paying kickbacks when implementing UN Oil-for-Food Programme","Offenses - Settled":"Sanctions legislation by paying kickbacks when implementing UN Oil-for-Food Programme","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Netherlands Phase 2 Report of the OECD Anti-Bribery Working Group (December 17, 2008): \u0022As of October 2008, no foreign bribery cases had been brought before the Dutch courts. Nevertheless, the prosecution authorities have concluded out-of-court transactions with seven companies for paying kickbacks in the context of the Oil-for-Food Programme in Iraq, although the offence charged was the violation of sanctions legislation and not the foreign bribery offence.\u0022 (para 2); \u0022 the Prosecution Department reports that it has concluded financial transactions (out of court settlements) with 7 companies for violating sanction legislation by paying kickbacks when implementing the Oil for Food Programme. Criminal gains have also been confiscated. In July 2008 a press release has been issued about these settlements. Together with the names of the companies (Alfasan International B.V., N.V. Organon, Flowserve B.V. , OPW Fluid Transfer Group Europe B.V., Prodetra B.V. Solvochem Holland B.V., Stet Holland B.V.) the settlements have been made public. For the following Oil-for-food transactions out-of-court settlements have been reached: 1. Alfasan International BV Woerden, fine: \u20ac 31.800,-- and confiscation \u20ac 10.183,55 2. NV Organon Oss, fine: \u20ac 381.602 3. Flowerserve bv te Etten-Leur, fine: \u20ac 76.274 and confiscation \u20ac180.260 4. OPW Fluid Transfer Group Europe BV, Nieuw Vennep, fine \u20ac 57.204 and confiscation \u20ac 24.600 5. Prodetra bv,Wadinxveen, fine: 64.751 and confiscation \u20ac 34.485,95 6. Solvochem Holland bv, Rotterdam, fine \u20ac 136.000 and confiscation \u20ac 144.592 7. Stet Holland bv,Emmeloord, fine \u20ac 119.712 and confiscation \u20ac 54.458.\u0022 (Source: Ibid., at 14.)","Sources ":"OECD Anti-Bribery Working Group, The Netherlands Phase 2 Report (December 17, 2008), accessed at http:\/\/www.oecd.org\/dataoecd\/61\/59\/41919004.pdf; Melissa Lipman, \u0022Cos. Settle Dutch Probe Into Oil-For-Food For ?1.3M,\u0022 Law 360, July 16, 2008, accessed at http:\/\/www.law360.com\/articles\/62486\/cos-settle-dutch-probe-into-oil-for-food-for-1-3m (partial article, gives date of Dutch Public Prosecution Service press release.)","Documents":""},{"Case ID":"ST-339","Case Cluster ":"Switzerland \/ Individual Defendant X","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Switzerland, Unspecified Jurisdictions","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/02","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Summary Punishment Order","Monetary Sanctions  (Types)":"Criminal Fine, Suspended Criminal Fine","Total Monetary Sanctions (US$)":"$11,958.10","Criminal Fine\/Penalty (US$) ":"$11,958.10","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of Foreign Officails","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022On 17 February 2010, the Tax Administration of the Canton of Geneva advised the cantonal Office of the Attorney-General of illegal payments that had been made by a director of several Geneva hotels. Following this report, a case was opened by the Geneva Office of the Attorney-General. The investigation showed that between 2003 and 2007, X \u2013 a Swiss national \u2013 had paid intermediaries cash commissions totalling CHF 109 100 (approximately EUR 90 000) so that foreign diplomatic representations would choose to stay in his establishments. Examination of the accounting records of the companies operating the hotels showed in particular that CHF 48 000 had been paid in 2006-07 so that representatives of Office XY would stay in these establishments; that CHF 27 100 had been paid between 2003 and 2007 so that customers from consulate XY and permanent mission XY would stay there; and that CHF 34 000 had been paid so that customers connected with mission XY would stay there. The investigation determined that the payment of these commissions had enabled the hotels in question to generate turnover of CHF 1.5 million (or approximately EUR 1.2 million).  When questioned by the Geneva law enforcement authorities, the defendant acknowledged having paid commissions to attract customers, while contending that the customers brought in by the commissions had not, in his opinion, been members of official representations. The prosecutor in the case deemed, however, that a review of the accounting documents in evidence clearly showed that the customers were in fact official representatives, that a 2009 letter clearly indicated that the accused habitually paid commissions to foreign officials and lastly, that it made little difference whether the intermediaries receiving the commissions did not work formally for the various foreign missions insofar as a purpose of the commissions was to attract diplomatic clientele. The Geneva law enforcement authorities also rejected the defendant\u2018s contention that the payment of commissions to foreign public officials was a recurring practice in the hotel industry. After taking account of the defendant\u0027s lack of a criminal record and his personal and economic circumstances, and considering that the deeds of which he was accused were not serious enough to take the accused to trial, X was sentenced by Summary punishment order to a suspended fine of CHF 49 500 (approximately EUR 41 000), three years\u2018 probation and a fine of CHF 12 000 (approximately EUR 10 000).\u0022 (Source:  Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 54 and citing as its source Summary Punishment Order of the Attorney-General of the Republic and Canton of Geneva, 2 December 2010.).  The suspended fine has not been included in the monetary total for this entry.","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with: http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-340","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 1 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Criminal Confiscation","Total Monetary Sanctions (US$)":"$19,844,400.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$19,844,400","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-341","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 10 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"Unknown","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-342","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 11 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"Unknown","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-343","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 2 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"Unknown","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-344","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 3 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"Unknown","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-345","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 4 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"Unknown","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-346","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 5 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"Unknown","Criminal Fine\/Penalty (US$) ":"Unknown","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-347","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 6 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"Unknown","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with  http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-348","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 7 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"Un","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, repalce with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-349","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 8 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"Unknown","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-350","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 9 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"Unknown","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-351","Case Cluster ":"Syncor International Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Taiwan, China","Year of Settlement":"2002","Month\/Day of Settlement (or Notes)":"12\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil (Administrative Order)","Legal Form of Settlement":"Consent to Cease-and-Desist Order ","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$500,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$500,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Syncor International Corporation, at 79-80, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf:  Misconduct in Taiwan, 1997-2002; Criminal and civil charges stemmed from (1) series of payments totalling at least $344,110 in \u0022commissions\u0022 by Syncor and its employees to physicians employed by hospitals owned by the legal authorities in Taiwan for the purpose of obtaining and retaining business from the hospitals and in connection with the purchase and sale of unit dosages of certain radiopharmaceuticals.  Monty Fu, Syncor Taiwan\u0027s founder and board chairman authorized the payments and (2) at least $113,007 in improper payments (1998-2002) authorized by Fu and made by Syncor Taiwan to physicians employed at hospitals owned by the legal authorities in Taiwan in exchange for their referrals of patients to medical imaging centers owned and operated by Syncor. Settlement amounts: criminal fine of $2 million (Syncor); Civil: $500,000 civil penalty (Syncor), $75,000 civil penalty (Fu).  Resulting criminal enforcement actions: US v. Syncor Taiwan, Inc. (C.D. Cal., December 4, 2002); Civil: SEC v. Monty Fu (D.D.C., September 27, 2008), SEC v. Syncor International Corporation (D.D.C., December 10, 2002), In the Matter of Syncor International Corporation (December 10, 2002).  The SEC Litigation Release acknowledged the investigative assistance by the Taiwan Taipei Prosecutors Office. ","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Syncor International Corporation at 79-80, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.  US v. Syncor International Corporation (D.D.C.), Complaint filed December 10, 2002, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/comp17887.htm; Add http:\/\/www.sec.gov\/litigation\/litreleases\/lr17887.htm US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Syncor International Corporation Case Summary at 95-96, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-352","Case Cluster ":"Syncor International Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Taiwan, China","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"09\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$75,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$75,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"False Accounting Violations, Aiding and Abetting Internal Controls Violations, Aiding and Abetting Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Syncor International Corporation, at 79-80, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf:  Misconduct in Taiwan, 1997-2002; Criminal and civil charges stemmed from (1) series of payments totalling at least $344,110 in \u0022commissions\u0022 by Syncor and its employees to physicians employed by hospitals owned by the legal authorities in Taiwan for the purpose of obtaining and retaining business from the hospitals and in connection with the purchase and sale of unit dosages of certain radiopharmaceuticals.  Monty Fu, Syncor Taiwan\u0027s founder and board chairman authorized the payments and (2) at least $113,007 in improper payments (1998-2002) authorized by Fu and made by Syncor Taiwan to physicians employed at hospitals owned by the legal authorities in Taiwan in exchange for their referrals of patients to medical imaging centers owned and operated by Syncor. Resulting civil enforcement actions: SEC v. Monty Fu (D.D.C., September 27, 2008), SEC v. Syncor International Corporation (D.D.C., December 10, 2002), In the Matter of Syncor International Corporation (December 10, 2002).  The SEC Litigation Release acknowledged the investigative assistance by the Taiwan Taipei Prosecutors Office. ","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Syncor International Corporation at 79-80, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.  US v. Monty Fu, Case No. 1:07-cv-01735 (D.D.C.), Complaint filed September 27, 2007, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2007\/comp20310.pdf; And SEC press release http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20310.htmUS Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Syncor International Corporation Case Summary at 95-96, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-353","Case Cluster ":"Syncor International Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Taiwan, China","Year of Settlement":"2002","Month\/Day of Settlement (or Notes)":"12\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,000,000.00","Criminal Fine\/Penalty (US$) ":"$2,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Syncor International Corporation, at 79-80, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf:  Misconduct in Taiwan, 1997-2002; Criminal and civil charges stemmed from (1) series of payments totalling at least $344,110 in \u0022commissions\u0022 by Syncor and its employees to physicians employed by hospitals owned by the legal authorities in Taiwan for the purpose of obtaining and retaining business from the hospitals and in connection with the purchase and sale of unit dosages of certain radiopharmaceuticals.  Monty Fu, Syncor Taiwan\u0027s founder and board chairman authorized the payments and (2) at least $113,007 in improper payments (1998-2002) authorized by Fu and made by Syncor Taiwan to physicians employed at hospitals owned by the legal authorities in Taiwan in exchange for their referrals of patients to medical imaging centers owned and operated by Syncor. Settlement amounts: criminal fine of $2 million (Syncor; noted in the DOJ press release as maximum penalty under FCPA); Civil: $500,000 civil penalty (Syncor), $75,000 civil penalty (Fu).  Resulting criminal enforcement actions: US v. Syncor Taiwan, Inc. (C.D. Cal., December 4, 2002.","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Syncor International Corporation at 79-80, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.  US v. Syncor Taiwan, Inc., Case No. 2-cr-12441 (C.D. Cal.), Information filed December 4, 2002; Plea Agreement dated December 4, 2002, accessed at ; http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/syncor-taiwan\/12-03-02syncor-taiwan-plea-agree.pdf; US Department of Justice Press Release, \u0022Syncor Taiwan, Inc. Pleads Guilty to Violating the Foreign Corrupt Practices Act,\u0022 December 10, 2002, accessed at  http:\/\/www.justice.gov\/opa\/pr\/2002\/December\/02_crm_707.htm; US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Syncor International Corporation Case Summary at 95-96, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-354","Case Cluster ":"Tanner Management Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"None (Sting Operation)","Year of Settlement":"1998","Month\/Day of Settlement (or Notes)":"08\/05","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$15,000.00","Criminal Fine\/Penalty (US$) ":"$15,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"No (Sting Operation) ","Summary":"According to the June 2011 US Report to the OECD, \u0022On March 24, 1998, Herbert Tannenbaum was arrested pursuant to a criminal complaint filed in the Southern District of New York, which charged him with conspiracy to violate the anti-bribery provisions of the FCPA. A one-count information, charging Tannenbaum with conspiracy to violate the FCPA, was subsequently filed on July 23, 1998. According to court documents, Tannenbaum, as President of Tanner Management Corporation, offered to make secret payments totaling 15% of the contract value to an undercover agent posing as a procurement officer of the Government of Argentina in order to induce the agent to purchase garbage incinerators. According to the plea agreement, the offered bribe totaled between $120,000 and $200,000. As part of the conspiracy and in an attempt to disguise the secret payment, Tannenbaum incorporated a fictitious entity named Cybernet USA and opened a bank account in the same name.  Tannenbaum pleaded guilty on August 5, 1998, and, pursuant to a plea agreement with the United States, was sentenced to a prison term of 1 year and 1 day, to be followed by 3 years of supervised release.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Tanner Management Corporation Case Summary at 135-36.)  According to the Judgment in his case, Mr. Tannenbaum was ordered to pay $15,000 in criminal fine. (Source: US v. Tannenbaum, Case No. 1:98-cr-784-TPG (S.D.N.Y.), Judgment in a criminal case dated March 19, 1999.)  The US Department of Justice Press Release stated that, \u0022According to the information, Tannenbaum helped incorporate and open a bank account in the name of Cybernet USA, a fictitious entity, to disguise the payment to the undercover agent.  During the investigation, the Argentine Ministry of Justice cooperated with the Department.\u0022 (Source: US Department of Justice Press Release, \u0022Long Island Man Pleads Guilty to Violating Foreign Corrupt Practices Act,\u0022 August 5, 1998.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Tanner Management Corporation Case Summary at 135-36, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Tannenbaum, Case No. 1:98-cr-784-TPG (S.D.N.Y.), Information of July 23, 1998, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tannenbaum\/07-23-98tannenbaum-info.pdf; Plea Agreement signed August 5, 1998, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tannenbaum\/06-23-98tannenbaum-plea-agree.pdf; Judgment in a criminal case dated March 19, 1999, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tannenbaum\/03-19-99tannenbaum-judgment.pdf; US Department of Justice Press Release, \u0022Long Island Man Pleads Guilty to Violating Foreign Corrupt Practices Act,\u0022 August 5, 1998, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tannenbaum\/08-05-98tannenbaum-pressrelease.pdf","Documents":""},{"Case ID":"ST-264","Case Cluster ":"Macmillan Publishers Limited","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Zambia, Rwanda, Uganda","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"07\/22","Other Jurisdictions of Settlement":"World Bank","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Civil Recovery Order (Proceeds of Crime Act) ","Monetary Sanctions  (Types)":"Civil Recovery Order, Legal Costs","Total Monetary Sanctions (US$)":"$18,298,658.80","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$18,254,901","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"$43,758","Other Civil Monetary Sanctions (Explanation)":"Legal Costs","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Sums derived from unlawful conduct","Offenses - Settled":"Sums derived from unlawful conduct ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a UK Serious Fraud Office press release, on July 22, 2011, the SFO obtained a Civil Recovery Order through the High Court in which Macmillan Publishers Limited will pay GBP 11,263,852.28 and also pay the SFO costs of pursuing the order which amount to GBP 27,000 (US$ 43,757.80).  The SFO acted on a referral from the World Bank regarding a World Bank tender to supply educational materials in Southern Sudan. The SFO, in cooperation with the City of London Police and the World Bank selected the three jurisdictions - Rwanda, Uganda and Zambia - in relation to which it would require the company\u0027s external lawyers to conduct detailed investigations into all public tender contracts in these three jurisdictions over the period of 2002-2009 whether funded by the World Bank or otherwise. These jurisdictions fell within the business activities of Macmillan\u0027s Education Division in East and West Africa. The press release stated that \u0022It was impossible to be sure that the awards of tender to the Company in the three jurisdictions were not accompanied by a corrupt relationship.\u0022  Richard Alderman, the then-Director of the SFO stated,\u0022Civil recovery allows us to deal with certain cases of corporate wrong-doing effectively. It delivers value for money to the public by saving the cost of lengthy investigations and protracted legal proceedings and removes any property obtained as a result of wrong-doing. At the same time it forces the company to reform its practices for the future.\u0022 (Source: UK Serious Fraud Office Press Release, \u0022Action on Macmillan Publishers Limited,\u0022 July 22, 2011, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2011\/action-on-macmillan-publishers-limited.aspx.)","Sources ":"UK Serious Fraud Office Press Release, \u0022Action on Macmillan Publishers Limited,\u0022 July 22, 2011, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2011\/action-on-macmillan-publishers-limited.aspx; MacMillan Press Release, \u0022MacMillan Publishers Ltd concludes co-operative process with SFO,\u0022 July 22, 2011, accessed at http:\/\/international.macmillan.com\/MediaArticle.aspx?id=3046\u0026SearchURL=http:--slh----slh--international.macmillan.com--slh--MediaCentreResults.aspx--Qst--Page=1--amp--SearchString=world%20bank;  United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf","Documents":""},{"Case ID":"ST-265","Case Cluster ":"Macmillan Publishers Limited","Jurisdiction of Settlement":"","Jurisdiction of Settlement \/ Enforcement Agency":"Integrity Vice Presidency","Jurisdiction of Foreign Public Official(s) ":"Southern Sudan","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"04\/30","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Debarment","Monetary Sanctions  (Types)":"None ","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Payment of bribery","Offenses - Settled":"Payment of bribery","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a World Bank Press Release of July 22, 2011 welcoming the UK Serious Fraud Office\u0027s announcement to order Macmillan Publishers Limited to pay penalties, \u0022In April 2010, the World Bank Group debarred Macmillan Limited, a U.K. company, declaring the company ineligible to be awarded Bank-financed contracts for a period of six years in the wake of the company\u0027s admission of bribery payments relating to a Trust Fund-supported education project in Sudan. [ ] Following the INT investigation, the World Bank referred its findings to the UK authorities, which launched their own investigation.\u0022  (Source: The World Bank Press Release, \u0022World Bank Applauds Action by the UK Serious Fraud Office in Relation to Bribery Charges Against Macmillan Publishers Limited In An Education Project in Sudan,\u0022 Press Release No:2012\/038\/INT, July 22, 2011.)","Sources ":"The World Bank Press Release, \u0022World Bank Applauds Action by the UK Serious Fraud Office in Relation to Bribery Charges Against Macmillan Publishers Limited In An Education Project in Sudan,\u0022 Press Release No:2012\/038\/INT, July 22, 2011, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,contentMDK:22967949~pagePK:34370~piPK:34424~theSitePK:4607,00.html; UK Serious Fraud Office Press Release, \u0022Action on Macmillan Publishers Limited,\u0022 July 22, 2011, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2011\/action-on-macmillan-publishers-limited.aspx; Mark Tran, \u0022Macmillan ordered to pay $17m for corruption in Southern Sudan,\u0022 The Guardian, July 25, 2011, at http:\/\/www.guardian.co.uk\/global-development\/2011\/jul\/25\/macmillan-education-deal-south-sudan\/print (accessed on September 12, 2011)http:\/\/www.guardian.co.uk\/global-development\/2011\/jul\/25\/macmillan-education-deal-south-sudan?INTCMP=SRCH;     MacMillan Press Release, \u0022MacMillan Publishers Ltd concludes co-operative process with SFO,\u0022 July 22, 2011, accessed at http:\/\/international.macmillan.com\/MediaArticle.aspx?id=3046\u0026SearchURL=http:--slh----slh--international.macmillan.com--slh--MediaCentreResults.aspx--Qst--Page=1--amp--SearchString=world%20bank. (not a functioning link)","Documents":""},{"Case ID":"ST-266","Case Cluster ":"MAN","Jurisdiction of Settlement":"","Jurisdiction of Settlement \/ Enforcement Agency":"Munich Public Prosecution Office","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"12\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Administrative Offences Act","Monetary Sanctions  (Types)":"Fine, Confiscation of Profits","Total Monetary Sanctions (US$)":"$110,859,672.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$110,418,000","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"$441,672","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Sections 130 and 30 OWiG","Offenses - Settled":"Sections 130 and 30 OWiG","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to the March 2011 Germany Phase 3 Report to the OECD, \u0022iv) Decision of Munich I Public Prosecution office of 10 December 2009 pursuant to sections 130 and 30 OWiG - against the Trucks unit of MAN - Fine of EUR 75.3 million (see Annual report 2009 Bavaria (d) and Germany\u0027s reply to Phase 3 questionnaires), hereinafter Case \u0022Trucks Unit of MAN\u0022 (Source: Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at footnote 49.)","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-267","Case Cluster ":"MAN","Jurisdiction of Settlement":"","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"12\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Administrative Offences Act","Monetary Sanctions  (Types)":"Fine, Confiscation of Profits","Total Monetary Sanctions (US$)":"$110,859,672.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$110,418,000","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"$441,672","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Section 30 OWiG in connection with sections 334 and 299 Criminal Code","Offenses - Settled":"Section 30 OWiG in connection with sections  334 and 299 Criminal Code","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to the March 2011 Germany Report to the OECD, \u0022v) Decision of a Munich I Regional Court of 10 December 2009 pursuant to section 30 OWiG in conjunction with sections 334 and 299 CC - against the Turbo engines Unit of MAN - Fine of EUR 75.3 million, hereinafter Case ?Turbo engines Unit of MAN\u0022 (Source: Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at footnote 49.)","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-268","Case Cluster ":"Maxwell Technologies Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; United States Attorney for the Southern District of California","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"1\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$8,000,000.00","Criminal Fine\/Penalty (US$) ":"$8,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Deferred Prosecution Agreement, Maxwell Technologies accepted the following Statement of Facts:  the company\u0027s wholly-owned subsidiary Maxwell Technologies S.A. (incorporated and headquartered in Switzerland) manufactured and sold high-voltage capacitors in several countries, inclding China.  \u0022Agent 1,\u0022 a Chinese national, was a third-party agent responsible for Maxwell S.A.\u0027s Chinese customers (listed in the Statement of Facts as (1) Pinggao Group Co. Ltd, a state-owned manufacturer of electric-utility infrastructure in Henan Province, (2) New Northeast Electric Shenyang HV Switchgear Co., Ltd., a state-owned manufacturer of electric-utility infrastructure in Liaoning Province, and (3) Xi-an XD High Voltage Apparatus Co., Ltd., a state-owned manufacturer of eletric-utility infrastructure in Shaanxi Province.  From at least 2002 to 2009, Maxwell and its subsidiaries paid approximately $2,789,131 to Agent 1 to be distributed to Chinese foreign officials, in return for securing contracts that profited Maxwell, namely by using a kick-back scheme in which Agent 1 requested quotes from Maxwell S.A. on behalf of prospective Chinese state-owned entities and then upon Agent 1\u0027s instruction, Maxwell S.A. added an \u0022extra\u0022 20 percent to the quoted amounts to arrive at a higher price for Maxwell S.A.\u0027s equipment.  Maxwell S.A. then invoiced the Chinese state-owned entities for equipment at the higher-priced rate, which the entities paid. Agent 1 distributed the \u0022extra amounts\u0022 to officials at the Chinese state-owned entities, including employees at Pinggao Group, shenyang HV, and Xi-an XD. (Source: US x. Maxwell Technologies, Inc., Case no. 3:11-cr-00329-JM (C.D. Cal.), Deferred Prosecution Agreement and Appendix A: Statement of Facts, filed January 31, 2011). ","Sources ":"US v. Maxwell Technologies, Inc., Case No. 11-cr-329-JM (D.D.C. 2011), Information filed January 31, 2011 and Deferred Prosecution Agreement (and Appensix A: Statement of Facts), filed January 31, 2011, both accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/maxwell-tech.html; SEC v. Maxwell Technologies, Inc., Case No. 1:11-cv-00258 (D.D.C.), Complaint filed January 31, 2011, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp21832.pdf;   U.S. Securities and Exchange Commission, Litigation Release No. 21832 \/ January 31, 2011, U.S. Securities and Exchange Commission v. Maxwell Technologies Inc., Civil Action No. 1:11-CV-00258 (DDC) (BAH), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr21832.htm.","Documents":""},{"Case ID":"ST-269","Case Cluster ":"Maxwell Technologies Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"01\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$6,350,890.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$5,654,576","Civil Prejudgment Interest (US$) ":"$696,314","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, improper internal controls, books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Deferred Prosecution Agreement, Maxwell Technologies accepted the following Statement of Facts:  the company\u0027s wholly-owned subsidiary Maxwell Technologies S.A. (incorporated and headquartered in Switzerland) manufactured and sold high-voltage capacitors in several countries, including China.  \u0022Agent 1,\u0022 a Chinese national, was a third-party agent responsible for Maxwell S.A.\u0027s Chinese customers (listed in the Statement of Facts as (1) Pinggao Group Co. Ltd, a state-owned manufacturer of electric-utility infrastructure in Henan Province, (2) New Northeast Electric Shenyang HV Switchgear Co., Ltd., a state-owned manufacturer of electric-utility infrastructure in Liaoning Province, and (3) Xi-an XD High Voltage Apparatus Co., Ltd., a state-owned manufacturer of eletric-utility infrastructure in Shaanxi Province.  From at least 2002 to 2009, Maxwell and its subsidiaries paid approximately $2,789,131 to Agent 1 to be distributed to Chinese foreign officials, in return for securing contracts that profited Maxwell, namely by using a kick-back scheme in which Agent 1 requested quotes from Maxwell S.A. on behalf of prospective Chinese state-owned entities and then upon Agent 1\u0027s instruction, Maxwell S.A. added an \u0022extra\u0022 20 percent to the quoted amounts to arrive at a higher price for Maxwell S.A.\u0027s equipment.  Maxwell S.A. then invoiced the Chinese state-owned entities for equipment at the higher-priced rate, which the entities paid. Agent 1 distributed the \u0022extra amounts\u0022 to officials at the Chinese state-owned entities, including employees at Pinggao Group, shenyang HV, and Xi-an XD. (Source: US x. Maxwell Technologies, Inc., Case no. 3:11-cr-00329-JM (C.D. Cal.), Deferred Prosecution Agreement and Appendix A: Statement of Facts, filed January 31, 2011).  ","Sources ":"US v. Maxwell Technologies, Inc., Case No. 11-cr-329-JM (D.D.C. 2011), Information filed January 31, 2011 and Deferred Prosecution Agreement (and Appendix A: Statement of Facts), filed January 31, 2011, both accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/maxwell-tech.html; SEC v. Maxwell Technologies, Inc., Case No. 1:11-cv-00258 (D.D.C.), Complaint filed January 31, 2011, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp21832.pdf;   U.S. Securities and Exchange Commission, Litigation Release No. 21832 \/ January 31, 2011, U.S. Securities and Exchange Commission v. Maxwell Technologies Inc., Civil Action No. 1:11-CV-00258 (DDC) (BAH), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr21832.htm.","Documents":""},{"Case ID":"ST-270","Case Cluster ":"Metcalf \u0026 Eddy International, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Egypt","Year of Settlement":"1999","Month\/Day of Settlement (or Notes)":"12\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty, Legal Costs","Total Monetary Sanctions (US$)":"$450,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$400,000","Other Civil Monetary Sanctions (US$)":"$50,000","Other Civil Monetary Sanctions (Explanation)":"Legal Costs","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Metcalf \u0026 Eddy International, Inc. at 123: On December 14, 1999, the Department of Justice initiated a settled civil enforcement action against Metcalf \u0026 Eddy International, Inc. in connection with a 1994 trip the company paid for the Chairman (of the Alexandria General Organization for Sanitary Drainage (AGOSD), an Egyptian government agency responsible for wastewater and sewage treatment in Alexandria, Egypt) and his family to Boston, Paris, and San Diego and \u0022per diem\u0022 payments given to him in advance in Alexandria. \u0022In exchange, the Chairman exerted influence over the board in charge of awarding these contracts and recommended that M\u0026E be given $36 million contracts, which were funded by the U.S. Agency for International Development.\u0022  On December 14, 1999, without admitting or denying the Department\u0027s allegations, M\u0026E consented to an injunction to pay a fine of $400,000 and costs of investigation of $50,0000, and to be permanently enjoined from FCPA violations.  According to the Court Docket Report in US v. Metcalf \u0026 Eddy International, Inc. Case No. 1;99-cv-12566-NG, the judgment was entered for USA against Metcalf \u0026 Eddy on December 17, 1999; a copy of the judgment (and the other case documents) are not available online via Pacer.  (Court Docket Report retrieved on October 19, 2011.) ","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Metcalf \u0026 Eddy International, Inc. at 123, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; Court Docket Report in US v. Metcalf \u0026 Eddy International, Inc. Case No. 1;99-cv-12566-NG, the judgment was entered for USA against Metcalf \u0026 Eddy on December 17, 1999; a copy of the judgment (and the other case documents) are not available online via Pacer.  (Court Docket Report retrieved on October 19, 2011.) ","Documents":""},{"Case ID":"ST-271","Case Cluster ":"Micrus Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"France, Germany, Spain, Turkey","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"02\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$450,000.00","Criminal Fine\/Penalty (US$) ":"$450,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations","Offenses - Settled":"Bribery of foreign officials, Internal controls violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice\u0027s Press Release on its settlement agreement with the Micrus Corporation and its Swiss subsidiary Micrus S.A., \u0022The investigation by the Department revealed that Micrus, through the conduct of certain officers, employees, agents and salespeople paid more than $105,000 - disguised in Micrus\u0027s books and records as stock options, honorariums and commissions - to doctors employed at publicly owned and operated hospitals in [France, Turkey, Spain and Germany] in return for the hospitals\u0027 purchase of embolic coils from Micrus. An additional $250,000 was comprised of payments for which Micrus did not obtain the necessary prior administrative or legal approval, as required under the laws of the relevant foreign jurisdiction.\u0022  (Source: US Department of Justice Press Release, \u0022Micrus Corporation Enters into Agreement to Resolve Potential Foreign Corrupt Practices Act Liability,\u0022 March 2, 2005.) ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Micrus Corporation Case Summary at 121-122, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Department of Justice Press Release, \u0022MICRUS CORPORATION ENTERS INTO AGREEMENT TO RESOLVE POTENTIAL FOREIGN CORRUPT PRACTICES ACT LIABILITY,\u0022 March 2, 2005, accessed at http:\/\/www.justice.gov\/opa\/pr\/2005\/March\/05_crm_090.htm; In Re: Micrus Corporation, Non-Prosecution Agreement (dated February 28, 2005), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/micrus-corp\/02-28-05micrus-agree.pdf","Documents":""},{"Case ID":"ST-272","Case Cluster ":"Midway Trading","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"New York County District Attorney\u0027s Office","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"10\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$250,000.00","Criminal Fine\/Penalty (US$) ":"$250,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art.2","Offenses - Alleged":"Grand Larceny","Offenses - Settled":"Grand Larceny","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the New York County District Attorney\u0027s Office Press Release on October 20, 2005, \u0022Manhattan District Attorney Robert M. Morgenthau announced today the guilty plea of a Reston, Virginia-based oil trading company for its involvement in a scheme to pay kickbacks to Iraq in connection with oil purchases made under the United Nations Oil-for-Food Program.  MIDWAY TRADING (MIDWAY) pleaded guilty in New York State Court to Grand Larceny in the First Degree in connection with the scheme. According to the charges, Midway and one of its trading partners, Bulf Oil, paid more than $440,000 in kickbacks to Iraqi officials in connection with oil purchases but falsely represented to the United Nations that no kickbacks were paid. Relying on those false representations, United Nations officials approved the contracts and authorized millions of dollars in payments for the benefit of Iraq from the Oil-for-Food Program. MIDWAY will pay a fine of $250,000, with $100,000 due by December 1, 2005. The plea by MIDWAY is part of a continuing investigation by the Manhattan District Attorney\u0027s Office into the Oil-for-Food Program. This investigation began as a result of this office\u0027s cooperation with the Independent Inquiry Committee into the United Nations Oil-for-Food Program, headed by Paul Volker.[  ]  Through its attorney, MIDWAY OIL admitted in court that in late 2000, the company purchased the right to lift oil from Iraq under the United Nations Oil-for-Food Program from Bulf Oil, a Romanian oil company. Under United Nations resolutions, all money paid for the purchase of Iraqi crude oil was deposited into a UN trust account at a branch of BNP Paribas, a French bank, in Manhattan. Payments from the trust account, including payments for so-called \u0022humanitarian goods\u0022 to be sent to Iraq, had to be authorized by United Nations officials. No money for the purchase of crude oil from Iraq was to go directly to Iraq.  Under its initial $42 million agreement with Bulf, MIDWAY was to provide financing for the purchase cost of the Iraqi crude oil and to share any profits from MIDWAY\u0027s subsequent sale of that crude oil. An employee of Bulf Oil asked MIDWAY to pay him an additional 25 cents per barrel, an extra payment that MIDWAY did not make, at first.  MIDWAY sold the Iraqi crude oil lift to Texaco Corp., which, in turn, sold the crude oil lift to British Petroleum (\u0027BP\u0027). MIDWAY provided BP with a price guarantee. On March 28, 2001, a ship chartered by BP arrived at the Turkish Port of Ceyhan, but was not allowed to lift the oil. On April 1, 2001, MIDWAY wired $225,000 from an account at SunTrust Bank in Virginia to the Jordan National Bank\u0027s correspondent bank account at Chase Manhattan Bank in New York for the benefit of an account in name of the Bulf employee. The $225,000 was the approximate equivalent of the 25 cent per barrel kickback that the Bulf employee had asked for. On April 2nd and 3rd, the oil was loaded onto BP\u0027s ship. MIDWAY later learned that the money wired to the Jordan National Bank was for the benefit of Iraqi government officials and that the \u0027surcharge\u0027 had to be paid as a precondition for oil to be loaded. As a consequence of the price guarantee given to BP and the delay in lifting the oil, MIDWAY lost $ 1 million on this initial transaction.  In September, 2001, MIDWAY acquired the remainder of Bulf Oil\u0027s allocation of oil, at a purchase price of $22 million, under the Oil-for-Food Program. This time, prior to the lift of oil, MIDWAY wired $215,442.25 to Jordan National Bank\u0027s correspondent account at Chase Manhattan Bank in New York in the name of an agent of MIDWAY\u0027s. Midway knew that, as in the first transaction, the money wired to the Jordan National Bank account was, in fact, a kickback to be paid to Iraqi officials, in violation of United Nations Security Council Resolution 986. MIDWAY did not inform the UN about its payment to the Jordan National Bank. And, as MIDWAY knew, Bulf Oil\u0027s contract for the purchase of Iraqi oil falsely represented that all of the United Nations Security Council resolutions had been complied with. The second lift went smoothly and Midway profited approximately $375,000 from the sale of the crude oil.  The contract purchase price for the oil, $22 million, was paid into the United Nations trust account for the Oil-for-Food Program. Subsequently, relying on the false representations that no kickbacks had been paid, United Nations officials authorized the disbursement from the account of a like amount, less fees and administrative costs, for various purposes in accordance with program regulations. This included $13 million in payments for goods to be sent to Iraq.\u0022 (Source:  New York County District Attorney\u0027s Office, News Release on Midway Trading Plea, October 20,2005.)","Sources ":"New York County District Attorney\u0027s Office, News Release on Midway Trading Plea, October 20,2005, accessed at http:\/\/manhattanda.client.tagonline.com\/whatsnew\/press\/2005-10-20.shtml; New York County District Attorney\u0027s Office, News Release on Vitol SA Plea, November 20, 2007, accessed at http:\/\/manhattanda.client.tagonline.com\/whatsnew\/press\/2007-11-20.shtml; http:\/\/www.nysun.com\/new-york\/morgenthau-gains-a-plea-of-guilty-in-un-scandal\/21880\/","Documents":""},{"Case ID":"ST-273","Case Cluster ":"Monsanto Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Indonesia","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"01\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,000,000.00","Criminal Fine\/Penalty (US$) ":"$1,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records","Offenses - Settled":"Bribery of Foreign Officials, Falsification of Books and Records","Public Procurement Contract \/ SOE Involved?":"No (License)","Summary":"According to the June 2011 United States Report to the OECD, \u0022Monsanto, a producer of various agricultural products, hired an Indonesian consulting company to assist it in obtaining various Indonesian governmental approvals and licenses necessary to sell its genetically modified products in Indonesia. At the time, the Indonesian government required an environmental impact study before authorizing the cultivation of genetically modified crops. After a change in governments in Indonesia, Monsanto sought, unsuccessfully, to have the new government, in which the senior environment official had a post, amend or repeal the requirement for the environmental impact statement. Having failed to obtain the senior environment official\u0027s agreement to amend or repeal this requirement, in 2002, Charles Martin, the Government Affairs Director for Asia for Monsanto, authorized and directed an Indonesian consulting firm to make an illegal payment totaling $50,000 to the senior environment official to \u0022incentivize\u0022 him to agree to do so. Martin also directed representatives of the Indonesian consulting company to submit false invoices to Monsanto for \u0022consultant fees\u0022 to obtain reimbursement for the bribe, and agreed to pay the consulting company for taxes that company would owe by reporting income from the \u0022consultant fees.\u0022  In February 2002, an employee of the Indonesian consulting company delivered $50,000 in cash to the senior environment official, explaining that Monsanto wanted to do something for him in exchange for repealing the environmental impact study requirement. The senior environment official promised that he would do so at an appropriate time. In March 2002, Monsanto, through its Indonesian subsidiary, paid the false invoices thus reimbursing the consulting company for the $50,000 bribe, as well as the tax it owed on that income. A false entry for these \u0022consulting services\u0022 was included in Monsanto\u0027s books and records. The senior environment official never authorized the repeal of the environmental impact study requirement.\u0022 (Source: .US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Monsanto Company Case Summary at 108-109.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Monsanto Company Case Summary at 108-109, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Monsanto Company, (D.D.C. 2005), Information filed January 6, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/monsanto-co\/01-06-05monsanto-info.pdf;  Deferred Prosecution Agreement and Statement of Facts filed January 6, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/monsanto-co\/01-06-05monsanto-agree.pdf; Order Approving the Deferred Prosecution Agreement filed March 16, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/monsanto-co\/03-16-05monsanto-order-dpa.pdf.  See also, US Department of Justice Press Release. \u0022Monsanto Company Charged with Bribing Indonesian Government Official: Prosecution Deferred for Three Years.\u0022 Jan. 6, 2005, accessed at http:\/\/www.justice.gov\/opa\/pr\/2005\/January\/05_crm_008.htm","Documents":""},{"Case ID":"ST-274","Case Cluster ":"Monsanto Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"01\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment, Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$500,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$500,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Internal Controls Violations, Falsification of Books and Records, False Accounting","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (License)","Summary":"According to the June 2011 United States Report to the OECD, \u0022Monsanto, a producer of various agricultural products, hired an Indonesian consulting company to assist it in obtaining various Indonesian governmental approvals and licenses necessary to sell its genetically modified products in Indonesia. At the time, the Indonesian government required an environmental impact study before authorizing the cultivation of genetically modified crops. After a change in governments in Indonesia, Monsanto sought, unsuccessfully, to have the new government, in which the senior environment official had a post, amend or repeal the requirement for the environmental impact statement. Having failed to obtain the senior environment official\u0027s agreement to amend or repeal this requirement, in 2002, Charles Martin, the Government Affairs Director for Asia for Monsanto, authorized and directed an Indonesian consulting firm to make an illegal payment totaling $50,000 to the senior environment official to \u0022incentivize\u0022 him to agree to do so. Martin also directed representatives of the Indonesian consulting company to submit false invoices to Monsanto for \u0022consultant fees\u0022 to obtain reimbursement for the bribe, and agreed to pay the consulting company for taxes that company would owe by reporting income from the \u0022consultant fees.\u0022  In February 2002, an employee of the Indonesian consulting company delivered $50,000 in cash to the senior environment official, explaining that Monsanto wanted to do something for him in exchange for repealing the environmental impact study requirement. The senior environment official promised that he would do so at an appropriate time. In March 2002, Monsanto, through its Indonesian subsidiary, paid the false invoices thus reimbursing the consulting company for the $50,000 bribe, as well as the tax it owed on that income. A false entry for these \u0022consulting services\u0022 was included in Monsanto\u0027s books and records. The senior environment official never authorized the repeal of the environmental impact study requirement.\u0022 (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Monsanto Company Case Summary at 108-109.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Monsanto Company Case Summary at 108-109, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 19023 \/ January 6, 2005, Securities and Exchange Commission v. Monsanto Company, Case No. 1:05CV00014 (U.S.D.C., D.D.C) (filed January 6, 2005), \u0022SEC Sues Monsanto Company for Paying a Bribe, Monsanto Settles Action and Agrees to Pay a  $500,000 Penalty,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr19023.htm; Complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/comp19023.pdf","Documents":""},{"Case ID":"ST-275","Case Cluster ":"Monsanto Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"03\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$30,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$30,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, False Accounting, Aiding and Abetting Monsanto\u0027s internal controls violations, Aiding and Abetting Monsanto\u0027s falsification of books and records ","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (License)","Summary":"According to the June 2011 United States Report to the OECD, \u0022Monsanto, a producer of various agricultural products, hired an Indonesian consulting company to assist it in obtaining various Indonesian governmental approvals and licenses necessary to sell its genetically modified products in Indonesia. At the time, the Indonesian government required an environmental impact study before authorizing the cultivation of genetically modified crops. After a change in governments in Indonesia, Monsanto sought, unsuccessfully, to have the new government, in which the senior environment official had a post, amend or repeal the requirement for the environmental impact statement.  Having failed to obtain the senior environment official\u0027s agreement to amend or repeal this requirement, in 2002, Charles Martin, the Government Affairs Director for Asia for Monsanto, authorized and directed an Indonesian consulting firm to make an illegal payment totaling $50,000 to the senior environment official to \u0022incentivize\u0022 him to agree to do so. Martin also directed representatives of the Indonesian consulting company to submit false invoices to Monsanto for \u0022consultant fees\u0022 to obtain reimbursement for the bribe, and agreed to pay the consulting company for taxes that company would owe by reporting income from the \u0022consultant fees.\u0022   In February 2002, an employee of the Indonesian consulting company delivered $50,000 in cash to the senior environment official, explaining that Monsanto wanted to do something for him in exchange for repealing the environmental impact study requirement. The senior environment official promised that he would do so at an appropriate time. In March 2002, Monsanto, through its Indonesian subsidiary, paid the false invoices thus reimbursing the consulting company for the $50,000 bribe, as well as the tax it owed on that income. A false entry for these \u0022consulting services\u0022 was included in Monsanto\u0027s books and records. The senior environment official never authorized the repeal of the environmental impact study requirement.\u0022 (Source: .US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Monsanto Company Case Summary at 108-109.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, NATCO Group, Inc. Case Summary at 55-56, accessed at http:\/\/www.oecd.org.  US Securities and Exchange Commission Litigation Release No. 2572 \/ March 6, 2007, SEC v. Charles Michael Martin, Case No. 1:07CV0434 (D.D.C.) (filed March 6, 2007), \u0022SEC Sues Former Senior Monsanto Manager Charles Martin for Authorizing a Bribe of $50,000; Martin Agrees to Pay a Penalty of $30,000,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20029.htm; Complaint filed March 6, 2007, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2007\/comp20029.pdf","Documents":""},{"Case ID":"ST-276","Case Cluster ":"Montedison S.p.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Italy","Year of Settlement":"2001","Month\/Day of Settlement (or Notes)":"03\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment ","Monetary Sanctions  (Types)":"Civil Penalty  ","Total Monetary Sanctions (US$)":"$300,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$300,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Anti-fraud, financial reporting and books and records of U.S. federal securities laws","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Regulator)","Summary":"According to the SEC Litigation Release of March 30, 2001, Montedison S.p.A., an Italian company whose senior management at the time fradulently overstated company income by at least $398 million through early 1993, without admitting or denying charges by the SEC agreed to pay a civil penalty for violating US federal securities laws.  The SEC Complaint had alleged that Montedison disguised hundreds of millions of dollars in payments that, among other things, were used to bribe politicians in Italy and other persons.  Virtually all of the former management at Montedison responsible for the fraud were convicted by Italian criminal authorities and were sued by the company. (Source: Litigation Release No. 16948, SEC v. Montedison, S.p.A., 1:96-cv-02631 (D.D.C.) and Complaint filed November 21, 1996.)   According to the Shearman \u0026 Sterling FCPA website case summary, \u0022This case was one of the first cases focusing on bribery brought by the SEC against a foreign issuer. The bribes formed the basis for the books and records violations and were allegedly paid by an Italian company to Italian politicians using offshore subsidiaries. It is, therefore, a unique FCPA case, as the bribes in question were paid by a foreign company to a foreign official in the same country, i.e., the officials were not \u0022foreign\u0022 to the company.\u0022 (Source: Case summary page, SEC v. Montedison, SpA, at http:\/\/fcpa.shearman.com\/?s=matter\u0026mode=form\u0026id=68.)  According  to the SEC Complaint, (1) Exilar Loan was one of the fake loans that Montedison made through a wholly-owned subsidiary to Financing and Investments NV, a wholly-owend Curacao corporation, which in turn \u0022loaned\u0022 the amount to Exilar International SA, a British Virgin Islands company.  The Complaint alleged that the Exilar Loan was designed to aggregate numerous bribes that had been paid over an extended period of time and disguise them as a single loan. Then in fiscal year ending in 1992, Montedison determined that the entire amount of the Exilar loan was uncollectible and should be written off.  (2) the ENIMONT Affair involved an effort by Montedison to gain control of ENIMONT, a joint venture by Montedison and the Italian state energy agency, ENI; Montedison management entered into an arrangment with a Rome real estate developer to pay artificially high prices thereby transferring  hundreds of millions of dollars with the Developer allegedly using this money to bribe politicians in Italy and other persons on Montedison\u0027s behalf. ","Sources ":"US Securities and Exchange Commission Litigation Release No. 16948 (March 30, 2001), re: settlement in SEC v. Montedison, S.p.A., Case No: 1:96-cv-02631-RWR (D.D.C.), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr16948.htm; SEC v. Montedison, S.p.A, Case No. 1:96-cv-02631-HHG (D.D.C.), Complaint filed November 21, 1996 and Final Judgment filed March 28, 2001, both accessed from www.fcpa.shearman.com","Documents":""},{"Case ID":"ST-277","Case Cluster ":"Morgan Stanley","Jurisdiction of Settlement":"","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"04\/25","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit, Prejudgment Interest","Total Monetary Sanctions (US$)":"$3,822,613.44","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$3,667,713","Civil Prejudgment Interest (US$) ":"$154,900","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign official, Books and Records, Internal Controls Provisions, Aiding and Abetting violations of Anti-fraud provisions of the Investment Advisers Act of 1940","Offenses - Settled":"Bribery of foreign official, Books and Records, Internal Controls Provisions, Aiding and Abetting violations of Anti-fraud provisions of the Investment Advisers Act of 1940","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the April 25, 2012 press release by the US Securities and Exchangeg Commission, Garth R. Peterson, formerly a managing director of Morgan Stanley consented to a civil settlement to resolve FCPA and other fraud charges pending against him.  According to the press release, \u0022The SEC alleges that Garth R. Peterson, who was a managing director in Morgan Stanley\u0027s real estate investment and fund advisory business, had a personal friendship and secret business relationship with the former Chairman of Yongye Enterprise (Group) Co.  - a Chinese state-owned entity with influence over the success of Morgan Stanley\u0027s real estate business in Shanghai. Peterson secretly arranged to have at least $1.8 million paid to himself and the Chinese official that he disguised as finder\u0027s fees that Morgan Stanley\u0027s funds owed to third parties. Peterson also secretly arranged for him, the Chinese official, and an attorney to acquire a valuable Shanghai real estate interest from a Morgan Stanley fund. Peterson was acquiring an interest from the fund but negotiated both sides of the transaction. In exchange for offers and payments from Peterson, the Chinese official helped Peterson and Morgan Stanley obtain business while personally benefitting from some of these same investments. Peterson\u0027s deception, self-dealing, and misappropriation breached the fiduciary duties he owed to Morgan Stanley\u0027s funds as their representative.\u0022  (Source: US Securities and Exchange Commission Press Release 2012-78, \u0022SEC Charges Former Morgan Stanley Executive with FCPA Violations and Investment Adviser Fraud,\u0022 April 25, 2012.) According to the SEC\u0027s complaint, Peterson and the Chinese official and involved Canadian lawyer used a British Virgin Islands registered entity, Asiasphere Holdings Ltd. to conceal their interest in the real estate; other BVI entities were used to hold ownership in Asiasphere:  Strong Man Ltd. and ParaPlay; the complaint alleges that the men misrepresented Asiasphere as a subsidiary of Yongye and that other legal entities were also employed to hold ownership in the real estate. (Source: SEC v. Garth Ronald Peterson, Case No. 1:12-cv-02033-JBW (E.D.N.Y.), Complaint filed April 25, 2012, paras 10, 14, 16.)  As part of the final judgment in his civil case, Mr. Peterson was ordered to pay $3,667,713 in disgorgement and $154,900.44 in prejudgment interest; the court specified that $2,741,693 represented profits by Mr. Peterson in the involved real estate. (Source: SEC v. Garth Ronald Peterson, Case No. 1:12-cv-02033-JBW (E.D.N.Y.), Final Judgment filed May 3, 2012.)","Sources ":"US Securities and Exchange Commission Press Release 2012-78, \u0022SEC Charges Former Morgan Stanley Executive with FCPA Violations and Investment Adviser Fraud,\u0022 April 25, 2012, accessed at http:\/\/www.sec.gov\/news\/press\/2012\/2012-78.htm; copy of Complaint filed in SEC v. Garth Ronald Peterson (E.D.N.Y.) accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-78.pdf;  SEC v. Garth Ronald Peterson, Case No. 1:12-cv-02033-JBW (E.D.N.Y.), Final Judgment filed May 3, 2012 (accessed via PACER). ","Documents":""},{"Case ID":"ST-278","Case Cluster ":"NATCO Group, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Kazakhstan","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"01\/11","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order, Consent to Final Judgment","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$65,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$65,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Immigration)","Summary":"According to the US Securities and Exchange Commission Litigation Release in SEC v. NATCO Group, Inc., on January 11, 2010, the SEC filed a settled civil action in the U.S. District Court for the Southern District of Texas charging NATCO Group Inc.  Without admitting or denying the allegations in the Commission\u0027s complaint, NATCO agreed to pay a $65,000 civil penalty.  The Complaint had alleged that NATCO\u0027s wholly-owned subsidiary TEST Automation \u0026 Controls, Inc. \u0022created and accepted false documents while paying extorted immigration fines and obtaining immigration visas in the Republic of Kazakhstan.\u0022 (Source: SEC Litigation Release No. 21374 \/ January 11, 2010, SEC v. NATCO Group Inc., Civil Action No. 4:10-CV-98 (S.D. Tex.).  According to the SEC Complaint, TEST maintained a branch office in Kazakhstan; in February and September 2007, Kazakh immigration prosecutors conducted audits and claimed that TEST expatriate employees were working in Kazkahstan without proper documentation and \u0022the prosecutors threatened to fine, jail or deport the workers if TEST Kazakhstan did not pay cash fines. [para 6]  Believing the prosecutor\u0027s threats to be genuine,\u0022 TEST employees paid and then were later reimbursed by the company. (Source: SEC v. NATCO Group, Inc., Case No. 4:10-cv-98 (S.D. Tex.), Complaint filed January 11, 2010.)  NATCO also consented to an SEC Cease and Desist Order, enjoining the company from future FCPA violations. (Source: In the Matter of NATCO Group Inc., Administrative Proceeding File No. 3-13742, Cease and Desist Order)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, NATGO Group Inc. Case Summary at 55-56, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. In the Matter of NATCO Group Inc., Administrative Proceeding File No. 3-13742, Cease and Desist Order, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2010\/34-61325.pdf; SEC Litigation Release No. 21374 \/ January 11, 2010, SEC v. NATCO Group Inc., Civil Action No. 4:10-CV-98 (S.D. Tex.), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21374.htm; Complaint, Consent Order and Final Judgment in SEC v. NATCO Group, Inc. Case No. 4:10-cv-98 (S.D. Tex.), accessed from The FCPA Blog at http:\/\/www.fcpablog.com\/blog\/2010\/1\/12\/natco-settles-extorted-bribe-case.html. ","Documents":""},{"Case ID":"ST-279","Case Cluster ":"Nature\u0027s Sunshine Products Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Brazil","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"07\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$600,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$600,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Fraud in Connection with the Purchase or Sale of Securities, Disclosure Violations, Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the June 2011 United States Report to the OECD, \u0022On July 31, 2009, the SEC filed a settled enforcement action against Nature\u0027s Sunshine Products Inc. (NSP), a manufacturer of nutritional and personal care products, as well as its Chief Executive Officer Douglas Faggioli and its former Chief Financial Officer Craig D. Huff. This complaint alleged that the defendants violated the antifraud, issuer reporting, books and records, and internal controls provisions of federal securities laws in connection with a series of cash payments to Brazilian government officials in 2000 and 2001. The complaint alleged that, faced with changes to Brazilian regulations which resulted in classifying many of NSP\u0027s products as medicines, which would have required NSP to register many of its products for importation and sale, NSP\u0027s Brazilian subsidiary made a series of cash payments to customs officials in order to induce them to allow NSP to import unregistered products into that country. NSP\u0027s Brazilian subsidiary then purchased false documentation to conceal the nature of the payments, which were later falsely recorded in the books and records of NSP. The complaint also alleged that Faggioli and Huff, in their capacities as control persons, violated the books and records and internal controls provisions of the FCPA in connection with the Brazilian cash payments. In addition, it is alleged that NSP failed to disclose the payments to Brazilian customs agents in its filings with the SEC.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Nature\u0027s Sunshine Products Inc. Case Summary at 61-62.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Nature\u0027s Sunshine Products Inc. Case Summary at 61-62, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 21162 \/ July 31, 2009, SEC v. Nature\u0027s Sunshine Products, Inc., Douglas Faggioli and Craig D. Huff, Case No. 09CV672 (D. Utah, Filed July 31, 2009), \u0022SEC Charges Nature\u0027s Sunshine Products, Inc. with Making Illegal Foreign Payments,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21162.htm; Complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp21162.pdf","Documents":""},{"Case ID":"ST-280","Case Cluster ":"Nature\u0027s Sunshine Products Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Brazil","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"07\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$25,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$25,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the June 2011 United States Report to the OECD, \u0022On July 31, 2009, the SEC filed a settled enforcement action against Nature\u2018s Sunshine Products Inc. (NSP), a manufacturer of nutritional and personal care products, as well as its Chief Executive Officer Douglas Faggioli and its former Chief Financial Officer Craig D. Huff. This complaint alleged that the defendants violated the antifraud, issuer reporting, books and records, and internal controls provisions of federal securities laws in connection with a series of cash payments to Brazilian government officials in 2000 and 2001. The complaint alleged that, faced with changes to Brazilian regulations which resulted in classifying many of NSP\u2018s products as medicines, which would have required NSP to register many of its products for importation and sale, NSP\u2018s Brazilian subsidiary made a series of cash payments to customs officials in order to induce them to allow NSP to import unregistered products into that country. NSP\u2018s Brazilian subsidiary then purchased false documentation to conceal the nature of the payments, which were later falsely recorded in the books and records of NSP. The complaint also alleged that Faggioli and Huff, in their capacities as control persons, violated the books and records and internal controls provisions of the FCPA in connection with the Brazilian cash payments. In addition, it is alleged that NSP failed to disclose the payments to Brazilian customs agents in its filings with the SEC.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Nature\u0027s Sunshine Products Inc. Case Summary at 61-62.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Nature\u0027s Sunshine Products Inc. Case Summary at 61-62, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 21162 \/ July 31, 2009, SEC v. Nature\u0027s Sunshine Products, Inc., Douglas Faggioli and Craig D. Huff, Case No. 09CV672 (D. Utah, Filed July 31, 2009), \u0022SEC Charges Nature\u0027s Sunshine Products, Inc. with Making Illegal Foreign Payments,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21162.htm; Complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp21162.pdf","Documents":""},{"Case ID":"ST-281","Case Cluster ":"Nature\u0027s Sunshine Products Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Brazil","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"07\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$25,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$25,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the June 2011 United States Report to the OECD, \u0022On July 31, 2009, the SEC filed a settled enforcement action against Nature\u2018s Sunshine Products Inc. (NSP), a manufacturer of nutritional and personal care products, as well as its Chief Executive Officer Douglas Faggioli and its former Chief Financial Officer Craig D. Huff. This complaint alleged that the defendants violated the antifraud, issuer reporting, books and records, and internal controls provisions of federal securities laws in connection with a series of cash payments to Brazilian government officials in 2000 and 2001. The complaint alleged that, faced with changes to Brazilian regulations which resulted in classifying many of NSP\u2018s products as medicines, which would have required NSP to register many of its products for importation and sale, NSP\u2018s Brazilian subsidiary made a series of cash payments to customs officials in order to induce them to allow NSP to import unregistered products into that country. NSP\u2018s Brazilian subsidiary then purchased false documentation to conceal the nature of the payments, which were later falsely recorded in the books and records of NSP. The complaint also alleged that Faggioli and Huff, in their capacities as control persons, violated the books and records and internal controls provisions of the FCPA in connection with the Brazilian cash payments. In addition, it is alleged that NSP failed to disclose the payments to Brazilian customs agents in its filings with the SEC.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Nature\u0027s Sunshine Products Inc. Case Summary at 61-62.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Nature\u0027s Sunshine Products Inc. Case Summary at 61-62, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 21162 \/ July 31, 2009, SEC v. Nature\u0027s Sunshine Products, Inc., Douglas Faggioli and Craig D. Huff, Case No. 09CV672 (D. Utah, Filed July 31, 2009), \u0022SEC Charges Nature\u0027s Sunshine Products, Inc. with Making Illegal Foreign Payments,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21162.htm; Complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp21162.pdf","Documents":""},{"Case ID":"ST-282","Case Cluster ":"Nexus Technologies Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; United States Attorney for the Eastern District of Pennsylania","Jurisdiction of Foreign Public Official(s) ":"Vietnam","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"06\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Special Assessment","Total Monetary Sanctions (US$)":"$11,200.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"$11,200 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy, Bribery of foreign officials, Commercial bribery,  Money laundering ","Offenses - Settled":"Conspiracy, Bribery of foreign officials, Commercial bribery, Money laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 57-58, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: Time period of misconduct in Vietnam 1999-2008; on September 4, 2008, Nexus and its employees Nam Quoc Nguyen, Kim Nguyen, and An Nguyen and joint venture partner Joseph Lukas were indicted by a grand jury in Philadephia on charges related to scheme to pay bribes totalling at least $250,000 to employees of state-owned enterprises in Vietnam in exchange for favorable treatment for Nexus in the award of procurement contracts.  In accordance with its plea agreement, Nexus was given 1 year of organizational probation in which to completely cease operations, formally dissolve, and turn over all assets to the court. Nexus was ordered to pay $11,200 in special assessment but no fine and no restitution. (Source: US v. Nexus Technologies, Inc. Case No. 2:08-cr-00522-TJS (E.D. Pa.), Final Judgment filed September 16, 2010.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 58-59, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Dept of Justice Press Release. \u0022Former Nexus Technologies Inc. Employees and Partner Sentenced for Roles in Foreign Bribery Scheme Involving Vietnamese Officials.\u0022 Sept. 16, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/September\/10-crm-1032.html; US Dept of Justice Press Release. \u0022Nexus Technologies Inc. and Three Employees Plead Guilty to Paying Bribes to Vietnamese Officials.\u0022 Mar. 16, 2010, accessed at www.justice.gov\/usao\/pae\/News\/Pr\/2010\/mar\/nexus_release.pdf; Superseding Indictment, U.S. v. Nexus Technologies, Inc. et al., no. 2:08-cr-00522-TJS (E.D. Pa., Oct. 29, 2009); Final Judgment filed September 16, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nguyenn\/09-16-10nguyennexus-judgment.pdf.  The Department of Justice press release on the sentencing of Nexus Technologies and related individual defendants acknowledged the assistance in the case by the Hong Kong\u0027s Independent Commission Against Corruption. (The bribery funds had been transferred from the US to HK).","Documents":""},{"Case ID":"ST-283","Case Cluster ":"Nexus Technologies Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; United States Attorney for the Eastern District of Pennsylania","Jurisdiction of Foreign Public Official(s) ":"Vietnam","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"9\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy, Bribery of foreign officials, Commercial bribery, Money laundering","Offenses - Settled":"Conspiracy, Bribery of foreign officials, Commercial bribery, Money laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 57-58, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: Time period of misconduct in Vietnam 1999-2008; on September 4, 2008, Nexus and its employees Nam Quoc Nguyen, Kim Nguyen, and An Nguyen and joint venture partner Joseph Lukas were indicted by a grand jury in Philadephia on charges related to scheme to pay bribes totalling at least $250,000 to employees of state-owned enterprises in Vietnam in exchange for favorable treatment for Nexus in the award of procurement contracts.  In accordance with its plea agreement, Nexus was given 1 year of organizational probation in which to completely cease operations, formally dissolve, and turn over all assets to the court. Nexus was ordered to pay $11,200 in special assessment but no fine and no restitution. (Source: US v. Nexus Technologies, Inc. Case No. 2:08-cr-00522-TJS (E.D. Pa.), Final Judgment filed September 16, 2010.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 58-59, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Dept of Justice Press Release. \u0022Former Nexus Technologies Inc. Employees and Partner Sentenced for Roles in Foreign Bribery Scheme Involving Vietnamese Officials.\u0022 Sept. 16, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/September\/10-crm-1032.html; US Dept of Justice Press Release. \u0022Nexus Technologies Inc. and Three Employees Plead Guilty to Paying Bribes to Vietnamese Officials.\u0022 Mar. 16, 2010, accessed at www.justice.gov\/usao\/pae\/News\/Pr\/2010\/mar\/nexus_release.pdf; Superseding Indictment, U.S. v. Nexus Technologies, Inc. et al., no. 2:08-cr-00522-TJS (E.D. Pa., Oct. 29, 2009); Final Judgment filed September 16, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nguyenn\/09-16-10nguyennexus-judgment.pdf.  The Department of Justice press release on the sentencing of Nexus Technologies and related individual defendants acknowledged the assistance in the case by the Hong Kong\u0027s Independent Commission Against Corruption. (The bribery funds had been transferred from the US to HK).","Documents":""},{"Case ID":"ST-284","Case Cluster ":"Nexus Technologies Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; United States Attorney for the Eastern District of Pennsylania","Jurisdiction of Foreign Public Official(s) ":"Vietnam","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"06\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,000.00","Criminal Fine\/Penalty (US$) ":"$1,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy, Bribery of foreign officials","Offenses - Settled":"Conspiracy, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 57-58, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: Time period of misconduct in Vietnam 1999-2008; on September 4, 2008, Nexus and its employees Nam Quoc Nguyen, Kim Nguyen, and An Nguyen and joint venture partner Joseph Lukas were indicted by a grand jury in Philadephia on charges related to scheme to pay bribes totalling at least $250,000 to employees of state-owned enterprises in Vietnam in exchange for favorable treatment for Nexus in the award of procurement contracts.  In accordance with its plea agreement, Nexus was given 1 year of organizational probation in which to completely cease operations, formally dissolve, and turn over all assets to the court. Nexus was ordered to pay $11,200 in special assessment but no fine and no restitution. (Source: US v. Nexus Technologies, Inc. Case No. 2:08-cr-00522-TJS (E.D. Pa.), Final Judgment filed September 16, 2010.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 58-59, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Dept of Justice Press Release. \u0022Former Nexus Technologies Inc. Employees and Partner Sentenced for Roles in Foreign Bribery Scheme Involving Vietnamese Officials.\u0022 Sept. 16, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/September\/10-crm-1032.html; US Dept of Justice Press Release. \u0022Nexus Technologies Inc. and Three Employees Plead Guilty to Paying Bribes to Vietnamese Officials.\u0022 Mar. 16, 2010, accessed at www.justice.gov\/usao\/pae\/News\/Pr\/2010\/mar\/nexus_release.pdf; Superseding Indictment, U.S. v. Nexus Technologies, Inc. et al., no. 2:08-cr-00522-TJS (E.D. Pa., Oct. 29, 2009); Final Judgment filed September 16, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nguyenn\/09-16-10nguyennexus-judgment.pdf.  The Department of Justice press release on the sentencing of Nexus Technologies and related individual defendants acknowledged the assistance in the case by the Hong Kong\u0027s Independent Commission Against Corruption. (The bribery funds had been transferred from the US to HK).","Documents":""},{"Case ID":"ST-285","Case Cluster ":"Nexus Technologies Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; United States Attorney for the Eastern District of Pennsylania","Jurisdiction of Foreign Public Official(s) ":"Vietnam","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"9\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$20,000.00","Criminal Fine\/Penalty (US$) ":"$20,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy, Bribery of foreign officials, Commercial bribery, Money laundering","Offenses - Settled":"Conspiracy, Bribery of foreign officials, Commercial bribery, Money laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 57-58, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: Time period of misconduct in Vietnam 1999-2008; on September 4, 2008, Nexus and its employees Nam Quoc Nguyen, Kim Nguyen, and An Nguyen and joint venture partner Joseph Lukas were indicted by a grand jury in Philadephia on charges related to scheme to pay bribes totalling at least $250,000 to employees of state-owned enterprises in Vietnam in exchange for favorable treatment for Nexus in the award of procurement contracts.  In accordance with its plea agreement, Nexus was given 1 year of organizational probation in which to completely cease operations, formally dissolve, and turn over all assets to the court. Nexus was ordered to pay $11,200 in special assessment but no fine and no restitution. (Source: US v. Nexus Technologies, Inc. Case No. 2:08-cr-00522-TJS (E.D. Pa.), Final Judgment filed September 16, 2010.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 58-59, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Dept of Justice Press Release. \u0022Former Nexus Technologies Inc. Employees and Partner Sentenced for Roles in Foreign Bribery Scheme Involving Vietnamese Officials.\u0022 Sept. 16, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/September\/10-crm-1032.html; US Dept of Justice Press Release. \u0022Nexus Technologies Inc. and Three Employees Plead Guilty to Paying Bribes to Vietnamese Officials.\u0022 Mar. 16, 2010, accessed at www.justice.gov\/usao\/pae\/News\/Pr\/2010\/mar\/nexus_release.pdf; Superseding Indictment, U.S. v. Nexus Technologies, Inc. et al., no. 2:08-cr-00522-TJS (E.D. Pa., Oct. 29, 2009); Final Judgment filed September 16, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nguyenn\/09-16-10nguyennexus-judgment.pdf.  The Department of Justice press release on the sentencing of Nexus Technologies and related individual defendants acknowledged the assistance in the case by the Hong Kong\u0027s Independent Commission Against Corruption. (The bribery funds had been transferred from the US to HK).","Documents":""},{"Case ID":"ST-286","Case Cluster ":"Nexus Technologies Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; United States Attorney for the Eastern District of Pennsylania","Jurisdiction of Foreign Public Official(s) ":"Vietnam","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"9\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy, Bribery of foreign officials, Commercial bribery, Money laundering","Offenses - Settled":"Conspiracy, Bribery of foreign officials, Commercial bribery, Money laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 57-58, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: Time period of misconduct in Vietnam 1999-2008; on September 4, 2008, Nexus and its employees Nam Quoc Nguyen, Kim Nguyen, and An Nguyen and joint venture partner Joseph Lukas were indicted by a grand jury in Philadephia on charges related to scheme to pay bribes totalling at least $250,000 to employees of state-owned enterprises in Vietnam in exchange for favorable treatment for Nexus in the award of procurement contracts.  In accordance with its plea agreement, Nexus was given 1 year of organizational probation in which to completely cease operations, formally dissolve, and turn over all assets to the court. Nexus was ordered to pay $11,200 in special assessment but no fine and no restitution. (Source: US v. Nexus Technologies, Inc. Case No. 2:08-cr-00522-TJS (E.D. Pa.), Final Judgment filed September 16, 2010.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 58-59, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Dept of Justice Press Release. \u0022Former Nexus Technologies Inc. Employees and Partner Sentenced for Roles in Foreign Bribery Scheme Involving Vietnamese Officials.\u0022 Sept. 16, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/September\/10-crm-1032.html; US Dept of Justice Press Release. \u0022Nexus Technologies Inc. and Three Employees Plead Guilty to Paying Bribes to Vietnamese Officials.\u0022 Mar. 16, 2010, accessed at www.justice.gov\/usao\/pae\/News\/Pr\/2010\/mar\/nexus_release.pdf; Superseding Indictment, U.S. v. Nexus Technologies, Inc. et al., no. 2:08-cr-00522-TJS (E.D. Pa., Oct. 29, 2009); Final Judgment filed September 16, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nguyenn\/09-16-10nguyennexus-judgment.pdf.  The Department of Justice press release on the sentencing of Nexus Technologies and related individual defendants acknowledged the assistance in the case by the Hong Kong\u0027s Independent Commission Against Corruption. (The bribery funds had been transferred from the US to HK).","Documents":""},{"Case ID":"ST-287","Case Cluster ":"Niko Resources Ltd.","Jurisdiction of Settlement":"Canada","Jurisdiction of Settlement \/ Enforcement Agency":"Crown Counsel","Jurisdiction of Foreign Public Official(s) ":"Bangladesh","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"06\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Victim Surcharge","Total Monetary Sanctions (US$)":"$9,731,180.00","Criminal Fine\/Penalty (US$) ":"$8,400,430","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$1,330,750","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Provide Improper Benefits to Foreign Official (Section 3(1)(b) of the Corruption of Foreign Public Officials Act) ","Offenses - Settled":"Provide Improper Benefits to Foreign Official (Section 3(1)(b) of the Corruption of Foreign Public Officials Act)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the press release issued by the Royal Canadian Mounted Police, \u0022As a result of a six-year investigation conducted by the Calgary RCMP International Anti-Corruption Unit, a Calgary based, publicly-traded corporation, Niko Resources Ltd., was charged with one count of Section 3(1)(b) of the Corruption of Foreign Public Officials Act covering the period of February 1st, 2005 to June 30th, 2005.  Between the dates of the indictment, Niko provided the following improper benefits:  In May 2005, the company, through its subsidiary Niko Bangladesh, provided the use of a vehicle to AKM Mosharraf Hossain, the former Bangladeshi State Minister for Energy and Mineral Resources. The vehicle, which cost $190,984 CAN, was provided in order to influence the Minister in dealings with Niko Bangladesh. In June 2005, Niko paid travel and accommodation expenses for Minister AKM Mosharraf Hossain to travel from Bangladesh to Calgary to attend the GO EXPO oil and gas exposition. Niko also improperly paid approximately $5000 for non-business travel to New York and Chicago so the Minister could visit his family.  Today, Niko Resources Ltd. attended the Court of Queen\u0027s Bench and entered a guilty plea to the charge. Counsel for the Crown and Niko made a recommendation to the Court for a fine of $8,200,000 and the victim surcharge for a total of $9,499,000.00, which Justice Brooker of the Court of Queen\u0027s Bench imposed as the appropriate sentence. Niko Resources Ltd. has also been placed under a Probation Order which puts the company under the Court?s supervision for the next three years to ensure that audits are completed to examine Niko\u0027s compliance with the Corruption of Foreign Public Officials Act.  These types of investigations are complex and resource intensive, involving many separate jurisdictions. In addition, they cannot be completed without the cooperation of authorities in other countries.  The RCMP\u0027s International Anti-Corruption Unit would like to thank the Bangladesh Anti-Corruption Commission, the United States Department of Justice Fraud Section, the Federal Bureau of Investigation International Corruption Unit, as well as various law enforcement and government agencies in Switzerland, Japan, the United Kingdom, and Barbados.\u0022 (Source: Royal Canadian Mounted Police Press Release, \u0022Corruption Charges Laid Against NIKO Resources,\u0022 June 24, 2011.)","Sources ":"Royal Canadian Mounted Police Press Release, \u0022Corruption Charges Laid Against NIKO Resources,\u0022 June 24, 2011, accessed at http:\/\/www.rcmp-grc.gc.ca\/ab\/news-nouvelles\/2011\/110624-niko-eng.htm; The Corruption of Foreign Public Officials Act \/ A Guide, accessed at http:\/\/www.justice.gc.ca\/eng\/dept-min\/pub\/cfpoa-lcape\/index.html;  Between Her Majesty the Queens and Niko Resources Ltd., Agreed Statement of Facts (Queen\u0027s Bench of Alberta, Judicial District of Calgary), June 23, 2011, accessed at http:\/\/www.osler.com\/uploadedFiles\/Agreed%20statement%20of%20facts.pdf","Documents":""},{"Case ID":"ST-288","Case Cluster ":"Novo Nordisk A\/S","Jurisdiction of Settlement":"Denmark","Jurisdiction of Settlement \/ Enforcement Agency":"Public Prosecutor for Serious Economic Crime","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"6\/26","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Criminal Confiscation","Total Monetary Sanctions (US$)":"$5,663,620.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$5,663,620","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"OECD Phase 2 report noted investigations under section 110c(2) of the Danish Criminal Code - known as \u0022breach of UN sanctions\u0022","Offenses - Settled":"OECD Phase 2 report noted investigations under section 110c(2) of the Danish Criminal Code - known as \u0022breach of UN sanctions\u0022","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 29, 2009 Press Release by the Novo Nordisk company, \u0022Novo Nordisk announced today that it has reached a settlement with the Danish Public Prosecutor for Serious Economic Crime regarding the company\u0027s sales to Iraq during 2000 to 2003 under the United Nations Oil-for-Food programme.  Under the terms of the settlement, Novo Nordisk will pay back past profits of 30 million Danish kroner. Novo Nordisk cooperated fully with the Public Prosecutor in his investigations of the company, which are now concluded. In May, Novo Nordisk reached settlements on the same issue with the US.\u0022  (Source: Novo Nordisk Company Press Release, \u0022Novo Nordisk reaches settlement with the Danish authorities regarding Oil-for-Food activities,\u0022 June 29, 2009.)","Sources ":"Novo Nordisk Company Press Release, \u0022Novo Nordisk reaches settlement with the Danishauthorities regarding Oil-for-Food activities,\u0022 June 29, 2009, accessed at http:\/\/www.novonordisk.com\/press\/sea\/sea.asp?sNewsTypeGUID=\u0026lMonth=6\u0026lYear=2009\u0026sLanguageCode=en-GB\u0026sSearchText=danish\u0026fb=2574\u0026cat=pr\u0026sShowNewsItemGUID=6f5581f7-a9f0-4f3a-b914-d5335dc0feeb\u0026sShowLanguageCode=en-GB","Documents":""},{"Case ID":"ST-289","Case Cluster ":"Novo Nordisk A\/S","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"5\/6","Other Jurisdictions of Settlement":"Denmark","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$9,000,000.00","Criminal Fine\/Penalty (US$) ":"$9,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"","Offenses - Alleged":"Conspiracy to Commit Wire Fraud, Conspiracy to Falsify Books and Records","Offenses - Settled":"Conspiracy to Commit Wire Fraud, Conspiracy to Falsify Books and Records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On May 11, 2009, Novo Nordisk A\/S (Novo), a Danish corporation based in Bagsvaerd, Denmark, was charged in a one-count criminal information with conspiracy to commit wire fraud and to violate the books and records provisions of the FCPA. On the same date, the SEC filed a settled civil complaint against Novo in the U.S. District Court for the District of Columbia. According to court documents, between 2001 and 2003, a Jordan-based agent acting on behalf of Novo, an international manufacturer of insulin, medicines and other pharmaceutical supplies, made improper payments worth approximately $1.4 million to the former Iraqi government in order to obtain contracts with the Iraqi Ministry of Health to provide insulin and other medicines as part of the Oil-for-Food Program (OFFP).Novo engaged its long-time Jordan-based agent to submit bids on Novo\u0027s behalf to Kimadia, the Iraqi State Company for the Importation and Distribution of Drugs and Medical Appliances, a state-owned company which was part of the Iraqi Ministry of Health. Two branches of Novo Nordisk - RONE, based in Athens, Greece, and NEO, based in Amman, Jordan - handled the sales to the Iraq and supplied the agent with bid prices for each contract. In late 2000 or early 2001, a Kimadia import manager advised the agent that Kimadia required Novo Nordisk to pay a ten percent kickback in order to obtain a contract under the Program. The Kimadia import manager told the agent that Novo Nordisk should increase its prices by ten percent and pay that amount to Kimadia. By doing so, Novo would recover the secret kickback from the U.N. escrow account when the contract, with the inflated price, was subsequently approved for disbursement and paid by the U.N.  Beginning in 2001 and continuing through 2003, Novo paid these kickbacks, characterized as \u0022after-sales service fees\u0022 (\u0022ASSFs\u0022), by inflating the price of contracts by 10 percent before submitting the contracts to the U.N. for approval. Novo also concealed from the U.N. the fact that the price contained a kickback to the former Iraqi government. In addition, on at least two occasions in 2001, Novo paid increased commissions to its agent to pay the kickbacks to Kimadia. The agent\u0027s commission was increased under the guise that the payment was used to cover the agent\u0027s increased distribution and marketing costs. All together, Novo paid over $1.4 million in kickbacks payments on eleven contracts through the agent, and agreed to pay approximately $1.3 million in ASSFs on two additional contracts. Novo then inaccurately recorded the kickback payments as \u0022commissions\u0022 in its books and records.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Novo Nordisk A\/S Case Summary at 66-68, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Novo Nordisk A\/S Case Summary at 66-68, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Novo Nordisk A\/S, Case No. 1:09-cr-00126-RJL (D.D.C.), Information filed May 11, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nordiskn\/05-11-09novo-info.pdf; Deferred Prosecution Agreement filed May 11, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nordiskn\/05-06-09novo-agree.pdf; US Department of Justice Press Release, \u0022Novo Nordisk Agrees to Pay $9 Million Fine in Connection with Payment of $1.4 Million in Kickbacks Through the United Nations Oil-for-food Program,\u0022 May 11, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nordiskn\/05-06-09novo-agree.pdf","Documents":""},{"Case ID":"ST-290","Case Cluster ":"Novo Nordisk A\/S","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"05\/11","Other Jurisdictions of Settlement":"Denmark","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$9,030,145.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$4,321,523","Civil Prejudgment Interest (US$) ":"$1,683,556","Civil Fine \/ Penalty (US$)":"$3,025,066","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art.1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On May 11, 2009, Novo Nordisk A\/S (Novo), a Danish corporation based in Bagsvaerd, Denmark, was charged in a one-count criminal information with conspiracy to commit wire fraud and to violate the books and records provisions of the FCPA. On the same date, the SEC filed a settled civil complaint against Novo in the U.S. District Court for the District of Columbia.According to court documents, between 2001 and 2003, a Jordan-based agent acting on behalf of Novo, an international manufacturer of insulin, medicines and other pharmaceutical supplies, made improper payments worth approximately $1.4 million to the former Iraqi government in order to obtain contracts with the Iraqi Ministry of Health to provide insulin and other medicines as part of the Oil-for-Food Program (OFFP).Novo engaged its long-time Jordan-based agent to submit bids on Novo?s behalf to Kimadia, the Iraqi State Company for the Importation and Distribution of Drugs and Medical Appliances, a state-owned company which was part of the Iraqi Ministry of Health. Two branches of Novo Nordisk - RONE, based in Athens, Greece, and NEO, based in Amman, Jordan -- handled the sales to the Iraq and supplied the agent with bid prices for each contract. In late 2000 or early 2001, a Kimadia import manager advised the agent that Kimadia required Novo Nordisk to pay a ten percent kickback in order to obtain a contract under the Program. The Kimadia import manager told the agent that Novo Nordisk should increase its prices by ten percent and pay that amount to Kimadia. By doing so, Novo would recover the secret kickback from the U.N. escrow account when the contract, with the inflated price, was subsequently approved for disbursement and paid by the U.N.Beginning in 2001 and continuing through 2003, Novo paid these kickbacks, characterized as \u0022after-sales service fees\u0022 (\u0022ASSFs\u0022), by inflating the price of contracts by 10 percent before submitting the contracts to the U.N. for approval. Novo also concealed from the U.N. the fact that the price contained a kickback to the former Iraqi government. In addition, on at least two occasions in 2001, Novo paid increased commissions to its agent to pay the kickbacks to Kimadia. The agent\u0027s commission was increased under the guise that the payment was used to cover the agent\u0027s increased distribution and marketing costs. All together, Novo paid over $1.4 million in kickbacks payments on eleven contracts through the agent, and agreed to pay approximately $1.3 million in ASSFs on two additional contracts. Novo then inaccurately recorded the kickback payments as \u0022commissions\u0022 in its books and records.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Novo Nordisk A\/S Case Summary at 66-68, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.)  According to the SEC Litigation Release, the Commission acknowledged the assistance of the United Nations Independent Inquiry Committee. (Source: US Securities and Exchange Commission, Litigation Release No. 21033 \/ May 11, 2009, Securities \u0026 Exchange Commission v. Novo Nordisk A\/S, Civil Action No. 1:09-CV-00862 (D.D.C.) (EGS), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Novo Nordisk for Improper Payments to Iraq Under the U.N. Oil for Food Program \/ Novo Nordisk Agrees to Pay Over $10 Million in Disgorgement, Interest, and Penalties.\u0022)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Novo Nordisk A\/S Case Summary at 66-68, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21033 \/ May 11, 2009, Securities \u0026 Exchange Commission v. Novo Nordisk A\/S, Civil Action No. 1:09-CV-00862 (D.D.C.) (EGS), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Novo Nordisk for Improper Payments to Iraq Under the U.N. Oil for Food Program \/ Novo Nordisk Agrees to Pay Over $10 Million in Disgorgement, Interest, and Penalties,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21033.htm; Complaint filed May 11, 2009, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp21033.pdf.","Documents":""},{"Case ID":"ST-291","Case Cluster ":"NV Organon Oss","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Rijksrecherche (Dutch Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Out of court settlement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$608,213.00","Criminal Fine\/Penalty (US$) ":"$608,213","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Unknown","Offenses - Settled":"Sanctions legislation by paying kickbacks when implementing UN Oil-for-Food Programme","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Netherlands Phase 2 Report of the OECD Anti-Bribery Working Group (December 17, 2008): \u0022As of October 2008, no foreign bribery cases had been brought before the Dutch courts. Nevertheless, the prosecution authorities have concluded out-of-court transactions with seven companies for paying kickbacks in the context of the Oil-for-Food Programme in Iraq, although the offence charged was the violation of sanctions legislation and not the foreign bribery offence.\u0022 (para 2); \u0022 the Prosecution Department reports that it has concluded financial transactions (out of court settlements) with 7 companies for violating sanction legislation by paying kickbacks when implementing the Oil for Food Programme. Criminal gains have also been confiscated. In July 2008 a press release has been issued about these settlements. Together with the names of the companies (Alfasan International B.V., N.V. Organon, Flowserve B.V. , OPW Fluid Transfer Group Europe B.V., Prodetra B.V. Solvochem Holland B.V., Stet Holland B.V.) the settlements have been made public. For the following Oil-for-food transactions out-of-court settlements have been reached: 1. Alfasan International BV Woerden, fine: \u20ac 31.800,-- and confiscation \u20ac 10.183,55 2. NV Organon Oss, fine: \u20ac 381.602 3. Flowerserve bv te Etten-Leur, fine: \u20ac 76.274 and confiscation \u20ac180.260 4. OPW Fluid Transfer Group Europe BV, Nieuw Vennep, fine \u20ac 57.204 and confiscation \u20ac 24.600 5. Prodetra bv,Wadinxveen, fine: 64.751 and confiscation \u20ac 34.485,95 6. Solvochem Holland bv, Rotterdam, fine \u20ac 136.000 and confiscation \u20ac 144.592 7. Stet Holland bv,Emmeloord, fine \u20ac 119.712 and confiscation \u20ac 54.458.\u0022 (Source: Ibid., at 14.)","Sources ":"OECD Anti-Bribery Working Group, The Netherlands Phase 2 Report (December 17, 2008), accessed at http:\/\/www.oecd.org\/dataoecd\/61\/59\/41919004.pdf;    http:\/\/www.oecd.org\/daf\/anti-bribery\/Netherlandsphase3reportEN.pdf    Melissa Lipman, \u0022Cos. Settle Dutch Probe Into Oil-For-Food For \u20ac1.3M,\u0022 Law 360, July 16, 2008, accessed at http:\/\/www.law360.com\/articles\/62486\/cos-settle-dutch-probe-into-oil-for-food-for-1-3m (partial article, gives date of Dutch Public Prosecution Service press release.)","Documents":""},{"Case ID":"ST-293","Case Cluster ":"Oily Rock","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Azerbaijan","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"06\/19","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Civil  Asset Forfeiture","Total Monetary Sanctions (US$)":"$500,000.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"$500,000","Other Civil Monetary Sanctions (Explanation)":"Forfeiture","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering, Bribery of Foreign Officials, Violation of Travel Act ","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On May 12, 2005, Viktor Kozeny, Frederic A. Bourke Jr., and David Pinkerton were indicted in the Southern District of New York on charges of conspiracy to violate the FCPA and Travel Act, substantive FCPA violations, substantive Travel Act Violations, conspiracy to commit money laundering, substantive money laundering charges, and, in the case of Bourke and Pinkerton, making false statements. These charges stemmed from their role in a scheme to pay millions of dollars worth of bribes to Azeri government officials to ensure that the defendants\u0027 investment consortium would gain, in secret partnership with the Azeri officials, a controlling interest in the State Oil Company of the Azerbaijan Republic (SOCAR) and its substantial oil reserves.  According to evidence presented in the trial of Bourke, in August 1997, Kozeny allegedly agreed to transfer to corrupt Azeri officials two-thirds of the vouchers and options purchased by his investment consortium, Oily Rock, and to give them two-thirds of all of the profits arising from his investment consortium\u0027s participation in SOCAR\u0027s privatization. In addition, evidence presented at trial showed that in June 1998, Bourke knew that Kozeny arranged for Oily Rock to increase its authorized share capital from $150 million to $450 million so that the additional $300 million worth of Oily Rock shares could be transferred to one or more of the Azeri officials as a further bribe payment. Bourke also arranged for two of the corrupt officials to travel to New York City on different occasions in 1998 to receive medical treatment, for which Oily Rock paid. Thereafter, in interviews with the FBI in April and May of 2002, Bourke falsely stated that he was not aware that Kozeny had made the alleged payments to the Azeri Officials.  Three others have been charged in connection with their roles in this bribery scheme. Thomas Farrell, a former employee of Oily Rock, was charged in an information with one count of conspiracy to violate the FCPA and one count of violating the FCPA\u0027s anti-bribery provisions. On July 31, 2003, Clayton Lewis, a former principal of Omega Advisors and a co-investor in the scheme, was indicted on one count of conspiracy to violate the FCPA and one count of conspiracy to commit money laundering. On August 5, 2003, a grand jury in New York returned an indictment charging the third individual, Hans Bodmer, a Swiss lawyer who represented Kozeny and his investment consortium, with conspiring to violate the FCPA\u0027s anti-bribery provisions and conspiracy to commit money laundering. At the United States\u0027 request, Korea extradited Mr. Bodmer to the United States in 2004.  In June 2007, the Department entered into a nonprosecution agreement with Omega Advisors, regarding its role as a major investor in the consortium.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Oily Rock Case Summary at 102-103.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Oily Rock Case Summary at 102-103, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  In Re: Omega Advisors, Inc., Non-Prosecution Agreement dated June 19,2007,accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/omega-advisors\/06-19-07omega-agree.pdf; United States Attorney for Southern District of New York Press Release, \u0022U.S. Announces Settlement with Hedge Fund Omega Advisors, Inc. in Connection with Omega\u0027s Investment in Privatization Program in Azerbaijan,\u0022  July 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/omega-advisors\/07-06-07omega-settlement.pdf (accessed on September 14, 2011).","Documents":""},{"Case ID":"ST-294","Case Cluster ":"OPW Fluid Transfer Group Europe BV","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Rijksrecherche (Dutch Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Out of court settlement ","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation ","Total Monetary Sanctions (US$)":"$130,382.50","Criminal Fine\/Penalty (US$) ":"$91,174","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$39,208.50","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Unspecified","Offenses - Settled":"Sanctions legislation by paying kickbacks when implementing UN Oil-for-Food Programme","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Netherlands Phase 2 Report of the OECD Anti-Bribery Working Group (December 17, 2008): \u0022As of October 2008, no foreign bribery cases had been brought before the Dutch courts. Nevertheless, the prosecution authorities have concluded out-of-court transactions with seven companies for paying kickbacks in the context of the Oil-for-Food Programme in Iraq, although the offence charged was the violation of sanctions legislation and not the foreign bribery offence.\u0022 (para 2); \u0022 the Prosecution Department reports that it has concluded financial transactions (out of court settlements) with 7 companies for violating sanction legislation by paying kickbacks when implementing the Oil for Food Programme. Criminal gains have also been confiscated. In July 2008 a press release has been issued about these settlements. Together with the names of the companies (Alfasan International B.V., N.V. Organon, Flowserve B.V. , OPW Fluid Transfer Group Europe B.V., Prodetra B.V. Solvochem Holland B.V., Stet Holland B.V.) the settlements have been made public. For the following Oil-for-food transactions out-of-court settlements have been reached: 1. Alfasan International BV Woerden, fine:  \u20ac 31.800,-- and confiscation \u20ac 10.183,55 2. NV Organon Oss, fine:  \u20ac 381.602 3. Flowerserve bv te Etten-Leur, fine:  \u20ac 76.274 and confiscation  \u20ac180.260 4. OPW Fluid Transfer Group Europe BV, Nieuw Vennep, fine  \u20ac 57.204 and confiscation  \u20ac 24.600 5. Prodetra bv,Wadinxveen, fine: 64.751 and confiscation  \u20ac 34.485,95 6. Solvochem Holland bv, Rotterdam, fine  \u20ac 136.000 and confiscation   \u20ac 144.592 7. Stet Holland bv,Emmeloord, fine  \u20ac 119.712 and confiscation  \u20ac 54.458.\u0022 (Source: Ibid., at 14.)","Sources ":"OECD Anti-Bribery Working Group, The Netherlands Phase 2 Report (December 17, 2008), accessed at http:\/\/www.oecd.org\/dataoecd\/61\/59\/41919004.pdf; Melissa Lipman, \u0022Cos. Settle Dutch Probe Into Oil-For-Food For  \u20ac1.3M,\u0022 Law 360, July 16, 2008, accessed at http:\/\/www.law360.com\/articles\/62486\/cos-settle-dutch-probe-into-oil-for-food-for-1-3m (partial article, gives date of Dutch Public Prosecution Service press release.)","Documents":""},{"Case ID":"ST-295","Case Cluster ":"Owl Securities and Investment Ltd.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Costa Rica","Year of Settlement":"2001","Month\/Day of Settlement (or Notes)":"08\/03","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1 ","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022In 2001, the Department of Justice filed charges against two executives and a part-owner of Owl Securities and Investment Ltd., a Missouri company, as well as an agent that represented the company and its wholly-owned Costa Rican subsidiary, OSI Proyectos. According to court documents, OSI Proyectos was engaged in the development of port facilities in Costa Rica, including an international airport and various luxury properties. In 1998, the ruling Costa Rican political party signed a letter agreeing to allow OSI and its subsidiary to move forward with developing the port facilities. However, before it granted formal permission, Pablo Barquero Hernandez, OSI\u0027s Costa Rican Representative indicated that OSI would be required to pay a final \u0022closing cost\u0022 or \u0022toll\u0022 of $1 million. This amount was later increased to $1.5 million. Together, Robert Richard King, a large shareholder in OSI, and Hernandez allegedly agreed to pay the Costa Rican ruling party a $1 million \u0022closing cost\u0022 to secure the contract. For their roles in this bribery scheme, King and Hernandez were indicted by a federal grand jury in the Western District of Missouri on June 27, 2001.  Two additional OSI executives were charged on August 3, 2001, for their roles in the illicit payments to Costa Rican officials. According to court documents, Richard K. Halford, then the CFO of OSI, had communicated with Hernandez and was aware of the payments to Costa Rican officials. He proposed opening a new account in Panama or the U.S. to route the payments. Albert Reitz, OSI?s Vice President and Secretary, assisted in raising funds from investors to pay for the bribe.\u0022  Reitz was sentenced to five years\u0027 probation. (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Owl Securities and Investment Ltd. Case Summary at 129-130.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Owl Securities and Investment Ltd. Case Summary at 129-130, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Albert Reitz, Case No. No.01-00222-01-Cr-W-1 (W.D. Mo.), Information filed August 3, 2001, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/reitz\/08-03-01reitz-info.pdf; Plea Agreement filed August 3, 2001, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/reitz\/08-03-01reitz-plea-agree.pdf","Documents":""},{"Case ID":"ST-296","Case Cluster ":"Owl Securities and Investment Ltd.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Costa Rica","Year of Settlement":"2001","Month\/Day of Settlement (or Notes)":"08\/03","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1 ","Offenses - Alleged":"Conspiracy to bribe foreign officials, Failure to Pay Taxes ","Offenses - Settled":"Conspiracy to bribe foreign officials, Failture to Pay Taxes","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022In 2001, the Department of Justice filed charges against two executives and a part-owner of Owl Securities and Investment Ltd., a Missouri company, as well as an agent that represented the company and its wholly-owned Costa Rican subsidiary, OSI Proyectos. According to court documents, OSI Proyectos was engaged in the development of port facilities in Costa Rica, including an international airport and various luxury properties. In 1998, the ruling Costa Rican political party signed a letter agreeing to allow OSI and its subsidiary to move forward with developing the port facilities. However, before it granted formal permission, Pablo Barquero Hernandez, OSI\u0027s Costa Rican Representative indicated that OSI would be required to pay a final \u0022closing cost\u0022 or \u0022toll\u0022 of $1 million. This amount was later increased to $1.5 million. Together, Robert Richard King, a large shareholder in OSI, and Hernandez allegedly agreed to pay the Costa Rican ruling party a $1 million \u0022closing cost\u0022 to secure the contract. For their roles in this bribery scheme, King and Hernandez were indicted by a federal grand jury in the Western District of Missouri on June 27, 2001.  Two additional OSI executives were charged on August 3, 2001, for their roles in the illicit payments to Costa Rican officials. According to court documents, Richard K. Halford, then the CFO of OSI, had communicated with Hernandez and was aware of the payments to Costa Rican officials. He proposed opening a new account in Panama or the U.S. to route the payments. Albert Reitz, OSI\u0027s Vice President and Secretary, assisted in raising funds from investors to pay for the bribe.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Owl Securities and Investment Ltd. Case Summary at 129-130.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Owl Securities and Investment Ltd. Case Summary at 129-130, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Richard K. Halford, Case No. 4:01-00221-cr-w-sow (W. Missouri), Information filed August 3, 2001, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/halford\/02-17-02halford-info.pdf; Plea Agreement filed June 26, 2001, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/halford\/06-26-01halford-plea.pdf; Government Motion for Downward Departure from the Sentencing Guidelines filed July 3, 2002, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/halford\/07-03-02halford-motion.pdf; and Judgment of July 9, 2002, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/halford\/07-0902halford-judgment.pdf","Documents":""},{"Case ID":"ST-298","Case Cluster ":"Oxford University Press","Jurisdiction of Settlement":"","Jurisdiction of Settlement \/ Enforcement Agency":"Integrity Vice Presidency","Jurisdiction of Foreign Public Official(s) ":"Unspecified sub-Saharan African countries (acts by Kenyan and Tanzanian subsidiaries whose geographical region included Kenya, Burundi, Malawi, Rwanda, Sudan, Uganda, Tanzania, Zanzibar archipelago)","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"07\/03","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Negotiated Resolution Agreement","Monetary Sanctions  (Types)":"Unspecified","Total Monetary Sanctions (US$)":"$500,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"$500,000","Other Civil Monetary Sanctions (Explanation)":"Unspecified form of settlement payment","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Improper payments to government officials","Offenses - Settled":"Improper payments to government officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the World Bank Press Release, \u0022The World Bank Group today announced the debarment of two wholly-owned subsidiaries of Oxford University Press (OUP), namely: Oxford University Press East Africa Limited (OUPEA) and Oxford University Press Tanzania Limited (OUPT) - for a period of three years following OUP\u0027s acknowledgment of misconduct by its two subsidiaries in relation to two Bank-financed education projects in East Africa.  The debarment is part of a Negotiated Resolution Agreement between OUP and the World Bank Group.  In May 2011, investigators from the World Bank\u0027s Integrity Vice Presidency (INT) approached OUP about potential misconduct in Africa.  Following this, OUP conducted an internal investigation into its operations and reported its findings to INT. [ ]  The two companies made improper payments to government officials for two contracts to supply text books in relation to two World Bank-financed projects.  As a result, OUPEA and OUPT will be debarred for three years and OUP will receive a conditional non-debarment. In addition, in order to remedy part of the harm done by the misconduct, OUP has agreed to make a payment of US$500,000 to the World Bank as part of the Negotiated Resolution.\u0022 (Source: The World Bank Press Release, \u0022World Bank Sanctions Oxford University Press for Corrupt Practices Impacting Education Projects in East Africa,\u0022 July 3, 2012.)","Sources ":"The World Bank Press Release, \u0022World Bank Sanctions Oxford University Press for Corrupt Practices Impacting Education Projects in East Africa,\u0022 July 3, 2012, accessed at http:\/\/www.worldbank.org\/en\/news\/2012\/07\/03\/world-bank-sanctions-oxford-university-press-corrupt-practices-impacting-education-projects-east-africa","Documents":""},{"Case ID":"ST-207","Case Cluster ":"Innospec Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Treasury (Office of Foreign Assets Control)","Jurisdiction of Foreign Public Official(s) ":"Cuba  ","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/18","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Settlement Agreement","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$2,200,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"$2,200,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Violations of the Cuban Assets Control Regulations","Offenses - Settled":"Violations of the Cuban Assets Control Regulations","Public Procurement Contract \/ SOE Involved?":"No (Sanctions)","Summary":"According to the US Department of Treasury, Office of Foreign Assets Control Enforcement Notice, \u0022Innospec Inc., a Delaware corporation (\u0022Innospec\u0022), has agreed to pay $2.2 million to settle allegations of violations of the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (the \u0022CACR\u0022).  [  ] OFAC alleged that, after its acquisition of a foreign corporation that maintained a local sales office in Cuba, Innospec conducted business in Cuba through its acquired subsidiary, including conducting transactions in which the government of Cuba and\/or Cuban nationals had an interest in apparent violation of \u00a7 515.201(b) of the CACR.\u0022  Innospec admitted to allegations of violations of the CACR as part of its settlement agreement with the US Department of Justice. (Source: US Department of Treasury, Office of Foreign Assets Control, Enforcement Information for March 19, 2010, \u0022Innospec Inc. Settles Cuban Assets Control Regulations Allegations.\u0022) ","Sources ":"US Department of Treasury, Office of Foreign Assets Control, Enforcement Information for March 19, 2010, \u0022Innospec Inc. Settles Cuban Assets Control Regulations Allegations,\u0022 accessed at http:\/\/www.treasury.gov\/resource-center\/sanctions\/OFAC-Enforcement\/Documents\/03192010.pdf and text of Settlement Agreement at http:\/\/www.treasury.gov\/resource-center\/sanctions\/OFAC-Enforcement\/Documents\/innospec_ag.pdf.","Documents":""},{"Case ID":"ST-208","Case Cluster ":"Innospec Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia, Iraq (UN Oil-for-Food); Iraq","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/18","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits","Total Monetary Sanctions (US$)":"$11,200,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$11,200,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, \u0022Without admitting or denying the Commission\u0027s allegations, Innospec has consented to the entry of a court order [  ] ordering it to pay $60,071,613 in disgorgement, provided that the Commission waive all but $11,200,000 of disgorgement and permitting payment in four installments based upon Innospec\u0027s sworn Statement of Financial Condition.\u0022 (Source:  US Securities and Exchange Commission Litigation Release No. 21454 \/ March 18, 2010, in Securities \u0026 Exchange Commission v. Innospec, Inc., Civil Action No. 1:10-cv-00448 (RMC) (D.D.C.)).  The SEC had alleged that Innospec had paid bribes to Iraqi officials, from 2000-2007, in connection with their UN Oil-for-Food contracts and continued the misconduct after the UN Oil-for-Food Programme ended.  The bribes included lavish trips and entertainment. According to the SEC\u0027s Litigation Release, the agency had also alleged that \u0022Innospec also had several schemes to pay bribes to Indonesian government officials from at least 2000 through 2005 to win contracts with state owned oil and gas companies.  Approximately $2,883,507 in bribes was funneled through an Indonesian agent.  One scheme involved bribes paid annually to a senior official at BP Migas; another involved \u0022special commissions\u0022 paid to a Swiss account; and one involved a \u0022one off payment\u0022 of $300,000.\u0022 (Source: Ibid. and Securities and Exchange Commission v. Innospec Inc., Case No. 1:10-cv-00448 (D.D.C.), Complaint filed on March 18, 2010.)","Sources ":"US Securities and Exchange Commission Litigation Release No. 21454 \/ March 18, 2010, in Securities \u0026 Exchange Commission v. Innospec, Inc., Civil Action No. 1:10-cv-00448 (RMC) (D.D.C.), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21454.htm; Securities and Exchange Commission v. Innospec Inc., Case No. 1:10-cv-00448 (D.D.C.), Complaint filed on March 18, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21454.pdf.  See also, US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Innospec Inc. at 14-16, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf ","Documents":""},{"Case ID":"ST-209","Case Cluster ":"Innospec Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Cuba, Indonesia, Iraq (UN Oil-for-Food); Iraq","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/18","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$14,100,000.00","Criminal Fine\/Penalty (US$) ":"$14,100,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Conspiracy to commit wire fraud, Bribery of foreign officials; Falsificaton of books and records, Wire fraud","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Conspiracy to commit wire fraud, Bribery of foreign officials ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Plea Agreement filed in US v. Innospec Inc., the Delaware-incorporated company with executive offices located in the UK pleaded guilty on March 17, 2010 to a twelve-count information, accepting responsibility for (1) improper payments with regard to the UN Oil-for-Food Programme (during 2000-2003, in order for Innospec\u0027s Swiss subsidiary Alcor to obtain more then EU40 million in contracts with the Iraqi Ministry of Oil); (2) violation of the US Cuban embargo law in its sale of nearly $20 million in oil soluable fuel additives to state-owned Cuban power plants (La Empresa Importadora de Abastecimientos de Petroleo Abapet and Empresa Importadora de Objectivos Electroenergeticos) and facilitation of travel by a Specially Designated National; and (3) improper payments to Iraqi officials in connection wtih the 2004 and 2008 Long Term Purchase Agreements with the Ministry of Oil. (Source: US v. Innospec Inc., Case No. 1:10-cr-00061 (D.D.C.), Plea Agreement filed on March 18, 2010.)","Sources ":"US v. Innospec Inc., Case No. 1:10-cr-00061 (D.D.C.), Plea Agreement filed on March 18, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/innospec-inc\/03-18-10innospec-plea.pdf; Information filed March 17, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/innospec-inc\/03-17-10innospec-info.pdf; US Department of Justice Press Release, \u0022Innospec Inc. Pleads Guilty to FCPA Charges and Defrauding the United Nations; Admits to Violating the U.S. Embargo Against Cuba,\u0022 March 18, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/March\/10-crm-278.html; US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Innospec Inc. at 14-16, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf ","Documents":""},{"Case ID":"ST-210","Case Cluster ":"Innospec Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia, Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits","Total Monetary Sanctions (US$)":"$40,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$40,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations, Aiding and abetting Innospec\u0027s falsification of books and records, Aiding and abetting Innospec\u0027s internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Innospec, Inc. at 14-16: \u0022Turner and other senior Innospec officials also caused more than $2.8 million in bribes to be paid through an Indonesian agent to officials of the Indonesian government in order to secure contracts for Innospec.\u0022 Period of misconduct in Indonesia, 2000-2005.  The US v. Innospec, Case No. 1:10-cr-00061, Plea Agreement and Statement of Facts contains no additional details with respect to misconduct in Indonesia. According to the SEC litigation release (August 5, 2010) in Securities \u0026 Exchange Commission v. David P. Turner and Ousama M. Naaman., Civil Action No. 1:10-CV-01309 (D.D.C.) (RMC), Turner was Business Director of Innospec\u0027s Tetra Ethyl Lean group.  The SEC complaint had alleged that he engaged in bribery of Indonesian officials (officials V,X,Y and Z) in order to sell TEL to Indonesian stated-owned oil companies and the TEL was sold in until 2005 in Indonesia to state owned companies - Pertamina, BP Migas and Leimgas - through Alcor Chemie Vertriebs GMBH (\u0022Alcor\u0022), a wholly owned subsidiary of Innospec; Alcor is incorporated in Switzerland and headquartered in Zug, Switzerland. According to the Turner complaint, \u0022The bribes were made through Indonesian Agent and totaled approximately $2,883,507. Innospec\u0027s revenues in connection with the illicitbribes were approximately $48,571,937 and profits were $21,506,610.\u0022 (para 55.)  The payments were proportionate to the amount of product sold. (Source: SEC v. David P. Turner and Ousama M. Naaman, Case No. 1:10-cv-01309 (D.D.C.), Complaint of August 4, 2010). Turner was ordered to disgorge $40,000; the final judgment does not indicate how much of this amount is attributed to his misconduct in Indonesia. (Source: SEC v. Davis P. Turner, Case No. 1:10-cv-01309-RMC (D.D.C.), Final Judgment filed August 10, 2010, accessed at http:\/\/fcpa.shearman.com\/files\/d77\/d7776278ba193aae54822323ae19641e.pdf?i=a60613ed673d696fed541f265929a833.)","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Innospec, Inc. at 14-16, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c-.pdf; US v. Innospec, Case No. 1:10-cr-00061-ESH (D.D.C.), Information filed March 17, 2010 and Plea Agreement and Statement of Facts filed March 18, 2010, both accessed at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/innospec-inc.html; SEC v. David P. Turner and Ousama M. Naaman, Case No. 1:10-cv-01309 (D.D.C.), Complaint of August 4, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21615.pdf; SEC v. Davis P. Turner, Case No. 1:10-cv-01309-RMC (D.D.C.), Final Judgment filed August 10, 2010, accessed at http:\/\/fcpa.shearman.com\/files\/d77\/d7776278ba193aae54822323ae19641e.pdf?i=a60613ed673d696fed541f265929a833.","Documents":""},{"Case ID":"ST-211","Case Cluster ":"Innospec Inc.","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Indonesia; Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/18","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Civil Recovery Order (Proceeds of Crime Act)","Monetary Sanctions  (Types)":"Civil Recovery Order","Total Monetary Sanctions (US$)":"$12,700,000.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$12,700,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office Press Release, \u0022On 18 March 2010, Innospec Ltd appeared before Lord Justice Thomas at Southwark Crown Court and entered a plea of guilty to bribing employees of Pertamina (an Indonesian state owned refinery) and other government officials in Indonesia.  At that hearing the judge indicated he would impose a financial penalty of the sterling equivalent of US$12.7 million and he adjourned sentencing and remarks to today.  In sentencing today, Lord Justice Thomas stated that that sum is to be paid by way of a fine. The 14-page judgment also includes guidance.\u0022  The Judgment details the discussions between the United States and the United Kingdom with regards to the financial settlements by the two countries.  (Sources: US Serious Fraud Office Press Release, \u0022Innospec Judgment,\u0022 March 26, 2010 and R. v. Innospec Limited, In the Crown Court at Southwark, Sentencing remarks of Lord Justice Thomas (26 March 2010).)  In the Judgment, Lord Justice Thomas noted: \u0022Through agents in Indonesia, the directing minds of the company engaged in systematic and large-scale corruption of senior Government officials. Those corrupted in this way included Rachmat Sudibyo, Director-General of Oil and Gas in the Ministry of Energy and Mineral Resources in Indonesia and subsequently Chairman of Migas, an authority that regulated oil and gas in Indonesia, and Suroso Atmomartoyo, a Director of Pertamina, the Indonesian state oil company, and one of the most senior members of its management.  The bribes paid to Rachmat Sudibyo exceeded $1 million.  [ ] It is not possible to calculate precisely the total amount of the bribes, but the best estimate is approximately 5% of $160 million, namely $8 million.\u0022 (Source:  R. v. Innospec Limited, In the Crown Court at Southwark, Sentencing remarks of Lord Justice Thomas (26 March 2010).)  ","Sources ":"R. v. Innospec Limited, In the Crown Court at Southwark, Sentencing remarks of Lord Justice Thomas (26 March 2010), accessed at http:\/\/www.judiciary.gov.uk\/NR\/rdonlyres\/5343F038-A6E5-448B-BB2D-7CA31F9E2DDA\/0\/sentencingremarksthomasljinnospec.pdf;  UK Serious Fraud Office, \u0022Innospec Limited prosecuted for corruption by the SFO,\u0022 March 18, 2010, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2010\/innospec-limited-prosecuted-for-corruption-by-the-sfo.aspx;  http:\/\/www.sfo.gov.uk\/press-room\/press-release-archive\/press-releases-2010\/innospec-judgment.aspx; UK Serious Fraud Office, \u0022Innospec Judgment,\u0022 March 26, 2010, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2010\/innospec-judgment.aspx.  See also, United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf","Documents":""},{"Case ID":"ST-212","Case Cluster ":"Innospec Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/05","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$1,315,144.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$810,076","Civil Prejudgment Interest (US$) ":"$67,030","Civil Fine \/ Penalty (US$)":"$438,038","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records, Internal Controls Violations ","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, on August 5, 2010, the Commission filed a settled complaint which alleged that \u0022David P. Turner, a former Business Director at Innospec, Inc., and Ousama M. Naaman, Innospec\u0027s agent in Iraq, with violating the Foreign Corrupt Practices Act (FCPA) by paying bribes to numerous government officials to obtain and retain business.The SEC\u0027s complaint alleges that: Turner and Naaman engaged in widespread bribery of Iraqi government officials to obtain contracts under the United Nations Oil for Food Program, and in order to continue selling Tetra Ethyl Lean (TEL) to Iraq after the Oil for Food Program ended. Turner also violated the FCPA by paying bribes to Indonesian officials to sell TEL to Indonesian state owned oil companies.  From 2000 to 2008, Innospec, Inc., a manufacturer and distributor of fuel additives and specialty chemicals, routinely paid bribes to government officials in Iraq and Indonesia to sell TEL. The bribery activities in Iraq began with Innospec\u0027s participation in the United Nations (\u0022UN\u0022) Oil for Food Program in 2001, and extended all the way until at least 2008. Turner, the Business Director of Innospec\u0027s TEL group, and Naaman, Innospec\u0027s agent, both actively participated in the bribery and kickback schemes in Iraq. Innospec also paid bribes to government officials in Indonesia beginning as early as 2000, and continued until 2005, when Indonesia\u0027s need for TEL ended. Turner actively participated in the bribery scheme in Indonesia. In all, Innospec made illicit payments of over $6.3 million and promised an additional $2.8 million in illicit payments to Iraqi ministries and government officials as well as Indonesian government officials. The contracts that Innospec obtained in exchange for the bribes were worth approximately $176 million.  Naaman paid kickbacks to Iraq on Innospec\u0027s behalf so that Innospec could obtain five Oil-for-Food Program contracts for the sale of TEL to the Iraqi Ministry of Oil and its component oil refineries. Naaman aided Innospec in obtaining the Oil for Food contracts by paying kickbacks equaling 10 percent of the contract value on three of the contracts. When the Oil-for-Food Program ended shortly before Innospec was to pay promised kickbacks on the two remaining contracts, Innospec kept the promised payments as part of its profit. [  ] After the Oil for Food Program ended in late 2003, Turner and Naaman paid bribes to Iraqi officials in order to secure TEL business contracts from Iraq. Turner and senior officials at Innospec directed and approved the bribery payments. From at least 2004 through 2008, Innospec made payments totaling approximately $1,610,327 and promised an additional $884,480. In one e-mail, Naaman informed management, including Turner, that Iraqi officials were demanding a 2% kickback related to one TEL order. [  ]  Turner confirmed that the requested kickback would be paid through an additional 2% \u0022commission\u0022 to Naaman.  Turner and senior officials at Innospec also directed Naaman to pay a bribe of $155,000 to Iraqi officials to ensure the failure of a 2006 field trial test of MMT, a fuel product manufactured by a competitor of Innospec. Turner and other Innospec officials also authorized payments, through Naaman, to fund lavish trips for Iraqi officials [ ] and Turner also arranged for Naaman to pay thousands of dollars in cash to Iraqi officials for \u0022pocket money\u0022 on trips funded by Innospec.\u0022  The Litigation Release also noted that \u0022Naaman will disgorge $810,076 plus prejudgment interest of $67,030, and pay a civil penalty of $438,038, which will be deemed satisfied by a criminal order requiring Naaman to pay a criminal fine that is at least equal to the civil penalty amount. After his extradition to the United States, Naaman cooperated..\u0022  (Source:  US Securities and Exchange Commission Litigation Release No. 21615 \/ August 5, 2010, \u0022SEC Files Settled Charges Against David P. Turner and Ousama M. Naaman for Engaging in Bribery,\u0022 Securities \u0026 Exchange Commission v. David P. Turner and Ousama M. Naaman., Civil Action No. 1:10-CV-01309 (D.D.C.) (RMC).)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Innospec Inc. Case Summary at 24-27, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   US Securities and Exchange Commission Litigation Release No. 21615 \/ August 5, 2010, \u0022SEC Files Settled Charges Against David P. Turner and Ousama M. Naaman for Engaging in Bribery,\u0022 Securities \u0026 Exchange Commission v. David P. Turner and Ousama M. Naaman., Civil Action No. 1:10-CV-01309 (D.D.C.) (RMC), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21615.htm; Complaint filed August 5, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21615.pdf","Documents":""},{"Case ID":"ST-213","Case Cluster ":"Innospec Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"06\/25","Other Jurisdictions of Settlement":"[United Kingdom - ongoing criminal investigation]","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea  ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$250,000.00","Criminal Fine\/Penalty (US$) ":"$250,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8, Art. 10","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Conspiracy to Falsify Books and Records, Conspiracy to Commit Wire Fraud, Bribery of Foreign Officials ","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Conspiracy to Falsify Books and Records, Conspiracy to Commit Wire Fraud, Bribery of Foreign Officials ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022Canadian\/Lebanese dual national Ousama M. Naaman pleaded guilty today to participating in an eight-year conspiracy to defraud the United Nations Oil for Food Program (OFFP) and to bribe Iraqi government officials in connection with the sale of a chemical additive used in the refining of leaded fuel. [  ]  Naaman, 61, of Abu Dhabi, United Arab Emirates, was originally indicted on Aug. 7, 2008, in U.S. District Court for the District of Columbia.   Naaman was arrested on July 30, 2009, in Frankfurt, Germany, and extradited to the United States.   [ ]  Naaman and his companies were the Iraqi agents of Innospec Inc., a U.S. company.   On March 18, 2010, Innospec pleaded guilty to a 12-count indictment charging wire fraud in connection with its payment of kickbacks to the Iraqi government under the OFFP, as well as violations of the FCPA in connection with bribe payments it made to officials in the Iraqi Ministry of Oil.  From 2001 to 2003, acting on behalf of Innospec, Naaman offered and paid 10 percent kickbacks to the then Iraqi government in exchange for five contracts under the OFFP.   Naaman negotiated the contracts, including a 10 percent increase in the price to cover the kickback, and routed the funds to Iraqi government accounts in the Middle East.   Innospec inflated its prices in contracts approved by the OFFP to cover the cost of the kickbacks.  Naaman also admitted that from 2004 to 2008, he paid and promised to pay more than $3 million in bribes, in the form of cash, as well as travel, gifts and entertainment, to officials of the Iraqi Ministry of Oil and the Trade Bank of Iraq to secure sales of tetraethyl lead in Iraq, as well as to secure more favorable exchange rates on the contracts.   Naaman provided Innospec with false invoices to support the payments, and those invoices were incorporated into the books and records of Innospec.\u0022 (Source:  US Department of Justice Press Release, \u0022Innospec Agent Pleads Guilty to Bribing Iraqi Officials and Paying Kickbacks Under the Oil for Food Program,\u0022 June 25, 2010.)  According to the Court Docket Report in his case, on December 22, 2011, Naaman was sentenced and ordered to pay $250,000 fine. (Source: US v. Naaman, Case No. 1:08-cr-00246-ESH-1 (D.D.C.), Court Docket Report retrieved via Pacer on January 12, 2012.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Innospec Inc. Case Summary at 24-27, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   US v. Namaan, Case No. 1:08-cr-246-ESH (D.D.C.), Indictment filed August 7, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/naamano\/08-07-08naaman-indict.pdf;  Superseding Information filed June 24, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/naamano\/06-24-10naaman-supsersed-info.pdf; Plea Agreement filed June 25, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/naamano\/06-25-10naaman-plea-agmt.pdf; Statement of Offense filed June 25, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/naamano\/06-25-10naaman-state-offense.pdf; US v. Naaman, Case No. 1:08-cr-00246-ESH-1 (D.D.C.), Court Docket Report retrieved via Pacer on January 12, 2012.  US Department of Justice Press Release, \u0022Innospec Agent Pleads Guilty to Bribing Iraqi Officials and Paying Kickbacks Under the Oil for Food Program,\u0022 June 25, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/June\/10-crm-747.html.","Documents":""},{"Case ID":"ST-214","Case Cluster ":"Innospec Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia, Iraq (UN Oil-for-Food); Iraq","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"01\/24","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$229,037.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$116,092","Civil Prejudgment Interest (US$) ":"$12,945","Civil Fine \/ Penalty (US$)":"$100,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations, Aiding and Abetting Innospec\u0027s falsification of books and records, Aiding and Abetting Innospec\u0027s internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Litigation Release and Complaint in SEC v. Paul W. Jennings, Mr. Jennings joined Innospec in 2002 as the Chief Financial Officer. the SEC Complaint alleged that Mr. Jennings became aware of Innospec\u0027s bribery scheme in Iraq and as he took on additional executive roles, approved and\/or faciliated bribes and he also was aware of and approved bribery payments to Indonesian officials, including one scheme involving Pertamina, the Indonesian state-owned oil and gas company. (Sources:  US Securities and Exchange Commission Litigation Release No. 21822 \/ January 24, 2011, Securities \u0026 Exchange Commission v. Paul W. Jennings, 1:11-CV-00144 (D.D.C.) (RMC), \u0022SEC Files Settled Bribery Charges against Paul W. Jennings,\u0022 and Securities \u0026 Exchange Commission v. Paul W. Jennings, 1:11-CV-00144-RMC (D.D.C.), Complaint filed on January 24, 2011.)","Sources ":"US Securities and Exchange Commission Litigation Release No. 21822 \/ January 24, 2011, Securities \u0026 Exchange Commission v. Paul W. Jennings, 1:11-CV-00144 (D.D.C.) (RMC), \u0022SEC Files Settled Bribery Charges against Paul W. Jennings,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr21822.htm; Securities \u0026 Exchange Commission v. Paul W. Jennings, 1:11-CV-00144-RMC (D.D.C.), Complaint filed on January 24, 2011, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp21822.pdf","Documents":""},{"Case ID":"ST-215","Case Cluster ":"International Business Machines (Argentina)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2001","Month\/Day of Settlement (or Notes)":"01\/09","Other Jurisdictions of Settlement":"Argentina","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$300,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$300,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission\u0027s Litigation Release, \u0022Without admitting or denying the allegations in the complaint, IBM consented to the entry of a judgment ordering IBM to pay a $300,000 penalty. The Order finds that IBM violated Section 13(b)(2)(A) of the Exchange Act in connection with a $250 million contract to integrate and modernize the computer system of a commercial bank owned by the Argentine government. According to the Order, certain former senior management of IBM-Argentina, S.A. (\u0022IBM-Argentina\u0022), a wholly-owned subsidiary of IBM, caused IBM-Argentina to enter into a subcontract with Capacitacion Y Computacion Rural, S.A. (\u0022CCR\u0022), and money paid to CCR by IBM-Argentina in connection with the subcontract was apparently subsequently paid by CCR to certain bank officials. Specifically, the Order finds that, during 1994 and 1995, IBM-Argentina paid CCR approximately $22 million under the subcontract, of which at least $4.5 million was transferred to several bank directors by CCR.\u0022 (Source:  Securities and Exchange Commission, Litigation Release No. 16839 \/ December 21, 2000, SEC v. International Business Machines Corporation, Case No. 1:00-cv-03040-JR (D.D.C.), \u0022SEC Settles Foreign Corrupt Practices Act Case against IBM.\u0022)","Sources ":"Securities and Exchange Commission v. International Business Machines Corporation, Case No. 00-cv-3040-JR (D.D.C. January 9 2001), Final Judgment.  Background details in SEC Administrative Proceeding File No. 3-10397 and Litigation Release No. 16839 \/ December 21, 20000, \u0022SEC Settles Foreign Corrupt Practices Act Case against IBM,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr16839.htm; Complaint filed December 21, 2000, accessed at http:\/\/fcpa.shearman.com\/files\/d0c\/d0c38e4dd02cb168e08b10bfeb943905.pdf?i=213d33ba5837e54f76ad2217c8d46f7f and Final Judgment filed January 9, 2001, at http:\/\/fcpa.shearman.com\/files\/f6c\/f6c4f8147e24d085fe53df61f218f475.pdf?i=a6ed58903e4eafab05288d16d4de56b7.","Documents":""},{"Case ID":"ST-216","Case Cluster ":"International Business Machines (South Korea and China)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, South Korea","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"03\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$10,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$5,300,000","Civil Prejudgment Interest (US$) ":"$2,700,000","Civil Fine \/ Penalty (US$)":"$2,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violation","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"On March 18, 2011, the US Securities and Exchange Commission filed a settled civil complaint after International Business Marchines Corporation,  charging the company with violation of the books and records and internal controls provisions of the Foreign Corrupt Practices Act.  The SEC alleged (1) in South Korea, from 1998-2003, employees of IBM Korea, Inc., an IBM subsidiary and LG IBM PC Co., Ltd., a joint venture in which IBM held a majority interest, paid cash bribes (approximately $135,558 by IBM-Korea and $71,599 by LG-IBM Korea) and provided improper gifts and payments of travel and entertainment expenses to various government officials in South korea in order to secure the sale of IBM products.  The payments were alleged to have been made to \u0022South Korean Government Entities\u0022(SKGE) as SKGE 1, SKGE 2, SKGE 3, SKGE 3, SKGE 4, SKGE 5 and SKGE 6; (2) in China, between 2004 to early 2009, IBM China, a Hong Kong company owned by IBM, employees created slush funds at local travel agencies in China that were used to pay for overseas and other travel expenses incurred by Chinese government officials, and created slush funds at its business partners to provide a cash payment and improper gifts such as cameras and laptops to Chinese government officials. The complaint does not identify the involved Chinese officials.  (Source:  Securities and Exchange Commission v. International Business Machines Corporation, Case No. 1:11-cv-00563 (D.D.C.), Complaint filed March 18, 2011.)","Sources ":"Securities and Exchange Commission v. International Business Machines Corporation, Case No. 1:11-cv-00563 (D.D.C.), Complaint filed March 18, 2011, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp21889.pdf; US Securities and Exchange Commission, Litigation Release No. 21889 \/ March 18, 2011, \u0022IBM TO PAY $10 MILLION IN SETTLED FCPA ENFORCEMENT ACTION,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr21889.htm","Documents":""},{"Case ID":"ST-217","Case Cluster ":"International Materials Solutions Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Brazil","Year of Settlement":"1999","Month\/Day of Settlement (or Notes)":"02\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,000.00","Criminal Fine\/Penalty (US$) ":"$1,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 (June 2011): \u0022On February 8, 1999, the Department of Justice filed a two-count information in the Southern District of Ohio, charging International Materials Solutions Corporation (IMSC) and Thomas K. Qualey, IMSC\u0027s President, with one count of conspiring to violate the anti-bribery provisions of the FCPA and one count of bribing a foreign official. According to court documents, in 1995 and 1996, Qualey prepared and submitted bids on behalf of International Materials Solutions Corporation (IMSC) to sell forklifts to the Brazilian Air Force (BAF) and to service them. In order to secure these contracts, which were worth approximately $400,000, IMSC agreed to pay $67,000 in bribes to a Lieutenant Colonel in the BAF, who was stationed as a Foreign Liaison Officer in the United States. \/ Criminal Disposition: On February 10, 1999, Qualey pleaded guilty and was sentenced to four months home confinement and a $5,000 fine. IMSC also pleaded guilty on this date and was later sentenced to pay a $1,000 criminal fine.\u0022  (Source: International Materials Solutions Corporation. Case at 133.)  According to the Judgment Order in US v. International Materials Solutions, the fine was below guidelines because of the inability of the company to pay. (Source: US v. International Materials Solutions, Case No. 3:99-cr-008-WHR (S.D. Ohio), Judgment Order filed October 4, 1999.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, International Materials Solutions Corporation. Case at 133, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. International Materials Solutions Corporation, Case No. 3:99-cr-008-WHR (S.D. Ohio), Information filed on February 8, 1999, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/02-08-99imsc-info.pdf; Plea Agreement filed February 10, 1999, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/02-11-99imsc-plea-agree.pdf; Statement of Facts, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/02-10-99imsc-state-facts.pdf; Judgment Order filed October 4, 1999, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/09-1-99imsc-judgment.pdf.","Documents":""},{"Case ID":"ST-218","Case Cluster ":"International Materials Solutions Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Brazil","Year of Settlement":"1999","Month\/Day of Settlement (or Notes)":"02\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$5,000.00","Criminal Fine\/Penalty (US$) ":"$5,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 (June 2011): \u0022On February 8, 1999, the Department of Justice filed a two-count information in the Southern District of Ohio, charging International Materials Solutions Corporation (IMSC) and Thomas K. Qualey, IMSC\u0027s President, with one count of conspiring to violate the anti-bribery provisions of the FCPA and one count of bribing a foreign official. According to court documents, in 1995 and 1996, Qualey prepared and submitted bids on behalf of International Materials Solutions Corporation (IMSC) to sell forklifts to the Brazilian Air Force (BAF) and to service them. In order to secure these contracts, which were worth approximately $400,000, IMSC agreed to pay $67,000 in bribes to a Lieutenant Colonel in the BAF, who was stationed as a Foreign Liaison Officer in the United States. \/ Criminal Disposition: On February 10, 1999, Qualey pleaded guilty and was sentenced to four months home confinement and a $5,000 fine. IMSC also pleaded guilty on this date and was later sentenced to pay a $1,000 criminal fine.\u0022  (Source: International Materials Solutions Corporation. Case at 133.)  According to the Judgment Order in US v. International Materials Solutions, the fine was below guidelines because of the inability of the company to pay. (Source: US v. International Materials Solutions, Case No. 3:99-cr-008-WHR (S.D. Ohio), Judgment Order filed October 4, 1999.)  According to the Judgment in Mr. Qualey\u0027s case, \u0022The sentence departs from the guideline range: [due to] Criminal history over represents [sic] seriousness of past criminal conduct and likelihood of recidivism. Substantial assistance to foreign government.\u0022 (Source: US v. Thomas K. Qualey, Case No. 3:99-cr-008-WHR (S.D. Ohio), Judgment Order filed October 4, 1999.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, International Materials Solutions Corporation. Case at 133, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. International Materials Solutions Corporation, Case No. 3:99-cr-008-WHR (S.D. Ohio), Information filed on February 8, 1999, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/02-08-99imsc-info.pdf; Plea Agreement filed February 10, 1999, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/02-11-99imsc-plea-agree.pdf; Statement of Facts, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/02-10-99imsc-state-facts.pdf; Judgment Order filed October 4, 1999, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/09-1-99imsc-judgment.pdf; Thomas K. Quagley Plea Agreement filed on February 10, 1999, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/02-10-99qualey-plea-agree.pdf and Judgment (October 4, 1999), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/09-01-99qualey-judgment.pdf","Documents":""},{"Case ID":"ST-219","Case Cluster ":"InVision Technologies, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China, Philippines, Thailand","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"12\/03","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$800,000.00","Criminal Fine\/Penalty (US$) ":"$800,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.15, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 InVision Technologies, Inc. at 100-101, location and time period of misconduct: Thailand (2002-2004), China (2002-2004), Philippines (2001-2002); company became aware of a high probability that its agents or distributors in Thailand, China and the Philippines had paid or offered to pay money to foreign officials or political parties in connection with transactions or proposed transactions for the sale by InVision of its airport security screening machines.  In 2005, SEC settled with GE InVision, InVision\u0027s corporate successor. David Pillor was InVision\u0027s senior vice president for sales and marketing. Resulting criminal enforcement actions: In Re InVision Technologies, Inc. (December 6, 2004); Civil enforcement actions: SEC v. David M. Pillor (N.D. Cal., August 15, 2006), SEC v. GE InVision, Inc. (N.D. Cal., February 14, 2005), In the Matter of GE InVision, Inc. (February 14, 2005)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 InVision Technologies, Inc. at 100-101, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; In Re Invision Technologies, Non-Prosecution Agreement of  December 3, 2004, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/invision-tech\/12-03-04invisiontech-agree.pdf; US Department of Justice Press Release, \u0022InVision Technologies, Inc. Enters into Agreement with the United States,\u0022 December 6, 2004, accessed at http:\/\/www.justice.gov\/opa\/pr\/2004\/December\/04_crm_780.htm","Documents":""},{"Case ID":"ST-220","Case Cluster ":"InVision Technologies, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, Philippines, Thailand","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"08\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$65,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$65,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.27","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Falsification of books and records, Aiding and abetting InVision\u0027s internal controls violations","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission\u0027s Litigation Release, the agency alleged that \u0022during the period from late 2001 through June 2004, InVision completed sales to airports in China, the Philippines, and Thailand. In the course of these transactions, Pillor received e-mail messages from his Asian regional sales manager that suggested that InVision\u0027s overseas sales agents and distributors intended to make improper payments or other gifts to foreign government officials, in violation of the FCPA. InVision subsequently paid invoices to its agents and distributors in China and the Philippines and improperly recorded the payments as legitimate business expenses.  InVision\u0027s FCPA violations occurred, in part, because the company lacked adequate internal controls to detect and prevent such conduct. For example, InVision\u0027s sales department provided only informal training about the FCPA to its employees and foreign agents. Similarly, the company\u0027s sales department failed to monitor its employees and foreign agents to ensure that they did not violate the requirements of the FCPA. As InVision\u0027s head of sales and a member of the company\u0027s board of directors, Pillor aided and abetted InVision\u0027s failure to establish adequate internal controls.\u0022  (Source: US Securities and Exchange Commission Litigation Release No. 19803 \/ August 15, 2006, SEC v. David M. Pillor, Case No. C-06-4906-WHA (N.D. Cal. filed Aug. 15, 2006), \u0022SEC Settles Charges Against Former InVision Technologies Senior Vice President for Sales and Marketing.\u0022)   According to the same Litigation Release, \u0022Simultaneous with the filing of the Commission\u0027s complaint, Pillor agreed, without admitting or denying the allegations, to pay a $65,000 civil penalty and to entry of a permanent injunction against future violations, in settlement of the matter.\u0022 (Source: Ibid.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 InVision Technologies, Inc. at 100-101, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Securities and Exchange Commission Litigation Release No. 19803 \/ August 15, 2006, SEC v. David M. Pillor, Case No. C-06-4906-WHA (N.D. Cal. filed Aug. 15, 2006), \u0022SEC Settles Charges Against Former InVision Technologies Senior Vice President for Sales and Marketing,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2006\/lr19803.htm.","Documents":""},{"Case ID":"ST-221","Case Cluster ":"InVision Technologies, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, Philippines, Thailand","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"02\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty ","Total Monetary Sanctions (US$)":"$1,117,703.57","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$589,000","Civil Prejudgment Interest (US$) ":"$28,703.57","Civil Fine \/ Penalty (US$)":"$500,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 InVision Technologies, Inc. at 100-101, location and time period of misconduct: Thailand (2002-2004), China (2002-2004), Philippines (2001-2002); company became aware of a high probability that its agents or distributors in Thailand, China and the Philippines had paid or offered to pay money to foreign officials or political parties in connection with transactions or proposed transactions for the sale by InVision of its airport security screening machines.  In 2005, SEC settled with GE InVision, InVision\u0027s corporate successor. David Pillor was InVision\u0027s senior vice president for sales and marketing. Resulting criminal enforcement actions: In Re InVision Technologies, Inc. (December 6, 2004); Civil enforcement actions: SEC v. David M. Pillor (N.D. Cal., August 15, 2006), SEC v. GE InVision, Inc. (N.D. Cal., February 14, 2005), In the Matter of GE InVision, Inc. (February 14, 2005) ","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 InVision Technologies, Inc. at 100-101, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Securities and Exchange Commission, Litigation Release No. 19078 \/ February 14, 2005, Securities and Exchange Commission v. GE InVision, Inc. (formerly known as InVision Technologies, Inc.), United States District Court for the Northern District of California, Civil Action No. C-05-0660 MEJ, \u0022SEC Settles Charges against InVision Technologies for $1.1 Million for Violations of the Foreign Corrupt Practices Act,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr19078.htm, and Complaint filed February 14, 2005, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/comp19078.pdf","Documents":""},{"Case ID":"ST-222","Case Cluster ":"Italy \/ COGIM case (Oil for Food case 15)","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Piacenza court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"05\/12","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$1,210,494.00","Criminal Fine\/Penalty (US$) ":"$129,094","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$1,081,400 ","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Criminal Code 322 bis","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Report on Italy, the case involved \u0022Alleged bribery of public officials to obtain contracts to supply medical equipment to the Iraqi Ministry of Health.\u0022 (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 70.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 70, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/47\/49377261.pdf  http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-223","Case Cluster ":"Italy \/ Libyan Arms Traffickers case","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Perugia court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"Libya","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"08\/07","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Confiscation","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of Foreign Officials, Sale of Military Weapons without Proper Registration with Italian Ministry of Defence, Engaging in Negotiations without Filing Proper Notifications (Criminal Code 110, 112, 81: Law 285\/1990; Law 895\/1967; Criminal Code 416, Criminal Code 110, 322-bis)","Offenses - Settled":"Foreign Bribery","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to the December 2011 OECD Phase 3 Report on Italy, two unnamed individual defendants were sanctioned through the Patteggiamento process for their misconduct relatedt o the Libyan Arms Traffickers Case.  The case involved approximately EUR 65 million in bribes. (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 65.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 65, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/47\/49377261.pdf    http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-224","Case Cluster ":"Italy \/ Libyan Arms Traffickers case","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Perugia court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"Libya","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"08\/07","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Confiscation","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of Foreign Officials, Sale of Military Weapons without Proper Registration with Italian Ministry of Defence, Engaging in Negotiations without Filing Proper Notifications (Criminal Code 110, 112, 81: Law 285\/1990; Law 895\/1967; Criminal Code 416, Criminal Code 110, 322-bis)","Offenses - Settled":"Foreign Bribery","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to the December 2011 OECD Phase 3 Report on Italy, two unnamed individual defendants were sanctioned through the Patteggiamento process for their misconduct relatedt o the Libyan Arms Traffickers Case.  The case involved approximately EUR 65 million in bribes. (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 65.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 65, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/47\/49377261.pdf    http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-225","Case Cluster ":"Italy \/ Oil Company Case","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Milan court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"Libya","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"03\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Confiscation","Total Monetary Sanctions (US$)":"$158,002.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$158,002","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Criminal Code 322 bis","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Report on Italy, the case involved \u0022Alleged bribery of Libyan public officials through an intermediary in order to obtain business in Libya\u0022 and bribe amount was EUR 14 million. (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 71.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 71, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/47\/49377261.pdf    http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-226","Case Cluster ":"Italy \/ Oil Company Case","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Milan court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"Libya","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"04\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Confiscation","Total Monetary Sanctions (US$)":"$1,588,430.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$1,588,430","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Criminal Code 322 bis and other [unspecified] offenses","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Report on Italy, the case involved \u0022Alleged bribery of Libyan public officials through an intermediary in order to obtain business in Libya\u0022 and bribe amount was EUR 14 million. (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 71.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 71, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/47\/49377261.pdf   http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-227","Case Cluster ":"Italy \/ Oil for Food Case 1 (compressor company)","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Milan Court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"03\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Unknown if ordered","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unspecified","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Criminal Code 322 bis","Offenses - Settled":"Criminal Code 322 bis","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Italy, an unnamed individual defendant related to the  United Nations \u0022Oil for Food Case 1 [compressor company]\u0022 was sanctioned for foreign bribery and sentenced to one year imprisonment. (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 63.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/59\/47\/49377261.pdf         http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-228","Case Cluster ":"Italy \/ Pirelli Telecom Case","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Milan Court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"France","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$535,484.00","Criminal Fine\/Penalty (US$) ":"$535,484","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials (Criminal Code 322-bis)","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Report on Italy, in the Pirelli\/Telecom case, two legal persons - Pirelli and telecom Italia - Italy \u0022alleged bribery of French public officials to obtain business authorization, carried out in 33 total operations.\u0022  The total bribe amount given was \u0022approximately EUR 200 000.\u0022  (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 67.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 67, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/47\/49377261.pdf      http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-229","Case Cluster ":"Italy \/ Pirelli Telecom Case","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Milan Court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"France","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$535,484.00","Criminal Fine\/Penalty (US$) ":"$535,484","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials (Criminal Code 322-bis)","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Report on Italy, in the Pirelli\/Telecom case, two legal persons - Pirelli and telecom Italia - Italy \u0022alleged bribery of French public officials to obtain business authorization, carried out in 33 total operations.\u0022  The total bribe amount given was \u0022approximately EUR 200 000.\u0022  (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 67.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 67, accessed at http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-230","Case Cluster ":"Italy \/ Pirelli Telecom Case","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Perugia court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"France","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal, Civil","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Confiscation, Compensation for Civil Damages","Total Monetary Sanctions (US$)":"$200,806.50","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$133,871","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"$66,936","Other Civil Monetary Sanctions (Explanation)":"Compensation for civil damages","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Criminal Code 322 bis","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Report on Italy, in the Pirelli\/Telecom case, Unnamed Individuals 3 and 4 were sanctioned for foreign bribery.  The Date Crime Committed is noted as 2001-2005.  (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 68.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), accessed at http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-231","Case Cluster ":"Italy \/ Pirelli Telecom Case","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Perugia court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"France","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal, Civil","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Confiscation, Compensation for Civil Damages","Total Monetary Sanctions (US$)":"$40,161.30","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$26,774","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"$13,387","Other Civil Monetary Sanctions (Explanation)":"Compensation for civil damages","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Criminal Code 322 bis","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Report on Italy, in the Pirelli\/Telecom case, Unnamed Individuals 3 and 4 were sanctioned for foreign bribery.  The Date Crime Committed is noted as 2001-2005.  (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 68.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), accessed at http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-232","Case Cluster ":"ITT Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"02\/11","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$1,678,650.11","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,041,112","Civil Prejudgment Interest (US$) ":"$387,538.11","Civil Fine \/ Penalty (US$)":"$250,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 ITT Corporation, at 48:  Misconduct in China, 2001-2005; misconduct involved alleged payments to Chinese government officials by ITT\u0027s wholly-owned Chinese subsidiary, Nanjing Goulds Pumps Ltd. (NGP).   Securities and Exchange Commission complaint had alleged that approximately $200,000 in illicit payments to 32 different Chinese state-owned entities which generated over $4 million in sales to NGP, from which ITT realized improper profits of more than $1 million.  The complaint mentioned two involved projects: the Xiaolangdi Hydroelectric Power Plant on the Yellow River and the Three Gorges Dam infrastructure project. Payments disguised as increased commissions in NGP\u0027s books and records.  (See also, US Securities and Exchange Commission Litigation Release No. 20896 \/ February 11, 2009, SEC v. ITT Corporation, Civil Action No. 1:09-cv-00272 (RJL) (D.D.C. filed February 11, 2009.)","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 ITT Corporation, at 48;  US Securities and Exchange Commission Litigation Release No. 20896 \/ February 11, 2009, SEC v. ITT Corporation, Civil Action No. 1:09-cv-00272 (RJL) (D.D.C. filed Feb. 11, 2009), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr20896.htm; Texts of the Complaint, Consent agreement, and final judgment available at http:\/\/fcpa.shearman.com.","Documents":""},{"Case ID":"ST-233","Case Cluster ":"ITXC Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Rwanda, Senegal,Mali","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"09\/02","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$7,000.00","Criminal Fine\/Penalty (US$) ":"$7,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy, Bribery of foreign officials, Commercial bribery","Offenses - Settled":"Conspiracy, Bribery of foreign officials, Commercial bribery","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022Three former executives of ITXC Corporation, a global telecommunications company based in Princeton, NJ, have pleaded guilty to conspiring to violate the FCPA and the Travel Act in connection with a scheme to bribe government telecommunications officials in four African countries. ITXC was a publicly traded company that provided telecommunication services, primarily Voice Over Internet Protocol (VOIP) services, to carriers across the globe. In pleading, the defendants admitted that between September 1999 and October 2004, they conspired with each other and other former ITXC employees and officers to make corrupt payments totaling approximately $450,000 to employees of foreign state-owned and foreign-owned telecommunications carriers in Nigeria, Rwanda, Senegal, and Mali to obtain and retain contracts for ITXC. For example, in Nigeria, ITXC entered into a service agreement with and agreed to pay a consulting company headed by an official of NITEL, the state-owned Nigerian telecommunications authority, in exchange for assistance in obtaining agreements with other service providers in the country. Between November 2002 and May 2004, ITXC wire transferred approximately $166,541.31 to the Nigerian bank account of the foreign official\u0027s company.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-101.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-101, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Department of Justice Press Release, \u0022Former ITXC Corporation Executives Sentenced for Roles in Foreign Bribery Scheme,\u0022 September 2, 2008, accessed at  http:\/\/www.justice.gov\/opa\/pr\/2007\/July\/07_crm_556.html","Documents":""},{"Case ID":"ST-234","Case Cluster ":"ITXC Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Rwanda, Senegal, Mali","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/21","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$10,000.00","Criminal Fine\/Penalty (US$) ":"$10,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy, Bribery of foreign officials, Commercial bribery","Offenses - Settled":"Conspiracy, Bribery of foreign officials, Commercial bribery","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022Three former executives of ITXC Corporation, a global telecommunications company based in Princeton, NJ, have pleaded guilty to conspiring to violate the FCPA and the Travel Act in connection with a scheme to bribe government telecommunications officials in four African countries. ITXC was a publicly traded company that provided telecommunication services, primarily Voice Over Internet Protocol (VOIP) services, to carriers across the globe. In pleading, the defendants admitted that between September 1999 and October 2004, they conspired with each other and other former ITXC employees and officers to make corrupt payments totaling approximately $450,000 to employees of foreign state-owned and foreign-owned telecommunications carriers in Nigeria, Rwanda, Senegal, and Mali to obtain and retain contracts for ITXC. For example, in Nigeria, ITXC entered into a service agreement with and agreed to pay a consulting company headed by an official of NITEL, the state-owned Nigerian telecommunications authority, in exchange for assistance in obtaining agreements with other service providers in the country. Between November 2002 and May 2004, ITXC wire transferred approximately $166,541.31 to the Nigerian bank account of the foreign official\u0027s company.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-101.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-101, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Department of Justice Press Release, \u0022Former ITXC Corporation Executives Sentenced for Roles in Foreign Bribery Scheme,\u0022 September 2, 2008, accessed at  http:\/\/www.justice.gov\/opa\/pr\/2007\/July\/07_crm_556.html","Documents":""},{"Case ID":"ST-235","Case Cluster ":"ITXC Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Rwanda, Senegal, Mali","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"05\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, False Accounting Violations, Aiding and Abetting Falsification of Books and Records, Aiding and Abetting Internal Controls Violations","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022Three former executives of ITXC Corporation, a global telecommunications company based in Princeton, NJ, have pleaded guilty to conspiring to violate the FCPA and the Travel Act in connection with a scheme to bribe government telecommunications officials in four African countries. ITXC was a publicly traded company that provided telecommunication services, primarily Voice Over Internet Protocol (VOIP) services, to carriers across the globe. In pleading, the defendants admitted that between September 1999 and October 2004, they conspired with each other and other former ITXC employees and officers to make corrupt payments totaling approximately $450,000 to employees of foreign state-owned and foreign-owned telecommunications carriers in Nigeria, Rwanda, Senegal, and Mali to obtain and retain contracts for ITXC. For example, in Nigeria, ITXC entered into a service agreement with and agreed to pay a consulting company headed by an official of NITEL, the state-owned Nigerian telecommunications authority, in exchange for assistance in obtaining agreements with other service providers in the country. Between November 2002 and May 2004, ITXC wire transferred approximately $166,541.31 to the Nigerian bank account of the foreign official\u0027s company.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-101.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-102, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20556 \/ May 6, 2008, Securities and Exchange Commission v. Steven J. Ott and Roger Michael Young, Civil Action No. 06-4195 (GEB) (D.N.J.), Securities and Exchange Commission v. Yaw Osei Amoako Civil Action No. 05-4284 (GEB) (D.N.J.), \u0022Former Executives Of ITXC Corp. Settle Foreign Bribery Charges,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20556.htm","Documents":""},{"Case ID":"ST-236","Case Cluster ":"ITXC Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Rwanda, Senegal, Mali","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"09\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$7,500.00","Criminal Fine\/Penalty (US$) ":"$7,500","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Conspiracy, Bribery of foreign officials, Commercial bribery","Offenses - Settled":"Conspiracy, Bribery of foreign officials, Commercial bribery","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022Three former executives of ITXC Corporation, a global telecommunications company based in Princeton, NJ, have pleaded guilty to conspiring to violate the FCPA and the Travel Act in connection with a scheme to bribe government telecommunications officials in four African countries. ITXC was a publicly traded company that provided telecommunication services, primarily Voice Over Internet Protocol (VOIP) services, to carriers across the globe. In pleading, the defendants admitted that between September 1999 and October 2004, they conspired with each other and other former ITXC employees and officers to make corrupt payments totaling approximately $450,000 to employees of foreign state-owned and foreign-owned telecommunications carriers in Nigeria, Rwanda, Senegal, and Mali to obtain and retain contracts for ITXC. For example, in Nigeria, ITXC entered into a service agreement with and agreed to pay a consulting company headed by an official of NITEL, the state-owned Nigerian telecommunications authority, in exchange for assistance in obtaining agreements with other service providers in the country. Between November 2002 and May 2004, ITXC wire transferred approximately $166,541.31 to the Nigerian bank account of the foreign official?s company.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-101.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-101, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Department of Justice Press Release, \u0022Former ITXC Corporation Executives Sentenced for Roles in Foreign Bribery Scheme,\u0022 September 2, 2008, accessed at  http:\/\/www.justice.gov\/opa\/pr\/2007\/July\/07_crm_556.html","Documents":""},{"Case ID":"ST-237","Case Cluster ":"ITXC Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Rwanda, Senegal, Mali","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"05\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$188,453.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$150,411","Civil Prejudgment Interest (US$) ":"$38,042","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"","Offenses - Alleged":"Bribery of Foreign Officials, False Accounting Violations, Aiding and Abetting Falsification of Books and Records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"YES","Summary":"According to the June 2011 United States Report to the OECD, \u0022Three former executives of ITXC Corporation, a global telecommunications company based in Princeton, NJ, have pleaded guilty to conspiring to violate the FCPA and the Travel Act in connection with a scheme to bribe government telecommunications officials in four African countries. ITXC was a publicly traded company that provided telecommunication services, primarily Voice Over Internet Protocol (VOIP) services, to carriers across the globe. In pleading, the defendants admitted that between September 1999 and October 2004, they conspired with each other and other former ITXC employees and officers to make corrupt payments totaling approximately $450,000 to employees of foreign state-owned and foreign-owned telecommunications carriers in Nigeria, Rwanda, Senegal, and Mali to obtain and retain contracts for ITXC. For example, in Nigeria, ITXC entered into a service agreement with and agreed to pay a consulting company headed by an official of NITEL, the state-owned Nigerian telecommunications authority, in exchange for assistance in obtaining agreements with other service providers in the country. Between November 2002 and May 2004, ITXC wire transferred approximately $166,541.31 to the Nigerian bank account of the foreign official?s company.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-101.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-101, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. http:\/\/www.justice.gov\/opa\/pr\/2007\/July\/07_crm_556.html","Documents":""},{"Case ID":"ST-238","Case Cluster ":"Japan Settlement","Jurisdiction of Settlement":"Japan","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"Month and Day unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,600.00","Criminal Fine\/Penalty (US$) ":"$2,600","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the OECD December 2011 Phase 3 Report of Japan, the case \u0022involved the bribery of two foreign government officials by Defendant \u0027A,\u0027 a senior executive of a foreign subsidiary of a Japanese company, and Defendant \u0027B,\u0027 an employee of the same foreign subsidiary, in order to obtain favourable treatment in a foreign public procurement contracting process.  The bribes, which were in the form of material gifts, were approximately JPY 800 000 (USD 10 400). [footnote: The conversion of Japanese Yen (JPY) into US dollars (USD) throughout this report is based on the exchange rate on 14 September 2011.]  The company did not win the contract, the value of which is not specified.  Defendant \u0027A,\u0027 a Japanese national, was convicted and fined JPY 500 000 (USD 6 500).  Defendant \u0027B,\u0027 also a Japanese national, was convicted and fined JPY 200 000 (USD 2 600).  The defendants admitted guilt and were convicted on summary trial.  The facts that gave rise to to the case took place in 2004, and the convictions were obtained in 2007.\u0022  (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Japan,\u0022 December 2011, at 9.)","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Japan,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/51\/49377330.pdf     http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Japanphase3reportEN.pdf","Documents":""},{"Case ID":"ST-239","Case Cluster ":"Japan Settlement","Jurisdiction of Settlement":"Japan","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"Month and Day unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$6,500.00","Criminal Fine\/Penalty (US$) ":"$6,500","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the OECD December 2011 Phase 3 Report of Japan, the case \u0022involved the bribery of two foreign government officials by Defendant \u0027A,\u0027 a senior executive of a foreign subsidiary of a Japanese company, and Defendant \u0027B,\u0027 an employee of the same foreign subsidiary, in order to obtain favourable treatment in a foreign public procurement contracting process.  The bribes, which were in the form of material gifts, were approximately JPY 800 000 (USD 10 400). [footnote: The conversion of Japanese Yen (JPY) into US dollars (USD) throughout this report is based on the exchange rate on 14 September 2011.]  The company did not win the contract, the value of which is not specified.  Defendant \u0027A,\u0027 a Japanese national, was convicted and fined JPY 500 000 (USD 6 500).  Defendant \u0027B,\u0027 also a Japanese national, was convicted and fined JPY 200 000 (USD 2 600).  The defendants admitted guilt and were convicted on summary trial.  The facts that gave rise to to the case took place in 2004, and the convictions were obtained in 2007.\u0022  (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Japan,\u0022 December 2011, at 9.)","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Japan,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/51\/49377330.pdf","Documents":""},{"Case ID":"ST-240","Case Cluster ":"Johnson \u0026 Johnson","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Greece, Poland, Romania, Iraq (UN Oil-for-Food)","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"04\/08","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$21,400,000.00","Criminal Fine\/Penalty (US$) ":"$21,400,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Statement of Facts agreed to be Johnson \u0026 Johson as part of its Deferred Prosecution Agreement, J\u0026J engaged in misconduct with respect to the UN Oil-for-Food program and in Greece, Poland and Romania.  In Greece, DePuy Inc. (Delaware-registered) and DePuy International (wholly owned subsidiary) from 2001 to 2003, Greek Agent A was paid approximately EUR 7,987,540, and from 2003 through 2005, Greek Agent B was paid approximately EUR 7,303,754; significant portion of these payments were used to pay cash incentives to Greek health care workers at publicly-owned hospitals to induce them to buy J\u0026J products; from 2002-2006, in addition to the payments to the agents, approximately EUR500,000 was withdrawn by J\u0026J subsidiary Depuy Hellas employees to cover payments owed to the health care workers by the agents but not yet paid.  In Poland, Johnson \u0026 Johnson Poland Sp. z.o.o. (wholly owned subsidiary) entered into approximately 4,400 civil contracts between 2000 and 2006, for which the company paid Romanian health care workers of publicly-owned hospitals approximately $3.65 million, some of which were used to make improper payments. Between 2000 and through 2006, J\u0026J also made approximately 15,000 payment sto sponsor travel for publicly-employed Polish health care professionals, totaling approximately $7.6 million, a portion of which were improper.  In Romania, between 2005 and 2008, Johnson \u0026 Johnson d.o.o. (wholly-owned Romanian subsidiary) and its employees directly or indirectly authorized th epayment of $140,000 in incentives to publicly-owned Romanian health care professionals (most of whom are government employees) to induce the purchase of pharmaceuticals manufactured by J\u0026J subsidiaries and operating companies.  In Iraq, between 2000 and 2003, Janssen Pharmaceutica, NV (wholly owned subsidiary headquartered in Beerse, Belgium) and Cilag AG International (wholly owned subsidiary headquartered in Schaffhausen, Switzerland) were awarded 18 contracts for the sale of pharmaceuticals to the Iraqi Ministry of Health State Company for Marketing Drugs and Medical Appliances under the UN Oil for Food Program, with a total contract value of approximately $9.9 million, which generated approximately $6.1 million in profits. Janssen and Cilag secured thse contracts through the payment of approximately $857,387 in kickbacks to the government of Iraq; the kickbacks were paid to the government of Iraq through a Lebanon Agent and concealed from the United Nations by inflating Janssen and Cilag\u0027s contract prices by 10%. Among the relevant considerations listed in the DPA are: Johnson and Johnson\u0027s agreement to resolve related cases then being investigated by the SEC and the UK Serious Fraud Office (SFO) (para 4-i) and the possibility that were the DOJ to \u0022initiate a prosecution of J\u0026J or one of its operating companies and obtain conviction, instead of entering into this Agreement to defer prosecution, J\u0026J could be subject to exclusion from participation in federal health programs pursuant to 42 U.S.C. Section 1320a-7(a). (para 4-j). Also as outlined in the DPA, J\u0026J agreed to pay a monetary penalty as part of its settlement with the Department of Justice that was \u0022a 25 percent reduction off the bottom of the fine range.\u0022 (para 6) (Source:  Johnson \u0026 Johnson, Deferred Prosecution Agreement and Attachment A: Statement of Facts, filed in US v. Depuy, Inc. Case No. 1:11-cr-00099-JDB (D.D.C. April 8, 2011)).  The US Department of Justice Press Release on the case noted that \u0022The Justice Department acknowledges and expresses its appreciation for the significant assistance provided by the authorities of the 8th Ordinary Interrogation Department of the Athens Court of First Instance and the Athens Economic Crime Squad in Greece; the 5th Investigation Department of the Regional Prosecutor\u0027s Office in Radom, Poland; the Fraud Squad of the West Yorkshire Police Department in the United Kingdom; and the SEC\u0027s Division of Enforcement, as well as the coordination and cooperation with the authorities of the United Kingdom\u0027s Serious Fraud Office.\u0022 (Source: US Department of Justice Press Release, \u0022Johnson \u0026 Johnson Agrees to Pay $21.4 Million Criminal Penalty to Resolve Foreign Corrupt Practices Act and Oil for Food Investigations,\u0022 April 8, 2011.)","Sources ":"Johnson \u0026 Johnson, Deferred Prosecution Agreement and Attachment A: Statement of Facts, filed in US v. Depuy, Inc. Case No. 1:11-cr-00099-JDB (D.D.C. April 8, 2011), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/depuy-inc\/04-08-11depuy-dpa.pdf;  US Department of Justice Press Release, \u0022Johnson \u0026 Johnson Agrees to Pay $21.4 Million Criminal Penalty to Resolve Foreign Corrupt Practices Act and Oil for Food Investigations,\u0022 April 8, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/April\/11-crm-446.html;  US Securities and Exchange Commission, Litigation Release No. 21922 \/ April 8, 2011, \u0022Johnson and Johnson to pay more than $70 million in settled FCPA enforcement action,\u0022 Securities and Exchange Commission v. Johnson \u0026 Johnson, Civil Action No. 1: 11-CV-00686-EFH  (D.D.C., April 8, 2011).   See also Johnson \u0026 Johnson Press Release, \u0022Johnson \u0026 Johnson Announces Settlement with U.S. Department of Justice and U.S. Securities and Exchange Commission,\u0022 April 8, 2011, accessed at http:\/\/www.jnj.com\/connect\/news\/all\/johnson-johnson-announces-settlement-with-us-department-of-justice-and+us-securities-and-exchange-commission","Documents":""},{"Case ID":"ST-241","Case Cluster ":"Johnson \u0026 Johnson","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Greece, Poland, Romania, Iraq (UN Oil-for-Food)","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"04\/08","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$48,666,316.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$38,227,826","Civil Prejudgment Interest (US$) ":"$10,438,490","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Statement of Facts agreed to be Johnson \u0026 Johson as part of its Deferred Prosecution Agreement with the Department of Justice, J\u0026J engaged in misconduct with respect to the UN Oil-for-Food program and in Greece, Poland and Romania.  In Greece, DePuy Inc. (Delaware-registered) and dePuy International (wholly owned subsidiary) from 2001 to 2003, Greek Agent A was paid approximately EUR 7,987,540, a and from 2003 through 2005, Greek Agent B was paid approximately EUR 7,303,754; significant portion of these payments were used to pay cash incentives to Greek health care workers at publicly-owned hospitals to induce them to buy J\u0026J products; from 2002-2006, in addition to the payments to the agents, approximately EUR500,000 was withdrawn by J\u0026J subsidiary Depuy Hellas employees to cover payments owed to the health care workers by the agents but not yet paid.  In Poland, Johnson \u0026 Johnson Poland Sp. z.o.o. (wholly owned subsidiary) entered in to approximately 4,400 civil contracts between 2000 and 2006, for which the company paid Romanian health care workers of publicly-owned hospitals approximately $3.65 million, some of which were used to make improper payments. Between 2000 and through 2006, J\u0026J also made approximately 15,000 payment sto sponsor travel for publicly-employed Polish health care professionals, totaling approximately $7.6 million, a portion of which were improper.  In Romania, between 2005 and 2008, Johnson \u0026 Johnson d.o.o. (wholly-owned Romanian subsidiary) and its employees directly or indirectly authorized the payment of $140,000 in incentives to publicly-owned Romanian health care professionals (most of whom are government employees) to induce the purchase of pharmaceuticals manufactured by J\u0026J subsidiaries and operating companies.  In Iraq, between 2000 and 2003, Janssen Pharmaceutica, NV (wholly owned subsidiary headquartered in Beerse, Belgium) and Cilag AG International (wholly owned subsidiary headquartered in Schaffhausen, Switzerland) were awarded 18 contracts for the sale of pharmaceuticals to the Iraqi Ministry of Health State Company for Marketing Drugs and Medical Appliances under the UN Oil for Food Program, wht a total contract value of approximately $9.9 million, which generated approximately $6.1 million in profits. Janssen and Cilag secured thse contracts through the payment of approximately $857,387 in kickbacks to the government of Iraq; the kickbacks were paid to the government of Iraq through a Lebanon Agent and concealed from the United Nations by inflating Janssen and Cilag\u0027s contract prices by 10%. Among the relevant considerations listed in the DPA are: Johnson and Johnson\u0027s agreement to resolve related cases then being investigated by the SEC and the UK Serious Fraud Office (SFO) (para 4-i) and the possibility that were the DOJ to \u0022initiate a prosecution of J\u0026J or one of its operating companies and obtain conviction, instead of entering into this Agreement to defer prosecution, J\u0026J could be subject to exclusion from participation in federal health programs pursuant to 42 U.S.C. Section 1320a-7(a). (para 4-j). Also as outlined in the DPA, J\u0026J agreed to pay a monetary penalty as part of its settlement with the Department of Justice that was \u0022a 25 percent reduction off the bottom of the fine range.\u0022 (para 6) (Source:  Johnson \u0026 Johnson, Deferred Prosecution Agreement and Attachment A: Statement of Facts, filed in US v. Depuy, Inc. Case No. 1:11-cr-00099-JDB (D.D.C. April 8, 2011)).  SEC:  \u0022Without admitting or denying the SEC\u0027s allegations, J\u0026J has consented to the entry of a court order permanently enjoining it from future violations of Sections 30A, 13(b)(2)(A), and 13(b)(2)(B) of the Securities Exchange Act of 1934; ordering it to pay $38,227,826 in disgorgement and $10,438,490 in prejudgment interest; and ordering it to comply with certain undertakings regarding its FCPA compliance program.\u0022 (Source: US Securities and Exchange Commission, Litigation Release No. 21922 \/ April 8, 2011, \u0022Johnson and Johnson to pay more than $70 million in settled FCPA enforcement action,\u0022 Securities and Exchange Commission v. Johnson \u0026 Johnson, Civil Action No. 1: 11-CV-00686-EFH  (D.D.C., April 8, 2011), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr21922.htm.)  The US Department of Justice Press Release on the case noted that \u0022The Justice Department acknowledges and expresses its appreciation for the significant assistance provided by the authorities of the 8th Ordinary Interrogation Department of the Athens Court of First Instance and the Athens Economic Crime Squad in Greece; the 5th Investigation Department of the Regional Prosecutor\u0027s Office in Radom, Poland; the Fraud Squad of the West Yorkshire Police Department in the United Kingdom; and the SEC\u0027s Division of Enforcement, as well as the coordination and cooperation with the authorities of the United Kingdom\u0027s Serious Fraud Office.\u0022 (Source: US Department of Justice Press Release, \u0022Johnson \u0026 Johnson Agrees to Pay $21.4 Million Criminal Penalty to Resolve Foreign Corrupt Practices Act and Oil for Food Investigations,\u0022 April 8, 2011.)","Sources ":"US Securities and Exchange Commission, Litigation Release No. 21922 \/ April 8, 2011, \u0022Johnson and Johnson to pay more than $70 million in settled FCPA enforcement action,\u0022 Securities and Exchange Commission v. Johnson \u0026 Johnson, Civil Action No. 1: 11-CV-00686-EFH  (D.D.C., April 8, 2011); Johnson \u0026 Johnson, Deferred Prosecution Agreement and Attachment A: Statement of Facts, filed in US v. Depuy, Inc. Case No. 1:11-cr-00099-JDB (D.D.C. April 8, 2011), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/depuy-inc\/04-08-11depuy-dpa.pdf;  US Department of Justice Press Release, \u0022Johnson \u0026 Johnson Agrees to Pay $21.4 Million Criminal Penalty to Resolve Foreign Corrupt Practices Act and Oil for Food Investigations,\u0022 April 8, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/April\/11-crm-446.html.  See also Johnson \u0026 Johnson  Press Release, \u0022Johnson \u0026 Johnson Announces Settlement with U.S. Department of Justice and U.S. Securities and Exchange Commission,\u0022 April 8, 2011, accessed at http:\/\/www.jnj.com\/connect\/news\/all\/johnson-johnson-announces-settlement-with-us-department-of-justice-and+us-securities-and-exchange-commission http:\/\/www.investor.jnj.com\/releasedetail.cfm?releaseid=564971  and add the following link: http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr21922.htm","Documents":""},{"Case ID":"ST-244","Case Cluster ":"Julian Messent (PWS International Ltd.)","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Costa Rica","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"10\/26","Other Jurisdictions of Settlement":"Costa Rica","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Restitution","Total Monetary Sanctions (US$)":"$157,399.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$157,399","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$157,399","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Costa Rica","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 2","Offenses - Alleged":"Making or authorizing corrupt payments (section 1(1) of the Prevention of Corruption Act 1906)","Offenses - Settled":"Making or authorizing corrupt payments (section 1(1) of the Prevention of Corruption Act 1906)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office Press Release, on October 26, 2010, Julian Messent, former head of the Property (Americas) Division at London-based insurance bsiness PWS International Ltd., pleaded guilty at Southwark Court to two counts of making corrupt payments between February 1999 and 2002.  He was sentenced to 21 months\u0027 imprisonment and ordered to pay GBP 100,000 in compensation within 28 days to the Republic of Costa Rica or serve an additional 12 months imprisonment if he fails to do so. The corrupt payments were: (1) in 1999, a payment of $25,832.22 to Roxana Cordero Bogantes, the wife of Alvaro Alcuna, an agent of the Instituto Nacional de Seguros of the Republic of Costa Rica, and (2) in 2002, payment of $250,000 to Reska Financial Inc., a company associated with an agent of the Instituto Nacional de Seguros of the Republic of Costa Rica, namely Critobal Zawadski; both payments were as  inducment or reward for assisting in the appointment or retention of PWS International Limited as broker of the reinsurance contract known as \u0022U-500.\u0022  The Press Release also noted that between 1999 and 2002, Messent authorized 41 corrupt payments totalling $1,982,230.77 to Costa Rican officials, their wives and associated companies. This was a joint investigation by the SFO and the City of London Police.  Following elections in Costa Rica in 2002, officials in INS and ICE were replaced. Enquiries were made into the contract with PWS and the payments made unider it; the Foreign and Commonwealth Office referred the case to SFO in October 2005. (Source: UK Serious Fraud Office, \u0022Insurance Broker jailed for bribing Costa Rican officials,\u0022 October 26, 2010.)  The US Government cited the case of Julian Messent in its Response to ICE\u0027s [Instituto Costariccense de Electricidad\u0027s] Petition for Victim Status and Restitution, noting that in Messent\u0027s case, he had admitted that he authorized corrupt payments of almost $2 million to Costa Rican officials at ICE and the state insurance company, Instituto Nacional de Seguros, and that under the UK sentencing order, Messent was not required to pay restitution to ICE or Instituto Nacional de Seguros. Rather, he was ordered to pay money to the government of Costa Rica, something which Alcatel-Lucent had done in the US settlement cases. (Source: US v. Alcatel France S.A., et al Case No. 1:10-cr-20906-MGC and US v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907-MGC (S.D. Fla.), Government\u0027s Response to ICE\u0027s Petition for Victim Status and Restitution filed May 23, 2011).  ","Sources ":"United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf;  UK Serious Fraud Office Press Release, \u0022Insurance Broker jailed for bribing Costa Rican officials,\u0022 October 26, 2010, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2010\/insurance-broker-jailed-for-bribing-costa-rican-officials.aspx; US v. Alcatel France S.A., et al Case No. 1:10-cr-20906-MGC and US v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907-MGC (S.D. Fla.), Government\u0027s Response to ICE\u0027s Petition for Victim Status and Restitution filed May 23, 2011 (obtained via Pacer).  ","Documents":""},{"Case ID":"ST-245","Case Cluster ":"Kazakh Oil Mining","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Kazakhstan","Year of Settlement":"2003","Month\/Day of Settlement (or Notes)":"09\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Restitution","Total Monetary Sanctions (US$)":"$8,025,000.00","Criminal Fine\/Penalty (US$) ":"$25,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$8,000,000","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Subscribing to False Tax Returns, Tax Evasion","Offenses - Settled":"Subscribing to False Tax Returns, Tax Evasion","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On April 2, 2003, James H. Giffen, the Chairman of The Mercator Corporation (Mercator), a merchant bank with offices in New York and the Republic of Kazakhstan, was indicted in the Southern District of New York on charges that he made a series of illegal payments to senior Kazakh officials in connection with numerous oil deals in that country. According to court documents, Giffen allegedly made corrupt payments to senior Kazakh officials in connection with the following transactions in which Giffen represented the Republic of Kazakhstan: 1) Mobil Oil\u0027s 1996 purchase of a 25% share in the Tengiz oil field; (2) Mobil Oil\u0027s 1995 agreement to finance the processing and sale of gas condensate from the Karachaganak oil and gas field; (3) Amoco\u0027s 1997 purchase of a share in the Caspian Pipeline Consortium; (4) Texaco and other oil companies\u0027 purchase of a share in the Karachaganak oil and gas field in 1998; (5) Mobil and other oil companies\u0027 1998 purchase of exploration rights in the Kazakh portion of the Caspian Sea, and; (6) Phillips Petroleum\u0027s 1998 purchase of Caspian Sea exploration rights. [  ] According to the original indictment, Giffen and Mercator were advisors to the Kazakh government on strategic planning, development of foreign investment and the negotiation of priority investment projects relating to the exploration, development, production, transportation, and processing of oil and gas. During this period, Giffen had held the title of counselor to the President of Kazakhstan. According to the charges, Mobil oil agreed to pay the success fees owed by Kazakhstan to Giffen and Mercator, and out of those fees, Giffen made unlawful payments of $22 million dollars to secret Swiss accounts beneficially owned by two high level Kazakh officials.  In addition, according to the Indictment, between 1995 and 2000, Giffen caused approximately $70 million paid by various oil companies into escrow accounts in Switzerland in connection with the purchase of oil and gas rights in Kazakhstan to be diverted into secret Swiss bank accounts under his control. Giffen then used this money to make additional unlawful payments of approximately $55 million to the two senior officials of the Kazakh Government.  Also on April 2, 2003, J. Bryan Williams a senior executive at Mobil Oil, was charged in connection with a kickback and tax evasion scheme involving a related oil deal in Kazakhstan. According to court documents, Williams was sent by Mobil\u0027s Chairman to finalize the negotiations with Kazakhstan regarding Mobil\u0027s purchase for approximately $1 billion of a 25% interest in the Tengiz oil field in 1996. After the Tengiz deal closed, Mobil paid $41 million to a New York merchant bank that represented the Republic of Kazakhstan in the transaction. The merchant bank\u0027s Chairman kicked back $2 million of that payment to Williams, by transferring money through a secret Swiss bank account.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, The Mercator Corporation Case Summary at 104-106.)  According to the Press Release by the United States Attorney for the Southern District of New York, Swiss authorities provided \u0022outstanding cooperation\u0022 in the case.  (Source:  United States Attorney for the Southern District of New York, \u0022Former Mobil Executive Sentenced on Tax Evasion Charges in Connection with Kazakhstan Oil Transactions,\u0022 September 18, 2003.)  According to the Court Docket Report in the case, the ordered restitution was to be paid to the US Internal Revenue Services.  (Source:  US v. Williams, Case No. 03-cr-406 (SDNY), Court Docket Report retrieved January 15, 2012, via Pacer.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, The Mercator Corporation Case Summary at 104-106, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Williams, Case No. 03-cr-406-HB (SDNY), Superseding Indictment filed April 14, 2003, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/williamsjb\/04-14-03williams-supersed-indict.pdf; Superseding Information filed June 12, 2003, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/williamsjb\/06-12-03williams-supersed-info.pdf; Amended Judgment filed October 22, 2003, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/williamsjb\/04-02-03williams-judgment.pdf; Court Docket Report retrieved January 15, 2012, via Pacer.  United States Attorney for the Southern District of New York, \u0022Former Mobil Executive Sentenced on Tax Evasion Charges in Connection with Kazakhstan Oil Transactions,\u0022 September 18, 2003, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/williamsjb\/09-18-03williams-pressrelease.pdf. ","Documents":""},{"Case ID":"ST-246","Case Cluster ":"Kazakh Oil Mining","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Kazakhstan","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture of any interest held in specified bank accounts ","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"BOTA Foundation (see Summary for explanation)","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Commit Wire Fraud, Conspiracy to Commit Mail Fraud, Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering, Conspiracy to Defraud the United States by Impairing and Impeding Its Lawful Functions, Bribery of Foreign Officials, Wire Fraud, Mail fraud, International Money Laundering, Money Laundering, Obstructing the Enforcement of the Internal Revenue Service, Subscribing to False Tax Returns, Failure to Supply Information Regarding Foreign Bank Accounts on an Income Tax Return ","Offenses - Settled":"Failure to Supply Information Regarding Foreign Bank Accounts on an Income Tax Return ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On April 2, 2003, James H. Giffen, the Chairman of The Mercator Corporation (Mercator), a merchant bank with offices in New York and the Republic of Kazakhstan, was indicted in the Southern District of New York on charges that he made a series of illegal payments to senior Kazakh officials in connection with numerous oil deals in that country. According to court documents, Giffen allegedly made corrupt payments to senior Kazakh officials in connection with the following transactions in which Giffen represented the Republic of Kazakhstan: 1) Mobil Oil\u0027s 1996 purchase of a 25% share in the Tengiz oil field; (2) Mobil Oil\u0027s 1995 agreement to finance the processing and sale of gas condensate from the Karachaganak oil and gas field; (3) Amoco\u0027s 1997 purchase of a share in the Caspian Pipeline Consortium; (4) Texaco and other oil companies\u0027 purchase of a share in the Karachaganak oil and gas field in 1998; (5) Mobil and other oil companies\u0027 1998 purchase of exploration rights in the Kazakh portion of the Caspian Sea, and; (6) Phillips Petroleum\u0027s 1998 purchase of Caspian Sea exploration rights. [  ] According to the original indictment, Giffen and Mercator were advisors to the Kazakh government on strategic planning, development of foreign investment and the negotiation of priority investment projects relating to the exploration, development, production, transportation, and processing of oil and gas. During this period, Giffen had held the title of counselor to the President of Kazakhstan. According to the charges, Mobil oil agreed to pay the success fees owed by Kazakhstan to Giffen and Mercator, and out of those fees, Giffen made unlawful payments of $22 million dollars to secret Swiss accounts beneficially owned by two high level Kazakh officials.  In addition, according to the Indictment, between 1995 and 2000, Giffen caused approximately $70 million paid by various oil companies into escrow accounts in Switzerland in connection with the purchase of oil and gas rights in Kazakhstan to be diverted into secret Swiss bank accounts under his control. Giffen then used this money to make additional unlawful payments of approximately $55 million to the two senior officials of the Kazakh Government.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, The Mercator Corporation Case Summary at 104-106.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, The Mercator Corporation Case Summary at 104-106, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. James H. Giffen, Case No. 2:03-cr-404 (SDNY), Complaint filed March 28, 2003, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/giffen\/03-28-03giffen-complaint.pdf; Second Superseding Indictment filed August 4, 2004, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/giffen\/08-04-04giffen-second-superseding-indict.pdf; Plea Agreement dated August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/giffen\/08-06-10giffen-plea-agree.pdf; Judgment filed November 23, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/giffen\/11-23-10giffen-judgment.pdf","Documents":""},{"Case ID":"ST-247","Case Cluster ":"Kazakh Oil Mining","Jurisdiction of Settlement":"Kazakhstan","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Kazakhstan","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"05\/02","Other Jurisdictions of Settlement":"Switzerland, United States","Settlement with Individual or Legal Person?":"Other (In Rem Forfeiture) ","Type of Settlement":"Other","Legal Form of Settlement":"Memorandum of Understanding","Monetary Sanctions  (Types)":"Civil Asset Forfeiture","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"BOTA Foundation (see Summary for explanation)","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Forfeiture","Offenses - Settled":"Forfeiture","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"Pursuant to a 2007 Memorandum of Understanding among the Governments of Kazakhstan, Switzerland and the United States, approximately $84 mllion held on deposit in the account of Orel Capital Ltd. at Credit Agricole Indosuez in Geneva, Switzerland were transferred in July 1999 to an account in the name of the Treasury of the Ministry of Finance of the Republic of Kazakhstan at Pictet \u0026 Cie in Geneva, Switzerland.  The funds had been frozen by order of a Swiss examining magistrate and in the United States, a criminal indictment had been filed against James H. Giffen which included a criminal forfeiture allegation.  The MOU stipulated that the funds be used to establish and operate the BOTA Foundation which carries out social programs and whose operations are being overseen by the World Bank pursuant to a Service Agreement.  (Source:  Memorandum of Understanding Among the Governments of the United States of America, the Swiss Confederation, and the Republic of Kazakhstan (May 2007); Amended in 2008.)  Please note that the amount of forfeited and returned sums are noted on the Kazakh Oil Mining - US Settlement Bota Foundation entry only so as to avoid double counting of settlement sums.","Sources ":"Memorandum of Understanding by the Swiss Confederation, United States and the Republic of Kazakhstan (May 2007) and Annex 2 (Service Agreement for TDB BOTA Foundation among the International Bank for Reconstruction and Development and the Governments of the United States of America, the Swiss Confederation, and the Republic of Kazakhstan, accessed at http:\/\/www.state.gov\/documents\/organization\/108887.pdf.  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, The Mercator Corporation Case Summary at 104-106, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Approximately $84 Million, Case No. 2:07-cr-03559-LAP (SDNY), Verified Complaint for forfeiture in rem, filed May 3, 2007 and Final Order filed June 1, 2009 (both accessed via Pacer). ","Documents":""},{"Case ID":"ST-248","Case Cluster ":"Kazakh Oil Mining","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Kazakhstan","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"05\/02","Other Jurisdictions of Settlement":"Kazakhstan, United States","Settlement with Individual or Legal Person?":"Other (Confiscated Funds)","Type of Settlement":"Other","Legal Form of Settlement":"Memorandum of Understanding  ","Monetary Sanctions  (Types)":"Civil Confiscation","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"BOTA Foundation (see Summary for explanation)","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"Pursuant to a 2007 Memorandum of Understanding among the Governments of Kazakhstan, Switzerland and the United States, approximately $84 mllion held on deposit in the account of Orel Capital Ltd. at Credit Agricole Indosuez in Geneva, Switzerland were transferred in July 1999 to an account in the name of the Treasury of the Ministry of Finance of the Republic of Kazakhstan at Pictet \u0026 Cie in Geneva, Switzerland.  The funds had been frozen by order of a Swiss examining magistrate and in the United States, a criminal indictment had been filed against James H. Giffen and Mercator Corporation which included a criminal forfeiture allegation.  The MOU stipulated that the funds be used to establish and operate the BOTA Foundation which carries out social programs and whose operations are being overseen by the World Bank pursuant to a Service Agreement.  (Source:  Memorandum of Understanding Among the Governments of the United States of America, the Swiss Confederation, and the Republic of Kazakhstan (May 2007); Amended in 2008.)   Please note that the amount of forfeited and returned sums are noted on the Kazakh Oil Mining - US Bota Foundation entry only so as to avoid double counting of settlement sums.","Sources ":"Memorandum of Understanding by the Swiss Confederation, United States and the Republic of Kazakhstan (May 2007) and Annex 2 (Service Agreement for TDB BOTA Foundation among the International Bank for Reconstruction and Development and the Governments of the United States of America, the Swiss Confederation, and the Republic of Kazakhstan, accessed at http:\/\/www.state.gov\/documents\/organization\/108887.pdf.  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, The Mercator Corporation Case Summary at 104-105, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-249","Case Cluster ":"Kazakh Oil Mining","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Kazakhstan","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"05\/02","Other Jurisdictions of Settlement":"Kazakhstan, Switzerland","Settlement with Individual or Legal Person?":"Other (Confiscated Funds)","Type of Settlement":"Other","Legal Form of Settlement":"Memorandum of Understanding  ","Monetary Sanctions  (Types)":"Civil Confiscation","Total Monetary Sanctions (US$)":"$84,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"$84,000,000","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$84,000,000","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"BOTA Foundation (see Summary for explanation)","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"Pursuant to a 2007 Memorandum of Understanding among the Governments of Kazakhstan, Switzerland and the United States, approximately $84 mllion held on deposit in the account of Orel Capital Ltd. at Credit Agricole Indosuez in Geneva, Switzerland were transferred in July 1999 to an account in the name of the Treasury of the Ministry of Finance of the Republic of Kazakhstan at Pictet \u0026 Cie in Geneva, Switzerland.  The funds had been frozen by order of a Swiss examining magistrate and in the United States, a criminal indictment had been filed against James H. Giffen and Mercator Corporation which included a criminal forfeiture allegation.  The MOU stipulated that the funds be used to establish and operate the BOTA Foundation which carries out social programs and whose operations are being overseen by the World Bank pursuant to a Service Agreement.  (Source:  Memorandum of Understanding Among the Governments of the United States of America, the Swiss Confederation, and the Republic of Kazakhstan (May 2007); Amended in 2008.)   Please note that the amount of forfeited and returned sums are noted on the Kazakh Oil Mining - US Settlement Bota Foundation entry only so as to avoid double counting of settlement sums.","Sources ":"Memorandum of Understanding by the Swiss Confederation, United States and the Republic of Kazakhstan (May 2007) and Annex 2 (Service Agreement for TDB BOTA Foundation among the International Bank for Reconstruction and Development and the Governments of the United States of America, the Swiss Confederation, and the Republic of Kazakhstan, accessed at http:\/\/www.state.gov\/documents\/organization\/108887.pdf.  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, The Mercator Corporation Case Summary at 104-105, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-250","Case Cluster ":"Kazakh Oil Mining","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Kazakhstan","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine; Criminal forfeiture","Total Monetary Sanctions (US$)":"$32,000.00","Criminal Fine\/Penalty (US$) ":"$32,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"BOTA Foundation (see Summary for explanation)","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On April 2, 2003, James H. Giffen, the Chairman of The Mercator Corporation (Mercator), a merchant bank with offices in New York and the Republic of Kazakhstan, was indicted in the Southern District of New York on charges that he made a series of illegal payments to senior Kazakh officials in connection with numerous oil deals in that country. According to court documents, Giffen allegedly made corrupt payments to senior Kazakh officials in connection with the following transactions in which Giffen represented the Republic of Kazakhstan: 1) Mobil Oil\u0027s 1996 purchase of a 25% share in the Tengiz oil field; (2) Mobil Oil\u0027s 1995 agreement to finance the processing and sale of gas condensate from the Karachaganak oil and gas field; (3) Amoco\u0027s 1997 purchase of a share in the Caspian Pipeline Consortium; (4) Texaco and other oil companies\u0027 purchase of a share in the Karachaganak oil and gas field in 1998; (5) Mobil and other oil companies\u0027 1998 purchase of exploration rights in the Kazakh portion of the Caspian Sea, and; (6) Phillips Petroleum\u0027s 1998 purchase of Caspian Sea exploration rights.  Subsequently, on August 6, 2010, Mercator was charged with one count of violating the anti-bribery provisions of the FCPA in connection with the purchase of two snowmobiles in November 1999. These snowmobiles were later shipped to Kazakhstan for delivery to a senior Kazakh official.According to the original indictment, Giffen and Mercator were advisors to the Kazakh government on strategic planning, development of foreign investment and the negotiation of priority investment projects relating to the exploration, development, production, transportation, and processing of oil and gas. During this period, Giffen had held the title of counselor to the President of Kazakhstan. According to the charges, Mobil oil agreed to pay the success fees owed by Kazakhstan to Giffen and Mercator, and out of those fees, Giffen made unlawful payments of $22 million dollars to secret Swiss accounts beneficially owned by two high level Kazakh officials.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, The Mercator Corporation Case Summary at 104-106.)   Please note that the amount of forfeited and returned sums are noted on the Kazakh Oil Mining - US Settlement Bota Foundation entry only so as to avoid double counting of settlement sums.","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, The Mercator Corporation Case Summary at 104-106, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Mercator Corporation, Case No. 1:03-cr-404-WHP (S.D.N.Y.), Superseding Information filed August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/mercator\/08-06-10mercator-info.pdf; Plea Agreement filed August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/mercator\/08-06-10mercator-plea-agmt.pdf; Judgment filed November 23, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/mercator\/11-30-10mercator-judgment.pdf.  United States Attorney for the Southern District of New York Press Release, \u0022New York Merchant Bank Pleads Guilty to FCPA Violation; Bank Chairman Pleads Guilty to Failing to Disclose Control of Foreign Bank Account,\u0022 August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/giffen\/08-06-10giffen-press-plea-usao-sdny.pdf","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Kazakhstan_Oil_Switzerland_MOU-CH-US-KZ_BOTA_FDN_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Kazakhstan_Oil_Final_Order_Jun_1_2009.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Kazakhstan_Oil_%2484m_Verified_Complaint_May_3_2007.pdf"},{"Case ID":"ST-251","Case Cluster ":"Latin Node Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Honduras, Yemen","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"04\/07","Other Jurisdictions of Settlement":"[Yemen: investigation]","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,000,000.00","Criminal Fine\/Penalty (US$) ":"$2,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On March 23, 2009, Latin Node Inc. (LatiNode) was charged with one count of violating the anti-bribery provisions of the FCPA in connection with improper payment in Honduras and Yemen. According to court documents, LatiNode was a privately held Florida corporation that provided wholesale telecommunications services using Internet protocol technology in a number of countries throughout the world, including Honduras and Yemen.  On December 14, 2010, LatiNode\u0027s former CEO and Vice President for Business Development, Jorge Granados and Manuel Caceres, were indicted by a Grand Jury in the Southern District of Florida on 19 counts of conspiracy, violations of the FCPA, and money laundering. Subsequently, on December 17, 2010, Manuel Salvoch, LatiNode\u0027s former CFO, and Juan Pablo V. Vasquez, a former senior commercial executive at LatiNode, were each charged with one count of conspiracy to violate the anti-bribery provisions of the FCPA.\u0022  According to the Report, in Honduras, \u0022between September 2006 and June 2007, these executives paid or caused to be paid more than $500,000 in bribes to the Honduran officials. In all, according to court documents filed in the case against LatiNode, between March 2004 and June 2007, the company paid or caused to be paid approximately $1,099,889 in payments to third parties, knowing that some or all of those funds would be passed on as bribes to officials of Hondutel. In addition to the payments for the interconnection agreement, LatiNode admitted that these payments were also, in part, intended to secure reduced call termination rates for the company\u0027s traffic.  Each of these illicit payments originated from LatiNode\u0027s Miami bank account, and many of the payments were concealed by laundering the money through LatiNode subsidiaries in Guatemala and through accounts in Honduras controlled by Honduran government officials.\u0022  In Yemen, according to the same Report, \u0022LatiNode admitted that from approximately July 2005 through April 2006, the company made 17 payments totaling approximately $1,150,654 to a third-party consultant with the knowledge that some or all of the money would be passed on to Yemeni officials in exchange for favorable interconnection rates in Yemen. Each of these payments was also made from LatiNode\u0027s Miami bank account. Company e-mails indicated that company executives believed that potential recipients of these payments included Yemeni government officials.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30.)  According to the World Bank Anti-Corruption Authorities website, Yemen was investigating the case (Source:  Anti-Corruption Authorities, Yemeni Anti-Corruption Authority summary of work on Latin Node case, accessed on January 18, 2012 at http:\/\/www.acauthorities.org\/aca\/sucessstory\/case-no-09-20239cr-houck-0-50-wvan-against-latin-no-de-inc-company.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Latin Node, Inc., Case No. 1:09-cr-20239-PCH (S.D. Fla.), Information filed March 24, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/litton-applied\/03-23-09latinnode-info.pdf; Plea Agreement filed April 3, 2009, accessed at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/litton-applied\/04-03-09latinnode-plea-agree.pdf; Statement of Offense filed April 3, 2009 accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/litton-applied\/04-03-09latinnode-state-offense.pdf.  The World Bank, Anti-Corruption Authorities, Yemeni Anti-Corruption Authority summary of work on Latin Node case, accessed on January 18, 2012 at http:\/\/www.acauthorities.org\/aca\/sucessstory\/case-no-09-20239cr-houck-0-50-wvan-against-latin-no-de-inc-company.","Documents":""},{"Case ID":"ST-252","Case Cluster ":"Latin Node Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Honduras, Yemen","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"05\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to commit international money laundering, Bribery of foreign officials, International money laundering","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On March 23, 2009, Latin Node Inc. (LatiNode) was charged with one count of violating the anti-bribery provisions of the FCPA in connection with improper payment in Honduras and Yemen. According to court documents, LatiNode was a privately held Florida corporation that provided wholesale telecommunications services using Internet protocol technology in a number of countries throughout the world, including Honduras and Yemen.  On December 14, 2010, LatiNode\u0027s former CEO and Vice President for Business Development, Jorge Granados and Manuel Caceres, were indicted by a Grand Jury in the Southern District of Florida on 19 counts of conspiracy, violations of the FCPA, and money laundering. Subsequently, on December 17, 2010, Manuel Salvoch, LatiNode\u0027s former CFO, and Juan Pablo V. Vasquez, a former senior commercial executive at LatiNode, were each charged with one count of conspiracy to violate the anti-bribery provisions of the FCPA.\u0022  According to the Report, in Honduras, \u0022between September 2006 and June 2007, these executives paid or caused to be paid more than $500,000 in bribes to the Honduran officials. In all, according to court documents filed in the case against LatiNode, between March 2004 and June 2007, the company paid or caused to be paid approximately $1,099,889 in payments to third parties, knowing that some or all of those funds would be passed on as bribes to officials of Hondutel. In addition to the payments for the interconnection agreement, LatiNode admitted that these payments were also, in part, intended to secure reduced call termination rates for the company\u0027s traffic.  Each of these illicit payments originated from LatiNode\u0027s Miami bank account, and many of the payments were concealed by laundering the money through LatiNode subsidiaries in Guatemala and through accounts in Honduras controlled by Honduran government officials.\u0022  In Yemen, according to the same Report, \u0022LatiNode admitted that from approximately July 2005 through April 2006, the company made 17 payments totaling approximately $1,150,654 to a third-party consultant with the knowledge that some or all of the money would be passed on to Yemeni officials in exchange for favorable interconnection rates in Yemen. Each of these payments was also made from LatiNode\u0027s Miami bank account. Company e-mails indicated that company executives believed that potential recipients of these payments included Yemeni government officials.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Granados and Vasquez, Case No. 1:10-cr-20881 (S.D. Fla.), Indictment filed on December 21, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/granados-jorge\/12-21-10granados-indict.pdf; Plea Agreement filed May 19, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/granados-jorge\/05-19-11granados-plea.pdf; Judgment in a Criminal Case filed September 13, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/granados-jorge\/09-13-11granados-judgment.pdf","Documents":""},{"Case ID":"ST-253","Case Cluster ":"Latin Node Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Honduras, Yemen","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"01\/21","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$7,500.00","Criminal Fine\/Penalty (US$) ":"$7,500 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On March 23, 2009, Latin Node Inc. (LatiNode) was charged with one count of violating the anti-bribery provisions of the FCPA in connection with improper payment in Honduras and Yemen. According to court documents, LatiNode was a privately held Florida corporation that provided wholesale telecommunications services using Internet protocol technology in a number of countries throughout the world, including Honduras and Yemen.  On December 14, 2010, LatiNode\u0027s former CEO and Vice President for Business Development, Jorge Granados and Manuel Caceres, were indicted by a Grand Jury in the Southern District of Florida on 19 counts of conspiracy, violations of the FCPA, and money laundering. Subsequently, on December 17, 2010, Manuel Salvoch, LatiNode\u0027s former CFO, and Juan Pablo V. Vasquez, a former senior commercial executive at LatiNode, were each charged with one count of conspiracy to violate the anti-bribery provisions of the FCPA.\u0022  According to the Report, in Honduras, \u0022between September 2006 and June 2007, these executives paid or caused to be paid more than $500,000 in bribes to the Honduran officials. In all, according to court documents filed in the case against LatiNode, between March 2004 and June 2007, the company paid or caused to be paid approximately $1,099,889 in payments to third parties, knowing that some or all of those funds would be passed on as bribes to officials of Hondutel. In addition to the payments for the interconnection agreement, LatiNode admitted that these payments were also, in part, intended to secure reduced call termination rates for the company\u0027s traffic.  Each of these illicit payments originated from LatiNode\u0027s Miami bank account, and many of the payments were concealed by laundering the money through LatiNode subsidiaries in Guatemala and through accounts in Honduras controlled by Honduran government officials.\u0022  In Yemen, according to the same Report, \u0022LatiNode admitted that from approximately July 2005 through April 2006, the company made 17 payments totaling approximately $1,150,654 to a third-party consultant with the knowledge that some or all of the money would be passed on to Yemeni officials in exchange for favorable interconnection rates in Yemen. Each of these payments was also made from LatiNode\u0027s Miami bank account. Company e-mails indicated that company executives believed that potential recipients of these payments included Yemeni government officials.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Vasquez, Case No. 1:10-cr-20894 (S.D. Fla.), Judgment in a Criminal Case, filed April 25, 2012  (accessed via PACER); Information filed January 19, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vasquezjp\/12-17-10vasquez-juan-info.pdf; Plea Agreement filed January 21, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vasquezjp\/01-21-11vasquez-juan-plea.pdf; Statement of Offense filed January 21, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vasquezjp\/1-21-11vasquez-juan-statement.pdf","Documents":""},{"Case ID":"ST-254","Case Cluster ":"Latin Node Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Honduras, Yemen","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"04\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None ","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to commit international money laundering, Bribery of foreign officials, International money laundering","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Judgment in Mr. Caceres\u0027 case, on April 24, 2012 he was sentenced to a prison term of twenty-three months; other than a $100 court assessment fee, no monetary sanctions were ordered in his case. (Source: US v. Caceres, Case No. 1:10-cr-20881 (S.D. Fla.), Judgment in a Criminal Case, April 24, 2012.)  According to the June 2011 United States Report to the OECD, \u0022On March 23, 2009, Latin Node Inc. (LatiNode) was charged with one count of violating the anti-bribery provisions of the FCPA in connection with improper payment in Honduras and Yemen. According to court documents, LatiNode was a privately held Florida corporation that provided wholesale telecommunications services using Internet protocol technology in a number of countries throughout the world, including Honduras and Yemen.  On December 14, 2010, LatiNode\u0027s former CEO and Vice President for Business Development, Jorge Granados and Manuel Caceres, were indicted by a Grand Jury in the Southern District of Florida on 19 counts of conspiracy, violations of the FCPA, and money laundering. Subsequently, on December 17, 2010, Manuel Salvoch, LatiNode\u0027s former CFO, and Juan Pablo V. Vasquez, a former senior commercial executive at LatiNode, were each charged with one count of conspiracy to violate the anti-bribery provisions of the FCPA.\u0022  According to the Report, in Honduras, \u0022between September 2006 and June 2007, these executives paid or caused to be paid more than $500,000 in bribes to the Honduran officials. In all, according to court documents filed in the case against LatiNode, between March 2004 and June 2007, the company paid or caused to be paid approximately $1,099,889 in payments to third parties, knowing that some or all of those funds would be passed on as bribes to officials of Hondutel. In addition to the payments for the interconnection agreement, LatiNode admitted that these payments were also, in part, intended to secure reduced call termination rates for the company\u0027s traffic.  Each of these illicit payments originated from LatiNode\u0027s Miami bank account, and many of the payments were concealed by laundering the money through LatiNode subsidiaries in Guatemala and through accounts in Honduras controlled by Honduran government officials.\u0022  In Yemen, according to the same Report, \u0022LatiNode admitted that from approximately July 2005 through April 2006, the company made 17 payments totaling approximately $1,150,654 to a third-party consultant with the knowledge that some or all of the money would be passed on to Yemeni officials in exchange for favorable interconnection rates in Yemen. Each of these payments was also made from LatiNode\u0027s Miami bank account. Company e-mails indicated that company executives believed that potential recipients of these payments included Yemeni government officials.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Granados, et al, Case No. 1:10-cr-20881 (S.D. Fla.), Indictment filed on December 21, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/granados-jorge\/12-21-10granados-indict.pdf; Plea Agreement filed May 20, 2011 and Judgment in a Criminal Case filed April 25, 2012, all accessed via PACER.  (Copy of Judgment can also be accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/cacercesj\/2012-04-25-cacercesj-judgment.pdf)","Documents":""},{"Case ID":"ST-255","Case Cluster ":"Latin Node Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Honduras, Yemen","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"01\/12","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea  ","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On March 23, 2009, Latin Node Inc. (LatiNode) was charged with one count of violating the anti-bribery provisions of the FCPA in connection with improper payment in Honduras and Yemen. According to court documents, LatiNode was a privately held Florida corporation that provided wholesale telecommunications services using Internet protocol technology in a number of countries throughout the world, including Honduras and Yemen.  On December 14, 2010, LatiNode\u0027s former CEO and Vice President for Business Development, Jorge Granados and Manuel Caceres, were indicted by a Grand Jury in the Southern District of Florida on 19 counts of conspiracy, violations of the FCPA, and money laundering. Subsequently, on December 17, 2010, Manuel Salvoch, LatiNode\u0027s former CFO, and Juan Pablo V. Vasquez, a former senior commercial executive at LatiNode, were each charged with one count of conspiracy to violate the anti-bribery provisions of the FCPA.\u0022  According to the Report, in Honduras, \u0022between September 2006 and June 2007, these executives paid or caused to be paid more than $500,000 in bribes to the Honduran officials. In all, according to court documents filed in the case against LatiNode, between March 2004 and June 2007, the company paid or caused to be paid approximately $1,099,889 in payments to third parties, knowing that some or all of those funds would be passed on as bribes to officials of Hondutel. In addition to the payments for the interconnection agreement, LatiNode admitted that these payments were also, in part, intended to secure reduced call termination rates for the company\u0027s traffic.  Each of these illicit payments originated from LatiNode\u0027s Miami bank account, and many of the payments were concealed by laundering the money through LatiNode subsidiaries in Guatemala and through accounts in Honduras controlled by Honduran government officials.\u0022  In Yemen, according to the same Report, \u0022LatiNode admitted that from approximately July 2005 through April 2006, the company made 17 payments totaling approximately $1,150,654 to a third-party consultant with the knowledge that some or all of the money would be passed on to Yemeni officials in exchange for favorable interconnection rates in Yemen. Each of these payments was also made from LatiNode?s Miami bank account. Company e-mails indicated that company executives believed that potential recipients of these payments included Yemeni government officials.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Manuel Salvoch, Case No. 1:10-cr-20893-PCH (S.D. Fla.), Judgment in a Criminal Case, filed June 8, 2012 (accessed via PACER); Information filed December 17, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/salvoch\/12-17-10salvoch-info.pdf; Plea Agreement dated January 12, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/salvoch\/01-12-11salvoch-plea.pdf; Statement of Offense dated January 12, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/salvoch\/01-12-11salvoch-statement.pdf.","Documents":""},{"Case ID":"ST-256","Case Cluster ":"Lesotho Highlands Water Project","Jurisdiction of Settlement":"Lesotho","Jurisdiction of Settlement \/ Enforcement Agency":"Director of Public Prosecutions","Jurisdiction of Foreign Public Official(s) ":"Lesotho","Year of Settlement":"2003","Month\/Day of Settlement (or Notes)":"10\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$62,266.50","Criminal Fine\/Penalty (US$) ":"$62,266.50","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$62,266.50","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the decision by the Lesotho High Court, Mr. DuPlooy, an intermediary for the Impreglio company, pleaded guilty to foreign bribery charges and was fined R500,000 in addition to receiving a prison term.  (Source: R v. Du Plooy, High Court of Lesotho, CRI\/T\/11\/1999.)  According to a presentation to the US Senate Foreign Relations Committee by Guido Penzhorn, SC, lead prosecutor in the Lesotho Highlands Water Projects case, \u0022In June 2003 one Du Plooy, the intermediary who acted on behalf of Impregilo of Italy, the lead partner of the consortium that built the main dam, pleaded guilty to bribing Mr Sole on behalf of Impregilo. In exchange for co-operation with the prosecution he was fined R500 000, coupled to a lengthy period of imprisonment which was conditionally suspended.\u0022   (Source:  Guido Penzhorn SC, Comments on the Current Lesotho Bribery Prosecutions, Presentation before the [U.S.] Senate Foreign Relations Committee, July 24, 2004.) Please note that June 1, 2003 was used as the date of currency conversion. ","Sources ":"R v. DuPlooy, High Court of Lesotho (CRI\/T\/111\/1999), October 17, 2003 sentencing date, accessed at http:\/\/www.lesotholii.org\/ls\/judgment\/high-court\/2003\/122; Guido Penzhorn SC, Comments on the Current Lesotho Bribery Prosecutions, Presentation before the [U.S.] Senate Foreign Relations Committee, July 24, 2004, accessed at http:\/\/www.odiousdebts.org\/odiousdebts\/publications\/SenatePaperJuly04.pdf. See also, LL Thesane and GH Penzhorn SC, \u0022Case Study: the lesotho bribery prosecutions,\u0022 presented at the Conference on the Protection and Optimization of Public Funds, the Cooperation between National and International Authorities, 14-16 May 2007, accessed at http:\/\/www1.worldbank.org\/finance\/star_site\/documents\/arw\/Lesotho_Highlands_EU_Anti_Fraud_Case_Study_Thetsane_Penzhorn_May_2007.pdf.  ","Documents":""},{"Case ID":"ST-257","Case Cluster ":"Lesotho Highlands Water Project","Jurisdiction of Settlement":"Lesotho","Jurisdiction of Settlement \/ Enforcement Agency":"Director of Public Prosecutions","Jurisdiction of Foreign Public Official(s) ":"Lesotho","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"02\/25","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,504,530.00","Criminal Fine\/Penalty (US$) ":"$1,504,530","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$1,504,530","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a presentation to the US Senate Foreign Relations Committee by Guido Penzhorn, SC, lead prosecutor in the Lesotho Highlands Water Projects case, \u0022On 25 February 2004 Schneider Electric SA (formerly Spie Batignolles), the multi-national French construction company involved in building the transfer tunnels, pleaded guilty to 16 counts of bribing Mr Sole. A fine of R10million was agreed with the prosecution and was paid.\u0022  (Source:  Guido Penzhorn SC, Comments on the Current Lesotho Bribery Prosecutions, Presentation before the [U.S.] Senate Foreign Relations Committee, July 24, 2004.)","Sources ":"Guido Penzhorn SC, Comments on the Current Lesotho Bribery Prosecutions, Presentation before the [U.S.] Senate Foreign Relations Committee, July 24, 2004, accessed at http:\/\/www.odiousdebts.org\/odiousdebts\/publications\/SenatePaperJuly04.pdf. See also, LL Thesane and GH Penzhorn SC, \u0022Case Study: the Lesotho bribery prosecutions,\u0022 presented at the Conference on the Protection and Optimization of Public Funds, the Cooperation between National and International Authorities, 14-16 May 2007, accessed at http:\/\/www1.worldbank.org\/finance\/star_site\/documents\/arw\/Lesotho_Highlands_EU_Anti_Fraud_Case_Study_Thetsane_Penzhorn_May_2007.pdf.  See also, Schneider Electric SA v. Director of Public Prosecutions (CRI\/APN\/751\/2003), accessed at  http:\/\/www.lesotholii.org\/ls\/judgment\/high-court\/2003\/150.","Documents":""},{"Case ID":"ST-258","Case Cluster ":"Litton Industries","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Central District of California","Jurisdiction of Foreign Public Official(s) ":"Taiwan, China; Greece","Year of Settlement":"1999","Month\/Day of Settlement (or Notes)":"06\/30","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Restitution, Investigation Costs","Total Monetary Sanctions (US$)":"$18,501,600.00","Criminal Fine\/Penalty (US$) ":"$16,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$737,000","Criminal Legal \/ Procedural Costs (US$)":"$1,264,600 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Defraud the Government (Litton Applied); Conspiracy to Defraud the Government, Causing False Statement to the US, Mail Fraud (Litton Systems Canada)","Offenses - Settled":"Conspiracy to Defraud the Government (Litton Applied); Conspiracy to Defraud the Government, Causing False Statement to the US, Mail Fraud (Litton Systems Canada)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Court Docket Report, pursuant to the E-Government Act, the final judgments are not available for public viewing. (Source: US v. Litton Applied Technologies, et al, Case No. 2:99-cr-00673 (C.D. Cal.), Docket Report retrieved via Pacer on October 4, 2011). The US Department of Justice website on FCPA Enforcement Actions lists the case but no documents.  (http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/litton-applied.html). According to the Court Docket Report in US v. Litton Applied et al, Litton Applied and Litton Systems were ordered to jointly pay $18.5 million, consisting of $16.5 million in fines, restitution of $737,000, Cost of Investigation of $1,263,000 and special assessment of $1,600.   The recipient of the restitution was not expressly stated.  According to the New York Times, the two Litton Industries units had \u0022agreed to pay $18.5 million to settle allegations of having made illegal payments to obtain defense business in Greece and Taiwan. [  ] The negotiated plea ends investigations of a $150 million deal to sell radar for F-16 fighter planes to Greece and $47 million in contracts to upgrade Taiwanese military aircraft. In both cases, the company was accused of paying private consultants for help in getting business. [  ] In the Taiwan case, prosecutors accused the Litton units of paying more than $4.3 million to Richard M. Hei, a retired Taiwanese Air Force major, for using his contacts to help secure contracts. [  ] In Greece, the Applied Technology division was alleged to have paid more than $12 million to four Greek agents for help in selling the F-16 radars in 1993. [  ] In both cases the companies were accused o hiding the payments from American regulators. Federal law does not ban the use of foreign consultants, but require the disclosure of any commissions that are promised or paid.\u0022 (Source: New York Times, \u00222 Litton Units Plead Guilty To Illegal Foreign Payments,\u0022 July 1, 1999.)","Sources ":"New York Times, \u00222 Litton Units Plead Guilty To Illegal Foreign Payments,\u0022 July 1, 1999, at http:\/\/www.nytimes.com\/1999\/07\/01\/business\/2-litton-units-plead-guilty-to-illegal-foreign-payments.html; [case listed but no documents on DOJ Fraud\/FCPA website]; US v. Litton Applied Technologies, Case No. 2:99-cr-00673 (C.D. Cal.), Docket Report retrieved via Pacer on October 4, 2011; New York Times, \u00222 Litton Units Plead Guilty To Illegal Foreign Payments,\u0022 July 1, 1999, accessed at http:\/\/www.nytimes.com\/1999\/07\/01\/business\/2-litton-units-plead-guilty-to-illegal-foreign-payments.html?pagewanted=print\u0026src=pm.","Documents":""},{"Case ID":"ST-155","Case Cluster ":"Fiat S.p.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"12\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$10,809,142.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$5,309,632","Civil Prejudgment Interest (US$) ":"$1,899,510","Civil Fine \/ Penalty (US$)":"$3,600,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release (December 22, 2008), the Commission \u0022filed Foreign Corrupt Practices Act books and records and internal controls charges against Fiat S.p.A. and CNH Global N.V. in the U.S. District Court for the District of Columbia. Fiat S.p.A., an Italian company, provides automobiles, trucks and commercial vehicles. CNH Global N.V., a majority-owned subsidiary of Fiat, provides agricultural and construction equipment. The Commission\u0027s complaint alleges that from 2000 through 2003, certain Fiat and CNH Global subsidiaries made approximately $4.3 million in kickback payments in connection with their sales of humanitarian goods to Iraq under the United Nations Oil for Food Program (the \u0022Program\u0022). The kickbacks were characterized as \u0022after sales service fees\u0022 (\u0022ASSFs\u0022), but no bona fide services were performed.\u0022  (Source: US Securities and Exchange Commission Litigation Release No. 20835 (December 22, 2008), Securities and Exchange Commission v. Fiat S.p.A. and CNH Global N.V., Civil Action No. 08 CV 0221 (D.D.C.) (CKK), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Fiat S.p.A. and CNH Global N.V. For Improper Payments to Iraq Under the U.N. Oil for Food Program ? Fiat Agrees to Pay Over $10 Million in Disgorgement, Interest, and Penalties.\u0022)","Sources ":"US Securities and Exchange Commission Litigation Release No. 20835 (December 22, 2008), Securities and Exchange Commission v. Fiat S.p.A. and CNH Global N.V., Civil Action No. 08 CV 0221 (D.D.C.) (CKK), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Fiat S.p.A. and CNH Global N.V. For Improper Payments to Iraq Under the U.N. Oil for Food Program -- Fiat Agrees to Pay Over $10 Million in Disgorgement, Interest, and Penalties,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20835.htm; Complaint filed December 22, 2008, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20835.pdf","Documents":""},{"Case ID":"ST-156","Case Cluster ":"Flowserve Corporation","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Rijksrecherche (Dutch Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/16","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$408,875.00","Criminal Fine\/Penalty (US$) ":"$121,569","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$287,306","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"","Offenses - Settled":"Sanctions legislation by paying kickbacks when implementing UN Oil-for-Food Programme","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Netherlands Phase 2 Report of the OECD Anti-Bribery Working Group (December 17, 2008): \u0022As of October 2008, no foreign bribery cases had been brought before the Dutch courts. Nevertheless, the prosecution authorities have concluded out-of-court transactions with seven companies for paying kickbacks in the context of the Oil-for-Food Programme in Iraq, although the offence charged was the violation of sanctions legislation and not the foreign bribery offence.\u0022 (para 2); \u0022 the Prosecution Department reports that it has concluded financial transactions (out of court settlements) with 7 companies for violating sanction legislation by paying kickbacks when implementing the Oil for Food Programme. Criminal gains have also been confiscated. In July 2008 a press release has been issued about these settlements. Together with the names of the companies (Alfasan International B.V., N.V. Organon, Flowserve B.V. , OPW Fluid Transfer Group Europe B.V., Prodetra B.V. Solvochem Holland B.V., Stet Holland B.V.) the settlements have been made public. For the following Oil-for-food transactions out-of-court settlements have been reached: 1. Alfasan International BV Woerden, fine: \u20ac 31.800,-- and confiscation \u20ac 10.183,55 2. NV Organon Oss, fine: \u20ac 381.602 3. Flowerserve bv te Etten-Leur, fine: \u20ac 76.274 and confiscation \u20ac 180.260 4. OPW Fluid Transfer Group Europe BV, Nieuw Vennep, fine \u20ac 57.204 and confiscation \u20ac 24.600 5. Prodetra bv, Wadinxveen, fine: 64.751 and confiscation \u20ac 34.485,95 6. Solvochem Holland bv, Rotterdam, fine \u20ac 136.000 and confiscation \u20ac 144.592 7. Stet Holland bv,Emmeloord, fine \u20ac 119.712 and confiscation \u20ac 54.458.\u0022 (Source: Ibid., at 14.)","Sources ":"OECD Anti-Bribery Working Group, The Netherlands Phase 2 Report (December 17, 2008), accessed at http:\/\/www.oecd.org\/dataoecd\/61\/59\/41919004.pdf; Melissa Lipman, \u0022Cos. Settle Dutch Probe Into Oil-For-Food For ?1.3M,\u0022 Law 360, July 16, 2008, accessed at http:\/\/www.law360.com\/articles\/62486\/cos-settle-dutch-probe-into-oil-for-food-for-1-3m (partial article, gives date of Dutch Public Prosecution Service press release); see also, US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Flowserve Corporation Case Summary at 83-84, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.","Documents":""},{"Case ID":"ST-158","Case Cluster ":"Flowserve Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"02\/21","Other Jurisdictions of Settlement":"Netherlands","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$4,000,000.00","Criminal Fine\/Penalty (US$) ":"$4,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud","Offenses - Settled":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD, \u0022On February 21, 2008, the Department of Justice and the SEC simultaneously filed a criminal information and a civil complaint against Flowserve Pompes SAS (Flowserve Pompes), and its parent company, Flowserve Corporation (Flowserve), in the U.S. District Court for the District of Columbia. The information charges that Flowserve Pompes engaged in a conspiracy to commit wire fraud and to violate the books and records provisions of the FCPA in connection with a scheme to pay kickbacks to the Iraqi government under the United Nations Oil for Food Program (OFFP). The SEC\u0027s civil complaint charges Flowserve with violating the books and records and internal controls provisions of the FCPA in connection with the same underlying conduct.  According to documents filed in the criminal and civil cases, the French and Dutch subsidiaries of Flowserve [ ] paid or promised to pay approximately $820,246 from 2001 to 2003 in connection with the sale of industrial equipment to the Iraqi government. Flowserve Pompes, Flowserve\u0027s French subsidiary, concealed illegal payments to the Iraqi government totaling $604,651 through a Jordanian entity that was its exclusive agent for Iraqi contracts. These payments were made to assist Flowserve Pompes in obtaining fifteen contracts for the sale of large-scale water pumps and spare parts for use in Iraqi oil refineries. Flowserve Pompes also agreed to, but did not ultimately make, an additional $173,758 in improper payments pursuant to four additional contracts, as delivery under these four contracts had not been completed by the time of the U.S. invasion of Iraq in March 2003. Senior officials at Flowserve Pompes, including its President, allegedly developed different false cover stories to conceal these kickback payments in the company\u0027s internal accounting records.  According to the SEC\u0027s complaint, Flowserve\u0027s Dutch Subsidiary, Flowserve B.V., also entered into one contract involving an improper kickback under the OFFP. Specifically, Flowserve B.V. paid $41,836 in kickbacks to Iraqi officials in order to obtain a contract to supply water pump spare parts to the Iraqi government-owned South Gas Company.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Flowserve Corporation Case Summary at 83-84.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Flowserve Corporation Case Summary at 83-84, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; US Department of Justice Press Release, \u0022Flowserve Corporation to Pay $4 Million Penalty for Kickback Payments to the Iraqi Government under the U.N. Oil for Food Program,\u0022 February 21, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/February\/08_crm_132.html; US v. Flowserve Pompes SAS, Case No. 1:08-cr-00035-RJL (D.D.C.), Information filed February 21, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/flowserve-sas\/02-21--08flowserve-inform.pdf and Deferred Prosecution Agreement (February 21, 2008), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/flowserve-sas\/02-21-08flowserve-deferred.pdf","Documents":""},{"Case ID":"ST-160","Case Cluster ":"General Electric Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"07\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$23,478,614.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$18,397,949","Civil Prejudgment Interest (US$) ":"$4,080,665","Civil Fine \/ Penalty (US$)":"$1,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD, \u0022On July 27, 2010, the SEC filed a settled civil action against General Electric Company (\u0022GE\u0022) and two GE subsidiaries (Ionics, Inc. (currently known as GE Ionics, Inc.) and Amersham plc (currently known as GE Healthcare Ltd.)  in the U.S. District Court for the District of Columbia. The SEC\u0027s complaint charged the companies with books and records and internal controls violations in connection with bribes paid to former Iraqi government officials under the United Nations Oil for Food Program (OFFP) by two GE subsidiaries and two other subsidiaries of public companies that have since been acquired by GE. [  ] According to the SEC\u0027s Complaint, from approximately 2000 to 2003, two GE subsidiaries, Marquette-Hellige (\u0022Marquette\u0022) and OEC-Medical Systems (Europa) AG (\u0022OEC-Medical\u0022), made approximately $2.04 million in kickback payments in the form of computer equipment, medical supplies, and services to the Iraqi Ministry of Health. [  ]  Two other current GE subsidiaries, Ionics S.r.l. and Nycomed Imaging AS made approximately $1.55 million in cash kickback payments under the OFFP prior to GE\u0027s acquisition of their parent companies.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, General Electric Company Case Summary at 47-48.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, General Electric Company Case Summary at 47-48, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; US Securities and Exchange Commission Litigation Release (July 27, 2010) at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21602.htm.","Documents":""},{"Case ID":"ST-161","Case Cluster ":"Germany \/ Company P","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"06\/26","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Administrative Offences Act","Monetary Sanctions  (Types)":"Fine","Total Monetary Sanctions (US$)":"$279,040.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"$279,040","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Section 30 OWiG in conjunction with sections 334 and 335 Criminal Code","Offenses - Settled":"Section 30 OWiG in conjunction with sections 334 and 335 Criminal Code","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to the March 2011 Germany Report to the OECD, \u0022Decision of Hildesheim Regional Court of 26 June 2009 pursuant to section 30 OWiG in conjunction with sections 334 and 335CC - against Company P. specialised in cleaning pipes -- Fine of EUR 200 000 (see Annual reports 2007-2008 and 2009 Lower Saxony (a) and Germany\u0027s reply to Phase 3 questionnaires), hereinafter Case \u0022Company P\u0022 (Source: Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at footnote 49.)","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf. http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Germanyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-162","Case Cluster ":"Germany \/ Hamburg-based Shipping Company","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Administrative Offences Act","Monetary Sanctions  (Types)":"Fine","Total Monetary Sanctions (US$)":"$47,675.40","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"$47,675.40","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Section 30 OWiG in connection with sections 299 and 400 Criminal Code","Offenses - Settled":"Section 30 OWiG in connection with sections 299 and 400 Criminal Code","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to the March 2011 Germany Phase 3 Report to the OECD, \u0022iii) Decision of the Hamburg Regional Court of 17 July 2008 pursuant to section 30 OWiG in conjunction with sections 299 and 300 CC- against a Hamburg based shipping company -- Fine of EUR 30 000 (see Germany\u0027s reply to Phase 3 questionnaires and Germany\u0027s reply to Phase 3 questionnaires Hamburg bb ? decision provided only in German), hereinafter Case \u0022Hamburg based shipping Company\u0022 (Source: Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at footnote 49.)","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf. http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Germanyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-163","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf. http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Germanyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-164","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.  http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Germanyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-165","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-166","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-167","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"YES","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-168","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"YES","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-169","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-170","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-171","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-172","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-173","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-174","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-175","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-176","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-177","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-178","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-179","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-180","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-181","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-182","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-183","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-184","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-185","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-186","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-187","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #25","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-188","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #26","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-189","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #27","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-190","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #28","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-191","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #29","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-192","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #30","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-193","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #31","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-194","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #32","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-195","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #33","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-196","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #34","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-197","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #35","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for expemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-154","Case Cluster ":"Fiat S.p.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"12\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$7,000,000","Criminal Fine\/Penalty (US$) ":"$7,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD, \u0022On December 22, 2008, three subsidiaries of Fiat S.p.A. (Fiat), an Italian corporation based in Turin, Italy, were charged in the U.S. District Court for the District of Columbia in connection with a scheme to pay bribes to Iraqi government officials in order to win contracts under the U.N. Oil-for-Food Program (OFFP). Two Fiat subsidiaries, Iveco S.p.A. (Iveco) and CNH Italia S.p.A. (CNH Italia), were each charged with one count of conspiracy to commit wire fraud and to violate the books and records provisions of the FCPA. A third subsidiary, CNH France S.A. (CNH France), was charged with one count of conspiracy to commit wire fraud. The SEC simultaneously filed a civil complaint against Fiat and CNH Global N.V., alleging that Fiat and its subsidiaries violated the books and records and internal controls provisions of the FCPA in relation to the same conduct.  These charges stemmed from a series of improper payments made by Fiat to Iraqi government officials in order to obtain contracts with Iraqi ministries to provide industrial pumps, gears, and other equipment. According to court documents, between 2000 and 2002, Iveco, CNH Italia, and CNH France paid a total of approximately $4.4 million in kickbacks (referred to as \u0022after sales service fees\u0022 (ASSFs)) to the Iraqi government by inflating the price of contracts by 10 percent before submitting the contracts to the U.N. for approval, and concealed from the U.N. the fact that the price contained a kickback to the Iraqi government. Iveco and CNH Italia also inaccurately recorded the kickback payments as commissions and service fees for its agents in its books and records.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Fiat S.p.A. Case Summary at 73-74.)  Fiat settled the charges against its subsidiaries by entering a Deferred Prosecution Agreement with the Department of Justice that required the company to pay $7 million criminal penalty.  (Source: Ibid.)  According to the Statements of Facts accompanying the Deferred Prosecution Agreement:  \u0022Company X,\u0022 a Lebanese company, acted as both an agent and distributor for Iveco in connection with sales to the Iraqi government under the OFFP; and \u0022Company Y,\u0022 a United Arab Emirates company, acted as a conduit for payments to the Iraqi government under the OFFP.  (Source: In Re Fiat S.p.A., et al, Deferred Prosecution Agreement (December 20, 2008), paras 15 and 16.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Fiat S.p.A. Case Summary at 73-74, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; In Re: Fiat S.p.A., et. al; United States v. Iveco S.p.A.; United States v. CNH Italia S.p.A.; and United States v. CNH France S.A., Deferred Prosecution Agreement (December 22, 2008), accessed at http:\/\/www.justice.gov\/opa\/documents\/fiat-dpa.pdf; US Department of Justice Press Release, \u0022Fiat Agrees to $7 Million Fine in Connection with Payment of $4.4 Million in Kickbacks by Three Subsidiaries Under the U.N. Oil for Food Program,\u0022 December 22, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/December\/08-crm-1140.html","Documents":""},{"Case ID":"ST-157","Case Cluster ":"Flowserve Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"02\/21","Other Jurisdictions of Settlement":"Netherlands","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$6,574,225.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$2,720,861","Civil Prejudgment Interest (US$) ":"$853,364","Civil Fine \/ Penalty (US$)":"$3,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, the \u0022Commission today filed Foreign Corrupt Practices Act books and records and internal controls charges against Flowserve Corporation (\u0022Flowserve\u0022) in the U.S. District Court for the District of Columbia. Flowserve is a Texas-based manufacturer of pumps, valves, seals, and related automation and services to the power, oil, gas, and chemical industries. The Commission\u0027s complaint alleges that from 2001 through 2003, two of Flowserve\u0027s subsidiaries entered into a total of twenty contracts in which $646,488 in kickback payments were made and another $173,758 were authorized in connection with sales of industrial equipment to Iraqi government entities under the U.N. Oil for Food Program (the \u0022Program\u0022). The kickbacks were characterized as \u0022after-sales service fees\u0022 (\u0022ASSFs\u0022), but no bona fide services were performed. The Program was intended to provide humanitarian relief for the Iraqi population, which faced severe hardship under international trade sanctions. The Program allowed the Iraqi government to purchase humanitarian goods through a U.N. escrow account. The kickbacks paid by Flowserve\u0027s subsidiaries diverted funds out of the escrow account and into an Iraqi slush fund. The contracts submitted to the U.N. did not disclose that the illicit payments were included in the inflated contract prices. [  ] Flowserve, without admitting or denying the allegations in the Commission\u0027s complaint, consented to the entry of a final judgment permanently enjoining it from future violations of Sections 13(b)(2)(A) and 13(b)(2)(B) of the Securities Exchange Act of 1934, ordering it to disgorge $2,720,861, in profits, plus $853,364 in pre-judgment interest, and to pay a civil penalty of $3,000,000. Flowserve will also pay a $4,000,000 fine pursuant to a deferred prosecution agreement with the U.S. Department of Justice, Fraud Section. Flowserve B.V. will enter into a criminal disposition with the Dutch Public Prosecutor pursuant to which it will pay a fine.\u0022 (Source: US Securities and Exchange Commission Litigation Release No. 20461 \/ February 21, 2008, Securities and Exchange Commission v. Flowserve Corporation, Civil Action No. 08 CV 00294 (D.D.C.) (EGS), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Flowserve Corporation For Improper Payments to Iraq Under the U.N. Oil for Food Program ? Company Agrees to Pay Over $6.5 Million in Civil Penalties, Disgorgement of Profits, and Prejudgment Interest.\u0022)","Sources ":"US Securities and Exchange Commission Litigation Release No. 20461 \/ February 21, 2008, Securities and Exchange Commission v. Flowserve Corporation, Civil Action No. 08 CV 00294 (D.D.C.) (EGS), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Flowserve Corporation For Improper Payments to Iraq Under the U.N. Oil for Food Program -- Company Agrees to Pay Over $6.5 Million in Civil Penalties, Disgorgement of Profits, and Prejudgment Interest,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20461.htm; Complaint filed February 21, 2008, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20461.pdf","Documents":""},{"Case ID":"ST-159","Case Cluster ":"Flowserve Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"02\/21","Other Jurisdictions of Settlement":"Netherlands","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$4,000,000.00","Criminal Fine\/Penalty (US$) ":"$4,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud","Offenses - Settled":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD, \u0022On February 21, 2008, the Department of Justice and the SEC simultaneously filed a criminal information and a civil complaint against Flowserve Pompes SAS (Flowserve Pompes), and its parent company, Flowserve Corporation (Flowserve), in the U.S. District Court for the District of Columbia. The information charges that Flowserve Pompes engaged in a conspiracy to commit wire fraud and to violate the books and records provisions of the FCPA in connection with a scheme to pay kickbacks to the Iraqi government under the United Nations Oil for Food Program (OFFP). The SEC\u0027s civil complaint charges Flowserve with violating the books and records and internal controls provisions of the FCPA in connection with the same underlying conduct.  According to documents filed in the criminal and civil cases, the French and Dutch subsidiaries of Flowserve [ ] paid or promised to pay approximately $820,246 from 2001 to 2003 in connection with the sale of industrial equipment to the Iraqi government. Flowserve Pompes, Flowserve\u0027s French subsidiary, concealed illegal payments to the Iraqi government totaling $604,651 through a Jordanian entity that was its exclusive agent for Iraqi contracts. These payments were made to assist Flowserve Pompes in obtaining fifteen contracts for the sale of large-scale water pumps and spare parts for use in Iraqi oil refineries. Flowserve Pompes also agreed to, but did not ultimately make, an additional $173,758 in improper payments pursuant to four additional contracts, as delivery under these four contracts had not been completed by the time of the U.S. invasion of Iraq in March 2003. Senior officials at Flowserve Pompes, including its President, allegedly developed different false cover stories to conceal these kickback payments in the company\u0027s internal accounting records.  According to the SEC\u0027s complaint, Flowserve\u0027s Dutch Subsidiary, Flowserve B.V., also entered into one contract involving an improper kickback under the OFFP. Specifically, Flowserve B.V. paid $41,836 in kickbacks to Iraqi officials in order to obtain a contract to supply water pump spare parts to the Iraqi government-owned South Gas Company.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Flowserve Corporation Case Summary at 83-84.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Flowserve Corporation Case Summary at 83-84, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; US Department of Justice Press Release, \u0022Flowserve Corporation to Pay $4 Million Penalty for Kickback Payments to the Iraqi Government under the U.N. Oil for Food Program,\u0022 February 21, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/February\/08_crm_132.html; US v. Flowserve Pompes SAS, Case No. 1:08-cr-00035-RJL (D.D.C.), Information filed February 21, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/flowserve-sas\/02-21--08flowserve-inform.pdf and Deferred Prosecution Agreement (February 21, 2008), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/flowserve-sas\/02-21-08flowserve-deferred.pdf","Documents":""},{"Case ID":"ST-198","Case Cluster ":"HealthSouth Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"04\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$500.00","Criminal Fine\/Penalty (US$) ":"$500","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"False Statements to the FBI (18 USC Section 1001)","Offenses - Settled":"False Statements to the FBI (18 USC Section 1001)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022Vincent Nico, former Vice President of HealthSouth Corporation, has been charged with wire fraud related to contracts with a hospital in Saudi Arabia.  Nico, 47, of Palm Harbor, Florida, has agreed to plead guilty to the wire fraud charge contained in a criminal information that was filed at U.S. District Court in Birmingham, Alabama. In addition, former HealthSouth Executive Vice President Thomas Carman, 52, of Birmingham, has agreed to plead guilty to a separate criminal information charging him with making a false statement to the FBI. [  ] HealthSouth was a corporation organized under the laws of the State of Delaware with its headquarters in Birmingham, Alabama. [ ] The charges against Nico and Carman stem from HealthSouth\u0027s agreement to provide staffing and management services for a 450-bed hospital in Saudi Arabia. Under HealthSouth\u0027s contract with a Saudi foundation which built and owned the hospital, HealthSouth was to receive $10 million annually over a five-year term.  According to the criminal informations, the Saudi foundation\u0027s director general solicited a $1 million payment from HealthSouth, ostensibly as a \u0022finders fee.\u0022  Against the advice of counsel, HealthSouth allegedly agreed to pay the Saudi foundation\u0027s director general the sum of $500,000 per year for a five-year period in return for his agreement to execute the contract on behalf of the Saudi foundation. In order to conceal the true nature of the scheme, HealthSouth officers, including Nico and Carman, allegedly arranged for the foundation\u0027s director general to execute a bogus consulting contract with a HealthSouth-affiliated entity in Australia. Until the scheme was detected in 2003, HealthSouth paid the amounts due under this phony consulting contract by wiring them to Australia, where they were subsequently wired to the foundation\u0027s director general in Saudi Arabia, according to the charges. The HealthSouth officers allegedly undertook this conduct despite the fact that they had been specifically advised beforehand by an attorney retained by HealthSouth that such conduct would amount to a violation of federal criminal law.  The criminal information against Nico charges that he violated his duty of honest services to HealthSouth by accepting a kickback from the foundation\u0027s director general whereby Nico received $125,000 per year from the $500,000 paid to the foundation\u0027s director general. Under this agreement, Nico received a total of $375,000 in undisclosed payments. In addition, Nico received $631,502 from HealthSouth as payment of a bonus he demanded based his claim that he had performed exemplary service for the company in securing and maintaining the contract with the Saudi foundation, and that he had not received any compensation for that service. Nico has agreed to forfeit $1,005,602, the total amount he received from the foundation\u0027s director general and as payment of the bonus from HealthSouth.  The criminal information against Carman charges that he made a false statement to the FBI when he claimed during an interview that the consulting contract with the foundation\u0027s director general was intended to be a legitimate arrangement under which real services were to be provided.\u0022 (Source:  US Department of Justice Press Release, \u0022Former HealthSouth Officers Charged in Fraud Conspiracy involving Saudi Hospitals,\u0022 March 2, 2004.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, HealthSouth Corporation Case Summary at 122-123, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Carman, Case No. 2:04-cr-00093-LSC-JEO (N.D. Ala.), Information filed March 2, 2004, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/carman\/03-02-04carman-info.pdf;  Plea Agreeement filed March 21, 2004, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/carman\/03-02-04carman-plea-agmt.pdf; Judgment dated August 3, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/carman\/08-03-05carman-judgment.pdf.  US Department of Justice Press Release, \u0022Former HealthSouth Officers Charged in Fraud Conspiracy involving Saudi Hospitals,\u0022 March 2, 2004, accessed at http:\/\/www.justice.gov\/opa\/pr\/2004\/March\/04_crm_131.htm","Documents":""},{"Case ID":"ST-199","Case Cluster ":"HealthSouth Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"04\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Forfeiture","Total Monetary Sanctions (US$)":"$1,256,502.00","Criminal Fine\/Penalty (US$) ":"$250,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$1,006,502","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Wire Fraud","Offenses - Settled":"Wire Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD, \u0022In March and July 2004, the Department of Justice filed charges against four HealthSouth executives in connection with an alleged scheme to bribe the director general of a Saudi Arabian foundation in furtherance of HealthSouth\u0027s effort to secure an agreement to provide staffing and management services for a 450-bed hospital in Saudi Arabia. Under the contract that HealthSouth eventually executed with the Saudi Arabian foundation, HealthSouth was to receive $10 million annually over a five-year term.  On July 1, 2004, the Department indicted Robert E. Thomson, President and COO of HealthSouth\u0027s in-patient division, and James C. Reilly, the Group Vice President of Legal Services for Health South, in the Northern District of Alabama. According to the indictment, the Saudi Arabian foundation\u0027s director general solicited a $1 million payment from HealthSouth, ostensibly as a \u0022finder\u0027s fee.\u0022  Against the advice of counsel, HealthSouth allegedly agreed to pay the Saudi Arabian foundation\u0027s director general the sum of $500,000 per year for a five-year period in return for his agreement to execute the contract on behalf of the Saudi Arabian foundation. In order to conceal the true nature of the scheme, HealthSouth officers, including Thomson and Reilly, allegedly arranged for the Saudi Arabian foundation\u0027s director general to execute a bogus consulting contract with a HealthSouth-affiliated entity in Australia. Until the scheme was detected in 2003, HealthSouth paid the amounts due under this phony consulting contract by wiring them to Australia, where they were subsequently wired to the foundation\u0027s director general in Saudi Arabia, according to the indictment. The HealthSouth officers allegedly undertook this conduct despite the fact that they had been specifically advised beforehand by an attorney retained by HealthSouth that such conduct would amountto a violation of federal criminal law.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, HealthSouth Corporation Case Summary at 122-123.)  According to Nico\u0027s Plea Agreement, \u0022The Defendant hereby agrees to surrender to the United States of America the sum of $1,006,502 pursuant to Title 18, United States Code. Section 981 (a)(1)(C), and Title 28, UnitedStates Code, Section 2461(e), as property constituting or derived from proceeds traceable to the violation of Title 18, United States Code, Section 1343.\u0022  (Source:  US v. Nico, Case No.  2:04-cr-00092-SLB-JEO (N.D. Ala.), Plea Agreement filed March 2, 2004.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, HealthSouth Corporation Case Summary at 122-123, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  U.S. v. Vincent Nico, Case No. 2:04-cr-00092-SLB-JEO (N.D. Ala.), Information filed Mar 2, 2004, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nico\/03-02-04nico-info.pdf; Plea Agreement filed March 2, 2004, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nico\/03-02-04nico-plea-agmt.pdf; Judgment filed June 9, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nico\/06-09-05nico-judgment.pdf","Documents":""},{"Case ID":"ST-200","Case Cluster ":"Helmerich \u0026 Payne, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Argentina, Venezuela","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"07\/30","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,000,000.00","Criminal Fine\/Penalty (US$) ":"$1,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"$0","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"Accrording to the June 2011 Report to the OECD, \u0022On July 30, 2009 Helmerich \u0026 Payne (H\u0026P) entered into a non-prosecution agreement with the Department of Justice and the SEC initiated a settled administrative proceeding against H\u0026P. These enforcement actions stemmed from a series of improper payments by H\u0026P to government officials in Argentina and Venezuela in violation of the FCPA. [ ] The improper payments were made to officials of the Argentine and Venezuelan customs services, both government agencies, made in order to import and export goods that were not within regulations, to import goods that could not lawfully be imported, and to evade higher duties and taxes on the goods. From 2004 through 2008, H\u0026P Argentina paid Argentine customs officials approximately $166,000, which allowed it to avoid more than an estimated $186,000 in expenses it would have otherwise incurred if it had properly imported and exported the equipment and materials. In addition, from 2003 through 2008, H\u0026P Venezuela made corrupt payments to Venezuelan customs officials totaling approximately $19,673, which allowed it to avoid more than an estimated $134,000 in expenses it would have otherwise incurred if it had properly imported and exported the equipment and materials. H\u0026P and its subsidiaries then falsely, or at least misleadingly, described these improper payments in H\u0026P\u0027s books and records.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Helmerich \u0026 Payne, Inc. Case Summary at 62-63.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Helmerich \u0026 Payne, Inc. Case Summary at 62-63, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  In Re Helmerich \u0026 Payne, Inc., Nonprosecution Agreement (July 29, 2009), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/helmerich-payne\/06-29-09helmerich-agree.pdf; US Department of Justice Press Release, \u0022Helmerich \u0026 Payne Agrees to Pay $1 Million Penalty to Resolve Allegations of Foreign Bribery in South America,\u0022 July 30, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/July\/09-crm-741.html.","Documents":""},{"Case ID":"ST-201","Case Cluster ":"Helmerich \u0026 Payne, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina, Venezuela","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"07\/30","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Pre-judgment Interest","Total Monetary Sanctions (US$)":"$375,681.22","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$320,604","Civil Prejudgment Interest (US$) ":"$55,077.22","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"$0","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"Accrording to the June 2011 Report to the OECD, \u0022On July 30, 2009 Helmerich \u0026 Payne (H\u0026P) entered into a non-prosecution agreement with the Department of Justice and the SEC initiated a settled administrative proceeding against H\u0026P. These enforcement actions stemmed from a series of improper payments by H\u0026P to government officials in Argentina and Venezuela in violation of the FCPA. [ ] The improper payments were made to officials of the Argentine and Venezuelan customs services, both government agencies, made in order to import and export goods that were not within regulations, to import goods that could not lawfully be imported, and to evade higher duties and taxes on the goods. From 2004 through 2008, H\u0026P Argentina paid Argentine customs officials approximately $166,000, which allowed it to avoid more than an estimated $186,000 in expenses it would have otherwise incurred if it had properly imported and exported the equipment and materials. In addition, from 2003 through 2008, H\u0026P Venezuela made corrupt payments to Venezuelan customs officials totaling approximately $19,673, which allowed it to avoid more than an estimated $134,000 in expenses it would have otherwise incurred if it had properly imported and exported the equipment and materials. H\u0026P and its subsidiaries then falsely, or at least misleadingly, described these improper payments in H\u0026P\u0027s books and records.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Helmerich \u0026 Payne, Inc. Case Summary at 62-63.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Helmerich \u0026 Payne, Inc. Case Summary at 62-63, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; US Securities and Exchange Commission, In the Matter of Helmerich \u0026 Payne, Inc., Administrative Proceedings File No. 3-13565, Order Instituting Cease-and-Desist Proceedings, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2009\/34-60400.pdf","Documents":""},{"Case ID":"ST-203","Case Cluster ":"Immucor, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Italy","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"09\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission\u0027s Litigation Release in SEC v. Gioacchino De Chirico, on September 28, 2007, the Securities and Exchange Commission \u0022announced the filing of a settled civil action against Gioacchino De Chirico, Chief Executive Officer of Immucor, Inc., for violating Section 13(b)(5) of the Exchange Act and Rule 13b2-1, and for aiding and abetting violations of Sections 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act. The Commission\u0027s complaint, filed in the United States District Court of the Northern District of Georgia, alleges that in April 2004, Immucor paid \u20ac13,500 (Euros) [US$16,119] to the director of a public hospital in Milan, Italy as a quid pro quo for the hospital director favoring Immucor in selecting contracts for supplies and equipment. The complaint further alleges that De Chirico approved an invoice that falsely described the \u20ac13,500 payment as a consulting fee for services in connection with opportunities in Switzerland -- work De Chirico knew the hospital director had never performed.With the filing of the Commission\u0027s action, De Chirico has agreed, without admitting or denying the allegations in the Commission\u0027s complaint, to the entry of a final judgment ordering him to pay a civil penalty of $30,000. Separately, Immucor and De Chirico consented to a Commission cease-and-desist order related to the same events, without admitting or denying the Commission\u0027s findings. (Exchange Act Release No. 56558).\u0022 (Source: SEC Litigation Release No. 20316, SEC v. Giaocchino De Chirico, Case No. 1:07-cv-2367 (N.D. Ga., September 28, 2007)  The SEC had alleged that the payment request had been submitted by Immucor\u0027s local sales agent who asked that it be paid to a Swiss bank account for the benefit of the hospital director (para 5); in accordance with the sales agent\u0027s earlier agreement with the hospital director\u0027s request to assist him in avoiding Italian taxes, De Chirico authorized that the EUR 13,500 payment be made through Immucor\u0027s German subsidiary, Immucor Medizinische Diagnostik GmbH. (para 6) (Source:  In the Matter of Immucor, Inc. and Gioacchino de Chirico, Order Instituting Cease and Desist Proceedings, Administrative Proceeding File No. 3-12846.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Immucor, Inc. Case Summary at 94-95, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  SEC v. Gioacchino De Chirico, Case No. 1:07-cv-2367 (N.D. GA), Complaint filed September 28, 2007, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2007\/comp20316.pdf; US Securities and Exchange Commission Litigation Release No. 20316, SEC v. De Chirico, http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20316.htm; In Re: Immucor, Inc. and Gioacchino De Chirico, Order Instituting Cease and Desist Proceedings (September 27, 2007), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2007\/34-56558.pdf.","Documents":""},{"Case ID":"ST-204","Case Cluster ":"Immucor, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Italy","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"09\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$30,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$30,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"False accounting violations, Aiding and abetting internal controls violations, Aiding and abetting falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission\u0027s Litigation Release in SEC v. Gioacchino De Chirico, on September 28, 2007, the Securities and Exchange Commission \u0022announced the filing of a settled civil action against Gioacchino De Chirico, Chief Executive Officer of Immucor, Inc., for violating Section 13(b)(5) of the Exchange Act and Rule 13b2-1, and for aiding and abetting violations of Sections 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act. The Commission\u0027s complaint, filed in the United States District Court of the Northern District of Georgia, alleges that in April 2004, Immucor paid \u20ac13,500 (Euros) [US$16,119] to the director of a public hospital in Milan, Italy as a quid pro quo for the hospital director favoring Immucor in selecting contracts for supplies and equipment. The complaint further alleges that De Chirico approved an invoice that falsely described the \u20ac13,500 payment as a consulting fee for services in connection with opportunities in Switzerland -- work De Chirico knew the hospital director had never performed.With the filing of the Commission\u0027s action, De Chirico has agreed, without admitting or denying the allegations in the Commission\u0027s complaint, to the entry of a final judgment ordering him to pay a civil penalty of $30,000. Separately, Immucor and De Chirico consented to a Commission cease-and-desist order related to the same events, without admitting or denying the Commission\u0027s findings. (Exchange Act Release No. 56558).\u0022 (Source: SEC Litigation Release No. 20316, SEC v. Giaocchino De Chirico, Case No. 1:07-cv-2367 (N.D. Ga., September 28, 2007)  The SEC had alleged that the payment request had been submitted by Immucor\u0027s local sales agent who asked that it be paid to a Swiss bank account for the benefit of the hospital director (para 5); in accordance with the sales agent\u0027s earlier agreement with the hospital director\u0027s request to assist him in avoiding Italian taxes, De Chirico authorized that the EUR 13,500 payment be made through Immucor\u0027s German subsidiary, Immucor Medizinische Diagnostik GmbH. (para 6) (Source:  In the Matter of Immucor, Inc. and Gioacchino de Chirico, Order Instituting Cease and Desist Proceedings, Administrative Proceeding File No. 3-12846.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Immucor, Inc. Case Summary at 94-95, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  SEC v. Gioacchino De Chirico, Case No. 1:07-cv-2367 (N.D. GA), Complaint filed September 28, 2007, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2007\/comp20316.pdf; US Securities and Exchange Commission Litigation Release No. 20316, SEC v. De Chirico, http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20316.htm; SEC Release No. 56558, In Re: Immucor, Inc. and Gioacchino De Chirico, Cease and Desist Order (September 27, 2007), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2007\/34-56558.pdf.","Documents":""},{"Case ID":"ST-206","Case Cluster ":"Ingersoll - Rand Company Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"10\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$4,220,987.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,710,034","Civil Prejudgment Interest (US$) ":"$560,953","Civil Fine \/ Penalty (US$)":"$1,950,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, on October 31, 2007, the Commission \u0022filed Foreign Corrupt Practices Act books and records and internal controls charges against Ingersoll-Rand Company Ltd., a New Jersey-based industrial equipment company, in the U.S. District Court for the District of Columbia. The Commission\u0027s complaint alleges that from 2000 through 2003, four of Ingersoll-Rand\u0027s subsidiaries entered into contracts in which $963,148 in kickback payments were made and $544,697 in additional payments were authorized in connection with sales of humanitarian goods to Iraq under the U.N. Oil for Food Program (the \u0022Program\u0022). The kickbacks were characterized as \u0022after-sales service fees\u0022 (\u0022ASSFs\u0022), but no bona fide services were performed. The Program was intended to provide humanitarian relief for the Iraqi population, which faced severe hardship under international trade sanctions. It allowed the Iraqi government to purchase humanitarian goods through a U.N. escrow account. The kickbacks paid by Ingersoll-Rand\u0027s subsidiaries and third parties diverted funds out of the escrow account and into an Iraqi slush fund. The contracts submitted to the U.N. did not disclose that the illicit payments were included in the inflated contract prices. The complaint also alleges that $8,000 in \u0022pocket money\u0022 and travel expenses were paid to Iraqi government officials in connection with a trip to Italy.\u0022  (Source: US Securities and Exchange Commission, Litigation Release No. 20353 \/ October 31, 2007, Securities and Exchange Commission v. Ingersoll-Rand Company Ltd., Civil Action No. 107- CV- 01955 (D.D.C.) (JDB), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Ingersoll-Rand Company Ltd. For Improper Payments to Iraq Under the U.N. Oil for Food Program - - Company Agrees to Pay Over $4.2 Million and to Make Certain Undertakings Regarding its Foreign Corrupt Practices Act Compliance Program.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Ingersoll-Rand Company Limited  Case Summary at 92-93, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 20353 \/ October 31, 2007, Securities and Exchange Commission v. Ingersoll-Rand Company Ltd., Civil Action No. 107- CV- 01955 (D.D.C.) (JDB), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Ingersoll-Rand Company Ltd. For Improper Payments to Iraq Under the U.N. Oil for Food Program - - Company Agrees to Pay Over $4.2 Million and to Make Certain Undertakings Regarding its Foreign Corrupt Practices Act Compliance Program,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20353.htm","Documents":""},{"Case ID":"ST-205","Case Cluster ":"Ingersoll - Rand Company Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"10\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,500,000.00","Criminal Fine\/Penalty (US$) ":"$2,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to falsify books and records","Offenses - Settled":"Conspiracy to falsify books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On October 31, 2007, the Department of Justice filed criminal charges against two subsidiaries of Ingersoll-Rand Company Limited (Ingersoll-Rand), in connection with payments made by these and other subsidiaries to obtain contracts administered by the United Nations Oil for Food Program (OFFP). On the same day, the SEC filed a settled civil complaint against Ingersoll-Rand, charging it with violations of the internal controls and books and records provisions of the FCPA arising out of the same underlying conduct.According to court documents, between October 2000 and August 2003, employees of three subsidiaries, one unnamed, Ingersoll-Rand Italiana, and Thermo King Ireland Limited, made $963,148 in kickback payments to the Iraqi government, and promised an additional $544,697, in exchange for contracts to provide road construction equipment, air compressors and parts, and refrigerated trucks under the OFFP. In order to both pay for and conceal these kickbacks, the subsidiaries inflated the price of contracts by approximately 10 percent before submitting them to the U.N. for approval. The subsidiaries never revealed to the U.N. the fact that the contract prices contained a kickback to the Iraqi government.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Ingersoll-Rand Company Limited Case Summary at 92-93.)  Ingersoll-Rand, on behalf of itself and its subsidiaries, entered into Deferred Prosecution Agreement with the Department of Justice and agreed to pay a criminal fine of $2.5 million.  (Source: US v. Ingersoll-Rand Italiana SpA, Case No. 1:07-cr-00296-RJL (D.D.C.), Deferred Prosecution Agreement filed November 14, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/ingerand-italiana\/11-17-07ingersollrand-def-agree.pdf.","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Ingersoll-Rand Company Limited Case Summary at 92-93, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Thermo-King Ireland Limited, Case No. 1:07-cr-00296-RJL (D.D.C.), Notice of Filing of Deferred Prosecution Agreement (as to Ingersoll-Rand Company Limited), filed November 14, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/thermoking-ireland\/11-14-07thermo-king-ingersoll-dpa.pdf; Attachment A: Statement of Offenses, filed November 14, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/ingerand-italiana\/10-30-07ingersollrand-statement.pdf","Documents":""},{"Case ID":"ST-103","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$7,265,080.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$5,981,693","Civil Prejudgment Interest (US$) ":"$1,283,387","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission Litigation Release, the Commission \u0022filed a settled enforcement action on November 4, 2010, in the U.S. District Court for the District of Columbia charging Transocean Inc. (\u0022Transocean\u0022), an international provider of offshore drilling services and equipment to oil companies throughout the world, with violations of the anti-bribery, books and records, and internal controls provisions of the Foreign Corrupt Practices Act (\u0022FCPA\u0022). Transocean has agreed to pay disgorgement, interest, and a civil penalty totaling $7,265,080 to settle the charges.  The SEC\u0027s complaint alleges that: From at least 2002 through 2007, Transocean made illicit payments through its customs agents to Nigerian government officials to extend the temporary importation status of its drilling rigs, to obtain false paperwork associated with its drilling rigs, and obtain inward clearance authorizations for its rigs and a bond registration. In addition, Transocean made illicit payments through Panalpina World Transport Holding Ltd.\u0027s Pancourier express courier service to Nigerian government officials to expedite the import of various goods, equipment and materials into Nigeria. In most instances, customs duties for these items were not paid by either Panalpina or Transocean. Transocean also made illicit payments through Panalpina to Nigerian government officials to expedite the delivery of medicine and other materials into Nigeria. Transocean\u0027s total gains from the conduct were approximately $5,981,693.\u0022  (Source:  US Securities and Exchange Commission, Litigation Release No. 21725 \/ November 4, 2010, Securities \u0026 Exchange Commission v. Transocean Inc., Civil Action No. 1:10-CV-01891 (JDB) (D.D.C.), \u0022SEC Charges Transocean for Bribery Scheme in Nigeria - Transocean to Pay Disgorgement and Civil Penalties of $7,265,080.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21725 \/ November 4, 2010, Securities \u0026 Exchange Commission v. Transocean Inc., Civil Action No. 1:10-CV-01891 (JDB) (D.D.C.), \u0022SEC Charges Transocean for Bribery Scheme in Nigeria - Transocean to Pay Disgorgement and Civil Penalties of $7,265,080,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21725.htm; Complaint filed November 4, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21725.pdf","Documents":""},{"Case ID":"ST-104","Case Cluster ":"Bribery of a Senior Iraqi Police Official","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"08\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign official ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Bribery of a Senior Iraqi Police Official, at 105: Salam admitted that in January 2006, while working as a civilian translator for a U.S. army subcontractor, he offered a senior Iraqi police official $60,000 in exchange for the official\u0027s assistance via official use of his position with the Iraqi police force to coordinate the purchase of 1,000 armored vests and a sophisticated map printer for approximately $1 million by the multinational Civilian Police Assistance Training Team (CPATT), an organization designed to train the Iraqi police and border guard in Iraq.  Salam admiited that he later made final arangements with an undercover agent of the Office of the Special Inspector General for Iraq Reconstruction who was posing as a procurement officer for CPATT, that he offered a separate $28,000 to $35,000 \u0022gift\u0022 to the agent to process the contracts.  Salam pleaded guilty on August 4, 2006 and was sentenced on February 2, 2007 to 36 months\u0027 imprisonment, 24 months\u0027 supervised release and 250 hours\u0027 community service.  According to the Complaint in the case, Mr. Salam is a US citizen. (Sources: US v. Faheem Mousa Salam, Case No. 1:06-cr-00157-RJL (D.D.C.), Complaint filed June 7, 2006 and Judgment in a Criminal Case filed February 7, 2007.)","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Bribery of a Senior Iraqi Police Official, at 105, accessed at http:\/\/www.justice.gov\/opa\/pr\/2006\/August\/06_crm_500.html; US v. Faheem Mousa Salam, Case No. 1:06-cr-00157-RJL (D.D.C.), Complaint fileed June 7, 2006 and Judgment in a Criminal Case filed February 7, 2007.","Documents":""},{"Case ID":"ST-105","Case Cluster ":"Bribery of and by World Bank Officials","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice ","Jurisdiction of Foreign Public Official(s) ":"Kenya, Ethiopia, World Bank","Year of Settlement":"2002","Month\/Day of Settlement (or Notes)":"02\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Restitution","Total Monetary Sanctions (US$)":"$133,000.00","Criminal Fine\/Penalty (US$) ":"$6,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$127,000","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$127,000","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Former Employer (World Bank)","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to commit wire fraud, Bribery of foreign officials","Offenses - Settled":"Conspiracy to commit wire fraud, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD, \u0022In 2002, the Department of Justice charged two World Bank officials, Ramendra Basu, a national of India, and Gautam Sengupta, with conspiring to steer World Bank contracts to certain consultants in exchange for kickbacks. According to court documents, the two defendants conspired with a Swedish consultant and others to use their official positions with the World Bank to steer World Bank contracts in Ethiopia and Kenya to certain Swedish companies in exchange for approximately $127,000 in kickbacks. In addition, the defendants admitted that in January 1999, they received a request for a $50,000 bribe from a Kenyan government official working on a Project Implementation Unit involved in a World Bank-financed project, which was to be paid by the Swedish consultant. Collectively, Basu and Sengupta forwarded this request to the Swedish consultant and passed along related bank account information, despite knowing that the payment was meant to corruptly influence an act or decision of the foreign official in his official capacity, in violation of the anti-bribery provisions of the FCPA. [  ]  Sengupta pleaded guilty on February 13, 2002, and was sentenced in 2006, Sengupta to two months\u0027 imprisonment and one year of supervised release, which was to include four months of home confinement. Sengupta was also sentenced to pay a criminal fine of $3,000.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of and by World Bank Officials Case Summary, at 125-126.)  According to Mr. Sengupta\u0027s Plea Agreement, \u0022III. RESTITUTION \/ 5. Pursuant to 18 U.S.C. \u00a7 3663 (a)(3), the defendant and the government agree that the amount of loss in this case is $127,000 and the defendant agrees to pay full restitution of this amount for all damage that resulted from his violations of the statutes listed in Section I herein. The United States and the Defendant agree that the Defendant has made such restitution, and The World Bank, Mr. Sengupta\u0027s former employer, has represented to the Department of Justice that it has no further claim against the defendant.\u0022 (Source: US v. Gautam Sengupta, Case No. 1:02-cr-040-RWR (D.D.C.), Plea Agreement filed January 30, 2002.)  According to the Judgment, Mr. Sengupta was ordered to pay $6,000 in criminal fines. (Source: US v. Gautam Sengupta, Case No. 1:02-cr-040-RWR (D.D.C.), Judgment filed in a criminal case, February 15, 2006.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of and by World Bank Officials Case Summary, at 125-126, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Department of Justice Press Release, \u0022Former World Bank Employee Sentenced for Taking Kickbacks and Assisting in the Bribery of a Foreign Official,\u0022 April 25, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/April\/08-crm-341.html; US v. Gautam Sengupta, Case No. 1:02-cr-040-RWR (D.D.C.), Plea Agreement filed January 30, 2002, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/sengupta\/01-30-02sengupta-plea-agree.pdf; Judgment filed February 15, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/sengupta\/02-15-06sengupta-judgment.pdf.","Documents":""},{"Case ID":"ST-106","Case Cluster ":"Bribery of and by World Bank Officials","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Kenya, Ethiopia, World Bank","Year of Settlement":"2002","Month\/Day of Settlement (or Notes)":"12\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to commit wire fraud, Bribery of foreign officials","Offenses - Settled":"Conspiracy to commit wire fraud, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD, \u0022In 2002, the Department of Justice charged two World Bank officials, Ramendra Basu, a national of India, and Gautam Sengupta, with conspiring to steer World Bank contracts to certain consultants in exchange for kickbacks. According to court documents, the two defendants conspired with a Swedish consultant and others to use their official positions with the World Bank to steer World Bank contracts in Ethiopia and Kenya to certain Swedish companies in exchange for approximately $127,000 in kickbacks. In addition, the defendants admitted that in January 1999, they received a request for a $50,000 bribe from a Kenyan government official working on a Project Implementation Unit involved in a World Bank-financed project, which was to be paid by the Swedish consultant. Collectively, Basu and Sengupta forwarded this request to the Swedish consultant and passed along related bank account information, despite knowing that the payment was meant to corruptly influence an act or decision of the foreign official in his official capacity, in violation of the anti-bribery provisions of the FCPA.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of and by World Bank Officials Case Summary, at 125-126.)  According to the Judgment in Mr. Basu\u0027s case, no monetary penalty was assessed. (Source: US v. Ramendra Basu, Case No. 1:02-cr-00475-RWR (D.D.C.), Judgment in a criminal case, filed May 30, 2008.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of and by World Bank Officials Case Summary, at 125-126, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Ramendra Basu, Case No. 1:02-cr-00475-RWR (D.D.C.), Judgment in a criminal case, filed May 30, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/basu\/05-03-08basu-judgment.pdf","Documents":""},{"Case ID":"ST-107","Case Cluster ":"Bribery of Liberian Officials for False Accreditation of Academic Institutions","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Liberia","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"03\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to commit wire and mail fraud, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to commit wire and mail fraud, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"No (Education License)","Summary":"According to the June 2011 United States Report to the OECD, \u0022In a superseding information filed on March 20, 2006, Richard John Novak was charged with one count of bribery in violation of the FCPA and an additional count of conspiracy to bribe foreign officials, to commit mail fraud, and to commit wire fraud. These charges stemmed from a series of bribe payments, in excess of $43,000, which were made to several Liberian officials in order to obtain accreditation from Liberia for Saint Regis University, Robertstown University, and James Monroe University, and to induce Liberian officials to issue letters and other documents to third parties falsely representing that Saint Regis University was properly accredited by Liberia. These \u0022online universities\u0022 were in fact part of an online \u0022diploma mill scheme,\u0022 and they provided no legitimate educational services and had no legitimate academic accreditation. According to court documents, between October 2002 and September 2004, approximately $19,200 was wired from an account in the State of Washington controlled by Novak\u0027s co-defendants, Dixie Ellen Randock and Steven Karl Randock, Sr., to a bank account in Maryland in the name of the Liberian Consul. These corrupt payments benefited officials of the Liberian Embassy in Washington, D.C., the Director of National Commission of Higher Education of Liberia, and the Director General of Higher Education of Liberia.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Liberian Officials for False Accreditation of Academic Institutions Case Summary at 119-120.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Liberian Officials for False Accreditation of Academic Institutions Case Summary at 119-120,  accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Richard John Novak, Case No. 2:05-cr-180-LRJ (E.D. Wash.), Superseding Indictment filed March 20, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/novakr\/03-20-06novak-supersede-info.pdf; Plea Agreement filed March 20, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/novakr\/03-20-06novak-plea-agree.pdf; Judgment in a Criminal Case, October 2, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/novakr\/10-02-08novak-judgment.pdf.","Documents":""},{"Case ID":"ST-108","Case Cluster ":"Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Haiti","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"05\/15","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$36,375.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$36,375","Criminal Restitution \/ Reparation (US$)":"$0","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 4, 2009, two former executives of a Florida-based telecommunications company, the president of a Florida-based intermediary company, and two former Haitian government officials were charged in an indictment for their alleged roles in a foreign bribery, wire fraud, and money laundering scheme that lasted from at least November 2001 through March 2005. Joel Esquenazi, the former president of the telecommunications company; Carlos Rodriguez, the former executive vice-president of the telecommunications company; Marguerite Grandison, the former president of Telecom Consulting Services Corp.; Robert Antoine, a former director of international relations at the Republic of Haiti\u0027s state-owned national telecommunications company, Telecommunications D\u0027Haiti (Haiti Teleco); and Jean Rene Duperval, another former director of international relations at Haiti Teleco, were charged in connection with a scheme whereby the telecommunications company paid more than $800,000 to shell companies, including Grandison\u0027s Telecom Consulting Services Corp., to be used for bribes to foreign officials of Haiti Teleco. The purpose of these bribes was to obtain various business advantages from the Haitian officials for the telecommunications company, including issuing preferred telecommunications rates, reducing the number of minutes for which payment was owed, and giving a variety of credits toward owed sums, as well as to defraud the Republic of Haiti of revenue.Previously, on April 22, 2009, Juan Diaz, the president of J.D. Locator Services Inc., a Florida-based intermediary, and Antonio Perez, the former controller of the Florida-based telecommunications company, were charged in connection with their roles in the alleged foreign bribery scheme. According to court documents, from 1998 to 2003, Diaz and Perez conspired to make \u0022side payments\u0022 totaling $1 million to the Haitian government officials through a shell company belonging to Diaz, all on behalf of the Florida-based telecommunications company.On February 1, 2010, Jean Fourcand, the president of Fourcand Enterprises, Inc., another intermediary company, was charged in a one-count criminal information with engaging in monetary transactions involving property derived from the scheme to bribe the former Haitian government officials. Specifically, between November 2001 and August 2002, Fourcand received funds originating from this and other U.S. telecommunications companies for the benefit of Robert Antoine. A portion of these funds came in the form of a check from J.D. Locator Services Inc., and a portion of these funds were used to engage in a real estate transaction that benefitted Antoine.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco) Case Summary at 51-52.)   ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco) Case Summary at 51-52, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Perez, Case No. 1:09-cr-20347-JEM (S.D. Fla.), Information filed April 22, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pereza\/04-22-09perez-info.pdf; Plea Agreement filed April 27, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pereza\/04-27-09perez-plea-agree.pdf; Factual Agreement filed April 27, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pereza\/04-27-08perez-fact-agree.pdf.  ","Documents":""},{"Case ID":"ST-109","Case Cluster ":"Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Haiti","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"02\/19","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture, Criminal Restitution","Total Monetary Sanctions (US$)":"$18,500.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$18,500","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Money Laundering","Offenses - Settled":"Money Laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 4, 2009, two former executives of a Florida-based telecommunications company, the president of a Florida-based intermediary company, and two former Haitian government officials were charged in an indictment for their alleged roles in a foreign bribery, wire fraud, and money laundering scheme that lasted from at least November 2001 through March 2005. Joel Esquenazi, the former president of the telecommunications company; Carlos Rodriguez, the former executive vice-president of the telecommunications company; Marguerite Grandison, the former president of Telecom Consulting Services Corp.; Robert Antoine, a former director of international relations at the Republic of Haiti?s state-owned national telecommunications company, Telecommunications D\u0027Haiti (Haiti Teleco); and Jean Rene Duperval, another former director of international relations at Haiti Teleco, were charged in connection with a scheme whereby the telecommunications company paid more than $800,000 to shell companies, including Grandison\u0027s Telecom Consulting Services Corp., to be used for bribes to foreign officials of Haiti Teleco. The purpose of these bribes was to obtain various business advantages from the Haitian officials for the telecommunications company, including issuing preferred telecommunications rates, reducing the number of minutes for which payment was owed, and giving a variety of credits toward owed sums, as well as to defraud the Republic of Haiti of revenue.Previously, on April 22, 2009, Juan Diaz, the president of J.D. Locator Services Inc., a Florida-based intermediary, and Antonio Perez, the former controller of the Florida-based telecommunications company, were charged in connection with their roles in the alleged foreign bribery scheme. According to court documents, from 1998 to 2003, Diaz and Perez conspired to make \u0022side payments\u0022 totaling $1 million to the Haitian government officials through a shell company belonging to Diaz, all on behalf of the Florida-based telecommunications company.On February 1, 2010, Jean Fourcand, the president of Fourcand Enterprises, Inc., another intermediary company, was charged in a one-count criminal information with engaging in monetary transactions involving property derived from the scheme to bribe the former Haitian government officials. Specifically, between November 2001 and August 2002, Fourcand received funds originating from this and other U.S. telecommunications companies for the benefit of Robert Antoine. A portion of these funds came in the form of a check from J.D. Locator Services Inc., and a portion of these funds were used to engage in a real estate transaction that benefitted Antoine.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco) Case Summary at 51-52.)   According to the Amended Judgment in US v. Esquenazi, Esquenazi, Rodriguez, Perez, Fourcand and Antoine were ordered joint and severally liable for $2.2 million in restitution.  (Source: US v. Esquenazi, Case No. 1:09-cr-20210-JEM (S.D. Fla.), Amended Judgment filed November 3, 2011, accessed via Pacer.)  Esquenazi and Rodriguez were sentenced following their convictions; hence there is no entry on their cases and the restitution sum is noted only in the Perez entry as to avoid double counting of the sum. ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco) Case Summary at 51-52, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; US v. Jean Fourcand, Case No. 1:10-cr-20062-JEM (S.D. Fla.), Information filed February 1, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/fourcandj\/02-01-10fourcand-info.pdf; Plea Agreement filed February 19, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/fourcandj\/02-19-10fourcand-plea-agree.pdf; Factual Agreement filed February 19, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/fourcandj\/02-19-10fourcand-agree.pdf; Judgment filed May 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/fourcandj\/05-06-10fourcand-judgment.pdf","Documents":""},{"Case ID":"ST-111","Case Cluster ":"Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Haiti","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"02\/08","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$955,596.69","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$955,596.69","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Commit Money Laundering","Offenses - Settled":"Conspiracy to Commit  Money Laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"In July 2012, as part of his February 8, 2012 plea agreement filed in US v. Patrick Joseph, Mr. Joseph, was sentenced on one one count conspiracy to commit money laundering and forfeited $955,596.69 in criminal proceeds.  (Source: US v. Joseph, Case No. 1:09-cr-21010-JEM (S.D. Fla.), Plea Agreement filed February 8, 2012; Order of Forfeiture filed on July 6, 2012 and Judgment filed July 10, 2012.)  According to the Superseding Indictment in the same case, Mr. Joseph had been the Director General of Haiti Teleco from 2001-2003, and had allegedly conspired with others to conceal bribery proceeds.  (Source: US v. Cruz, et al, Case No. 1:09-cr-21010-JEM (S.D. Fla.), Superseding Indictment filed July 13, 2011.)","Sources ":"US v. Joseph, Case No. 1:09-cr-21010-JEM (S.D. Fla.), Plea Agreement filed February 8, 2012, accessed at http:\/\/www.fcpablog.com\/blog\/2012\/2\/9\/haiti-telco-official-pleads-guilty.html; Order of Forfeiture filed on July 6, 2012 and Judgment filed July 10, 2012 oth accessed via PACER; US v. Cruz, et al, Case No. 1:09-cr-21010-JEM (S.D. Fla.), Superseding Indictment filed July 13, 2011, accessed via PACER.","Documents":""},{"Case ID":"ST-112","Case Cluster ":"Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Haiti","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/12","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture, Criminal Restitution","Total Monetary Sanctions (US$)":"$3,432,980.39","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$1,580,771","Criminal Restitution \/ Reparation (US$)":"$1,852,209","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution ordered but recipient unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Commit Money Laundering","Offenses - Settled":"Conspiracy to Commit Money Laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 4, 2009, two former executives of a Florida-based telecommunications company, the president of a Florida-based intermediary company, and two former Haitian government officials were charged in an indictment for their alleged roles in a foreign bribery, wire fraud, and money laundering scheme that lasted from at least November 2001 through March 2005. Joel Esquenazi, the former president of the telecommunications company; Carlos Rodriguez, the former executive vice-president of the telecommunications company; Marguerite Grandison, the former president of Telecom Consulting Services Corp.; Robert Antoine, a former director of international relations at the Republic of Haiti\u0027s state-owned national telecommunications company, Telecommunications D\u0027Haiti (Haiti Teleco); and Jean Rene Duperval, another former director of international relations at Haiti Teleco, were charged in connection with a scheme whereby the telecommunications company paid more than $800,000 to shell companies, including Grandison\u0027s Telecom Consulting Services Corp., to be used for bribes to foreign officials of Haiti Teleco. The purpose of these bribes was to obtain various business advantages from the Haitian officials for the telecommunications company, including issuing preferred telecommunications rates, reducing the number of minutes for which payment was owed, and giving a variety of credits toward owed sums, as well as to defraud the Republic of Haiti of revenue.Previously, on April 22, 2009, Juan Diaz, the president of J.D. Locator Services Inc., a Florida-based intermediary, and Antonio Perez, the former controller of the Florida-based telecommunications company, were charged in connection with their roles in the alleged foreign bribery scheme. According to court documents, from 1998 to 2003, Diaz and Perez conspired to make \u0022side payments\u0022 totaling $1 million to the Haitian government officials through a shell company belonging to Diaz, all on behalf of the Florida-based telecommunications company.On February 1, 2010, Jean Fourcand, the president of Fourcand Enterprises, Inc., another intermediary company, was charged in a one-count criminal information with engaging in monetary transactions involving property derived from the scheme to bribe the former Haitian government officials. Specifically, between November 2001 and August 2002, Fourcand received funds originating from this and other U.S. telecommunications companies for the benefit of Robert Antoine. A portion of these funds came in the form of a check from J.D. Locator Services Inc., and a portion of these funds were used to engage in a real estate transaction that benefitted Antoine.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco) Case Summary at 51-52.)   According to the Amended Judgment in US v. Esquenazi, Esquenazi, Rodriguez, Perez, Fourcand and Antoine were ordered joint and severally liable for $2.2 million in restitution.  (Source: US v. Esquenazi, Case No. 1:09-cr-20210-JEM (S.D. Fla.), Amended Judgment filed November 3, 2011, accessed via Pacer.)  Esquenazi and Rodriguez were sentenced following their convictions; hence there is no entry on their cases and the restitution sum is noted only in the Perez entry as to avoid double counting of the sum. ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco) Case Summary at 51-52, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf;  US v. Esquenazi et al (including Robert Antoine), Case No. 1:09-cr-21010-MGC (S.D. Fla.), Indictment filed December 8, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/esquenazij\/12-08-09esquenazi-indict.pdf; Plea Agreement filed March 12, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/antione\/03-12-10antoine-plea.pdf;  Factual Agreement filed March 12, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/antione\/03-12-10antoine-agree.pdf; Judgment filed June 10, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/antione\/06-01-10antoine-judgment.pdf.  US Department of Justice Press Release, \u0022Former Haitian Government Official Sentenced to Prison for His Role in Money Laundering Conspiracy Related to Foreign Bribery Scheme,\u0022 June 2, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/June\/10-crm-639.html","Documents":""},{"Case ID":"ST-113","Case Cluster ":"Bristow Group, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria ","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"09\/26","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"No (Tax) ","Summary":"According to the June 2011 US Report to the OECD on the Enforcement of the Anti-Bribery Convention, \u0022On September 26, 2007, the SEC instituted administrative proceedings against Bristow Group Inc., [ ]  for violations of the FCPA. The SEC\u0027s administrative order alleged that Bristow violated the anti-bribery, internal controls, and books and records provisions of the FCPA as a consequence of the actions of two of its subsidiaries in Nigeria.  According to the SEC\u0027s administrative filing, since at least 2003 and through approximately the end of 2004, Bristow Group\u0027s Nigerian affiliate, Pan African Airlines Nigeria Ltd. (PAAN), made improper payments totaling $423,000 to employees of the governments of two Nigerian states to influence them to improperly reduce the amount of expatriate employment taxes payable by PAAN to the respective Nigerian state governments. At the end of each year, PAAN was subject to an expatriate \u0022Pay As You Earn\u0022 (PAYE) tax, which was assessed on the salaries of PAAN employees by the government of each Nigerian state where PAAN operated. PAAN then negotiated with government tax officials to lower the amount assessed. In each instance, the PAYE tax demand amount was lowered and a separate cash payment for the tax officials was negotiated. Once PAAN paid the state government and the tax officials, each state government provided PAAN with a receipt reflecting only the amount payable to the state government. All together, PAAN secured an $854,000 reduction in its PAYE tax liability in exchange for these improper payments.\r\nDuring that same time period, Bristow Group underreported PAAN and another Bristow Group Nigerian affiliate\u0027s payroll expenses to certain Nigerian state governments. As a result, Bristow Group\u0027s periodic reports filed with the SEC did not accurately reflect certain of the company\u0027s payroll-related expenses. Accordingly, the SEC\u0027s administrative order found that during this time period, Bristow Group had both lacked sufficient internal accounting controls and mischaracterized the payments as legitimate payroll expenses on its books and records.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bristow Group Inc.Case,  at 96-97.)  According to the SEC Administrative Proceedings file, Bristow settled the charges by consenting to a cease and desist order; no monetary penalty was ordered. (Source: Securities and Exchange Commission, Administrative Proceeding File No. 3-12833, In the Matter of Bristow Group Inc., September 26, 2007, Order Instituting Cease and Desist Proceedings)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bristol Group Inc. Case Summary, at 96-97, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; Securities and Exchange Commission, Administrative Proceeding File No. 3-12833, In the Matter of Bristow Group Inc., September 26, 2007, Order Instituting Cease and Desist Proceedings, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2007\/34-56533.pdf","Documents":""},{"Case ID":"ST-115","Case Cluster ":"CBRN Ltd.","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Crown Prosecution Service","Jurisdiction of Foreign Public Official(s) ":"Uganda","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"08\/23","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea  ","Monetary Sanctions  (Types)":"Unknown if ordered","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown   ","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unknown","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Section 1 of the Prevention of Corruption Act 1906 (bribery)","Offenses - Settled":"Section 1 of the Prevention of Corruption Act 1906 (bribery)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United Kingdom\u0027s August 2011 Report to the OECD, \u0022City of London Police - Guilty plea to bribery sets legal landmark \/ The first UK prosecution of a foreign bribery offence was heard in August 2008. The Managing Director of a UK-based company was found guilty of making corrupt payments to foreign officials. A Ugandan Government official who received the payment was arrested in London and also convicted.\u0022  (Source: United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011).)  According to the City of London Police Press Release, Neils Jorgen Tobiasen, 65, from Denmark, pleaded guilty at Southwark Crown Court to making corrupt payments.  Tobiasen, financial director of CBRN Team Ltd, will be sentenced at a later date. Tobiasen was charged under Section 1 of the Prevention of Corruption Act 1906.\u0022 (Source:  City of London Police Press Release, \u0022Guilty plea to bribery sets legal landmark \/ The government welcomed the first successful prosecution by the City of London Police?s Overseas Anti-Corruption Unit,\u0022 August 23, 2008.)","Sources ":"United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf; City of London Police Press Release, \u0022Guilty plea to bribery sets legal landmark \/ The government welcomed the first successful prosecution by the City of London Police\u0027s Overseas Anti-Corruption Unit,\u0022 August 23, 2008, accessed at http:\/\/www.cityoflondon.police.uk\/CityPolice\/Departments\/ECD\/anticorruptionunit\/guiltypleatobribery.htm, and which gives link to Michael Peel, \u0022Guilty plea to bribery sets legal landmark,\u0022 Financial Times, August 23, 2008, accessed at http:\/\/www.ft.com\/intl\/cms\/s\/0\/ff993ec6-70ad-11dd-b514-0000779fd18c.html#axzz1hsufXAJV","Documents":""},{"Case ID":"ST-116","Case Cluster ":"Central Asia American Enterprise Fund","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"United Kingdom","Year of Settlement":"2002","Month\/Day of Settlement (or Notes)":"09\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Restitution","Total Monetary Sanctions (US$)":"$300,000.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$300,000","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$300,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction; Restitution","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Government Program Fraud, Wire Fraud, Conspiracy to Commit Fraud ","Offenses - Settled":"Government Program Fraud, Wire Fraud, Conspiracy to Commit Fraud ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Plea Agreement and Statement of Facts in US v. Richard G. Pitchford, Pitchford was the vice president and country manager in Turkmenistan for the US Government-funded Central Asia American Enterprise Fund (CAAEF).  In addition to theft from the fund by using a kick-back scheme, Pitchford admitted to engaging in a scheme to ensure that a British company would win the bid on a CAAEF funded project and that the British company\u0027s bid was inflated by 15% or $200K and Pitchford worked to ensure that the British company won the bid even though he knew that all or some of the inflated amount would be paid to a British official with the UK Department of Trade and Industry.  As part of Pitchford\u0027s restitution, he was ordered to forfeit amounts in two New York brokerage accounts and a yacht that he had denied owning.  Some of the kickback funds in the Pitchford case were funneled through a BVI shell company (K.P.H., Inc.) formed by a CAAEF consultant with whom Pitchford conspired and a Swiss legal entity (Melioservice) formed by the UK official and used as a \u0022commission\u0022 agent.  The plea agreement noted that the US Department of Justice\u0027s Fraud Section which prosecuted the case would recommend to the court that Pitchford receive the maximum applicable reduction in sentencing for his plea and that the government would not seek an upward departure from applicable sentencing guidelines.  Moreover, if Pitchford complied with all the conditions of his plea agreement, the government agreed to file a departure motion in his sentencing. (Source: US v. Pitchford, Case No. 1:02-cr-365 (D.D.C.), Plea Agreement and Statement of Facts filed September 13, 2002 and Information filed September 3, 2002). Patrick Dickey, a co-conspirator pleaded guilty to non-FCPA charges and was ordered to pay $300K in restitution to the United States. (Source: U.S. Agency for International Development Press Release, \u0022Investigation of International Fradulent Conspiracy Results in Incarceration for Two Co-Conspirators,\u0022 November 27, 2002.)  ","Sources ":"US v. Patrick Dickey, Case No. 1:02-cr-00369-RCL (D.D.C.), Court Docket Report accessed via Pacer (the documents are not accessible by Pacer).  US v. Richard G. Pitchford, Case No. 1:02-cr-365 (D.D.C.), Information filed September 3, 2002; Plea Agreement and Statement of Facts filed September 13, 2002;  U.S. Agency for International Development Press Release, \u0022Investigation of International Fradulent Conspiracy Results in Incarceration for Two Co-Conspirators,\u0022 November 27, 2002, all accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pitchford.html","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Dickey_DOJ_Court_Docket_Report.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Richard_Pitchford_Sentencing_USAID_Nov_27_2002_0.pdf"},{"Case ID":"ST-117","Case Cluster ":"Central Asia American Enterprise Fund","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"United Kingdom","Year of Settlement":"2002","Month\/Day of Settlement (or Notes)":"09\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Restitution, Criminal Forfeiture","Total Monetary Sanctions (US$)":"$400,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown value of accounts and yacht","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$400,000","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$400,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction; Restitution","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of Foreign Official, Government Program Fraud, Conspiracy to Commit Fraud","Offenses - Settled":"Bribery of Foreign Official, Government Program Fraud, Conspiracy to Commit Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Plea Agreement and Statement of Facts in US v. Richard G. Pitchford, Pitchford was the vice president and country manager in Turkmenistan for the US Government-funded Central Asia American Enterprise Fund (CAAEF).  In addition to theft from the fund by using a kick-back scheme, Pitchford admitted to engaging in a scheme to ensure that a British company would win the bid on a CAAEF funded project and that the British company\u0027s bid was inflated by 15% or $200K and Pitchford worked to ensure that the British company won the bid even though he knew that all or some of the inflated amount would be paid to a British official with the UK Department of Trade and Industry.  As part of Pitchford\u0027s restitution, he was ordered to forfeit amounts in two New York brokerage accounts and a yacht that he had denied owning.  Some of the kickback funds in the Pitchford case were funneled through a British Virgin Islands shell company (K.P.H., Inc.) formed by a CAAEF consultant with whom Pitchford conspired and a Swiss legal entity (Melioservice) formed by the UK official and used as a \u0022commission\u0022 agent.  The plea agreement noted that the US Department of Justice\u0027s Fraud Section which prosecuted the case would recommend to the court that Pitchford receive the maximum applicable reduction in sentencing for his plea and that the government would not seek an upward departure from applicable sentencing guidelines.  Moreover, if Pitchford complied with all the conditions of his plea agreement, the government agreed to file a departure motion in his sentencing. Pitchford also agreed to pay $400,000 in restitution to the United States and to forfeit funds in two asset management accounts, in addition to a yacht in which that he denied having any interest. (Source: US v. Pitchford, Case No. 1:02-cr-365 (D.D.C.), Plea Agreement and Statement of Facts filed September 13, 2002 and Information filed September 3, 2002). Patrick Dickey, a co-conspirator pleaded guilty to non-FCPA charges and was ordered to pay $300K in restitution to the United States. (Source: U.S. Agency for International Development Press Release, \u0022Investigation of International Fradulent Conspiracy Results in Incarceration for Two Co-Conspirators,\u0022 November 27, 2002.)  ","Sources ":"US v. Richard G. Pitchford, Case No. 1:02-cr-365 (D.D.C.), Information filed September 3, 2002, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pitchford\/09-03-02pitchford-info.pdf; Plea Agreement filed September 13, 2002, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pitchford\/09-13-02pitchford-plea-agree.pdf; and Statement of Facts filed September 13, 2002, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pitchford\/09-13-02pitchford-state-facts.pdf;  U.S. Agency for International Development Press Release, \u0022Investigation of International Fradulent Conspiracy Results in Incarceration for Two Co-Conspirators,\u0022 November 27, 2002, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pitchford\/11-27-02pitchford-pressrelease.pdf","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Richard_Pitchford_Information_Sep_3_2002.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Richard_Pitchford_Plea_Agreement_Sep_13_2002.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Richard_Pitchford_Statement_Of_Facts_Sep_13_2002.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Richard_Pitchford_Sentencing_USAID_Nov_27_2002.pdf"},{"Case ID":"ST-118","Case Cluster ":"Chevron Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Treasury (Office of Foreign Assets Control)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food) ","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"11\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Settlement agreement","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$2,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$2,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Iraqi Sanctions Regulations (31 C.F.R. part 575)","Offenses - Settled":"Wire Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a press release by the United States Attorney for the Southern District of New York, on November 14, 2007, the United States Attorney for the Southern District of New York, the District Attorney for New York County, and the Department of the Treasury\u0027s Office of Foreign Assets Control (\u0022OFAC\u0022), \u0022announced an agreement (\u0022the Agreement\u0022) resolving the criminal and civil regulatory liabilities of CHEVRON CORPORATION and its subsidiaries (\u0022CHEVRON\u0022) relating to CHEVRON?s procurement of Iraqi oil under the United Nations Oil-for-Food Program. According to the Agreement, CHEVRON obtained Iraqi oil under the Program from third parties that paid secret, illegal surcharges to the former government of Iraq, in violation of United States wire fraud statutes and administrative regulations that prohibited transactions with the former Government of Iraq. Pursuant to the Agreement, CHEVRON will make the following payments totaling $27,000,000: (1) forfeiture of $20,000,000 to the U.S. Attorney\u0027s Office for the Southern District of New York (\u0022SDNY\u0022), which will seek to transfer that money to the Development Fund of Iraq (established on May 21, 2003, by United Nations Security Council Resolution 1483) to be paid as restitution for the benefit of the people of Iraq; (2) $5,000,000 to the New York County District Attorney\u0027s Office (\u0022DANY\u0022) to be distributed as DANY shall deem appropriate; and (3) $2,000,000 to OFAC in settlement of civil penalties. In a separate agreement, CHEVRON agreed to pay an additional monetary penalty of $3,000,000 to the Securities and Exchange Commission (\u0022SEC\u0022), and to pay disgorgement of $25,000,000, which will be satisfied by their payments to SDNY and DANY.\u0022 (Source: United States Attorney for the Southern District of New York Press Release, \u0022Chevron Corproation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007.)  The Press Release also noted that, \u0022This case is one of many that are the result of an unprecedented, wide-ranging criminal investigation into the United Nations Oil-for-Food Program. [  ] To date, the investigation has produced cases against 12 individuals and 7 entities (including CHEVRON) -- of which 6 individuals and 2 entities pleaded guilty, 1 individual was found guilty at trial, and 2 entities reached agreements with SDNY. The remaining cases are pending. Also as a result of the investigation, over $47.5 million in criminal proceeds has been forfeited or has been agreed to be forfeited to SDNY; SDNY will seek to transfer these funds to the Development Fund of Iraq as restitution for the benefit of the people of Iraq.\u0022 (Source: Ibid.)  Resulting ciminal cases: US v. Chevron Corporation (S.D.N.Y., November 14, 2007) and New York v. Chevron Corporation (New York County, November 14, 2007)","Sources ":"United States Attorney for the Southern District of New York Press Release, \u0022Chevron Corporation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/November07\/chevronagreementpr.pdf; Chevron Corporation Non-Prosecution Agreement dated November 8, 2007, accessed at  http:\/\/judiciary.house.gov\/hearings\/pdf\/deferredprosecution\/Chevron071108.pdf.","Documents":""},{"Case ID":"ST-119","Case Cluster ":"Chevron Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"New York County District Attorney\u0027s Office","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food) ","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"11\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$5,000,000.00","Criminal Fine\/Penalty (US$) ":"$5,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2 ","Offenses - Alleged":"Wire Fraud","Offenses - Settled":"Wire Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a press release by the United States Attorney for the Southern District of New York, on November 14, 2007, the United States Attorney for the Southern District of New York, the District Attorney for New York County, and the Department of the Treasury\u0027s Office of Foreign Assets Control (\u0022OFAC\u0022), \u0022announced an agreement (\u0022the Agreement\u0022) resolving the criminal and civil regulatory liabilities of CHEVRON CORPORATION and its subsidiaries (\u0022CHEVRON\u0022) relating to CHEVRON\u0027s procurement of Iraqi oil under the United Nations Oil-for-Food Program. According to the Agreement, CHEVRON obtained Iraqi oil under the Program from third parties that paid secret, illegal surcharges to the former government of Iraq, in violation of United States wire fraud statutes and administrative regulations that prohibited transactions with the former Government of Iraq. Pursuant to the Agreement, CHEVRON will make the following payments totaling $27,000,000: (1) forfeiture of $20,000,000 to the U.S. Attorney\u0027s Office for the Southern District of New York (\u0022SDNY\u0022), which will seek to transfer that money to the Development Fund of Iraq (established on May 21, 2003, by United Nations Security Council Resolution 1483) to be paid as restitution for the benefit of the people of Iraq; (2) $5,000,000 to the New York County District Attorney\u0027s Office (\u0022DANY\u0022) to be distributed as DANY shall deem appropriate; and (3) $2,000,000 to OFAC in settlement of civil penalties. In a separate agreement, CHEVRON agreed to pay an additional monetary penalty of $3,000,000 to the Securities and Exchange Commission (\u0022SEC\u0022), and to pay disgorgement of $25,000,000, which will be satisfied by their payments to SDNY and DANY.\u0022 (Source: United States Attorney for the Southern District of New York Press Release, \u0022Chevron Corproation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007.)  The Press Release also noted that, \u0022This case is one of many that are the result of an unprecedented, wide-ranging criminal investigation into the United Nations Oil-for-Food Program. [  ] To date, the investigation has produced cases against 12 individuals and 7 entities (including CHEVRON) -- of which 6 individuals and 2 entities pleaded guilty, 1 individual was found guilty at trial, and 2 entities reached agreements with SDNY. The remaining cases are pending. Also as a result of the investigation, over $47.5 million in criminal proceeds has been forfeited or has been agreed to be forfeited to SDNY; SDNY will seek to transfer these funds to the Development Fund of Iraq as restitution for the benefit of the people of Iraq.\u0022 (Source: Ibid.)  Resulting ciminal cases: US v. Chevron Corporation (S.D.N.Y., November 14, 2007) and New York v. Chevron Corporation (New York County, November 14, 2007)","Sources ":"United States Attorney for the Southern District of New York Press Release, \u0022Chevron Corporation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/November07\/chevronagreementpr.pdf;  Chevron Corporation Non-Prosecution Agreement dated November 8, 2007, accessed at  http:\/\/judiciary.house.gov\/hearings\/pdf\/deferredprosecution\/Chevron071108.pdf","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Chevron_SDNY_Non-Prosecution_Agreement_2007.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Chevron_SDNY_Agreement_PR_Mar_7_2008.pdf"},{"Case ID":"ST-120","Case Cluster ":"Chevron Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"11\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Civil Penalty","Total Monetary Sanctions (US$)":"$3,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"$3,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Internal controls violations","Offenses - Settled":"No admission or denial of alleged offeses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a press release by the United States Attorney for the Southern District of New York, on November 14, 2007, the United States Attorney for the Southern District of New York, the District Attorney for New York County, and the Department of the Treasury\u0027s Office of Foreign Assets Control (\u0022OFAC\u0022), \u0022announced an agreement (\u0022the Agreement\u0022) resolving the criminal and civil regulatory liabilities of CHEVRON CORPORATION and its subsidiaries (\u0022CHEVRON\u0022) relating to CHEVRON\u0027s procurement of Iraqi oil under the United Nations Oil-for-Food Program. According to the Agreement, CHEVRON obtained Iraqi oil under the Program from third parties that paid secret, illegal surcharges to the former government of Iraq, in violation of United States wire fraud statutes and administrative regulations that prohibited transactions with the former Government of Iraq. Pursuant to the Agreement, CHEVRON will make the following payments totaling $27,000,000: (1) forfeiture of $20,000,000 to the U.S. Attorney\u0027s Office for the Southern District of New York (\u0022SDNY\u0022), which will seek to transfer that money to the Development Fund of Iraq (established on May 21, 2003, by United Nations Security Council Resolution 1483) to be paid as restitution for the benefit of the people of Iraq; (2) $5,000,000 to the New York County District Attorney\u0027s Office (\u0022DANY\u0022) to be distributed as DANY shall deem appropriate; and (3) $2,000,000 to OFAC in settlement of civil penalties. In a separate agreement, CHEVRON agreed to pay an additional monetary penalty of $3,000,000 to the Securities and Exchange Commission (\u0022SEC\u0022), and to pay disgorgement of $25,000,000, which will be satisfied by their payments to SDNY and DANY.\u0022 (Source: United States Attorney for the Southern District of New York Press Release, \u0022Chevron Corproation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007.)  The Press Release also noted that, \u0022This case is one of many that are the result of an unprecedented, wide-ranging criminal investigation into the United Nations Oil-for-Food Program. [  ] To date, the investigation has produced cases against 12 individuals and 7 entities (including CHEVRON) -- of which 6 individuals and 2 entities pleaded guilty, 1 individual was found guilty at trial, and 2 entities reached agreements with SDNY. The remaining cases are pending. Also as a result of the investigation, over $47.5 million in criminal proceeds has been forfeited or has been agreed to be forfeited to SDNY; SDNY will seek to transfer these funds to the Development Fund of Iraq as restitution for the benefit of the people of Iraq.\u0022 (Source: Ibid.)  ","Sources ":"United States Attorney for the Southern District of New York Press Release, \u0022Chevron Corporation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/November07\/chevronagreementpr.pdf; US v. Chevron Corporation, Non-Prosecution Agreement filed November 14, 2007, accessed at http:\/\/fcpa.shearman.com\/files\/a6f\/a6f9b06a5abb243a2c37f89af684cbfc.pdf?i=4ae86429c8e9a2d374783fd18138bb2d; US Securities and Exchange Commission v. Chevron Corporation, Case No. 1:07-cv-10299-SHS (S.D.N.Y.), Complaint filed on November 14, 2007 and Final Judgment filed on November 20, 2007, accessed at www.fcpa.shearman.com; SEC Litigation Release No. 20363 \/ November 14, 2007, accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20363.htm","Documents":""},{"Case ID":"ST-121","Case Cluster ":"Chevron Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food) ","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"11\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Penalties, Criminal Forfeiture","Total Monetary Sanctions (US$)":"$20,000,000.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$20,000,000","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$20,000,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Iraq via Development Fund for Iraq","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Wire Fraud","Offenses - Settled":"Wire Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a press release by the United States Attorney for the Southern District of New York, on November 14, 2007, the United States Attorney for the Southern District of New York, the District Attorney for New York County, and the Department of the Treasury\u0027s Office of Foreign Assets Control (\u0022OFAC\u0022), \u0022announced an agreement (\u0022the Agreement\u0022) resolving the criminal and civil regulatory liabilities of CHEVRON CORPORATION and its subsidiaries (\u0022CHEVRON\u0022) relating to CHEVRON\u0027s procurement of Iraqi oil under the United Nations Oil-for-Food Program. According to the Agreement, CHEVRON obtained Iraqi oil under the Program from third parties that paid secret, illegal surcharges to the former government of Iraq, in violation of United States wire fraud statutes and administrative regulations that prohibited transactions with the former Government of Iraq. Pursuant to the Agreement, CHEVRON will make the following payments totaling $27,000,000: (1) forfeiture of $20,000,000 to the U.S. Attorney\u0027s Office for the Southern District of New York (\u0022SDNY\u0022), which will seek to transfer that money to the Development Fund of Iraq (established on May 21, 2003, by United Nations Security Council Resolution 1483) to be paid as restitution for the benefit of the people of Iraq; (2) $5,000,000 to the New York County District Attorney\u0027s Office (\u0022DANY\u0022) to be distributed as DANY shall deem appropriate; and (3) $2,000,000 to OFAC in settlement of civil penalties. In a separate agreement, CHEVRON agreed to pay an additional monetary penalty of $3,000,000 to the Securities and Exchange Commission (\u0022SEC\u0022), and to pay disgorgement of $25,000,000, which will be satisfied by their payments to SDNY and DANY.\u0022 (Source: United States Attorney for the Southern District of New York Press Release, \u0022Chevron Corporation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007.)  The Press Release also noted that, \u0022This case is one of many that are the result of an unprecedented, wide-ranging criminal investigation into the United Nations Oil-for-Food Program. [  ] To date, the investigation has produced cases against 12 individuals and 7 entities (including CHEVRON) -- of which 6 individuals and 2 entities pleaded guilty, 1 individual was found guilty at trial, and 2 entities reached agreements with SDNY. The remaining cases are pending. Also as a result of the investigation, over $47.5 million in criminal proceeds has been forfeited or has been agreed to be forfeited to SDNY; SDNY will seek to transfer these funds to the Development Fund of Iraq as restitution for the benefit of the people of Iraq.\u0022 (Source: Ibid.)  Resulting ciminal cases: US v. Chevron Corporation (S.D.N.Y., November 14, 2007) and New York v. Chevron Corporation (New York County, November 14, 2007)  ","Sources ":"United States Attorney for the Southern District of New York Press Release, \u0022Chevron Corporation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/November07\/chevronagreementpr.pdf;  Chevron Corporation Non-Prosecution Agreement dated November 8, 2007, accessed at  http:\/\/judiciary.house.gov\/hearings\/pdf\/deferredprosecution\/Chevron071108.pdf","Documents":""},{"Case ID":"ST-122","Case Cluster ":"Chiquita Brands International, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Colombia","Year of Settlement":"2001","Month\/Day of Settlement (or Notes)":"10\/03","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order ","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$100,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$100,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission Litigation Release, on October 3, 2007, the agency announced that it had filed a settled complaint against Chiquita Brands, alleging that the company had violated the books and records and internal controls provisions of the FCPA as a result of the conduct of its Colombian subsidiary, C.I. Bananos de Exportaction, S.A (Banadex).  The SEC had alleged that Banadex\u0027s chief administrative officer authorized the company\u0027s customs broker, as well as Banadex\u0027s security officer and controller, to make a corrupt payment of $30,000 to local customs officials to secure the renewal of the port facility\u0027s license. The SEC also alleged that Banadex\u0027s books and records incorrectly identified the two installment payments, made in 1996 and 1997.  Without admitting or denying the Commission\u0027s findings, Chiquita consented to the entry of an order that requires Chiquita to cease and desist from violating those provisions. The Commission also filed a settled complaint in federal court seeking entry of a consent order requiring Chiquita to pay a $100,000 civil penalty. Chiquita settled the action without admitting or denying the Commission\u0027s allegations.   (Source:  US Securities and Exchange Commission Litigation Release No. 17169 \/ October 3, 2001, SEC v. Chiquita Brands International, Inc., Civ. Action No. 1:01CV02079 (D.D.C.) (filed October 3, 2001), \u0022SEC Settles Case against Chiquita Brands International, Inc.\u0022)  \r\n","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Chiquita Brands International, Inc. Case,  at 128-129, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; US Securities and Exchange Commission, Admin Proceedings File No. 3-10613, In the Matter of Chiquita Brands International, Inc., October 3, 2001, accessed at http:\/\/www.sec.gov\/litigation\/admin\/34-44902.htm; ","Documents":""},{"Case ID":"ST-123","Case Cluster ":"Comverse Technologies Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Greece","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"04\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,200,000.00","Criminal Fine\/Penalty (US$) ":"$1,200,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Falsification of books and records","Offenses - Settled":"Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Statement of Facts attached to the Non-Prosecution Agreement involving Comverse Technology Inc. (\u0022CTI\u0022), Comverse, Inc. and the subsidiaries of Comverse, Inc. (collectively referred to as \u0022Comverse\u0022), Comverse Ltd. is a wholly-owned subsidiary of Comverse, Inc. was an Israeli company based in Tel Aviv, Israel.   From in or around 2000 to in or around 2006, Comverse Ltd. paid Agent G monthly retainer fees of $5,000 or $5,500 per month and also commissions on purchase orders he helped to obtain for Comverse Ltd.  Agent G would keep 15% of the total commission, and the remaining 85% was used to make improper payments.  In or around early 2003, certain employees of the Europe, Middle East, and Africa (\u0022EMEA\u0022) division of Comverse Ltd, directed Agent C to set up a shell company and corresponding bank account in Cyprus, Agent G was told that the shell company would be used to make cash payments to sernior executives of one of Comverse Ltd\u0027s Greek private customers. In or around February 2003, with the assistance of a Cypriot lawyer, Agent G caused Corporation H to be incorporated in Cyprus and bank accounts to be opened in Cyprus in the name of Corporation H.  Corporation H had no offices or employees and was later described by Agent G as \u0022purely a money laundering operation.\u0022  Using a fake invoice scheme, money was transferred from Comverse Ltd.\u0027s bank account in Isael to one of Coporation H\u0027s Cyprus bank accounts. Then the money would be withdrawn by Agent G or an employee and carried to directly to a Greek private customer or customers in Italy. Between 2003 and 2006, Comverse Ltd. made approximately $536,000 in cash payments to Corporation H with the intent that the money would be passed onto individuals connected to the Hellenic Telecommunications Organization S.A. (\u0022OTE\u0022), a telecommunications provider controlled and partially owned by the Greek government, and included payments to employees of OTE\u0027s subsidiaries Cosmote, Cosmofon, and Cosmorom, in order to obtain purchase orders from those companies for Comverse Ltd. products and services, resulting in approximately $1,250,000 in adjusted operating income. (para 24) (In Re: Comverse Technology, Inc., Non-Prosecution Agreement and Statement of Facts, April 6, 2011).  The company also settled SEC charges by agreeing to pay $1,249,614 disgorgement and $358,887 in prejudgment interest, without admitting or denying the allegations the SEC\u0027s allegations.  In the Complaint filed in SEC v. Comverse Technologies, SEC had alleged that the Cypriot entity which funnelled the improper paymens was called Fintron Enterprises Ltd. (para 12), and that the payments resulted in contracts worth approximately $10 million in revenues and ill-gotten gains of approximately $1.2 million.  (Source:  SEC v. Comverse Technology, Inc., Case No. 11:cv-1704-LDW (E.D.N.Y.), Complaint filed on April 7, 2011 and Litigation release No. 21920, April 7, 2011).","Sources ":"In Re: Comverse Technologies, Inc., Non-Prosecution Agreement and Statement of Facts, April 6, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/rae-comverse\/04-06-11comverse-npa.pdf; US Department of Justice Press Release, \u0022Comverse Technology INC. Agrees to Pay $1.2 Million Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 April 7, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/April\/11-crm-438.html; Securities and Exchange Commission v. Comverse Technology, Inc., Case No. 11-CV-1704-LDW (E.D.N.Y. filed April 7, 2011), Litigation Release No. 21920 (April 7, 2011), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr21920.htm and Complaint at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp21920.pdf.\r\n","Documents":""},{"Case ID":"ST-124","Case Cluster ":"Comverse Technologies Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Greece","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"04\/07","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Conduct-based Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit, Prejudgment Interest","Total Monetary Sanctions (US$)":"$1,608,501.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,249,614","Civil Prejudgment Interest (US$) ":"$358,887","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Statement of Facts attached to the Non-Prosecution Agreement involving Comverse Technology Inc. (\u0022CTI\u0022), Comverse, Inc. and the subsidiaries of Comverse, Inc. (collectively referred to as \u0022Comverse\u0022), Comverse Ltd. is a wholly-owned subsidiary of Comverse, Inc. was an Israeli company based in Tel Aviv, Israel.   From in or around 2000 to in or around 2006, Converse Ltd. paid Agent G monthly retainer fees of $5,000 or $5,500 per month and also commissions on purchase orders he helped to obtain for Comverse Ltd.  Agent G would keep 15% of the total commission, and the remaining 85% was used to make improper payments.  In or around early 2003, certain employees of the Europe, Middle East, and Africa (\u0022EMEA\u0022) division of Comverse ltd, directed Agent C to set up a shell company and corresponding bank account in Cyprus, Agent G was told that the shell company would be used to make cash payments to sernior executives of one of Comverse Ltd\u0027s Greek private customers. In or around February 2003, with the assistance of a Cypriot lawyer, Agent G caused Corporation H to be incorporated in Cyprus and bank accounts to be opened in Cyprus in the name of Corporation H.  Corporation H had no offices or employees and was later described by Agent G as \u0022purely a money laundering operation.\u0022  Using a fake invoice scheme, money was transferred from Comverse Ltd.\u0027s bank account in Isael to one of Coporation H\u0027s Cyprus bank accounts. Then the money would be withdrawn by Agent G or an employee and carried to directly to a Greek private customer or customers in Italy. Between 2003 and 2006, Comverse Ltd. made approximately $536,000 in cash payments to Corporation H with the intent that the money would be passed onto individuals connected to the Hellenic Telecommunications Organization S.A. (\u0022OTE\u0022), a telecommunications provider controlled and partially owned by the Greek government, and included payments to employees of OTE\u0027s subsidiaries Cosmote, Cosmofon, and Cosmorom, in order to obtain purchase orders from those companies for Comverse Ltd. products and services, resulting in approximately $1,250,000 in adjusted operating income. (para 24) (In Re: Comverse Technology, Inc., Non-Prosecution Agreement and Statement of Facts, April 6, 2011).  In the Complaint filed in SEC v. Comverse Technologies, SEC had alleged that the Cypriot entity which funnelled the improper paymens was called Fintron Enterprises Ltd. (para 12), and that the payments resulted in contracts worth approximately $10 million in revenues and ill-gotten gains of approximately $1.2 million.  (Source:  SEC v. Comverse Technology, Inc., Case No. 11:cv-1704-LDW (E.D.N.Y.), Complaint filed on April 7, 2011 and Litigation release No. 21920, April 7, 2011)","Sources ":"In Re: Comverse Technologies, Inc., Non-Prosecution Agreement and Statement of Facts, April 6, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/rae-comverse\/04-06-11comverse-npa.pdf; US Department of Justice Press Release, \u0022Comverse Technology Inc. Agrees to Pay $1.2 Million Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 April 7, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/April\/11-crm-438.html; Securities and Exchange Commission v. Comverse Technology, Inc., Case No. 11-CV-1704-LDW (E.D.N.Y. filed April 7, 2011), Litigation Release No. 21920 (April 7, 2011), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr21920.htm and Complaint at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp21920.pdf.\r\n","Documents":""},{"Case ID":"ST-125","Case Cluster ":"Control Components, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China, Malaysia, South Korea, India, Romania, Brazil, United Arab Emirates (total over 36 countries - both private and public bribery)","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"07\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$18,200,000.00","Criminal Fine\/Penalty (US$) ":"$18,200,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.21, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art, 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to commit commercial bribery, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to commit commercial bribery, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On July 22, 2009, Control Components, Inc. (CCI), a Rancho Santa Margarita, California-based company, was charged in a three count criminal information with violations of the FCPA and the Travel Act, stemming from a decade-long scheme to secure contracts in approximately 36 countries by paying bribes to officials and employees of various foreign state-owned companies as well as foreign and domestic private companies. Previously, two former executives of CCI, Mario Covino and Richard Morlok, were each charged with one count of conspiracy to bribe foreign officials in violation of the FCPA (on December 17, 2008 and January 7, 2009, respectively). On April 9, 2009, a grand jury in the Central District of California returned an indictment against six additional former CCI executives for their alleged roles in this bribery scheme.  According to court documents, from 2003 through 2007, CCI, a manufacturer of service control valves for use in the nuclear, oil and gas, and power generation industries, made approximately 236 corrupt payments to officers and employees of foreign state-owned and private companies in more than 30 countries. Sales from these corrupt payments resulted in net profits to the company of approximately $46.5 million.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Control Components, Inc. Case Summary, at 64-65.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Control Componets, Inc. Case Summary, at 64-65, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Control Components, Inc., Case No. 09-cr-00162-JVS (C.D. Cal., July 22, 2009), Information filed on July 22, 2009 and Plea Agreement and Statement of Facts dated July 22, 2009; Company press release dated July 31, 2009; Court Docket report as of August 28, 2009; IMI (parent company) news release of August 27, 2009.  All documents accessed at FCPA website of Shearman and Sterling, at http:\/\/fcpa.shearman.com\/index.php (US v. Control Components, Inc. case summary page); udgment filed July 31, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/control-inc\/07-31-09cci-judgment.pdf","Documents":""},{"Case ID":"ST-126","Case Cluster ":"Control Systems Specialists, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Brazil","Year of Settlement":"1998","Month\/Day of Settlement (or Notes)":"10\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,500.00","Criminal Fine\/Penalty (US$) ":"$1,500","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.15, Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials; Bribery of foreign officials, Bribery of US officials","Offenses - Settled":"Conspiracy to bribe foreign officials; Bribery of foreign officials, Bribery of US officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD on the Enforcement of the Anti-Bribery Convention, \u0022On August 19, 1998, the Department of Justice filed a three-count information against Control Systems Specialist, Inc. (CSS) and its President, Darrold Richard Crites, charging both with conspiring to bribe foreign officials, as well as bribing both foreign and U.S. public officials. CSS, an Ohio corporation, was engaged in the business of buying and repairing surplus military equipment for resale. According to court documents, in 1994, CSS and Crites bid on a contract to supply refurbished military equipment to the Brazilian Aeronautical Commission. In order to win this contract, between November 1994 and December 1995, CSS and Crites made more than 21 bribe payments to a Brazilian Air Force Lt. Colonel, who was authorized to purchase military equipment on behalf of the Brazilian government. These bribe payments ultimately totaled more than $250,000. In addition, CSS and Crites paid approximately $66,000 to a U.S. Air Force officer to provide CSS with confidential information that helped the contracts with the Brazilian government. As a result of these bribe payments, CSS was awarded the contract with the Brazilian Air Force, which was ultimately worth more than $670,000.\r\nCriminal Disposition:\r\nCSS and Crites each pleaded guilty before Judge Walter H. Rice on October 15, 1998, and were subsequently sentenced on March 8, 1999. Defendant Crites was sentenced to 3 years\u0027 probation, including 6 months\u0027 home confinement. CSS was fined $1,500.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Control Systems Specialist, Inc. Case at 134.).  According to the Court Docket Report, the fine was $500 per each count. (Source: US v. Control Systems Specialist, Inc. and Darrold Richard Crites, Case No. 3:98-cr-073 (S.D. Ohio), Court Docket Report accessed at http:\/\/fcpa.shearman.com\/files\/6dc\/6dc8985e0fb5fd5bf9a9385bc162bb79.pdf?i=c5b5c161b6598bf223e61ed0033c2711.","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31,2011, Control Systems Specialist, Inc. Case at 134, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf;  US v. Control Systems Specialist, Inc. and Darrold Richard Crites, Case No. 3:98-cr-073 (S.D. Ohio), Information filed on August 19, 1998, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/control-inc\/08-19-98css-info.pdf; Plea Agreement filed October 15, 1998, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/control-inc\/10-15-98css-plea-agree.pdf; US v. Control Systems Specialist, Inc. and Darrold Richard Crites, Case No. 3:98-cr-073 (S.D. Ohio), Court Docket Report accessed at http:\/\/fcpa.shearman.com\/files\/6dc\/6dc8985e0fb5fd5bf9a9385bc162bb79.pdf?i=c5b5c161b6598bf223e61ed0033c2711.","Documents":""},{"Case ID":"ST-127","Case Cluster ":"Control Systems Specialists, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Brazil","Year of Settlement":"1998","Month\/Day of Settlement (or Notes)":"10\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea ","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.15","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to bribe foreign officials; Bribery of foreign officials, Bribery of US officials","Offenses - Settled":"Conspiracy to bribe foreign officials; Bribery of foreign officials, Bribery of US officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD on the Enforcement of the Anti-Bribery Convention, \u0022On August 19, 1998, the Department of Justice filed a three-count information against Control Systems Specialist, Inc. (CSS) and its President, Darrold Richard Crites, charging both with conspiring to bribe foreign officials, as well as bribing both foreign and U.S. public officials. CSS, an Ohio corporation, was engaged in the business of buying and repairing surplus military equipment for resale. According to court documents, in 1994, CSS and Crites bid on a contract to supply refurbished military equipment to the Brazilian Aeronautical Commission. In order to win this contract, between November 1994 and December 1995, CSS and Crites made more than 21 bribe payments to a Brazilian Air Force Lt. Colonel, who was authorized to purchase military equipment on behalf of the Brazilian government. These bribe payments ultimately totaled more than $250,000. In addition, CSS and Crites paid approximately $66,000 to a U.S. Air Force officer to provide CSS with confidential information that helped the contracts with the Brazilian government. As a result of these bribe payments, CSS was awarded the contract with the Brazilian Air Force, which was ultimately worth more than $670,000.\r\nCriminal Disposition:\r\nCSS and Crites each pleaded guilty before Judge Walter H. Rice on October 15, 1998, and were subsequently sentenced on March 8, 1999. Defendant Crites was sentenced to 3 years\u0027 probation, including 6 months\u0027 home confinement. CSS was fined $1,500.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Control Systems Specialist, Inc. Case at 134.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31,2011, Control Systems Specialist, Inc. Case at 134, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf;  US v. Control Systems Specialist, Inc. and Darrold Richard Crites, Case No. 3:98-cr-073 (S.D. Ohio), Information filed on August 19, 1998, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/control-inc\/08-19-98css-info.pdf; Plea Agreement filed October 15, 1998, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/control-inc\/10-15-98css-plea-agree.pdf; US v. Control Systems Specialist, Inc. and Darrold Richard Crites, Case No. 3:98-cr-073 (S.D. Ohio), Court Docket Report accessed at http:\/\/fcpa.shearman.com\/files\/6dc\/6dc8985e0fb5fd5bf9a9385bc162bb79.pdf?i=c5b5c161b6598bf223e61ed0033c2711.","Documents":""},{"Case ID":"ST-128","Case Cluster ":"Con-Way, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Philippines","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"08\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$300,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$300,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Con-Way Inc. at 58-59: Time period of misconduct in Philippines, 2000-2003; SEC complaint alleged that Con-Way\u0027s Philippine subsidiary, Emery Transnational, (1) made approximately $244,000 in improper payments to foreign officials of the Philippines Bureau of Customs and the Philippine Economic Zone Area, that the payments were made to induce these foreign officials to violate customs regulations, settle customs disputes, and reduce or not enforce otherwise legitimate fines; (2) $173,000 in improper payments to officials at fourteen state-owned airlines that conducted business in the Philippines, to induce airline officials to improperly reserve space for Emery Transnational on airplanes, to fasely under-weigh shipments, and to improperly consolidate multiple shipments into a single shipment, resulting in lower shipping charges.  Resulting civil\/administrative enforcement actions: SEC v. Con-Way Inc., Case No. 1:08-cv-01478-EGS (D.D.C.), Complaint filed August 27, 2008; In the Matter of Con-Way Inc. (August 27, 2008).  According to the US Securities and Exchange Commission Litigation Release, \u0022Without admitting or denying the allegations in the Commission?s complaint, Con-way agreed to pay a $300,000 civil penalty.\u0022  (Source: \r\nUS Securities and Exchange Commission, Litigation Release No. 20690 \/ August 27, 2008, Securities and Exchange Commission v. Con-way Inc., Civil Action No. 1:08-CV-01478 (D.D.C.) (EGS), \u0022SEC Files Settled Enforcement Action Charging Con-way Inc. with Violations of the Foreign Corrupt Practices Act.\u0022)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Con-Way Inc. at 58-59, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Securities and Exchange Commission, Litigation Release No. 20690 \/ August 27, 2008, Securities and Exchange Commission v. Con-way Inc., Civil Action No. 1:08-CV-01478 (D.D.C.) (EGS), \u0022SEC Files Settled Enforcement Action Charging Con-way Inc. with Violations of the Foreign Corrupt Practices Act,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20690.htm; US Securities and Exchange Commission v. Con-Way Inc., Case No. 1:08-cv-01478-EGS (D.D.C.), Complaint filed August 27, 2008, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20690.pdf","Documents":""},{"Case ID":"ST-129","Case Cluster ":"Daimler AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, Croatia, Egypt, Greece, Hungary, Indonesia, Iraq (UN Oil-for-Food), Ivory Coast, Latvia, Nigeria, Russia, Serbia and Montenegro, Thailand, Turkey, Turkmenistan, Uzbekistan, Vietnam and other unspecified countries (at least 22 countries)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"04\/01","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits","Total Monetary Sanctions (US$)":"$91,432,867.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$91,432,867","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offeses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Press Release, the Commission \u0022today announced a settlement with Daimler AG for violations of the Foreign Corrupt Practices Act (FCPA), alleging that the Stuttgart, Germany-based automobile manufacturer engaged in a repeated and systematic practice of paying bribes to foreign government officials to secure business in Asia, Africa, Eastern Europe and the Middle East.  Daimler agreed to pay $91.4 million in disgorgement to settle the SEC\u0027s charges and pay $93.6 million in fines to settle charges in separate criminal proceedings announced today by the U.S. Department of Justice.\r\n\r\nThe SEC alleges that Daimler paid at least $56 million in improper payments over a period of more than 10 years. The payments involved more than 200 transactions in at least 22 countries. Daimler earned $1.9 billion in revenue and at least $90 million in illegal profits through these tainted sales transactions, which involved at least 6,300 commercial vehicles and 500 passenger cars. Daimler also paid kickbacks to Iraqi ministries in connection with direct and indirect sales of motor vehicles and spare parts under the United Nations Oil for Food Program. [  ]   The SEC\u0027s complaint, filed in U.S. District Court for the District of Columbia, alleges that Daimler used bribes to further government sales in such countries as Russia, China, Vietnam, Nigeria, Hungary, Latvia, Croatia, and Bosnia. Among other means, Daimler used dozens of ledger accounts, known internally as \u0022interne Fremdkonten\u0022 or \u0022internal third party accounts\u0022 to maintain credit balances for the benefit of government officials. These credit balances were controlled by Daimler subsidiaries or outside third parties, including foreign government officials or Daimler\u0027s dealers, distributors or other agents who were at times used as intermediaries to make payments to foreign government officials. The accounts were funded through several bogus pricing mechanisms, such as \u0022price surcharges,\u0022 \u0022price inclusions,\u0022 or excessive commissions. Daimler also used artificial discounts or rebates on sales contracts to effectuate bribes. In those instances, all or a portion of the discount was kicked back through a ledger account to a foreign government official, rather than credited to the purchasing government customer.\u0022 (Source:  US Securities and Exchange Commission Press Release, \u0022SEC Charges Daimler AG with Global Bribery,\u0022 April 1, 2010.)\r\n\r\n","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31,2011, Daimler AG Case Summary at 49-50, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf;  US Securities and Exchange Commission Press Release, \u0022SEC Charges Daimler AG with Global Bribery,\u0022 April 1, 2010, accessed at http:\/\/www.sec.gov\/news\/press\/2010\/2010-51.htm; Complaint assigned March 22, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp-pr2010-51.pdf","Documents":""},{"Case ID":"ST-130","Case Cluster ":"Daimler AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China, Croatia, Egypt, Greece, Hungary, Indonesia, Iraq (UN Oil-for-Food), Ivory Coast, Latvia, Nigeria, Russia, Serbia and Montenegro, Thailand, Turkey, Turkmenistan, Uzbekistan, Vietnam and other unspecified countries (at least 22 countries)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"04\/01","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$37,220,000.00","Criminal Fine\/Penalty (US$) ":"$37,220,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to falsify books and records, Falsification of books and records","Offenses - Settled":"Conspiray to falsify books and records, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to DOJ Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Daimler AG, at 24-25:  Case involved Daimler AG and three subsidiaries:  DaimlerChrysler Automotive Russia SAO (DCAR), Daimler Export and Trade Finance GmbH (ETF), and DaimlerChrysler China Ltd. (DCCL).  Misconduct alleged (1) hundreds of  improper payments worth tens of millions of dollars by Daimler AG and its subsidiaries to foreign officials in at least 22 countries - including China, Croatia, Egypt, Greece, Hungary, Indonesia, Iraq, Ivory Coast, Latvia, Nigeria, Russia, Serbia and Montenegro, Thailand, Turkey, Turkmenistan, Uzbekistan, Vietnam and others - to assist in securing contracts with government customers for the purchase of Daimler vehicles.  (2) Daimler AG admitted that it agreed to pay kickbacks to former Iraqi government in connection with contracts to sell vehicles to Iraq under the UN\u0027s Oil-for-Food program.  Time period of conduct is 1998-2008. The contracts were valued in the hundreds of millions of dollars.  According to Daimler AG\u0027s Deferred Prosecution Agreement, the company agreed to pay a fine of $93.6 million; the parties agreed that any fines agreed to and\/or ordered against Daimler\u0027s subsidiaries would be deducted from that amount.  (Source: US v. Daimler AG, Case No. 1:10-cr-063-RJL (D.D.C.), Deferred Prosecution Agreement filed March 24, 2010.)  DaimlerChrysler Automotive Russia SAO agreed to pay $27.26 million in criminal fine and Daimler Export and Trade Finance agreed to pay $29.12 million in criminal fine.  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31,2011, Daimler AG Case Summary at 49-50.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31,2011, Daimler AG Case Summary at 49-50, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Daimler AG, at 24-25, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US v. Daimler AG, et al, Case No. 1:10-cr-00063-RJL (D.D.C.), United States\u0027 Sentencing Memorandum filed March 24, 2010 and Information filed Mar. 22, 2010, both accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/daimler-ag.html and Deferred Prosecution Agreement and Statement of Facts filed March 24, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/daimler\/03-24-10daimlerag-agree.pdf; ,US Department of Justice Press Release, \u0022Daimler AG and Three Subsidiaries Resolve Foreign Corrupt Practices Act Investigation and Agree to Pay $93.6 Million in Criminal Penalties,\u0022 April 1, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/April\/10-crm-360.html (accessed September 14, 2011). ","Documents":""},{"Case ID":"ST-131","Case Cluster ":"Daimler AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement ","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials; Bribery of foreign officials ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to DOJ Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Daimler AG, at 24-25:  Case involved Daimler AG and three subsidiaries:  DaimlerChrysler Automotive Russia SAO (DCAR), Daimler Export and Trade Finance GmbH (ETF), and DaimlerChrysler China Ltd. (DCCL).  Misconduct alleged (1) hundreds of  improper payments worth tens of millions of dollars by Daimler AG and its subsidiaries to foreign officials in at least 22 countries - including China, Croatia, Egypt, Greece, Hungary, Indonesia, Iraq, Ivory Coast, Latvia, Nigeria, Russia, Serbia and Montenegro, Thailand, Turkey, Turkmenistan, Uzbekistan, Vietnam and others - to assist in securing contracts with government customers for the purchase of Daimler vehicles.  (2) Daimler AG admitted that it agreed to pay kickbacks to former Iraqi government in connection with contracts to sell vehicles to Iraq under the UN\u0027s Oil-for-Food program.  Time period of conduct is 1998-2008. The contracts were valued in the hundreds of millions of dollars.  According to DaimlerChrysler China Ltd\u0027s Deferred Prosecution Agreement, in light of the parent company Daimler AG\u0027s payment of $93.6 million in criminal fines (offset by fines ordered against its Russian and Export and Trade Finance subsidiaries), no separate monetary fine was imposed against its China subsidiary.  (Source: US v. DaimlerChrysler China Ltd., Case No. 1:10-cr-066-RJL (D.D.C.), Deferred Prosecution Agreement filed March 24, 2010.)  ","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Daimler AG, at 24-25, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US v. Daimler AG, et al, Case No. 1:10-cr-00063-RJL (D.D.C.), Deferred Prosecution Agreement and Statement of Facts filed March 24, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/daimler\/03-24-10daimlerag-agree.pdf; US Department of Justice Press Release, \u0022Daimler AG and Three Subsidiaries Resolve Foreign Corrupt Practices Act Investigation and Agree to Pay $93.6 Million in Criminal Penalties,\u0022 April 1, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/April\/10-crm-360.html (accessed September 14, 2011). US v. DaimlerChrysler China Ltd., Case No. 1:10-cr-066-RJL (D.D.C.), Deferred Prosecution Agreement filed March 24, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/daimler\/03-24-10daimlerchina-prosecution.pdf","Documents":""},{"Case ID":"ST-132","Case Cluster ":"Daimler AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Croatia","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$29,120,000.00","Criminal Fine\/Penalty (US$) ":"$29,120,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials; Bribery of foreign officials ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to DOJ Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Daimler AG, at 24-25:  Case involved Daimler AG and three subsidiaries:  DaimlerChrysler Automotive Russia SAO (DCAR), Daimler Export and Trade Finance GmbH (ETF), and DaimlerChrysler China Ltd. (DCCL). Misconduct alleged (1) hundreds of  improper payments worth tens of millions of dollars by Daimler AG and its subsidiaries to foreign officials in at least 22 countries - including China, Croatia, Egypt, Greece, Hungary, Indonesia, Iraq, Ivory Coast, Latvia, Nigeria, Russia, Serbia and Montenegro, Thailand, Turkey, Turkmenistan, Uzbekistan, Vietnam and others - to assist in securing contracts with government customers for the purchase of Daimler vehicles.  (2) Daimler AG admitted that it agreed to pay kickbacks to former Iraqi government in connection with contracts to sell vehicles to Iraq under the UN\u0027s Oil-for-Food program.  Time period of conduct is 1998-2008. The contracts were valued in the hundreds of millions of dollars.  According to the Plea Agreements and the Amended Jugment filed in US v. Daimler Export and Trade Finance GmbH, the Daimler subsidiary agreed to and was ordered to pay $29.12 million in criminal fines.  (Sources:  US v. Daimler Export and Trade Finance GmbH, Case No. 1:10-cr-65-RJL (D.D.C.), Plea Agreement filed March 24, 2010 and Amended Judgment filed April 6, 2010.)","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Daimler AG, at 24-25, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.  US v. Daimler Export and Trade Finance GmbH, Case No. 1:10-cr-65-RJL (D.D.C.), Plea Agreement filed March 24, 2010, accessed at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/daimler\/03-24-10daimlerexp-plea.pdf and Amended Judgment filed April 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/daimler\/04-06-10daimlerexp-amend.pdf. See also, US Department of Justice Press Release, \u0022Daimler AG and Three Subsidiaries Resolve Foreign Corrupt Practices Act Investigation and Agree to Pay $93.6 Million in Criminal Penalties,\u0022 April 1, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/April\/10-crm-360.html and US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31,2011, Daimler AG Case Summary at 49-50","Documents":""},{"Case ID":"ST-133","Case Cluster ":"Daimler AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Russia","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$27,360,000.00","Criminal Fine\/Penalty (US$) ":"$27,360,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials; Bribery of foreign officials ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to DOJ Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Daimler AG, at 24-25:  Case involved Daimler AG and three subsidiaries:  DaimlerChrysler Automotive Russia SAO (DCAR), Daimler Export and Trade Finance GmbH (ETF), and DaimlerChrysler China Ltd. (DCCL).  Misconduct alleged (1) hundreds of  improper payments worth tens of millions of dollars by Daimler AG and its subsidiaries to foreign officials in at least 22 countries - including China, Croatia, Egypt, Greece, Hungary, Indonesia, Iraq, Ivory Coast, Latvia, Nigeria, Russia, Serbia and Montenegro, Thailand, Turkey, Turkmenistan, Uzbekistan, Vietnam and others - to assist in securing contracts with government customers for the purchase of Daimler vehicles.  (2) Daimler AG admitted that it agreed to pay kickbacks to former Iraqi government in connection with contracts to sell vehicles to Iraq under the UN\u0027s Oil-for-Food program.  Time period of conduct is 1998-2008. The contracts were valued in the hundreds of millions of dollars.  According to the Amended Judgment in US v. DaimlerChrysler Automotive Russia SAO, the Daimler subsidiary ordered to pay $27.36 million in criminal fine.  (Sources: US v. DaimlerChrysler Automotive Russia SAO, Case No. 1:10-cr-64 (D.D.C.), Plea Agreement filed March 24, 2010, and Amended Judgment filed April 6, 2010.)","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Daimler AG, at 24-25, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf;  US Department of Justice Press Release, \u0022Daimler AG and Three Subsidiaries Resolve Foreign Corrupt Practices Act Investigation and Agree to Pay $93.6 Million in Criminal Penalties,\u0022 April 1, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/April\/10-crm-360.html (accessed September 14, 2011).  US v. DaimlerChrysler Automotive Russia SAO, Case No. 1:10-cr-64 (D.D.C.), Plea Agreement filed March 24, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/daimler\/03-24-10daimlerrussia-plea.pdf and Amended Judgment filed April 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/daimler\/04-06-10daimlerrussia-amend.pdf.  See also, US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31,2011, Daimler AG Case Summary at 49-50, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf","Documents":""},{"Case ID":"ST-134","Case Cluster ":"Data Systems and Solutions, LLC","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Lithuania","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"06\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$8,820,000.00","Criminal Fine\/Penalty (US$) ":"$8,820,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Bribery of foreign officials, Conspiracy to bribe foreign officials","Offenses - Settled":"Bribery of foreign officials, Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022Data Systems \u0026 Solutions LLC (DS\u0026S), a company based in Reston, Va., that provides design, installation, maintenance and other services at nuclear and fossil fuel power plants, has agreed to pay an $8.82 million criminal penalty to resolve violations of the Foreign Corrupt Practices Act (FCPA) [  ]  The department filed a two-count criminal information today in the Eastern District of Virginia charging DS\u0026S with conspiring to violate, and violating, the FCPA\u0027s anti-bribery provisions.  According to court documents, DS\u0026S paid bribes to officials employed by the Ignalina Nuclear Power Plant, a state-owned nuclear power plant in Lithuania, to secure contracts to perform services for the plant.  To disguise the scheme, the bribes were funneled through several subcontractors located in the United States and abroad.  The subcontractors, in turn, made repeated payments to high-level officials at Ignalina via check or wire transfer.  \r\nThe department also filed today a deferred prosecution agreement with DS\u0026S.  Under the terms of the agreement, the department will defer prosecution of DS\u0026S for two years.\u0022 (Source: US Department of Justice Press Release, \u0022Data Systems \u0026 Solutions LLC Resolves Foreign Corrupt Practices Act Violations and Agrees to Pay $8.82 Million Criminal Penalty,\u0022 June 18, 2012.)  According to the Information filed in the case, \u0022Subcontractor C\u0022 was a shell company was a shell company incorporated in the US and was used to funnel bribe payments (para 12), including to the officials\u0027 bank accounts in the U.S. (para 16b) (Source: US v. Data Systems \u0026 Solutions LLC, Case No. 1:12-cr-262 (E.D.Va.), Information filed June 18, 2012.)\r\n","Sources ":"US Department of Justice Press Release, \u0022Data Systems \u0026 Solutions LLC Resolves Foreign Corrupt Practices Act Violations and Agrees to Pay $8.82 Million Criminal Penalty,\u0022 June 18, 2012, accessed at http:\/\/www.justice.gov\/opa\/pr\/2012\/June\/12-crm-768.html; US v. Data Systems \u0026 Solutions LLC, Case No. 1:12-cr-00262 (E.D. Va.), Information filed June 18, 2012 and Deferred Prosecution Agreement filed June 18, 2012, both accessed via PACER.","Documents":""},{"Case ID":"ST-135","Case Cluster ":"David Chalmers\/ Bayoil","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"08\/17","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Restitution","Total Monetary Sanctions (US$)":"$9,016,151.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$9,016,151","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$9,016,151","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Iraq via Development Fund for Iraq","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Multiple counts of conspiracy to commit wire fraud, violations of sanctions","Offenses - Settled":"Conspiracy to commit wire fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a press release by the United States Attorney for the Southern District of New York, \u0022David B. Chalmers, Jr. [ ] and two corporations that he operated -- BAYOIL (USA), INC. [  ] BAYOIL SUPPLY \u0026 TRADING LIMITED, a Bahamian company with principal offices in Nassau, Bahamas (collectively, the \u0022BAYOIL COMPANIES\u0022). CHALMERS and the BAYOIL COMPANIES each pleaded guilty today before United States District Judge DENNY CHIN to participating in a scheme to pay illegal surcharges to the former Government of Iraq in connection with the purchase of crude oil in the United Nations Oil-for-Food Program between mid-2000 and 2003. Judge CHIN also accepted earlier today the guilty plea of LUDMIL DIONISSIEV to related smuggling charges. DIONISSIEV worked with CHALMERS and the BAYOIL COMPANIES during the course of this scheme to purchase Iraqi oil. CHALMERS and the BAYOIL COMPANIES each pleaded guilty to participating in a conspiracy to commit wire fraud related to the payment of secret illegal surcharge payments to the former Government of Iraq.\u0022  (Source: United States Attorney for the Southern District of New York, \u0022U.S. Announces Four Guilty Pleas in Oil-for-Food Case,\u0022 August 17, 2007.)  According to the Restitution Order, on March 18, 2008, Mr. Chalmers and the Bayoil companies were ordered joint and severally liable for payment of restitution in the amount of $9,016,151.40 and the defendants were ordered to pay this sum \u0022in restitution to the Development Fund for Iraq, in care of Ambassador Srood Najib.\u0022 (Source: US v. David Chalmers, et al, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Order of Restitution filed March 25, 2008.).  Please note that the restitution figure has been included only in the company entry so as to avoid double-counting. ","Sources ":"US v. David B. Chalmers, Jr., Bayoil (USA) Inc., and Bayoil Supply \u0026 Trading Limited, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Order of Restitution filed on March 25, 2008; United States Attorney Southern District of New York Press Release, \u0022U.S. Announces Four Guilty Pleas in Oil-for-Food Case,\u0022 August 17, 2007, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/August07\/chalmersdionissievbayoiloilforfoodpleaspr.pdf.","Documents":""},{"Case ID":"ST-136","Case Cluster ":"David Chalmers\/ Bayoil","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"08\/17","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Restitution","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Iraq via Development Fund for Iraq (see Summary for explanation)","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Multiple counts of conspiracy to commit wire fraud, violations of sanctions","Offenses - Settled":"Conspiracy to commit wire fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a press release by the United States Attorney for the Southern District of New York, \u0022David B. Chalmers, Jr. [ ] and two corporations that he operated -- BAYOIL (USA), INC. [  ] BAYOIL SUPPLY \u0026 TRADING LIMITED, a Bahamian company with principal offices in Nassau, Bahamas (collectively, the \u0022BAYOIL COMPANIES\u0022). CHALMERS and the BAYOIL COMPANIES each pleaded guilty today before United States District Judge DENNY CHIN to participating in a scheme to pay illegal surcharges to the former Government of Iraq in connection with the purchase of crude oil in the United Nations Oil-for-Food Program between mid-2000 and 2003. Judge CHIN also accepted earlier today the guilty plea of LUDMIL DIONISSIEV to related smuggling charges. DIONISSIEV worked with CHALMERS and the BAYOIL COMPANIES during the course of this scheme to purchase Iraqi oil. CHALMERS and the BAYOIL COMPANIES each pleaded guilty to participating in a conspiracy to commit wire fraud related to the payment of secret illegal surcharge payments to the former Government of Iraq.\u0022  (Source: United States Attorney for the Southern District of New York, \u0022U.S. Announces Four Guilty Pleas in Oil-for-Food Case,\u0022 August 17, 2007.)  According to the Restitution Order, on March 18, 2008, Mr. Chalmers and the Bayoil companies were ordered joint and severally liable for payment of restitution in the amount of $9,016,151.40 and the defendants were ordered to pay this sum \u0022in restitution to the Development Fund for Iraq, in care of Ambassador Srood Najib.\u0022 (Source: US v. David Chalmers, et al, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Order of Restitution filed March 25, 2008.)  Please note that the restitution figure has been included only in the company entry so as to avoid double-counting.  ","Sources ":"US v. David B. Chalmers, Jr., Bayoil (USA) Inc., and Bayoil Supply \u0026 Trading Limited, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Order of Restitution filed on March 25, 2008; United States Attorney Southern District of New York Press Release, \u0022U.S. Announces Four Guilty Pleas in Oil-for-Food Case,\u0022 August 17, 2007, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/August07\/chalmersdionissievbayoiloilforfoodpleaspr.pdf.","Documents":""},{"Case ID":"ST-137","Case Cluster ":"David Chalmers\/ Bayoil","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"08\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$5,000.00","Criminal Fine\/Penalty (US$) ":"$5,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Multiple counts of conspiracy to commit wire fraud, violations of sanctions, smuggling of goods","Offenses - Settled":"Smuggling of goods","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a press release by the United States Attorney for the Southern District of New York, \u0022David B. Chalmers, Jr. [ ] and two corporations that he operated -- BAYOIL (USA), INC. [  ] BAYOIL SUPPLY \u0026 TRADING LIMITED, a Bahamian company with principal offices in Nassau, Bahamas (collectively, the \u0022BAYOIL COMPANIES\u0022). CHALMERS and the BAYOIL COMPANIES each pleaded guilty today before United States District Judge DENNY CHIN to participating in a scheme to pay illegal surcharges to the former Government of Iraq in connection with the purchase of crude oil in the United Nations Oil-for-Food Program between mid-2000 and 2003. Judge CHIN also accepted earlier today the guilty plea of LUDMIL DIONISSIEV to related smuggling charges. DIONISSIEV worked with CHALMERS and the BAYOIL COMPANIES during the course of this scheme to purchase Iraqi oil. CHALMERS and the BAYOIL COMPANIES each pleaded guilty to participating in a conspiracy to commit wire fraud related to the payment of secret illegal surcharge payments to the former Government of Iraq.\u0022  (Source: United States Attorney for the Southern District of New York, \u0022U.S. Announces Four Guilty Pleas in Oil-for-Food Case,\u0022 August 17, 2007.)  According to the Court Docket Report in US v. Chalmers, et al, Dionissiev paid the $5,000 fine on December 17, 2007. (Source: US v. Chalmers, et al Case No. 1:05-cr-00059-DC (S.D.N.Y.), Court Docket Report as of October 26, 2011.) ","Sources ":"US v. David B. Chalmers, Jr., Bayoil (USA) Inc., and Bayoil Supply \u0026 Trading Limited, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Order of Restitution filed on March 25, 2008; http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/March08\/chalmersetalsentencingpr.pdf.  United States Attorney Southern District of New York Press Release, \u0022U.S. Announces Four Guilty Pleas in Oil-for-Food Case,\u0022 August 17, 2007, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/August07\/chalmersdionissievbayoiloilforfoodpleaspr.pdf; US v. Chalmers, et al, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Court Docket Report as of October 26, 2011 (accessed via Pacer).","Documents":""},{"Case ID":"ST-138","Case Cluster ":"Delta Pine \u0026 Land Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Turkey","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"07\/25","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order ","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$300,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$300,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2 ","Offenses - Alleged":"Bribery of Foreign Officials (Turk Deltapine); Internal controls violations (Delta \u0026 Pine); Falsification of books and records (Delta \u0026 Pine)","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"No (Certification) ","Summary":"According to the US Securities and Exchange Commission Litigation Release in the case, on July 25 and July 26, 2007, the Commission filed two settled enforcement proceedings charging Delta \u0026 Pine Land Company, engaged in the production and marketing of cottonseed, and its subsidiary, Turk Deltapine, inc., with FCPA violations.  Delta Pine and Turk Deltapine consented to both actions without admitting or denying the allegations.  In both the July 25 US District Court complaint and the July 26 SEC Administrative Order, the Commission had charged that from 2001 through 2006, Turk Deltapine made payments of approximately $43,000 to officials of the Turkish Ministry of Agricultural and Rural Affairs in order to obtain governmental reports and certifications that were necessary for Turk Deltapine to obtain, retain, and operate its businesses in Turkey. In the federal lawsuit, Delta \u0026 Pine and Turk Deltapine agreed to the entry of a final judgment requiring them to pay jointly and severally a $300,000 penalty.  (Source:  SEC Litigation Release No. 20214 (July 26, 2007), CORRECTED, SEC v. Delta \u0026 Pine Land Company and Turk Deltapine, inc., Case No. 1:07-cv-01352 (RWR) (D.D.C.), Complaint filed July 25, 2007).","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Delta Pine \u0026 Land Company at 84-85, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf;  SEC v. Delta \u0026 Pine Land Company and Turk Deltapine, Inc., No. 1:07-cv-01352, (D.D.C. 2007): Administrative Proceeding No. 3-12712, Litigation Release No. 20214 (July 26, 2007); Final Judgment filed August 22, 2007 - all SEC enforcement action related documents accessed at www.fcpa.shearman.com, case entry SEC v. Delta \u0026 Pine Land Company and Turk Deltapine.","Documents":""},{"Case ID":"ST-139","Case Cluster ":"Deutsche Telekom AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Montenegro","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"12\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$4,360,000.00","Criminal Fine\/Penalty (US$) ":"$4,360,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Falsification of Books and Records","Offenses - Settled":"Falsification of Books and Records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022Magyar Telekom Plc., a Hungarian telecommunications company, and Deutsche Telekom AG, a German telecommunications company and majority owner of Magyar Telekom, have agreed to pay a combined $63.9 million criminal penalty to resolve a Foreign Corrupt Practices Act (FCPA) investigation into activities by Magyar Telekom and its subsidiaries in Macedonia and Montenegro. [ ]  The department filed a criminal information against Magyar Telekom and a two-year deferred prosecution agreement in U.S. District Court for the Eastern District of Virginia today.   The three-count information charges Magyar Telekom with one count of violating the anti-bribery provision of the FCPA and two counts of violating the books and records provisions of the FCPA.   At the time of the charged conduct, Magyar Telekom\u0027s American Depository Receipts (ADRs) traded on the New York Stock Exchange (NYSE).   As part of the deferred prosecution agreement, Magyar Telekom agreed to pay a $59.6 million penalty for its illegal activity [  ]    \r\n\r\nAccording to court documents, Magyar Telekom\u0027s scheme in Macedonia stemmed from potential legal changes being made to the telecommunications market in that country.    In early 2005, the Macedonian government tried to liberalize the Macedonian telecommunications market in a way that Magyar Telekom deemed detrimental to its Macedonian subsidiary, Makedonski Telekommunikacii AD Skopje (MakTel).   Throughout the late winter and spring of 2005, Magyar Telekom executives, with the help of Greek intermediaries, lobbied Macedonian government officials to prevent the implementation of the new telecommunications laws and regulations. [ ]  According to court documents, in order to secure the benefits in the protocol of cooperation, the Magyar Telekom executives engaged in a course of conduct with consultants, intermediaries and other third parties, including through sham consultancy contracts with entities owned and controlled by a Greek intermediary, to pay \u20ac4.875 (approximately $6 million) under circumstances in which they knew, or were aware of a high probability that circumstances existed in which, all or part of such payment would be passed on to Macedonian officials.   The sham contracts were recorded as legitimate on MakTel\u0027s books and records, which were consolidated into Magyar Telekom\u0027s financials.   Deutsche Telekom, which owned approximately 60 percent of Magyar Telekom, reported in the results of Magyar Telekom\u0027s operations in its consolidated financial statements.    \r\n\r\n Additionally, the criminal information charges Magyar Telekom with falsifying its books and records in regard to its activity in Montenegro.   According to the court filing, Magyar Telekom made improper payments in connection with its acquisition of a state-owned telecommunications company in Montenegro.   These payments were documented on Magyar Telekom\u0027s books and records through the execution of four bogus contracts.   For example, two of the contracts were backdated and concealed the true counterparties, and no legitimate services were provided under the contracts even though the contracts were for \u20ac4.47 million.\r\n\r\nThe department today also entered into a two-year non-prosecution agreement with Magyar Telekom\u0027s parent company, Deutsche Telekom, for its failure to keep books and records that accurately detailed the activities of Magyar Telekom.   Deutsche Telekom, which is headquartered in Germany, agreed to pay a $4.36 million penalty in connection with the inaccurate books and records.\u0022  (Source: US Department of Justice Press Release, Magyar Telekom and Deutsche Telekom Resolve Foreign Corrupt Practices Act Investigation and Agree to Pay Nearly $64 Million in Combined Criminal Penalties,\u0022 December 29, 2011.)","Sources ":"US Department of Justice, In Re: Deutsche Telekom AG, Non-Prosecution Agreeement dated December 29, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/deutsche-telekom\/2011-12-29-deustche-telekom-npa.pdf; US Department of Justice Press Release, Magyar Telekom and Deutsche Telekom Resolve Foreign Corrupt Practices Act Investigation and Agree to Pay Nearly $64 Million in Combined Criminal Penalties,\u0022 December 29, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/December\/11-crm-1714.html","Documents":""},{"Case ID":"ST-140","Case Cluster ":"Deutsche Telekom AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Macedonia and Montenegro","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"12\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$31,200,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$31,200,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records","Offenses - Settled":"No Admission or Denial of Allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, on December 29, 2011, the Commission \u0022charged the largest telecommunications provider in Hungary and three of its former top executives with bribing government and political party officials in Macedonia and Montenegro to win business and shut out competition in the telecommunications industry. The SEC alleges that three senior executives at Magyar Telekom Plc. orchestrated, approved, and executed a plan to bribe Macedonian officials in 2005 and 2006 to prevent the introduction of a new competitor and gain other regulatory benefits. Magyar Telekom\u0027s subsidiaries in Macedonia made illegal payments of approximately $6 million under the guise of bogus consulting and marketing contracts. The same executives orchestrated a second scheme in 2005 in Montenegro related to Magyar Telekom\u0027s acquisition of the state-owned telecommunications company there. Magyar Telekom paid approximately $9 million through four sham contracts to funnel money to government officials in Montenegro. Magyar Telekom\u0027s parent company Deutsche Telekom AG also is charged with books and records and internal controls violations of the Foreign Corrupt Practices Act (FCPA).\u0022 (Source:  US Securities and Exchange Commission, Litigation Release No. 22213 \/ December 29, 2011, SEC v. Magyar Telekom Plc. and Deutsche Telekom AG, Case No. 11 civ 9646 (S.D.N.Y.) and SEC v. Straub, et al., Case No. 11 civ 9645 (S.D.N.Y.), \u0022SEC Charges Magyar Telekom and Former Executives with Bribing Officials in Macedonia and Montenegro.\u0022)\r\n\r\n","Sources ":"US Securities and Exchange Commission, Litigation Release No. 22213 \/ December 29, 2011, SEC v. Magyar Telekom Plc. and Deutsche Telekom AG, Case No. 11 civ 9646 (S.D.N.Y.) and SEC v. Straub, et al., Case No. 11 civ 9645 (S.D.N.Y.), \u0022SEC Charges Magyar Telekom and Former Executives with Bribing Officials in Macedonia and Montenegro,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr22213.htm; Complaint in SEC v. Magyar Telekom plc and Deutsche Telekom AG, Case No. 1:11-cv-9646 (S.D.N.Y.. December 29, 2011), accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp22213-co.pdf","Documents":""},{"Case ID":"ST-141","Case Cluster ":"Deutsche Telekom AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Montenegro","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"12\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$59,600,000.00","Criminal Fine\/Penalty (US$) ":"$59,600,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022Magyar Telekom Plc., a Hungarian telecommunications company, and Deutsche Telekom AG, a German telecommunications company and majority owner of Magyar Telekom, have agreed to pay a combined $63.9 million criminal penalty to resolve a Foreign Corrupt Practices Act (FCPA) investigation into activities by Magyar Telekom and its subsidiaries in Macedonia and Montenegro. [ ]  The department filed a criminal information against Magyar Telekom and a two-year deferred prosecution agreement in U.S. District Court for the Eastern District of Virginia today.   The three-count information charges Magyar Telekom with one count of violating the anti-bribery provision of the FCPA and two counts of violating the books and records provisions of the FCPA.   At the time of the charged conduct, Magyar Telekom\u0027s American Depository Receipts (ADRs) traded on the New York Stock Exchange (NYSE).   As part of the deferred prosecution agreement, Magyar Telekom agreed to pay a $59.6 million penalty for its illegal activity [  ]    \r\n\r\nAccording to court documents, Magyar Telekom\u0027s scheme in Macedonia stemmed from potential legal changes being made to the telecommunications market in that country.    In early 2005, the Macedonian government tried to liberalize the Macedonian telecommunications market in a way that Magyar Telekom deemed detrimental to its Macedonian subsidiary, Makedonski Telekommunikacii AD Skopje (MakTel).   Throughout the late winter and spring of 2005, Magyar Telekom executives, with the help of Greek intermediaries, lobbied Macedonian government officials to prevent the implementation of the new telecommunications laws and regulations. [ ]  According to court documents, in order to secure the benefits in the protocol of cooperation, the Magyar Telekom executives engaged in a course of conduct with consultants, intermediaries and other third parties, including through sham consultancy contracts with entities owned and controlled by a Greek intermediary, to pay \u20ac4.875 (approximately $6 million) under circumstances in which they knew, or were aware of a high probability that circumstances existed in which, all or part of such payment would be passed on to Macedonian officials.   The sham contracts were recorded as legitimate on MakTel\u0027s books and records, which were consolidated into Magyar Telekom?s financials.   Deutsche Telekom, which owned approximately 60 percent of Magyar Telekom, reported in the results of Magyar Telekom\u0027s operations in its consolidated financial statements.    \r\n\r\n Additionally, the criminal information charges Magyar Telekom with falsifying its books and records in regard to its activity in Montenegro.   According to the court filing, Magyar Telekom made improper payments in connection with its acquisition of a state-owned telecommunications company in Montenegro.   These payments were documented on Magyar Telekom\u0027s books and records through the execution of four bogus contracts.   For example, two of the contracts were backdated and concealed the true counterparties, and no legitimate services were provided under the contracts even though the contracts were for \u20ac4.47 million.\r\n\r\nThe department today also entered into a two-year non-prosecution agreement with Magyar Telekom\u0027s parent company, Deutsche Telekom, for its failure to keep books and records that accurately detailed the activities of Magyar Telekom.   Deutsche Telekom, which is headquartered in Germany, agreed to pay a $4.36 million penalty in connection with the inaccurate books and records. [ ]  Significant assistance was provided by the FBI Washington Field Office?s dedicated FCPA squad, the SEC Division of Enforcement, the Criminal Division\u0027s Office of International Affairs and international legal partners in Switzerland, Germany, Greece, Hungary and the Republic of Macedonia. (Source: US Department of Justice Press Release, Magyar Telekom and Deutsche Telekom Resolve Foreign Corrupt Practices Act Investigation and Agree to Pay Nearly $64 Million in Combined Criminal Penalties,\u0022 December 29, 2011.)","Sources ":"US v. Magyar Telecom, Plc, Case No. 1:11-cr-00597 (E.D. Va.), Information filed December 29, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/magyar-telekom\/2011-12-29-information-magyar-telekom.pdf; Deferred Prosecution Agreement filed December 29, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/magyar-telekom\/2011-12-29-dpa-magyar.pdf.  US Department of Justice, In Re: Deutsche Telekom AG, Non-Prosecution Agreeement dated December 29, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/deutsche-telekom\/2011-12-29-deustche-telekom-npa.pdf; US Department of Justice Press Release, Magyar Telekom and Deutsche Telekom Resolve Foreign Corrupt Practices Act Investigation and Agree to Pay Nearly $64 Million in Combined Criminal Penalties,\u0022 December 29, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/December\/11-crm-1714.html","Documents":""},{"Case ID":"ST-142","Case Cluster ":"Diageo plc","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Thailand, India, South Korea","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"07\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$16,373,820.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$11,306,081","Civil Prejudgment Interest (US$) ":"$2,067,739","Civil Fine \/ Penalty (US$)":"$3,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records ","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"No (Customs, Tax)","Summary":"According to a US Securities and Exchange Commission Press Release, \u0022According to the SEC\u0027s order instituting settled administrative proceedings against Diageo, the company made more than $1.7 million in illicit payments to hundreds of government officials in India from 2003 to mid-2009. The officials were responsible for purchasing or authorizing the sale of its beverages in India, and increased sales from these payments yielded more than $11 million in profit for the company.  The SEC found that from 2004 to mid-2008, Diageo paid approximately $12,000 per month -- totaling nearly $600,000 -- to retain the consulting services of a Thai government and political party official. This official lobbied other high-ranking Thai government officials extensively on Diageo?s behalf in connection with pending multi-million dollar tax and customs disputes, contributing to Diageo\u0027s receipt of certain favorable decisions by the Thai government.  According to the SEC\u0027s order, Diageo paid 100 million in Korean currency (more than $86,000 in U.S. dollars) to a customs official in South Korea as a reward for his role in the government\u0027s decision to grant Diageo significant tax rebates. Diageo also improperly paid travel and entertainment expenses for South Korean customs and other government officials involved in these tax negotiations. Separately, Diageo routinely made hundreds of gift payments to South Korean military officials in order to obtain and retain liquor business. [  ] Without admitting or denying the findings, Diageo agreed to cease and desist from further violations and pay $11,306,081 in disgorgement, prejudgment interest of $2,067,739, and a financial penalty of $3 million.\u0022 (Source: US Securities and Exchange Commission Press Release, \u0022SEC Charges Liquor Giant Diageo with FCPA Violations,\u0022 July 27, 2011.)","Sources ":"US Securities and Exchange Commission Press Release, \u0022SEC Charges Liquor Giant Diageo with FCPA Violations,\u0022 July 27, 2011, accessed at http:\/\/www.sec.gov\/news\/press\/2011\/2011-158.htm; In the Matter of Diageo plc, SEC Administrative Proceeding File No. 3-14490, \u0022Order Instituting Cease-and-Desist Proceedings,\u0022 July 27, 2011, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2011\/34-64978.pdf","Documents":""},{"Case ID":"ST-143","Case Cluster ":"Diagnostic Products Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China ","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"05\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$2,788,622.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$2,038,727","Civil Prejudgment Interest (US$) ":"$749,895","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations  ","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Diagnostic Products Corporation, at 109-110:  From late 1991 through December 2002, DPC (Tianjin) Co., Ltd., a subsidiary of Diagnostics Product Corporation paid approximately $1.6 million in bribes in the form of illegal \u0022commissions\u0022 to physicians and lab personnel employed at government-owned hospitals in China in exchange for agreements that the hospitals would obtain DPC Tianjin\u0027s products and services. In most cases, bribes were paid in cash. The \u0022commissions,\u0022 typically between 3 percent and 10 percent of sales, allowed DPC Tianjin to earn approximately $2 million in profits from the sales. DPC Tianjin pleaded guilty to violating the FCPA and paid criminal fine of $2 million; to resolve SEC charges, DPC agreed to the issuance of an order to cease-and-desist from future violations and to disgorge $2,038,727 and $749,895 in prejudgment interest to the SEC.  Resulting Criminal Enforcement Actions: US v. DPC (Tianjin) Co., Ltd. (C.D. Cal., May 20, 2005); Resulting Civil\/Administrative Enforcement Action: In the Matter of Diagnostic Products Corporation (May 20, 2005).","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Diagnostic Products Corporation, at 109-110, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; In the Matter of Diagnostic Products Corporation, US Securities and Exchange Commission, Administrative Proceeding File No. 3-11933, Order Instituting Cease and Desist Proceedings, May 20, 2005, accessed at http:\/\/www.sec.gov\/litigation\/admin\/34-51724.pdf","Documents":""},{"Case ID":"ST-144","Case Cluster ":"Diagnostic Products Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China ","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"05\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,000,000.00","Criminal Fine\/Penalty (US$) ":"$2,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Diagnostic Products Corporation, at 109-110:  From late 1991 through December 2002, DPC (Tianjin) Co., Ltd., a subsidiary of Diagnostics Product Corporation paid approximately $1.6 million in bribes in the form of illegal \u0022commissions\u0022 to physicians and lab personnel employed at government-owned hospitals in China in exchange for agreements that the hospitals would obtain DPC Tianjin\u0027s products and services. In most cases, bribes were paid in cash. The \u0022commissions,\u0022 typically between 3 percent and 10 percent of sales, allowed DPC Tianjin to earn approximately $2 million in profits from the sales. DPC Tianjin pleaded guilty to violating the FCPA and paid criminal fine of $2 million; to resolve SEC charges, DPC agreed to the issuance of an order to cease-and-desist from future violations and to disgorge $2,038,727 and $749,895 in prejudgment interest to the SEC.  Resulting Criminal Enforcement Actions: US v. DPC (Tianjin) Co., Ltd. (C.D. Cal., May 20, 2005); Resulting Civil\/Administrative Enforcement Action: In the Matter of Diagnostic Products Corporation (May 20, 2005).","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Diagnostic Products Corporation, at 109-110, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.  US v. DPC (Tianjin), Case No. 05-cr-482 (C.D. Cal.), Information filed on May 20, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/dpc-tianjin\/05-20-05dpc-tianjin-info.pdf; Plea Agreement filed on May 20, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/dpc-tianjin\/05-19-05dpc-tianjin-plea-agree.pdf; Judgment filed June 21, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/dpc-tianjin\/06-23-05dpc-tianjin-judge.pdf","Documents":""},{"Case ID":"ST-145","Case Cluster ":"Dow Chemical Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"India","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"02\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$325,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$325,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"No (Registration and Inspection) ","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Dow Chemical Company, at 96:  (1) DE-Nocil, a subsidiary of Dow, made approximately $200,000 in improper payments to Indian government officials, including $39,700 to an official in India\u0027s Central Insecticides Board to expedite the registration of three DE-Nocil products. DE-Nocil made $435,000 in profits because of the accelerated registration, $329,295 of which went to Dow. (2) DE-Nocil payment of approximately $87,400 in small ($100 or less) payments to state-level agricultural inspectors to keep them from interfering in the sale of DE-Nocil products. (3) DE-Nocil payments to sales tax officials and customs officials, as well as improper gifts, travel, and entertainment to other government officials ($19,000), totalling more than $70,000.  To resolve SEC charges, Dow Chemical agreed to cease-and-desist order and pay $325,000 in civil penalties.  Resulting Civil\/Administrative Enforcement Actions: SEC v. Dow Chemical Company (D.D.C., February 13, 2007); In the Matter of Dow Chemical Company (February 13, 2007), which noted that payments to Central Insecticides Board official was through use of consultants and unrelated companies (para 5); and the third set of improper payments included  $11,800 to sales tax officials; $3,700 to excise tax officials; and $1,500 to customs officials. (para 10)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Dow Chemical Company, at 96, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; In the Matter of Dow Chemical Company, Administrative Proceeding File No. 3-12567, Order Instituting Cease-and-Desist Proceedings (February 13, 2007), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2007\/34-55281.pdf; SEC v. The Dow Chemical Company, Case No. 07-cv-0336 (D.D.C.), Consent of the Dow Chemical Company filed March 5, 2007, accessed at http:\/\/fcpa.shearman.com\/files\/e3a\/e3a9b7ff98db69bdcf91a57abb71ad9b.pdf?i=350f24b2193e00eee96548107c6882d6.  ","Documents":""},{"Case ID":"ST-146","Case Cluster ":"El Paso Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"02\/07","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Civil Penalty","Total Monetary Sanctions (US$)":"$2,250,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$2,250,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Faliure to Maintain Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, the Commission filed a settled complaint on February 7, 2007, which alleged \u0022that from approximately June 2001 through June 2002, El Paso, and its predecessor in-interest The Coastal Corporation, indirectly made approximately $5.5 million in illegal surcharge payments to Iraq in connection with its purchases of crude oil from third parties under the U.N. Oil for Food Program. The Program was intended to provide humanitarian relief for the Iraqi population, which faced severe hardship under international trade sanctions. However, beginning in August 2000, officials of Iraqi State Oil Marketing Organization, began demanding illegal kickbacks. The kickbacks were made in the form of surcharges, and were sent to Iraqi-controlled accounts at banks in Jordan and Lebanon. [  ]  El Paso, without admitting or denying the allegations in the Commission\u0027s complaint, consented to the entry of a final judgment permanently enjoining it from future violations of Sections 13(b)(2)(A) and 13(b)(2)(B) of the Securities Exchange Act of 1934, ordering it to disgorge $5,482,363 in profits, and to pay a civil penalty of $2,250,000. El Paso will satisfy its disgorgement obligation by forfeiting $5,482,363 pursuant to a non-prosecution agreement with the U.S. Attorney\u0027s Office for the Southern District of New York.\u0022 (Source: US Securities and Exchange Commission Litigation Release No. 19991 \/ February 7, 2007, Securities and Exchange Commission v. El Paso Corporation, Civil Action No. 07CV00899 (S.D.N.Y.), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against El Paso Corporation For Improper Payments to Iraq Under the U.N. Oil for Food Program - - Company Agrees to Pay $7.7 Million.\u0022)  Please note that the Disgorgement penalty has not been noted in this entry as it is already noted in the El Paso criminal case settlement. \r\n\r\n","Sources ":"US Securities and Exchange Commission Litigation Release No. 19991 \/ February 7, 2007, Securities and Exchange Commission v. El Paso Corporation, Civil Action No. 07CV00899 (S.D.N.Y.), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against El Paso Corporation For Improper Payments to Iraq Under the U.N. Oil for Food Program - - Company Agrees to Pay $7.7 Million,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr19991.htm; Complaint filed February 7, 2007, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2007\/comp19991.pdf","Documents":""},{"Case ID":"ST-147","Case Cluster ":"El Paso Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Iraq (\u0022UN Oil-for-Food\u0022)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"02\/05","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$5,482,363.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$5,482,363 ","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$5,482,363","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Iraq via Development Fund for Iraq","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to Defraud the United States, Wire Fraud","Offenses - Settled":"Failure to Maintain Internal Controls","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to El Paso Corporation\u0027s Non-Prosecution Agreement with the United States Attorney for the Southern District of New York, following the merger between El Paso Corporation and The Costal Corporation, \u0022EL PASO purchased Iraqi oil from third-party intermediaries and\/or allocation holders.  Although EL PASO took steps designed to prevent the purchase of Iraqi oil from third parties on which illegal surcharges had been paid, such procedures proved inadequate.  The United States Government has represented to EL PASO that records maintained by the former Government of Iraq and its agents demonstrate that, from June 2001 until May 2002, EL PASO purchased Iraqi oil for which third-party intermediaries and\/or allocation holders paid approximately $5.48 million in illegal surcharges to the former Government of Iraq.  These surcharge payments were not deposited into the Oil-for-Food Program\u0027s escrow account, which was established to purchase humanitarian goods for the Iraqi people. [ ] It is the intent of the United States Attorney\u0027s Office for the Southern District of New York to seek the transfer of these funds to the Development Fund for Iraq [ ] to be used as restitution to the Iraqi people as the intended beneficiaries of the proceeds of all Iraqi oil pursuant to the United Nations Oil-for-Food Program.\u0022  (Source: In Re: El Paso Corporation, Non-Prosecution Agreement with the United States Attorney for the Southern District of New York, Department of Justice, February 5, 2007.)","Sources ":"In Re: El Paso Corporation, Non-Prosecution Agreement with the United States Attorney for the Southern District of New York, February 5, 2007, accessed at http:\/\/fcpa.shearman.com\/files\/82c\/82c7a6a47d469bdfa8a7c6d82bf03737.pdf?i=dfef6d9305307bf27b828e9290194bef; United States Attorney for the Southern District of New York Press Release, \u0022Texas Oil Executive and Two Corporations Sentenced on Charges Involving a Scheme to Pay Secret Kickbacks to the Former Government of Saddam Hussein,\u0022 March 7, 2008, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/March08\/chalmersetalsentencingpr.pdf","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/El_Paso_SDNY_Non-Prosecution_Agreement_Feb_2007.pdf"},{"Case ID":"ST-148","Case Cluster ":"El Paso Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"10\/01","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Restitution","Total Monetary Sanctions (US$)":"$11,023,245.91","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$11,023,245.91","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$11,023,245.91","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Iraq via Development Fund for Iraq","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to commit wire fraud, Wire Fraud and others","Offenses - Settled":"Conspiracy to commit wire fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Court Docket Report in US v. Wyatt, on October 1, 2007, Mr. Wyatt,  charged with numerous misconduct related to the UN Oil-for-Food Programme a co-defendant in the case, changed his plea during mid-trial to a plea of guilty to one count conspiracy to commit wire fraud; on November 28, 2007, he was ordered to pay $11,023,245.91 in restitution (Source:  US v. Wyatt, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Court Docket Report retrieved January 5, 2012.)  According to the US Government\u0027s Sentencing Memorandum, \u0022In light of Wyatt\u0027s conduct, the parties have agreed in the Plea Agreement that Wyatt should forfeit $11,023,245.91.  That is the total value of: [1] the SOMO satellite communications services that Wyatt paid for (approximately $3,400,000), see supra; [2] the Phase 8 surcharge payment that Wyatt caused to be paid (220,000 Euros - approximately $200,000), see supra; and [3] the surcharge payments made in connection with the Phase 9-12 Nafta and Mednafta oil allocations (approximately $7,423,246). In the Government?s view, an appropriate representative of the people of Iraq for these purposes is the Development Fund for Iraq (\u0022DFI\u0022), an entity that has, according to published reports, received more than 2 billion dollars on behalf of the Iraqi people, and which has used the funds at its disposal to, among other things, buy wheat for the Iraqi people, and to improve the country\u0027s now-damaged electrical infrastructure. In connection with this matter, the United States Attorney\u0027s Office will work to transfer any funds forfeited by Wyatt to the DFI.\u0022  The Government\u0027s Sentencing Memorandum also noted that Mr. Wyatt used Cypriot \u0022Front Companies\u0022 in carrying out his misconduct. (US v. Wyatt, Case No. 1:05-cr-59-DC (S.D.N.Y.), Government Sentencing Memorandum filed November 26, 2007.)","Sources ":"United States Attorney Southern District of New York Press Release, \u0022U.S. Announces Four Guilty Pleas in Oil-for-Food Case,\u0022 August 17, 2007, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/November07\/wyattsentencingpr.pdf; US v. Wyatt, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Court Docket Report as of January 4, 2012 and Government Sentencing Memorandum filed November 26, 2007 (accessed via Pacer).","Documents":""},{"Case ID":"ST-149","Case Cluster ":"Electronic Data Systems Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"India","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"09\/25","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$490,902.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$358,800","Civil Prejudgment Interest (US$) ":"$132,102","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Disclosure violations, Regulation violations ","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Electronic Data Systems Corporation, at 81-82: Misconduct in India, 2001-2003; EDS\u0027s former Indian subsidiary, A.T. Kearney Ltd. - India (ATKI) alleged to have made at least $720,000 in illicit payments to high-level employees of two Indian state-owned enterprises threatened in order to retain business with those enterprises; ATKI made the payments at the direction of Srninivasan, ATKI\u0027s president, after the officials of the state-owned enterprises threatened to cancel the contracts with ATKI. These bribes allowed EDS to recognize over $7.5 million in revenue from the Indian companies\u0027 contracts after ATKI began paying the bribes.  Settlement amounts: $70,000 civil penalty (Srinivasan), $358,800 disgorgement and $132,102 prejudgment interest (EDS \/ ATKI-related penalties).  Resulting civil enforcement\/administrative actions:  In the Matter of Electronic Data Systems Corporation (September 25, 2007); SEC v. Chandramowli Srinivasan (D.D.C., September 25, 2007).","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Electronic Data Systems Corporation, at 81-82, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; SEC v. Chandramowli Srinivasan, case summary and related documents at http:\/\/fcpa.shearman.com\/?mode=form\u0026id=221; In the Matter of Electronic Data Systems Corporation, Administrative Proceedings, File No. 3-12825, Order Instituting Cease and Desist Proceedings (September 25, 2007), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2007\/34-56519.pdf.","Documents":""},{"Case ID":"ST-150","Case Cluster ":"Electronic Data Systems Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"India","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"09\/25","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$70,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$70,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, False accounting violations","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Electronic Data Systems Corporation, at 81-82: Misconduct in India, 2001-2003; EDS\u0027s former Indian subsidiary, A.T. Kearney Ltd. - India (ATKI) alleged to have made at least $720,000 in illicit payments to high-level employees of two Indian state-owned enterprises threatened in order to retain business with those enterprises; ATKI made the payments at the direction of Srninivasan, ATKI\u0027s president, after the officials of the state-owned enterprises threatened to cancel the contracts with ATKI. These bribes allowed EDS to recognize over $7.5 million in revenue from the Indian companies\u0027 contracts after ATKI began paying the bribes.  Settlement amounts: $70,000 civil penalty (Srinivasan), $358,800 disgorgement and $132,102 prejudgment interest (EDS \/ ATKI-related penalties).  Resulting civil enforcement\/administrative actions:  In the Matter of Electronic Data Systems Corporation (September 25, 2007); SEC v. Chandramowli Srinivasan (D.D.C., September 25, 2007).","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Electronic Data Systems Corporation, at 81-82, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; SEC v. Chandramowli Srinivasan, case summary and related documents at http:\/\/fcpa.shearman.com\/?mode=form\u0026id=221; In the Matter of Electronic Data Systems Corporation, Administrative Proceedings, File No. 3-12825, Order Instituting Cease and Desist Proceedings (September 25, 2007), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2007\/34-56519.pdf.","Documents":""},{"Case ID":"ST-151","Case Cluster ":"Faro Technologies, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"06\/05","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,100,000.00","Criminal Fine\/Penalty (US$) ":"$1,100,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records","Offenses - Settled":"Bribery of foreign official ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to DOJ Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Faro Technologies, at 35-37:  Time period of misconduct in China was 2003-2006.  Faro Technologies is a Florida-based company that develops and markets portable computerized measurement devices and software.  SEC complaint stated that Oscar H. Meza, the company\u0027s Vice-President for Asia-Pacific Sales and Director of Asia-Pacific Sales for Faro.  According to the Statement of Facts, Faro began direct sales of its products in China through its subsidiary, Faro China, based in Shanghai.  On several occasions, Meza authorized other Faro employees to make corrupt payments directly to employees of state-owned or controlled entities in China to secure business for Faro.  Meza authorized total of $444,492 in corrupt payments which allowed Faro to secure contracts worth approximately $4.5 - $4.9 million in sales an $1.4 million in net profits. Use of intermediary and shell company to funnel\/disguise bribe payments. DOJ: Criminal fine of $1.1 million (Faro); Civil: Disgorgement of $1.85 million (Faro); Civil Penalty of $30K (Meza), and Disgorgement and Prejudgment interest of $26,707 (Meza).  Related Criminal Enforcement Actions: In Re Faro Technologies Inc. (June 5, 2008); Civil Administrative \/ Enforcement Actions: SEC v. Oscar H. Meza (D.D.C., August 28, 2009), In the Matter of Faro Technologies, Inc. (June 5, 2008). ","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Faro Technologies, Inc. at 35-36, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Department of Justice Press Release, \u0022Faro Technologies Inc. Agrees to Pay $1.1 Million Penalty and Enter Non-Prosecution Agreement for FCPA Violations,\u0022 accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/June\/08-crm-505.html (accessed September 15, 2011).","Documents":""},{"Case ID":"ST-152","Case Cluster ":"Faro Technologies, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"06\/05","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$1,850,943.32","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,411,306","Civil Prejudgment Interest (US$) ":"$439,637","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to DOJ Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Faro Technologies, at 35-37:  Time period of misconduct in China was 2003-2006.  Faro Technologies is a Florida-based company that develops and markets portable computerized measurement devices and software.  SEC complaint stated that Oscar H. Meza, the company\u0027s Vice-President for Asia-Pacific Sales and Director of Asia-Pacific Sales for Faro.  According to the Statement of Facts, Faro began direct sales of its products in China through its subsidiary, Faro China, based in Shanghai.  On several occasions, Meza authorized other Faro employees to make corrupt payments directly to employees of state-owned or controlled entities in China to secure business for Faro.  Meza authorized total of $444,492 in corrupt payments which allowed Faro to secure contracts worth approximately $4.5 - $4.9 million in sales an $1.4 million in net profits. Use of intermediary and shell company to funnel\/disguise bribe payments. DOJ: Criminal fine of $1.1 million (Faro); Civil: Disgorgement of $1.85 million (Faro; encompassing $1,411,306 disgorgement and $439,637.32 prejudgment interest); Civil Penalty of $30K (Meza), and Disgorgement and Prejudgment interest of $26,707 (Meza).  Related Criminal Enforcement Actions: In Re Faro Technologies Inc. (June 5, 2008); Civil Administrative \/ Enforcement Actions: SEC v. Oscar H. Meza (D.D.C., August 28, 2009), In the Matter of Faro Technologies, Inc. (June 5, 2008). ","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Faro Technologies, Inc. at 35-36, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Securities and Exchange Commission, In the Matter of Faro Technologies, Inc., Administrative Proceeding File No. 3-13059 (June 5, 2008), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2008\/34-57933.pdf","Documents":""},{"Case ID":"ST-153","Case Cluster ":"Faro Technologies, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"08\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$56,707.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$26,707","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$30,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art, 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, False accounting, False statements to accountants, Aiding and abetting Faro\u0027s bribery of foreign officials, Aiding and abetting Faro\u0027s internal controls violations, Aiding and abetting Faro\u0027s falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, \u0022On August 28, 2009, the Securities and Exchange Commission filed a settled enforcement action in the United States District Court for the District of Columbia against Oscar H. Meza, formerly the Director of Asia-Pacific Sales for Faro Technologies, Inc. (\u0022Faro\u0022), a software development and manufacturing company. The Commission\u0027s complaint alleges that Meza authorized bribery payments to employees of Chinese state-owned companies in order to obtain contracts, and that in order to conceal the bribes Meza instructed that account entries be altered. The Commission charged Meza with violations of the anti-bribery, books and records and internal control provisions of the Foreign Corrupt Practices Act (\u0022FCPA\u0022), and with aiding and abetting Faro\u0027s violations of the anti-bribery, books and records and internal control provisions of the FCPA.  The Commission\u0027s complaint alleges that beginning in 2004, Meza authorized a former employee of Faro\u0027s subsidiary, Faro Shanghai Co., Ltd. (\u0022Faro-China\u0022), to make the improper payments. The complaint alleges that Meza\u0027s actions resulted in Faro-China\u0027s payment of $444,492 in bribes during the period 2004 through 2006, generating approximately $4.5 million in sales and approximately $1.4 million in net profit.  Without admitting or denying the allegations in the complaint, Meza has consented to the entry of a final judgment permanently enjoining him from violating Sections 30A and 13(b)(5) of the Securities Exchange Act of 1934 (\u0022Exchange Act\u0022) and Exchange Act Rule 13b2-1, and from aiding and abetting violations of Sections 30A, 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act. The final judgment also orders that Meza pay a $30,000 civil penalty, as well as $26,707 in disgorgement and prejudgment interest.\u0022 (Source: US Securities and Exchange Commission Litigation Release No. 21190 \/ August 28, 2009, SECURITIES AND EXCHANGE COMMISSION v. OSCAR H. MEZA, Civil Action No. 1:09-CV-01648 (D.D.C.) (Filed August 28, 2009), \u0022SEC SUES FORMER SALES EXECUTIVE FOR FOREIGN BRIBERY.\u0022)  Please note that the Litigation Release did not provide a breakdown of the figure for disgorgement and prejudgment interest; the amount was therefore recorded under disgorgement. \r\n","Sources ":"US Securities and Exchange Commission Litigation Release No. 21190 \/ August 28, 2009, SECURITIES AND EXCHANGE COMMISSION v. OSCAR H. MEZA, Civil Action No. 1:09-CV-01648 (D.D.C.) (Filed August 28, 2009), \u0022SEC SUES FORMER SALES EXECUTIVE FOR FOREIGN BRIBERY,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21190.htm, and Complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp21190.pdf\r\n","Documents":""},{"Case ID":"ST-53","Case Cluster ":"BAE Systems plc","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Czech Republic, Hungary, Saudi Arabia","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/01","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$400,000,000.00","Criminal Fine\/Penalty (US$) ":"$400,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to defraud the United States by impairing and impeding its lawful functions, Conspiracy to make false statements; Conspiracy to violate the Arms Export Control Act and International Traffic in Arms Regulations  ","Offenses - Settled":"Conspiracy to defraud the United States by impairing and impeding its lawful functions, Conspiracy to make false statements; Conspiracy to violate the Arms Export Control Act and International Traffic in Arms Regulations  ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On February 4, 2010, BAE Systems plc (BAES), a multinational defense contractor with headquarters in the United Kingdom, was charged in a one-count criminal information with conspiracy to defraud the United States by impairing and impeding its lawful functions, to make false statements about its FCPA compliance program, and to violate the Arms Export Control Act (AECA) and International Traffic in Arms Regulations (ITAR). These charges alleged that from 2000 to 2002, BAES represented to various U.S. government agencies, including the Departments of Defense and Justice, that it would create and implement policies and procedures to ensure its compliance with the anti-bribery provisions of the FCPA, as well as similar, foreign laws implementing the Organisation for Economic Co-operation and Development (OECD) Anti-bribery Convention.  In pleading guilty, BAES acknowledged that, despite its representations to the U.S. government to the contrary, BAES knowingly and willfully failed to create sufficient compliance mechanisms to ensure compliance with these legal prohibitions on foreign bribery. More specifically, BAES admitted that it regularly used and encouraged the establishment of shell companies and third party intermediaries to assist in securing sales of defense articles. BAES admitted that, from May 2001 onward, it made a series of substantial payments to these shell companies and third party intermediaries that were not subjected to the degree of scrutiny and review to which BAES told the U.S. government the payments would be subjected, even though BAES was aware there was a high probability that part of some of the payments would be used to ensure that BAES was favored in foreign government decisions regarding the purchase of defense articles. In addition, BAES admitted that, as part of the conspiracy, it knowingly and willfully failed to identify commissions paid to third parties for assistance in soliciting, promoting or otherwise securing sales of defense articles, in violation of the AECA and ITAR.\u0022 (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, BAE Systems Plc Case Summary at 50-51.)  According to the US Department of Justice Press Release, the DOJ acknowledged the assistance of the UK\u0027s Serious Fraud Office in its investigation. (Source: US Department of Justice Press Release, \u0022BAE Systems PLC Pleads Guilty and Ordered to Pay $400 Million Criminal Fine,\u0022 March 1, 2010.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, BAE Systems Plc Case Summary at 50-51, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US v. BAE Systems plc, Case No. 1:10-cr-0035-JDB (D.D.C.),  Information filed February 4,2 010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/bae-system\/02-01-10baesystems-info.pdf; Plea Agreement filed March 1, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/bae-system\/03-01-10baesystems-plea-agree.pdf3; United States Government Sentencing Memorandum filed February 22, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/bae-system\/02-22-10baesystems-memo.pdf; US Department of Justice Press Release, \u0022BAE Systems PLC Pleads Guilty and Ordered to Pay $400 Million Criminal Fine,\u0022 March 1, 2010, accessed at www.justice.gov\/opa\/pr\/2010\/March\/10-crm-209.html","Documents":""},{"Case ID":"ST-54","Case Cluster ":"BAE Systems plc","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of State","Jurisdiction of Foreign Public Official(s) ":"Czech Republic, Hungary, Saudi Arabia, Chile, Indonesia, South Africa and many others (unnamed)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"05\/16","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent Agreement","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$79,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$79,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Violations of Arms Export Control Act and International Traffic in Arms Regulations (Failure to Register as a Broker, Failure to Obtain Written Approval for Brokering, Failure to File Annual Broker Reports, Causing Unauthorized Brokering, Failure to Disclose Payments, Failure to Maintain Records)","Offenses - Settled":"Violations of Arms Export Control Act and International Traffic in Arms Regulations (Failure to Register as a Broker, Failure to Obtain Written Approval for Brokering, Failure to File Annual Broker Reports, Causing Unauthorized Brokering, Failure to Disclose Payments, Failure to Maintain Records)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of State Consent Agreement, on May 16, 2011, BAE Systems plc entered into an agreement with the State Department \u0022to settle 2,591 violations of the Arms Control Export Act and International Traffic in Arms Regulations in connection with the unauthorized brokering of U.S. defense articles and services, failure to register as a broker, failure to file annual broker reports, causing unauthorized brokering, failure to report the payment of fees or commissions, and failure to maintain records involving ITAR-controlled transactions.  As part of the Consent Agreement, the company was assessed $79 million in civil penalties, with $10 million possibly suspended upon implementation of remedial measures.  (Source: US Department of State, BAE Systems plc, Consent Agreement signed May 16, 2011.) The Statement Department\u0027s May 2011 Proposed Charging Letter included a Summary of Investigation, which noted misconduct related to activities in more than a dozen jurisdictions.  (Source: US Department of State, BAE Systems plc, Proposed Charging Letter, May [ ] 2011.)","Sources ":"US Department of State, BAE Systems, Plc. Proposed Charging Letter, May [ ]  2011, accessed at  http:\/\/www.pmddtc.state.gov\/compliance\/consent_agreements\/pdf\/BAES_PCL.pdf; Consent Agreement signed May 16, 2011, accessed at http:\/\/www.pmddtc.state.gov\/compliance\/consent_agreements\/pdf\/BAES_CA.pdf;  Order entered into on May 16, 2011, accessed at http:\/\/www.pmddtc.state.gov\/compliance\/consent_agreements\/pdf\/BAES_Order%20.pdf.","Documents":""},{"Case ID":"ST-55","Case Cluster ":"Baker Hughes Incorporated","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Indonesia, Kazakhstan","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"04\/11","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea (BHSI), Deferred Prosecution Agreement (Baker Hughes)","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$11,000,000.00","Criminal Fine\/Penalty (US$) ":"$11,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials (Baker Hughes, BHSI), Conspiracy to falsify books and records (Baker Hughes, BHSI), Bribery of foreign officials (BHSI), Falsification of books and records (BHSI)","Offenses - Settled":"Conspiracy to bribe foreign officials (Baker Hughes, BHSI), Conspiracy to falsify books and records (Baker Hughes, BHSI), Bribery of foreign officials (BHSI), Falsification of books and records (BHSI)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice press release, as part of the plea and deferred prosecution agreements, it was agreed that Baker Hughes Services international (BHSI) would pay a criminal fine of $11 million, serve a three-year term of organizational probation and adopt a comprehensive anti-bribery compliance program. In a related matter, Baker Hughes reached a settlement of a complaint filed by the Securities and Exchange Commission under which it agreed to pay $10 million in civil penalties and more than $24 million in disgorgement of all profits it earned in connection with the Karachaganak project, including prejudgment interest. The $44 million in combined fines and penalties is the largest monetary sanction ever imposed in an FCPA case.\u0022 (Source: US Department of Justice Press Release, \u0022Baker Hughes Subsidiary Pleads Guilty to Bribing Kazakh Official and  Agrees to Pay $11 Million Criminal Fine as Part of Largest Combined Sanction Ever Imposed in FCPA Case,\u0022 April 26, 2007).  As summarized in the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Baker Hughes Incorporated, at 92-94, \u0022According to the plea agreements, Baker Hughes and BHSI violated the FCPA by paying approximately $4.1 million in bribes to an intermediary, knowing that the intermediary would transfer all or part of the corrupt payments to an official of Kazakhoil, the state-owned oil company,\u0022 and in 2007, the SEC filed civil complaints against Baker Hughes and BHSI\u0027s Business Development Manager, Roy Fearnley with FCPA violations in the same bribery scheme. In 2001, the SEC had filed civil complaints against two former employees of Baker Hughes, a partner in an Indonesian accounting firm, and a partner of the accounting firm KPMG Siddarharta Siddharta \u0026 Harsono. (Source: US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Baker Hughes Incorporated, at 92-94, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf","Sources ":"US Department of Justice Press Release, \u0022Baker Hughes Subsidiary Pleads Guilty to Bribing Kazakh Official and  Agrees to Pay $11 Million Criminal Fine as Part of Largest Combined Sanction Ever Imposed in FCPA Case,\u0022 April 26, 2007, accessed at http:\/\/www.justice.gov\/opa\/pr\/2007\/April\/07_crm_296.html (accessed on September 14, 2011); US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Baker Hughes Incorporated, at 92-94, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.","Documents":""},{"Case ID":"ST-56","Case Cluster ":"Baker Hughes Incorporated","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia, Kazakhstan, India, Brazil","Year of Settlement":"2001","Month\/Day of Settlement (or Notes)":"09\/12","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, False accounting, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Administrative Proceeding File, \u0022In March 1999, Baker Hughes\u0027 CFO and its Controller authorized an illegal payment, through KPMG, its agent in Indonesia, to a local government official in Indonesia. Baker Hughes, through its CFO and Controller, directed that this improper payment be made while knowing or aware that KPMG would pass all or part of the payment along to a foreign government official for the purpose of influencing the official\u0027s decision affecting the business of Baker Hughes. This improper payment was made in violation of the Foreign Corrupt Practices Act (\u0022FCPA\u0022). In addition, in 1998 and 1995, senior managers at Baker Hughes authorized payments to Baker Hughes\u0027 agents in India and Brazil, respectively, without making an adequate inquiry as to whether the agents might give all or part of the payments to foreign government officials in violation of the FCPA. Baker Hughes improperly recorded all three transactions in its books and records as routine business expenditures. In addition to its false books and records, Baker Hughes also failed to devise and maintain an adequate system of internal accounting controls to detect and prevent improper payments to foreign government officials and to provide reasonable assurance that transactions were recorded as necessary to permit the preparation of financial statements in conformity with Generally Accepted Accounting Principles.\u0022  (Source:  US Securities and Exchange Commission, In the Matter of Baker Hughes, Inc., Administrative Proceeding File No. 3-10572 [September 12, 2001].)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Baker Hughes Incorporated Case Summary at 106-107, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, In the Matter of Baker Hughes, Inc., Administrative Proceeding File No. 3-10572 (September 12, 2001), accessed at http:\/\/www.sec.gov\/litigation\/admin\/34-44784.htm","Documents":""},{"Case ID":"ST-57","Case Cluster ":"Baker Hughes Incorporated","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia","Year of Settlement":"2001","Month\/Day of Settlement (or Notes)":"09\/11","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Aiding and abetting Baker Hughes\u0027 internal controls violations, Aiding and abetting Baker Hughes\u0027 falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Tax)","Summary":"According to a Litigation Release by the US Securities and Exchange Commission, on September 11, 2001, the SEC and the Department of Justice jointly filed a complaint which \u0022alleges that in 1999, Harsono authorized KPMG-SSH personnel to bribe an Indonesian tax official on behalf of one of KPMG-SSH\u0027s clients, PT Eastman Christensen (\u0022PTEC\u0022), an Indonesian company beneficially owned by Baker Hughes Incorporated (\u0022Baker Hughes\u0022). KPMG-SSH agreed to make the illicit payment to influence the Indonesian tax official to reduce a tax assessment for PTEC from $3.2 million to $270,000. Harsono advised KPMG-SSH personnel that if Baker Hughes represented directly to KPMG-SSH, not through PTEC, that it wanted KPMG-SSH to make the illicit payment, KPMG-SSH would be willing to pay the Indonesian tax official. To conceal the improper payment, Harsono agreed with KPMG-SSH personnel that KPMG-SSH should generate an invoice that would include money for the payment to the Indonesian tax official and for KPMG-SSH\u0027s fees for services rendered. The false invoice, although purporting to be for professional services rendered, in reality represented $75,000 to be paid to an Indonesian tax official, and the remainder for KPMG-SSH\u0027s actual fees and applicable taxes. After receiving the invoice, PTEC paid KPMG-SSH $143,000 and improperly entered the transaction on its books and records as payment for professional services rendered. On March 23, 1999, PTEC received a tax assessment of approximately $270,000 from the Indonesian government, almost $3 million lower than the original assessment.\u0022  (Source: US Securities and Exchange Commission Litigation Release No. 17127 \/ September 12, 2001, UNITED STATES OF AMERICA AND SECURITIES AND EXCHANGE COMMISSION v. KPMG SIDDHARTA SIDDHARTA \u0026 HARSONO AND SONNY HARSONO, Civil Action No. H-01-3105 (S.D. Tex.) (filed September 11, 2001), \u0022SEC AND DEPARTMENT OF JUSTICE FILE FIRST-EVER JOINT CIVIL ACTION AGAINST KPMG SIDDHARTA SIDDHARTA \u0026 HARSONO AND ITS PARTNER SONNY HARSONO FOR AUTHORIZING THE PAYMENT OF A BRIBE IN INDONESIA.\u0022)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Baker Hughes Incorporated Case Summary at 106-107, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 17127 \/ September 12, 2001, UNITED STATES OF AMERICA AND SECURITIES AND EXCHANGE COMMISSION v. KPMG SIDDHARTA SIDDHARTA \u0026 HARSONO AND SONNY HARSONO, Civil Action No. H-01-3105 (S.D. Tex.) (filed September 11, 2001), \u0022SEC AND DEPARTMENT OF JUSTICE FILE FIRST-EVER JOINT CIVIL ACTION AGAINST KPMG SIDDHARTA SIDDHARTA \u0026 HARSONO AND ITS PARTNER SONNY HARSONO FOR AUTHORIZING THE PAYMENT OF A BRIBE IN INDONESIA,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr17127.htm","Documents":""},{"Case ID":"ST-58","Case Cluster ":"Baker Hughes Incorporated","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia, Kazakhstan, Angola, Nigeria, Russia, Uzbekistan","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"04\/11","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty ","Total Monetary Sanctions (US$)":"$33,078,015.41","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$19,944,778","Civil Prejudgment Interest (US$) ":"$3,133,237","Civil Fine \/ Penalty (US$)":"$10,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8, Art. 9","Offenses - Alleged":"Bribery of foreign officials, False accounting, Internal controls violations, Falsification of books and records ","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the April 26, 2007 US Securities and Exchange Commission Press Release, \u0022The Securities and Exchange Commission today announced the filing of a settled enforcement action charging Baker Hughes Incorporated, a Houston, Texas-based global provider of oil field products and services, with violations of the Foreign Corrupt Practices Act (FCPA). Baker Hughes has agreed to pay more than $23 million in disgorgement and prejudgment interest for these violations and to pay a civil penalty of $10 million for violating a 2001 Commission cease-and-desist Order prohibiting violations of the books and records and internal controls provisions of the FCPA.  [  ] The SEC\u0027s complaint alleges that Baker Hughes paid approximately $5.2 million to two agents while knowing that some or all of the money was intended to bribe government officials, specifically officials of State-owned companies, in Kazakhstan. The complaint alleges that one agent was hired in September 2000 on the understanding that Kazakhoil, Kazakhstan\u0027s national oil company at that time, had demanded that the agent be hired to influence senior level employees of Kazakhoil to approve the award of business to the company. [  ] Baker Hughes, the complaint alleges, paid the agent $4.1 million to its bank account in London but received no identifiable services from the agent. The complaint also alleges that in 1998 Baker Hughes retained a second agent in connection with the award of a large chemical contract with KazTransOil, the national oil transportation operator of Kazakhstan. Between 1998 and 1999, Baker Hughes paid over $1 million to the agent\u0027s Swiss bank account, despite a company employee knowing by December 1998 that the agent\u0027s representative was a high-ranking executive of KazTransOil.  The SEC\u0027s complaint against Baker Hughes also alleges violations of the books and records and internal controls provisions of the FCPA in Nigeria, Angola, Indonesia, Russia, Uzbekistan and Kazakhstan.  [  ] The [SEC] staff also acknowledges the help provided, in the form of mutual legal assistance, by the Isle of Man Financial Supervision Commission, HM Procureur (Attorney General) for Guernsey, and by the authorities of the United Kingdom and Switzerland.\u0022  (Source:  US Securities and Exchange Commission Press Release, \u0022SEC Charges Baker Hughes With Foreign Bribery and With Violating 2001 Commission Cease-and-Desist Order \/ Baker Hughes Subsidiary Pleads Guilty to Three Felony Charges in Criminal Action Filed by Department of Justice; Criminal Fines, Civil Penalties and Disgorgement of Illicit Profits Total More Than $44 Million,\u0022 April 26, 2007.)  According to the April 26, 2007 Press Release by the US Securities and Exchange Commission, \u0022the SEC also charged Roy Fearnley, a former business development manager for Baker Hughes, with violating and aiding and abetting violations of the FCPA.\u0022  (Source:  US Securities and Exchange Commission Press Release, \u0022SEC Charges Baker Hughes With Foreign Bribery and With Violating 2001 Commission Cease-and-Desist Order \/ Baker Hughes Subsidiary Pleads Guilty to Three Felony Charges in Criminal Action Filed by Department of Justice; Criminal Fines, Civil Penalties and Disgorgement of Illicit Profits Total More Than $44 Million,\u0022 April 26, 2007.)  According to the Shearman and Sterling FCPA Digest, the case is noteworthy for its jurisdictional reach, as Mr. Fearnley was a British citizen residing in Kazakhstan.  According to the Default Judgment Order in his case, Mr. Fearnley did not respond to the complaint, and on January 26, 2010, was ordered to pay $5,000 in disgorgement of profits and $7,635.51 in prejudgment interest.  As Mr. Fearnley\u0027s case was not a settlement, the monetary penalty was not included in the total for this case. (Source: Shearman and Sterling, FCPA Digest, \u0022SEC vs. Baker Hughes Incorporated and Roy Fearnley, accessed at http:\/\/fcpa.shearman.com\/index.php; SEC v. Defendant Incorporated and Roy Fearnley, Case No. 4-07-cv-1408 (S.D. Tex.), Default Judgment filed January 26, 2010, also accessed at http:\/\/fcpa.shearman.com.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Baker Hughes Incorporated Case Summary at 106-107, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   US Securities and Exchange Commission Press Release, \u0022SEC Charges Baker Hughes With Foreign Bribery and With Violating 2001 Commission Cease-and-Desist Order \/ Baker Hughes Subsidiary Pleads Guilty to Three Felony Charges in Criminal Action Filed by Department of Justice; Criminal Fines, Civil Penalties and Disgorgement of Illicit Profits Total More Than $44 Million,\u0022 April 26, 2007, accessed at http:\/\/www.sec.gov\/news\/press\/2007\/2007-77.htm;  Shearman and Sterling, FCPA Digest, \u0022SEC vs. Baker Hughes Incorporated and Roy Fearnley, accessed at http:\/\/fcpa.shearman.com\/index.php; SEC v. Defendant Incorporated and Roy Fearnley, Case No. 4-07-cv-1408 (S.D. Tex.), Default Judgment filed January 26, 2010, also accessed at http:\/\/fcpa.shearman.com.)","Documents":""},{"Case ID":"ST-59","Case Cluster ":"Balfour Beatty plc","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Egypt","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"10\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Civil Recovery Order (Proceeds of Crime Act)","Monetary Sanctions  (Types)":"Civil Recovery Order, Legal Costs","Total Monetary Sanctions (US$)":"$3,983,920.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$3,983,920","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"Unspecified amount (Legal Costs)","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Irregular payments relating to a contract","Offenses - Settled":"Inaccurate business records (Section 221 Companies Act 1985)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office Press Release, in April 2008 the SFO obtained the power to issue civil recovery orders under the Proceeds of Crime Act 2002, under which the SFO can recover property obtained by unlawful conduct. The October 8, 2009 SFO press release noted that \u0022These provisions do not require a specific offence to be established against any particular company or individual, merely tht the property sought is the proceeds of unlawful conduct.\u0022 Balfour Beatty brought the payment irregularities to the attention of the SFO; the payments occurred within a subsidiary entity [name not mentioned in the press release] during the construction of The Bibliotheca Project in Alexandria, Egypt, completed in 2001; the project was undertaken by a Balfour Beatty subsidiary in a joint venture with an Egyptian company.  In a Consent Order agreed to on October 6, 2008 before the High Court, Balfour Beatty agreed to a settlement payment of GBP 2.25 million together with a contribution towards the costs of the Civil Recovery Order proceedings. (Source: UK Serious Fraud Office, \u0022Balfour Beatty plc,\u0022 October 6, 2008, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2008\/balfour-beatty-plc.aspx).  Balfour Beatty plc also announced the settlement in a statement released on October 8, 2008: \u0022Balfour Beatty reaches full settlement of issues relating to Bibliotheca Alexandrina [sic] project,\u0022 accessed at http:\/\/www.balfourbeatty.com\/index.asp?pageid=42\u0026newsid=173.","Sources ":"UK Serious Fraud Office Press Release, \u0022Balfour Beatty plc: Serious Fraud Office successfully obtains first ever Civil Recovery Order involving major plc.,\u0022 October 6, 2008, accessed at http:\/\/www.sfo.gov.uk\/press-room\/press-release-archive\/press-releases-2008\/balfour-beatty-plc.aspx; Balfour Beatty plc company statement, \u0022Balfour Beatty reaches full settlement of issues relating to Bibliotheca Alexandrina [sic] project,\u0022 October 8, 2008, accessed at http:\/\/www.balfourbeatty.com\/index.asp?pageid=42\u0026newsid=173.  See also, United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf","Documents":""},{"Case ID":"ST-60","Case Cluster ":"Ball Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"03\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$300,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$300,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the June 2011 United States Report to the OECD, Ball Corporation, \u0022entered into a settlement with the SEC pertaining to the company\u0027s alleged violations of the books and records and internal controls provisions of the FCPA.  According to the SEC\u0027s cease-and-desist order, after Ball acquired an Argentine company, Fornamental, S.A. in March 2006, certain accounting personnel at Ball learned that Fornamental employees may have made questionable payments and caused other compliance problems before the acquisition. Despite learning of these payments after the acquisition, Ball failed to take sufficient action to ensure that such activities did not recur at Fornamental. Within months of Ball\u0027s acquisition of Fornamental, two Fornamental executives, the then-Fornamental President and then-Fornamental Vice President of Institutional Affairs - authorized improper payments to Argentine officials. Specifically, in the period between July 2006 and October 2007, Fornamental\u0027s senior officers authorized at least ten unlawful payments totaling approximately $106,749 to Argentine government officials. These payments were intended to induce government custom officials to circumvent Argentine laws prohibiting the importation of prohibited used machinery, equipment and parts and also to secure the exportation of raw materials at reduced tariffs.Fornamental\u0027s bribes were funneled through a third party customs agent, who often included the bribes on invoices sent to the company. The bribes often appeared on the invoices as separate line items described inaccurately as \u0022fees for customs assistance \u0022customs advisory services,\u0022 \u0022verification charge,\u0022 or simply \u0022fees.\u0022  According to the SEC\u0027s order, the true nature of these payments was then mischaracterized as ordinary business expenses on Fornamental\u0027s books and records.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Ball Corporation Case Summary, at 19-20.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Ball Corporation Case Summary, at 19-20, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  In the Matter of Ball Corporation, Order Instituting Cease and Desist Proceedings, Administrative Proceeding File No. 3-14305 (March 24, 2011), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2011\/34-64123.pdf","Documents":""},{"Case ID":"ST-61","Case Cluster ":"BellSouth Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nicaragua","Year of Settlement":"2002","Month\/Day of Settlement (or Notes)":"01\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$150,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$150,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Internal controls violations; Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD on the Enforcement of the Anti-Bribery Convention, \u0022On January 15, 2002, the SEC filed two settled enforcement actions against BellSouth Corporation, charging that two of the company\u0027s subsidiaries had engaged in violations of the internal controls and books and records provisions of the FCPA. According to the SEC\u0027s Complaint, between September 1997 and August 2000, former senior management of BellSouth\u0027s Venezuelan subsidiary, Telcel, C.A. (Telcel), authorized payments totaling approximately $10.8 million to six offshore companies and improperly recorded the disbursements in Telcel\u0027s books and records, based on fictitious invoices, as bona fide services. Telcel\u0027s internal controls failed to detect the unsubstantiated payments for a period of at least two years. As an additional consequence of this control deficiency, the Complaint alleged that BellSouth was unable to reconstruct the circumstances or purpose of the Telcel payments, or determine the identity of their ultimate recipients. Telcel was Venezuela\u0027s leading wireless provider, contributing more revenue to BellSouth\u0027s Latin American Group segment than any other Latin American BellSouth operation. In addition, the SEC charged that between October 1998 and June 1999, BellSouth\u0027s Nicaraguan subsidiary, Telefonia Celular de Nicaragua, S.A.\u0027s (Telefonia), improperly recorded payments to the wife of the Nicaraguan legislator who was the chairman of the Nicaraguan legislative committee with oversight of Nicaraguan telecommunications.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, BellSouth Corporation Case,  at 127-128.)  According to the SEC Administrative Proceeding File, the agency issued a Cease and Desist Order enjoining the company from future violations. (Source:  Securities and Exchange Commission, Administrative Proceeding File No. 3-10678, In re: Matter of BellSouth Corporation, January 15, 2002.)  According to the Final Judgment issued against the company, BellSouth was ordered to pay $150,000 in civil penalties. (Source: SEC v. BellSouth Corporation, Case No. 1:02-cv-00113 (N.D. Ga.), Final Judgment and Other Relief Order filed January 24, 2002.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, BellSouth Corporation Case,  at 127-128, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; Securities and Exchange Commission, Administrative Proceeding File No. 3-10678, In re: Matter of BellSouth Corporation, January 15, 2002, accessed at http:\/\/www.sec.gov\/litigation\/admin\/34-45279.htm; SEC v. BellSouth Corporation, Case No. 1:02-cv-00113 (N.D. Ga.), Final Judgment and Other Relief Order filed January 24, 2002, Court Docket Report; actual text of the Judgment not able to be accessed via Pacer.)","Documents":""},{"Case ID":"ST-62","Case Cluster ":"Bid-Rigging in the International Market for Marine Hose","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Argentina, Brazil, Ecuador, Mexico, Venezuela","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"12\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$80,000.00","Criminal Fine\/Penalty (US$) ":"$80,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to violate the Sherman Antitrust Act, Conspiracy to bribe foreign officials ","Offenses - Settled":"Conspiracy to violate the Sherman Antitrust Act, Conspiracy to bribe foreign officials ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Mr. Hioki, the former general manager of his company\u0027s Industrial Engineered Products Department in Tokyo, Japan was charged for his role in a conspiracy to rig bids, fix prices and allocate market shares of marine hose in the US market and for his role in approving deals and corrupt payments and steps to conceal the improper payments via local sales agents in Latin America to employees of government-owned enterprises with which Mr. Hioki\u0027s company sought to do business.  From January 2004 through 2007, Mr. Hioki and others made more than $1 million in corrupt payments to foreign government officials in Latin America to secure or retain business. On December 10, 2008, Mr. Hioki became the ninth individual to plead guilty in the marine hose bid-rigging investigation and the first individual to plead guilty in the investigation of the FCPA conspiracy.  He was sentenced to 24 months\u0027 imprisonment and a criminal fine of $80,000, following the Department of Justice Antitrust Division\u0027s establishe practice of negotiating agreed-to-dispositions.  (Source: US Report to the OECD,  Bid-Rigging in the International Market for Marine Hose Case Summary, at 74-75.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bid-Rigging in the International Market for Marine Hose Case,  at 74-75, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Hisao Mioki, Case No. 4:08-cr-795 (S.D. Tex.), Criminal Information filed December 8, 2008, accessed at  http:\/\/www.justice.gov\/atr\/cases\/f240400\/240474.pdf; Plea Agreement filed December 10, 2008, accessed at http:\/\/www.justice.gov\/atr\/cases\/f243700\/243716.pdf","Documents":""},{"Case ID":"ST-63","Case Cluster ":"Biomet, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Argentina, Brazil, China","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"03\/26","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$17,280,000.00","Criminal Fine\/Penalty (US$) ":"$17,280,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials, Books and records provisions","Offenses - Settled":"Conspiracy to bribe foreign officials, Bribery of foreign officials, Books and records provisions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022According to the criminal information filed today in U.S. District Court in the District of Columbia in connection with the agreement, Biomet, its subsidiaries, employees and agents made various improper payments from approximately 2000 to 2008 to publicly-employed health care providers in Argentina, Brazil and China to secure lucrative business with hospitals.   During this time, more than $1.5 million in direct and indirect corrupt payments were made.   In addition, at the end of each fiscal year, Biomet, its executives, employees and agents falsely recorded the payments on its books and records as \u0022commissions,\u0022 \u0022royalties,\u0022 \u0022consulting fees\u0022 and \u0022scientific incentives\u0022 to conceal the true nature of the payments.\u0022  (Source: US Department of Justice Press Release, \u0022Third Medical Device Company Resolves Foreign Corrupt Practices Act Investigation,\u0022 March 26, 2012.)","Sources ":"US Department of Justice Press Release, \u0022Third Medical Device Company Resolves Foreign Corrupt Practices Act Investigation,\u0022 March 26, 2012, accessed at http:\/\/www.justice.gov\/opa\/pr\/2012\/March\/12-crm-373.html; US v. Biomet, Inc., Case No. 1:12-cr-080 (D.D.C.), Information filed March 26, 2012, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/biomet\/2012-03-26-biomet-information.pdf; Deferred Prosecution Agreement dated March 26, 2012, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/biomet\/2012-03-26-biomet-dpa.pdf","Documents":""},{"Case ID":"ST-64","Case Cluster ":"Biomet, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina, Brazil, China","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"03\/26","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$5,575,731.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$4,432,998","Civil Prejudgment Interest (US$) ":"$1,142,733","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Books and records provisions","Offenses - Settled":"Bribery of foreign officials, Books and records provisions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Complaint, Biomet and four of its subsidiaries paid bribes to public doctors employed by public hospitals and agencies in Argentina, Brazil and China. (Source: US SEC v. Biomet, Inc., Case No. 1:12-cv-00454 (D.D.C.), Complaint filed March 26, 2012.)  According to the SEC Press Release, \u0022According to the SEC\u0027s complaint filed in federal court in Washington D.C., employees of Biomet Argentina SA paid kickbacks as high as 15 to 20 percent of each sale to publicly-employed doctors in Argentina. Phony invoices were used to justify the payments, and the bribes were falsely recorded as \u0022consulting fees\u0022 or \u0022commissions\u0022 in Biomet\u0027s books and records. [  ] The SEC alleges that Biomet\u0027s U.S. subsidiary Biomet International used a distributor to bribe publicly-employed doctors in Brazil by paying them as much as 10 to 20 percent of the value of their medical device purchases. [  ] two additional subsidiaries - Biomet China and Scandimed AB - sold medical devices through a distributor in China who provided publicly-employed doctors with money and travel in exchange for their purchases of Biomet products.\u0022 (Source: US Securities and Exchange Commission Press Release 2012-50, \u0022SEC Charges Medical Device Company Biomet with Foreign Bribery,\u0022 March 26, 2012.)","Sources ":"US Securities and Exchange Commission Press Release 2012-50, \u0022SEC Charges Medical Device Company Biomet with Foreign Bribery,\u0022 March 26, 2012, accessed at http:\/\/www.sec.gov\/news\/press\/2012\/2012-50.htm; US SEC v. Biomet, Inc. Case No. 1:12-cv-00454 (D.D.C.), Complaint filed March 26, 2012, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp22306.pdf","Documents":""},{"Case ID":"ST-65","Case Cluster ":"BizJet International Sales and Support, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico, Panama","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"03\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$11,800,000.00","Criminal Fine\/Penalty (US$) ":"$11,800,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials  ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022 BizJet paid bribes to officials employed by the Mexican Policia Federal Preventiva, the Mexican Coordinacion General de Transportes Aereos Presidenciales, the air fleet for the Gobierno del Estado de Sinaloa, the air fleet for the Gobierno del Estado de Sonora and the Republica de Panama Autoridad Aeronautica Civil.  In many instances, BizJet paid the bribes directly to the foreign officials.  In other instances, BizJet funneled the bribes through a shell company owned and operated by a BizJet sales manager.  BizJet executives orchestrated, authorized and approved the unlawful payments.\u0022  (Source: US Department of Justice Press Release, \u0022Bizjet International Sales and Support Inc., Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $11.8 Million Criminal Penalty,\u0022 March 14, 2012.)  According to the Statement of Facts agreed to by the company as part of its Deferred Prosecution Agreement, \u0022Shell Company A\u0022 was owned by BizJet\u0027s Sales Manager and operated out of his personal residence in Van Nuys, California (para 7); Shell Company A \u0022operated under the pretense\u0022 of supplying aircraft maintenance, repair and overhaul services  but in fact was used in the conspiracy by BizJet executives and sales manager to make unlawful payments to foreign officials via its bank account in California. (para 18) (Source: US v. BizJet International Sales and Support, Inc., Case No. 4:12-cr-00061 (N.D. Okla.), Deferred Prosecution Agreement and Statement of Facts filed March 14, 2012.)","Sources ":"US v. BizJet International Sales and Support, Inc., Case No. 4:12-cr-00061 (N.D. Okla.), Deferred Prosecution Agreement and Statement of Facts filed March 14, 2012, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/bizjet\/2012-03-14-bizjet-deferred-prosecution-agreement.pdf; US Department of Justice Press Release, \u0022Bizjet International Sales and Support Inc., Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $11.8 Million Criminal Penalty,\u0022 March 14, 2012, accessed at http:\/\/www.justice.gov\/opa\/pr\/2012\/March\/12-crm-321.html","Documents":""},{"Case ID":"ST-66","Case Cluster ":"BizJet International Sales and Support, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"03\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"As part of the US settlements with the BizJet company, \u0022BizJet\u0027s indirect parent company, Lufthansa Technik AG, itself a German provider of aircraft-related services, entered into an agreement with the department in connection with the unlawful payments by BizJet and its directors, officers, employees and agents.  The department has agreed not to prosecute Lufthansa Technik provided that Lufthansa Technik satisfies its obligations under the agreement for a period of three years.  Those obligations include ongoing cooperation and the continued implementation of rigorous internal controls. (Source: US Department of Justice Press Release, \u0022Bizjet International Sales and Support Inc., Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $11.8 Million Criminal Penalty,\u0022 March 14, 2012.)  According to Luftansa Technik\u0027s Non-Prosecution Agreement with the Department of Justice, Luftansa \u0022admits, accepts, and acknowledges responsibility for the conduct of its subsidiary set forth in the Statement of Facts contained in the Deferred Prosecution Agreement between the Department and BizJet\u0022 (Source: Non-Prosecution Agreement between Department of Justice and Luftansa Technik A.G., December 21, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/lufthansa-technik\/2011-12-21-lufthansa-npa.pdf.) ","Sources ":"US Department of Justice Press Release, \u0022Bizjet International Sales and Support Inc., Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $11.8 Million Criminal Penalty,\u0022 March 14, 2012, accessed at http:\/\/www.justice.gov\/opa\/pr\/2012\/March\/12-crm-321.html; Non-Prosecution Agreement between Department of Justice and Luftansa Technik A.G., December 21, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/lufthansa-technik\/2011-12-21-lufthansa-npa.pdf.) ","Documents":""},{"Case ID":"ST-67","Case Cluster ":"BJ Services Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"03\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.15, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the June 2011, US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022:  \u0022On March 10, 2004, the SEC instituted settled administrative proceedings against BJ Services Company (BJ Services), for violations of the anti-bribery, internal controls, and books and records provisions of the FCPA. According to the SEC\u0027s filing, during 2001, BJ Services, through its wholly owned Argentinean subsidiary B.J. Services, S.A. (\u0022BJSA\u0022), made illegal or questionable payments, totaling approximately 72,000 pesos to Argentinean customs officials. Further, from 1998 through April 2002 certain undocumented or improperly characterized payments were made totaling approximately 151,000 pesos. In certain instances, entries were made in BJSA\u0027s books and records to conceal the payments. During the same period, BJ Services experienced certain breaches in the existing accounting policies, controls and procedures in certain areas of its Latin American Region.\u0022 (Source: BJ Services Case Summary at 124.)  Please note that as part of the Cease-and-Desist order proceedings, BJ Services Company did not admit or deny the SEC\u0027s findings.  (Source: US Securities and Exchange Commission, In the Matter of BJ Services Company, Administrative File No. 3-11427, March 10, 2004.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, BJ Services Company, at 124, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; US Securities and Exchange Commission, In the Matter of BJ Services Company, Administrative File No. 3-11427, March 10, 2004, accessed at http:\/\/www.sec.gov\/litigation\/admin\/34-49390.htm.","Documents":""},{"Case ID":"ST-68","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"09\/03","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Restitution","Total Monetary Sanctions (US$)":"$10,800,000.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$10,800,000","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$10,800,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Former Employer (unspecified)","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to commit wire fraud","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to commit wire fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  According to the Plea Agreement, Stanley, a US citizen, \u0022agrees to pay restitution to the victim(s) of Count 2 of the Information [Conspiracy to commit mail and wire fraud]. The Defendant stipulates and agrees that as a result of his criminal conduct the victim, his former employer, incurred a monetary loss of $10.8 million. The Defendant and the United States agree to recommend that the Court order restitution of $10.8 million.\u0022 (Source: US v. Stanley, Case No. 4:08-cr-597 (S.D. Tex.), Plea Agreement filed September 3, 2008, para 7.)  According to the US Department of Justice Press Release, \u0022Significant assistance was provided by the SEC\u0027s Division of Enforcement and by the authorities in France, Italy, Switzerland and the United Kingdom.\u0022 (Source: US Department of Justice Press Release, \u0022Former Officer and Director of Global Engineering and Construction Company Pleads Guilty to Foreign Bribery and Kickback Charges,\u0022 September 3, 2008.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   US v. Albert Jackson Stanley, Case No. 4:08-cr-597 (S.D. Tex.), Information filed on August 29, 2008 and unsealed on September 3, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/stanleya\/08-29-08stanley-info.pdf;  Plea Agreement filed September 3, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/stanleya\/09-03-08stanley-plea-agree.pdf; and Court Docket Report retrieved on February 27, 2012 (via PACER).  See also, US Department of Justice Press Release, \u0022Former Officer and Director of Global Engineering and Construction Company Pleads Guilty to Foreign Bribery and Kickback Charges,\u0022 September 3, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/September\/08-crm-772.html","Documents":""},{"Case ID":"ST-69","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"Nigeria","Jurisdiction of Settlement \/ Enforcement Agency":"Economic and Financial Crimes Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/20","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine, Disgorgement","Total Monetary Sanctions (US$)":"$32,500,000.00","Criminal Fine\/Penalty (US$) ":"$30,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"$2,500,000 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$32,500,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Unknown (Bribery offenses related to the Bonny Island Natural Gas Bribe Scheme) ","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a Press Release by the ENI company, its subsidiary Snamprogetti Netherlands BV entered into a settlement and non-prosecution agreement with the Nigerian authorities to resolve an investigation into the activities of Snamprogetti, as member of the TSKJ consortium, in connection with contracts to build liquid natural [gas] faciltiies on Bonny Island, Nigeria.  According to the company press release, \u0022Pursuant to the agreement, Snamprogetti Netherlands B.V. agreed to the payment of a criminal penalty of $30 million and of $2.5 million as reimbursement for legal costs and expenses incurred by the Nigerian authorities. The Federal Government of Nigeria agreed to dismiss all charges against Snamprogetti Netherlands BV and to renounce to any civil claims and criminal charges in any jurisdiction.\u0022   (Source: ENI\/Saipem company Press Release, \u0022Snamprogetti Netherlands BV enters agreement with Federal Government of Nigeria,\u0022 December 20, 2010.)  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.  However, on December 22, 2010, the Nigerian Attorney General and Minister of Justice stated at a media briefing that the total sum of $170.8 million had been paid by foreign companies, including Technip, to settle bribery charges and\/or allegations and that the sums represented fines and disgorgement of profits.  (Source: 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010.)","Sources ":"2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010, provided to the study by the Nigerian Economic and Financial Crimes Commission. ENI Company Press Release, \u0022Snamprogetti Netherlands BV enters agreement with Federal Government of Nigeria,\u0022 December 20, 2010, accessed at http:\/\/www.saipem.com\/site\/download.jsp?idDocument=2013\u0026instance=2.  For details on United States settlement in the case, please see: US v. Snamprogetti Netherlands BV, Case No. 4:10-cr-00460 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts, filed July 7, 2010, accessed at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/snamprogetti\/07-07-10snamprogetti-dpa.pdf","Documents":""},{"Case ID":"ST-70","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"09\/03","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, False Accounting, Aiding and Abetting Halliburton\u0027s Internal Controls Violations, Aiding and Abetting Halliburton\u0027s Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  The US Securities and Exchange Commission Litigation Release noted the assistance of foreign authorities in the case. (Source:  US Securities and Exchange Commission Litigation Release No. 20897A \/ February 11, 2009, Securities and Exchange Commission v. Halliburton Company and KBR, Inc., 4:09-CV-399, S.D. Tex. (Houston), \u0022SEC Charges KBR, Inc. with Foreign Bribery; Charges Halliburton Co. and KBR, Inc. with Related Accounting Violations -- Companies to Pay Disgorgement of $177 Million; KBR Subsidiary to Pay Criminal Fines of $402 Million; Total Payments to be $579 Million.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20897A \/ February 11, 2009, Securities and Exchange Commission v. Halliburton Company and KBR, Inc., 4:09-CV-399, S.D. Tex. (Houston), \u0022SEC Charges KBR, Inc. with Foreign Bribery; Charges Halliburton Co. and KBR, Inc. with Related Accounting Violations -- Companies to Pay Disgorgement of $177 Million; KBR Subsidiary to Pay Criminal Fines of $402 Million; Total Payments to be $579 Million,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr20897a.htm; Complaint filed September 3, 2008, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20700.pdf.","Documents":""},{"Case ID":"ST-71","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"03\/11","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Forfeiture ","Total Monetary Sanctions (US$)":"$148,989,568.67","Criminal Fine\/Penalty (US$) ":"$25,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$148,964,568.67","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  According to the US Department of Justice Press Release, \u0022Significant assistance was provided by [ ] the authorities in France, Italy, Switzerland and the United Kingdom, including in particular the Crown Prosecution Service, the Serious Fraud Office\u0027s International Assistance and Anti-Corruption Units, the London Metropolitan Police and the City of London Police in the United Kingdom.\u0022 (Source: US Department of Justice Press Release, \u0022UK Solicitor Pleads Guilty for Role in Bribing Nigerian Government Officials as Part of KBR Joint Venture Scheme,\u0022 March 11, 2011.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  U.S. v. Jeffrey Tesler and Wojciech J. Chodan, Case No. 09-cr-098 (S.D. Tex.), Indictment filed Feburary 17, 2009, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tesler\/tesler-indict.pdf; Plea Agreement filed March 11, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tesler\/tesler_plea_agmt.pdf and Court Docket Report retrieved on February 27, 2012 (via PACER).  US Department of Justice Press Release, \u0022UK Solicitor Pleads Guilty for Role in Bribing Nigerian Government Officials as Part of KBR Joint Venture Scheme,\u0022 March 11, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/March\/11-crm-313.html.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Tesler_Chodan_DOJ_Indictment_Feb_17_2009.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Tesler_DOJ_Plea_Agreement_Mar_11_2011.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Tesler_Plea_Agreement_DOJ_Press_Release_Mar_11_2011.pdf"},{"Case ID":"ST-72","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"Nigeria","Jurisdiction of Settlement \/ Enforcement Agency":"Economic and Financial Crimes Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"January","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution agreement","Monetary Sanctions  (Types)":"Criminal Fine, Disgorgement","Total Monetary Sanctions (US$)":"$28,500,000.00","Criminal Fine\/Penalty (US$) ":"$28,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$28,500,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Unknown (Bribery offenses related to the Bonny Island Natural Gas Bribe Scheme) ","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the JGC Corporation\u0027s January 31, 2011 Notice of Loss and Revisions of Earnings Forecasts for Fiscal Year Ending March 31, 2011, JGC reached a settlement with the Nigerian authorities in January 2011. No other details were noted in the company\u0027s notice. (Source: JGC Corporation\u0027s January 31, 2011 Notice of Loss and Revisions of Earnings Forecasts for Fiscal Year Ending March 31, 2011.)  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.  However, on December 22, 2010, the Nigerian Attorney General and Minister of Justice stated at a media briefing that the total sum of $170.8 million had been paid by foreign companies to settle bribery charges and\/or allegations and that the sums represented fines and disgorgement of profits.  (Source: 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010.)","Sources ":"Nigeria Settlement: 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010, provided to the study by the Nigerian Economic and Financial Crimes Commission. JGC Corporation\u0027s January 31, 2011 Notice of Loss and Revisions of Earnings Forecasts for Fiscal Year Ending March 31, 2011, accessed at http:\/\/www.jgc.co.jp\/en\/06ir\/pdf\/financial_statements_summary\/fy10\/fy10_3rdqtr_revision.pdf; US Settlement: US v. JGC Corporation,  Case No. 4:11-cr-00260 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts filed April 6, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/jgc-corp\/04-6-11jgc-corp-dpa.pdf.","Documents":""},{"Case ID":"ST-73","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"04\/06","Other Jurisdictions of Settlement":"Nigeria","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$218,800,000.00","Criminal Fine\/Penalty (US$) ":"$218,800,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Aiding and Abetting the Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Aiding and Abetting the Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  The US Department of Justice Press Release noted that \u0022Significant assistance was provided by [ ] authorities in France, Italy, Switzerland and the United Kingdom.\u0022 (Source: US Department of Justice Press Release, \u0022JGC Corporation Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay a $218.8 Million Criminal Penalty,\u0022 April 6, 2011.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   US v. JGC Corporation, Case No. 4:11-cr-260 (S.D. Tex.), Information filed April 6, 2011, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/jgc-corp\/04-6-11jgc-corp-info.pdf; Deferred Prosecution Agreement filed April 6, 2011, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/jgc-corp\/04-6-11jgc-corp-dpa.pdf; US Department of Justice Press Release, \u0022JGC Corporation Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay a $218.8 Million Criminal Penalty,\u0022 April 6, 2011, accessed at www.justice.gov\/opa\/pr\/2011\/April\/11-crm-431.html.","Documents":""},{"Case ID":"ST-75","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"02\/11","Other Jurisdictions of Settlement":"Nigeria","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits","Total Monetary Sanctions (US$)":"$177,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$177,000,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials (KBR), Internal controls violations (Halliburton), Falsification of books and records (Halliburton), False accounting (KBR), Aiding and Abetting Halliburton\u0027s Internal Controls Violations (KBR), Aiding and Abetting Halliburton\u0027s Falsification of Books and Records (KBR)","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20897 \/ February 11, 2009, Securities and Exchange Commission v. Halliburton Company, 4:09-CV-399, S.D. Tex. (Houston), \u0022SEC Charges KBR, Inc. with Foreign Bribery; Charges Halliburton Co. and KBR, Inc. with Related Accounting Violations ? Companies to Pay Disgorgement of $177 Million; KBR Subsidiary to Pay Criminal Fines of $402 Million; Total Payments to be $579 Million,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr20897.htm; Complaint filed February 11, 2009, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp20897.pdf","Documents":""},{"Case ID":"ST-76","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"Nigeria","Jurisdiction of Settlement \/ Enforcement Agency":"Economic and Financial Crimes Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"10\/21","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution agreement","Monetary Sanctions  (Types)":"Criminal Fine, Disgorgement, Procedural costs","Total Monetary Sanctions (US$)":"$35,000,000.00","Criminal Fine\/Penalty (US$) ":"$32,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"$2,500,000 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$35,000,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Unknown (Bribery offenses related to the Bonny Island Natural Gas Bribe Scheme) ","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Halliburton Company Press Release: \u0022Pursuant to this agreement [with Federal Government of Nigeria (FGN)], all lawsuits and charges against KBR and Halliburton corporate entities and associated persons have been withdrawn, The FGN agreed not to bring any further criminal charges or civil claims against those entities or persons, and Halliburton agreed to pay US$32.5 million to the FGN and to pay an additional US$2.5 million for FGN\u0027s attorneys\u0027 fees and other expenses. Among other provisions, Halliburton agreed to provide reasonable assistance in the FGN\u0027s effort to recover amounts frozen in a Swiss bank account of a former TSKJ agent and affirmed a continuing commitment with regard to corporate governance. Any charges related to this settlement will be reflected in discontinued operations.\u0022  (Source: Halliburton Company Press Release, \u0022Halliburton Confirms Agreement to Settle with Federal Government of Nigeria,\u0022 December 21, 2010.)   Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.  However, on December 22, 2010, the Nigerian Attorney General and Minister of Justice stated at a media briefing that the total sum of $170.8 million had been paid by foreign companies, including Halliburton, to settle bribery charges and\/or allegations and that the sums represented fines and disgorgement of profits.  (Source: 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010.)","Sources ":"2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010, provided to the study by the Nigerian Economic and Financial Crimes Commission.  Halliburton Company Press Release, \u0022Halliburton Confirms Agreement to Settle with Federal Government of Nigeria,\u0022 December 21, 2010, accessed at www.halliburton.com\/public\/news\/pubsdata\/press_release\/2010\/corpnws_12212010.html.","Documents":""},{"Case ID":"ST-77","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"02\/11","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$402,000,000.00","Criminal Fine\/Penalty (US$) ":"$402,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  The US Department of Justice Press Release noted that \u0022Significant assistance was provided by [  ] authorities in France, Italy, Switzerland and the United Kingdom.\u0022  (Source: US Department of Justice Press Release, \u0022Kellogg Brown \u0026 Root LLC Pleads Guilty to Foreign Bribery Charges and Agrees to Pay $402 Million Criminal Fine,\u0022 February 11, 2009.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US. v. Kellogg, Brown \u0026 Root LLC, Case No. 4:09-cr-071 (S.D. Tex.), Information filed February 6, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/kelloggb\/02-06-09kbr-info.pdf; Plea Agreement filed February 11, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/kelloggb\/02-11-09kbr-plea-agree.pdf; Judgment filed February 12, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/kelloggb\/02-12-09kbr-judgment.pdf.  US Department of Justice Press Release, \u0022Kellogg Brown \u0026 Root LLC Pleads Guilty to Foreign Bribery Charges and Agrees to Pay $402 Million Criminal Fine,\u0022 February 11, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/February\/09-crm-112.html","Documents":""},{"Case ID":"ST-78","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"07\/07","Other Jurisdictions of Settlement":"Nigeria","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$240,000,000.00","Criminal Fine\/Penalty (US$) ":"$240,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials, Aiding and Abetting the Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials, Aiding and Abetting the Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  The US Department of Justice Press Release noted that \u0022Significant assistance was provided by [  ] authorities in France, Italy, Switzerland and the United Kingdom.\u0022  (Source: US Department of Justice Press Release, \u0022Snamprogetti Netherlands B.V. Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $240 Million Criminal Penalty, $1.28 Billion in Total Penalties Obtained to Date for Scheme to Bribe Nigerian Government Officials to Obtain Contracts,\u0022 July 7, 2010.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Snamprogretti Netherlands BV, Case No. 4:10-cr-460 (S.D. Tex, 2010), Information filed July 7, 2010, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/snamprogetti\/07-07-10snamprogetti-info.pdf; Deferred Prosecution Agreement filed July 7, 2010, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/snamprogetti\/07-07-10snamprogetti-dpa.pdf.  US Department of Justice Press Release, \u0022Snamprogetti Netherlands B.V. Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $240 Million Criminal Penalty, $1.28 Billion in Total Penalties Obtained to Date for Scheme to Bribe Nigerian Government Officials to Obtain Contracts,\u0022 July 7, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/July\/10-crm-780.html","Documents":""},{"Case ID":"ST-79","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"07\/07","Other Jurisdictions of Settlement":"Nigeria","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits","Total Monetary Sanctions (US$)":"$125,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$125,000,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  According to the SEC Litigation Release, \u0022The SEC acknowledges the assistance of the U.S. Department of Justice, Fraud Section; the Federal Bureau of Investigation; and foreign authorities in Europe, Asia, Africa and the Americas.\u0022  (Source: US Securities and Exchange Commission Litigation Release No. 21588 \/ July 7, 2010, Securities and Exchange Commission v. ENI, S.p.A. and Snamprogetti Netherlands, B.V., Case No. 4:10-cv-02414, S.D. Tex. (Houston), \u0022SEC Charges Snamprogetti Netherlands, B.V. with Foreign Bribery and Related Accounting Violations and ENI, S.p.A. with Books and Records and Internal Controls Violations -- ENI and Snamprogetti to Pay Jointly $125 Million in Disgorgement; Snamprogetti Also to Pay a Criminal Penalty of $240 Million.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 21588 \/ July 7, 2010, Securities and Exchange Commission v. ENI, S.p.A. and Snamprogetti Netherlands, B.V., Case No. 4:10-cv-02414, S.D. Tex. (Houston), \u0022SEC Charges Snamprogetti Netherlands, B.V. with Foreign Bribery and Related Accounting Violations and ENI, S.p.A. with Books and Records and Internal Controls Violations -- ENI and Snamprogetti to Pay Jointly $125 Million in Disgorgement; Snamprogetti Also to Pay a Criminal Penalty of $240 Million,\u0022 accessed at www.sec.gov\/litigation\/litreleases\/2010\/lr21588.htm; Complaint filed July 7, 2010, accessed at www.sec.gov\/litigation\/complaints\/2010\/comp-pr2010-119.pdf.","Documents":""},{"Case ID":"ST-80","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"06\/28","Other Jurisdictions of Settlement":"Nigeria","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$240,000,000.00","Criminal Fine\/Penalty (US$) ":"$240,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  The US Department of Justice Press Release noted \u0022Significant assistance was provided by [ ] authorities in France, Italy, Switzerland and the United Kingdom.\u0022  (Source:  US Department of Justice Press Release, \u0022Technip S.A. Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $240 Million Criminal Penalty,\u0022 June 28, 2010.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Technip S.A., Case No. 4:10-cr-439 (S.D. Tex.), Information filed on June 28, 2010, accessed at ww.justice.gov\/criminal\/fraud\/fcpa\/cases\/technip-sa\/06-28-10-technip-%20information.pdf; Deferred Prosecution Agreement filed June 28, 2010, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/technip-sa\/06-28-10-technip-agreement.pdf. US Department of Justice Press Release, \u0022Technip S.A. Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $240 Million Criminal Penalty,\u0022 June 28, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/June\/10-crm-751.html","Documents":""},{"Case ID":"ST-81","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"06\/28","Other Jurisdictions of Settlement":"Nigeria","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$98,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$98,000,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  According to the US Securities and Exchange Commission Litigation Release, the $98 million represents disgorgement of profits and prejudgment interest; the breakdown in amounts was not given. Also according to the Litigation Release, \u0022The Commission acknowledges the assistance of [ ] foreign authorities in Europe, Asia, Africa and the Americas.\u0022  (Source: US Securities and Exchange Commission Litigation Release No. 21578 \/ June 28, 2010, Securities and Exchange Commission v. Technip, Case No. 4:10-cv-02289, S.D. Tex. (Houston), \u0022SEC Charges Technip with Foreign Bribery and Related Accounting Violations -- Technip to Pay $98 Million in Disgorgement and Prejudgment Interest; Company Also to Pay a Criminal Penalty of $240 Million.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 21578 \/ June 28, 2010, Securities and Exchange Commission v. Technip, Case No. 4:10-cv-02289, S.D. Tex. (Houston), \u0022SEC Charges Technip with Foreign Bribery and Related Accounting Violations -- Technip to Pay $98 Million in Disgorgement and Prejudgment Interest; Company Also to Pay a Criminal Penalty of $240 Million,\u0022 accessed at www.sec.gov\/litigation\/litreleases\/2010\/lr21578.htm; Complaint filed June 28, 2010, accessed at www.sec.gov\/litigation\/complaints\/2010\/comp-pr2010-110.pdf","Documents":""},{"Case ID":"ST-82","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"Nigeria","Jurisdiction of Settlement \/ Enforcement Agency":"Economic and Financial Crimes Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"Month and Day unspecified","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution agreement","Monetary Sanctions  (Types)":"Criminal Fine, Disgorgement","Total Monetary Sanctions (US$)":"$30,000,000.00","Criminal Fine\/Penalty (US$) ":"$30,000,000","Criminal Fine \/ Penalty (Explanation)":"Please note that the December 22, 2010 press briefing by the Nigerian Attorney General noted that $170.8 million had been paid in total by companies and individuals; no specific figure was given as to Technip. The press statement noted that the sums had been paid by the companies as fines and disgorgement but no breakdown was given.  The total amount for Technip is from a secondary source; as it was unknown what portion of the sums constituted fines or disgorgement. ","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$30,000,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Unknown (Bribery offenses related to the Bonny Island Natural Gas Bribe Scheme) ","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to secondary sources (including Marcus Cohen, David Elesinmogun \u0026 Obumneme Egwuatu, \u0022Will Nigeria Take Another Bite?,\u0022 FCPA Blog, August 4, 2011), Technip agreed to pay $30 million to Nigerian authorities as part of its settlement agreement.  For background on the US Foreign Corrupt Practices Act case and settlement with Technip, S.A. related to the Bonny Island natural gas project in Nigeria, please see US v. Technip S.A., Case No. 4:10-cr-00439 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts, filed June 28, 2010 and Technip S.A. Company Statement, \u0022Technip confirms resolution of DOJ and SEC investigation into TSKJ Nigeria,\u0022 June 28, 2010.  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.  However, on December 22, 2010, the Nigerian Attorney General and Minister of Justice stated at a media briefing that the total sum of $170.8 million had been paid by foreign companies, including Technip, to settle bribery charges and\/or allegations and that the sums represented fines and disgorgement of profits.  (Source: 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010.)","Sources ":"2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010, provided to the study by the Nigerian Economic and Financial Crimes Commission.  Marcus Cohen, David Elesinmodun \u0026 Obumneme Egwuatu, \u0022Will Nigeria Take Another Bite?,\u0022 FCPA Blog, August 4, 2011, accessed at http:\/\/www.fcpablog.com\/blog\/tag\/shell; US v. Technip S.A., Case No. 4:10-cr-00439 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts, filed June 28, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/technip-sa\/06-28-10-technip-agreement.pdf; Technip S.A. Company Statement, \u0022Technip confirms resolution of DOJ and SEC investigation into TSKJ Nigeria,\u0022 June 28, 2010, accessed at http:\/\/www.technip.com\/en\/press\/technip-confirms-resolution-doj-and-sec-investigation-tskj-nigeria","Documents":""},{"Case ID":"ST-83","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/06","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Forfeiture","Total Monetary Sanctions (US$)":"$746,885.00","Criminal Fine\/Penalty (US$) ":"$20,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$726,885","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  The US Department of Justice Press Release on Chodan\u0027s Plea Agreement noted that \u0022Significant assistance was provided by [ ] by authorities in France, Italy, Switzerland and the United Kingdom, including in particular the Crown Prosecution Service, the Serious Fraud Office?s International Assistance and Anti-Corruption Units, the London Metropolitan Police and the City of London Police.\u0022 (Source: US Department of Justice Press Release, \u0022UK Citizen Pleads Guilty to Conspiring to Bribe Nigerian Government Officials to Obtain Lucrative Contracts as Part of KBR Joint Venture Scheme,\u0022 December 6, 2010.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Jeffrey Tesler and Wojciech J. Chodan, Case No. 09-cr-098 (S.D. Tex.), Indictment filed Feburary 17, 2009, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tesler\/tesler-indict.pdf; Plea Agreement filed December 6, 2010, accessesd at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/chodan\/12-06-10chodan-plea.pdf and Court Docket Report retrieved on February 27, 2012 (via PACER).  US Department of Justice Press Release, \u0022UK Citizen Pleads Guilty to Conspiring to Bribe Nigerian Government Officials to Obtain Lucrative Contracts as Part of KBR Joint Venture Scheme,\u0022 December 6, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/December\/10-crm-1391.html","Documents":""},{"Case ID":"ST-84","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"01\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$54,600,000.00","Criminal Fine\/Penalty (US$) ":"$54,600,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Aiding and Abetting the Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Aiding and Abetting the Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022The department filed a deferred prosecution agreement and a criminal information today against Marubeni in U.S. District Court for the Southern District of Texas. The two-count information charges Marubeni with one count of conspiracy and one count of aiding and abetting violations of the FCPA. Marubeni is a Japanese trading company headquartered in Tokyo.  According to court documents, Marubeni was hired as an agent by the four-company TSKJ joint venture to help TSKJ obtain and retain EPC contracts to build liquefied natural gas (LNG) facilities on Bonny Island, Nigeria, by offering to pay and paying bribes to Nigerian government officials, among other means. TSKJ was comprised of Technip S.A., Snamprogetti Netherlands B.V., Kellogg Brown \u0026 Root Inc. (KBR) and JGC Corporation. Between 1995 and 2004, TSKJ was awarded four EPC contracts, valued at more than $6 billion, by Nigeria LNG Ltd. to build the LNG facilities on Bonny Island. The government-owned Nigerian National Petroleum Corporation was the largest shareholder of NLNG, owning 49 percent of the company. According to court documents, to assist in obtaining and retaining the EPC contracts, the joint venture hired two agents -- Marubeni and Jeffrey Tesler, a U.K. solicitor -- to pay bribes to a wide range of Nigerian government officials. The joint venture hired Tesler as a consultant to pay bribes to high-level Nigerian government officials, including top-level executive branch officials, and hired Marubeni to pay bribes to lower-level Nigerian government officials. At crucial junctures preceding the award of EPC contracts, a number of co-conspirators, including on two occasions an employee of Marubeni, met with successive holders of a top-level office in the executive branch of the Nigerian government to ask the office holders to designate a representative with whom TSKJ should negotiate bribes to Nigerian government officials. TSKJ paid approximately $132 million to a Gibraltar corporation controlled by Tesler and $51 million to Marubeni during the course of the bribery scheme and intended for these payments to be used, in part, for bribes to Nigerian government officials. [ ] Significant assistance was provided by authorities in France, Italy, Switzerland and the United Kingdom.\u0022  (Source:  US Department of Justice Press Release, \u0022Marubeni Corporation Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay a $54.6 Million Criminal Penalty,\u0022 January 17, 2012.)","Sources ":"US v. Marubeni Corporation, Case No. 4:12-cr-00022 (S.D. Tex.), Information filed January 17, 2012, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/marubeni\/2012-01-17-marubeni-information.pdf and Deferred Prosecution Agreement filed January 17, 2012, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/marubeni\/2012-01-17-marubeni-dpa.pdf.  US Department of Justice Press Release, \u0022Marubeni Corporation Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay a $54.6 Million Criminal Penalty,\u0022 January 17, 2012, accessed at http:\/\/www.justice.gov\/opa\/pr\/2012\/January\/12-crm-060.html; Marubeni Corporation Statement, \u0022Settlement with the U.S. Department of Justice regarding the Nigeria LNG Project,\u0022 January 18, 2012, accessed at http:\/\/www.marubeni.com\/news\/2012\/120118e.html","Documents":""},{"Case ID":"ST-85","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Gabon, Angola, Equatorial Guinea","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$5,858,165.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$2,694,405","Civil Prejudgment Interest (US$) ":"$1,063,760","Civil Fine \/ Penalty (US$)":"$2,100,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission Litigation Release, on November 3, 2010, the Commission \u0022charged GlobalSantaFe Corp. (GSF) (c\/k\/a Transocean Worldwide Inc.) with bribery and other violations of the Foreign Corrupt Practices Act (FCPA). According to the SEC?s complaint, filed today in federal district court in Washington, D.C., from approximately January 2002 through July 2007, GSF made illegal payments to officials of the Nigerian Customs Service (NCS), through companies acting as customs brokers for GSF. In November 2007, GSF, an oil and gas drilling services company, merged with a subsidiary of Transocean Inc. In December 2008, the listed company became Transocean Ltd. [  ]  The SEC alleges that GSF [GlobalSantaFe Corp], through its customs brokers, made other suspicious payments, some characterized as \u0022interventions,\u0022 to Nigerian customs officials. In addition, GSF similarly made a number of suspicious payments to government officials in Gabon, Angola, and Equatorial Guinea. These payments were described on invoices as, for example, \u0022customs vacation,\u0022 \u0022customs escort,\u0022 \u0022costs extra police to obtain visa,\u0022 \u0022official dues,\u0022 and \u0022authorities fees.\u0022  None of the payments were accurately reflected in GSF\u0027s books and records, nor was GSF\u0027s system of internal accounting controls adequate at the time to detect and prevent these illegal payments.  Without admitting or denying the SEC\u0027s allegations, GSF has consented to the entry of a court order permanently enjoining it from violating the anti-bribery and record keeping and internal controls provisions in Section 30A and Sections 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act. GSF also consented to the entry of a court order requiring GSF to pay disgorgement of $2,694,405, prejudgment interest of $1,063,760, and a civil penalty of $2.1 million.\u0022 (Source:  US Securities and Exchange Commission, Litigation Release No. 21724 \/ November 4, 2010, Securities and Exchange Commission v. GlobalSantaFe Corp., Civil Action No. 1:10-CV-01890 (RMC) (D.D.C.), \u0022SEC Charges GlobalSantaFe with Bribery and other  FCPA Violations.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21724 \/ November 4, 2010, Securities and Exchange Commission v. GlobalSantaFe Corp., Civil Action No. 1:10-CV-01890 (RMC) (D.D.C.), \u0022SEC Charges GlobalSantaFe with Bribery and other  FCPA Violations,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21724.htm; Complaint filed November 4, 2010,  accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21724.pdf","Documents":""},{"Case ID":"ST-86","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"Nigeria","Jurisdiction of Settlement \/ Enforcement Agency":"Economic and Financial Crimes Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"01\/28","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution agreement  ","Monetary Sanctions  (Types)":"Criminal Fine, Disgorgement","Total Monetary Sanctions (US$)":"$2,500,000.00","Criminal Fine\/Penalty (US$) ":"$2,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$2,500,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Unknown (Bribery offenses)","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to a filing by the Noble Corporation with the US Securities and Exchange Commission, \u0022Nigerian Customs Matter \/  In November 2010, Noble-Swiss reached a settlement with the U.S. Department of Justice and the Securities and Exchange Commission in connection with their investigation under the United States Foreign Corrupt Practices Act of certain reimbursement payments made by its Nigerian affiliate to customs agents in Nigeria. In January 2011, the Nigerian Economic and Financial Crimes Commission and the Nigerian Attorney General Office initiated an investigation into these same activities. A subsidiary of Noble-Swiss has resolved this matter through the execution of a non-prosecution agreement dated January 28, 2011. Pursuant to this agreement, the subsidiary will pay $2.5 million to resolve all charges and claims of the Nigerian government.\u0022 (Source:  Noble Corporation, SEC Form 8-K, January 31, 2011.)  ","Sources ":"Noble Corporation, \u0022Form 8-K Report of Noble Corporation,\u0022 filed with the US Securities \u0026 Exchange Commission, January 31, 2011, accessed at www.sec.gov\/Archives\/edgar\/data\/1169055\/000095012311006909\/h79316e8vk.htm.","Documents":""},{"Case ID":"ST-87","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Nigeria","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,590,000.00","Criminal Fine\/Penalty (US$) ":"$2,590,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Department of Justice Press Release, on November 4, 2010, \u0022the department and Noble Corporation, a Swiss corporation, reached an agreement in which Noble Corporation admitted that it had paid approximately $74,000 to a Nigerian freight forwarding agent, acknowledged that certain employees knew that some of the payments would be passed on as bribes to Nigerian customs officials, and admitted that the company falsely recorded the bribe payments as legitimate business expenses in its corporate books, records and accounts.  As part of the non-prosecution agreement entered into with the government, Noble will pay a $2.59 million criminal penalty. The non-prosecution agreement recognizes Noble\u0027s early voluntary disclosure, thorough self-investigation of the underlying conduct, full cooperation with the department and extensive remedial measures undertaken by the company. As a result of these factors, among others, the department agreed not to prosecute Noble or its subsidiaries for the bribe payments, provided that Noble satisfies its ongoing obligations under the agreement.\u0022 (Source:  US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   US Department of Justice, In Re: Noble Corporation, Non-Prosecution Agreement dated November 4, 2010, accessed at  www.justice.gov\/criminal\/fraud\/fcpa\/cases\/noble-corp\/11-04-10noble-corp-npa.pdf; US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010, accessed at www.justice.gov\/opa\/pr\/2010\/November\/10-crm-1251.html","Documents":""},{"Case ID":"ST-88","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Nigeria","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$5,576,998.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$4,294,933","Civil Prejudgment Interest (US$) ":"$1,282,065","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission Litigation Release, on November 4, 2010, the Commission \u0022announced a settlement with Noble Corporation (Noble) for violations of the Foreign Corrupt Practices Act (FCPA). The SEC alleged that Noble, an offshore drilling contractor headquartered in Switzerland with an office in Sugarland, Texas, made improper payments through its custom agents to officials of the Nigeria Customs Service to obtain permits and permit extensions necessary for operating offshore oil rigs in Nigeria. As part of the settlement, Noble will pay $5,576,998 in disgorgement and prejudgment interest.  [ ]   The Commission\u0027s complaint, filed today in federal court in Houston, alleges that from January 2003 through May 2007, Noble authorized payments by its Nigerian subsidiary to its customs agent, believing that the agent would give portions of the payments to Nigerian government officials to induce them to grant temporary importation permits (TIPs) and TIP extensions for Noble\u0027s drilling rigs. Although Noble was required to move its rigs out of Nigeria when TIPs and any extensions had expired, it did not do so in order to avoid the costs of moving the rigs, the potential loss of profits, and the break in performance of rigs under contract. Noble used the customs agents to submit false documents to Nigerian Customs Service showing export and re-import of its drilling rigs when in fact the rigs never moved. Noble paid its customs agents to present these false documents to the Nigeria Customs Service (NCS) and, through the customs agents, made improper payments to officials of the NCS to process the false documents and issue new TIPS. Noble obtained eight TIPs with false documentation.\u0022 (Source:  US Securities and Exchange Commission, Litigation Release No. 21728\/ November 4, 2010, Securities and Exchange Commission v. Noble Corporation, Case No. 4:10-cv-4336 (S.D. Tex.), \u0022SEC Charges Noble with FCPA Violations.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21728\/ November 4, 2010, Securities and Exchange Commission v. Noble Corporation, Case No. 4:10-cv-4336 (S.D. Tex.), \u0022SEC Charges Noble with FCPA Violations,\u0022  accessed at www.sec.gov\/litigation\/litreleases\/2010\/lr21728.htm; Complaint filed November 4, 2010, accessed at www.sec.gov\/litigation\/complaints\/2010\/comp21728. ","Documents":""},{"Case ID":"ST-89","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"02\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$35,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$35,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Aiding and Abetting Noble Corporation\u0027s violations of the anti-bribery, books and records, and internal controls provisions; Internal Controls and False Records violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to a Press Release by the US Securities and Exchange Commission, the agency had filed a complaint against Thomas F. O\u0027Rourke, former controller and head of internal audit at Noble Corporation, along with two other company executives whom the agency alleged perpetrated a scheme to bribe Nigerian customs officials to grant new temporary permits illegally and \u0022favorably exercise or abuse their discretion to grant permit extensions.\u0022  The press release noted that \u0022Noble Corporation was charged with FCPA violations as part of a sweep of the oil services industry in late 2010. The company cooperated with investigators and agreed to pay more than $8 million to settle civil and criminal cases.\u0022  (Source:  US Securities and Exchange Commission Press Release, \u0022SEC Charges Three Oil Services Executives with Bribing Customs Officials in Nigeria,\u0022 February 24, 2012.)","Sources ":"US Securities and Exchange Commission Press Release, \u0022SEC Charges Three Oil Services Executives with Bribing Customs Officials in Nigeria,\u0022 February 24, 2012, accessed at http:\/\/www.sec.gov\/news\/press\/2012\/2012-32.htm and complaint filed in US v. Thomas F. O\u0027Rourke (S.D. Tex), case number not provided, acccessed at http:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-32-1.pdf","Documents":""},{"Case ID":"ST-90","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Angola, Azerbaijan, Brazil, Kazakhstan, Nigeria, Russia, Turkmenistan, and other unspecified countries","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$70,560,000.00","Criminal Fine\/Penalty (US$) ":"$70,560,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to falsify books and records, Conspiracy to aiding and abetting falsification of books and records","Offenses - Settled":"Conspiracy to falsify books and records, Conspiracy to aiding and abetting falsification of books and records","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Department of Justice Press Release dated November 14, 2010, \u0022In documents filed in U.S. District Court for the Southern District of Texas, Panalpina World Transport (Holding) Ltd., a global freight forwarding and logistics services firm based in Basel, Switzerland, and its U.S.-based subsidiary, Panalpina Inc., admitted that the companies, through subsidiaries and affiliates (collectively \u0022Panalpina\u0022), engaged in a scheme to pay bribes to numerous foreign officials on behalf of many of its customers in the oil and gas industry. They did so in order to circumvent local rules and regulations relating to the import of goods and materials into numerous foreign jurisdictions. Panalpina admitted that between 2002 and 2007, it paid thousands of bribes totaling at least $27 million to foreign officials in at least seven countries, including Angola, Azerbaijan, Brazil, Kazakhstan, Nigeria, Russia and Turkmenistan. Also today, Panalpina\u0027s customers, including Shell Nigeria Exploration and Production Company Ltd. (SNEPCO), Transocean Inc. and Tidewater Marine International Inc., admitted that the companies approved of or condoned the payment of bribes on their behalf in Nigeria and falsely recorded the bribe payments made on their behalf as legitimate business expenses in their corporate books, records and accounts.  As part of the agreed resolution, the department today filed a criminal information charging Panalpina World Transport with conspiring to violate and violating the anti-bribery provisions of the FCPA. The department and Panalpina World Transport agreed to resolve the charges by entering into a deferred prosecution agreement. The department also filed a criminal information charging Panalpina Inc. with conspiring to violate the books and records provisions of the FCPA and with aiding and abetting certain customers in violating the books and records provisions of the FCPA. Panalpina Inc. has agreed to plead guilty to the charges. The agreements require the payment of a $70.56 million criminal penalty.\u0022 (Source:  US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties; SEC and Companies Agree to Civil Disgorgement and Penalties of Approximately $80 Million,\u0022 November 4, 2010.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Panalpina Inc., Case No. 4:10-cr-00765 (S.D. Tex.), Information filed November 4, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/panalpina-inc\/11-04-10panalpina-info.pdf;  Plea Agreement filed November 4, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/panalpina-inc\/11-04-10panalpina-plea.pdf; Judgmetn filed December 16, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/panalpina-inc\/12-16-10panalpina-judgment.pdf.  US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties; SEC and Companies Agree to Civil Disgorgement and Penalties of Approximately $80 Million,\u0022 November 4, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/November\/10-crm-1251.html.","Documents":""},{"Case ID":"ST-91","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Angola, Brazil, Kazakhstan, Nigeria, Russia, and other unspecified countries","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits","Total Monetary Sanctions (US$)":"$11,329,369.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$11,329,369","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations, Aiding and abetting the bribery of foreign officials, Aiding and abetting the falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission Litigation Release, on November 4, 2010, the Commission \u0022charged the U.S. subsidiary of Panalpina World Transport (Holding) Ltd. (PWT), a global freight forwarding and logistics services provider based in Basel, Switzerland, with violating the Foreign Corrupt Practices Act (FCPA) by bribing foreign officials around the world on behalf of its customers. The SEC\u0027s complaint, filed in federal district court in Houston, alleges that from 2002 through 2007 Panalpina, Inc. (Panalpina), in concert with other PWT subsidiaries and affiliates (Panalpina Group), bribed government officials in countries including Nigeria, Angola, Brazil, Russia, and Kazakhstan. The bribes were paid by Panalpina to obtain preferential customs, duties, and import treatment for its customers in connection with international freight shipments. Although PWT, Panalpina, and the Panalpina Group are not issuers for purposes of the FCPA, many of their customers are. By paying bribes on behalf of issuers, Panalpina both violated and aided and abetted violations of the FCPA.  To settle the SEC\u0027s charges, Panalpina will pay $11,329,369. [ ]  The complaint alleges that although the bribery schemes varied, most shared several similarities. The customers often used Panalpina or other Panalpina Group companies to ship goods internationally or sought Panalpina\u0027s assistance in obtaining customs or logistics services in the country to which goods were shipped. For various reasons --including delayed departures, insufficient or incorrect documentation, the nature of the goods being shipped and imported, or the refusal of local government officials to provide services without unofficial payments -- Panalpina\u0027s customers sometimes faced delays in importing goods. In other cases, Panalpina\u0027s customers sought to avoid local customs duties or inspection requirements or otherwise sought to import goods in circumvention of local law. In order to secure the importation of goods under these circumstances, Panalpina\u0027s customers often authorized Panalpina and other Panalpina Group companies to bribe foreign officials.  The complaint further alleges that Panalpina Group companies invoiced Panalpina\u0027s customers for the bribes. The invoices, which contained both legitimate and illegitimate charges, concealed the bribes by inaccurately referring to them as \u0022local processing,\u0022 \u0022special intervention,\u0022 \u0022special handing,\u0022 and other seemingly legitimate fees. Without admitting or denying the SEC\u0027s allegations, Panalpina consented to the entry of a final judgment ordering disgorgement and permanently enjoining it from violating the FCPA\u0027s anti-bribery provisions and aiding and abetting violations of the FCPA\u0027s books and records and internal controls provisions. These provisions are codified as Sections 30A, 13(b)(2)(A), and 13(b)(2)(B) of the Securities Exchange Act of 1934. The proposed settlement is subject to court approval.","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21727 \/ November 4, 2010, SEC v. Panalpina, Inc., Civil Action No. 4:10-cv-4334 (S.D. Texas, November 4, 2010), \u0022SEC Charges Panalpina with Violating Foreign Corrupt Practices Act,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21727.htm; Complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21727.pdf","Documents":""},{"Case ID":"ST-92","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"India, Mexico, Venezuela","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/07","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$32,625,000.00","Criminal Fine\/Penalty (US$) ":"$32,625,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to aiding and abetting falsification of books and records, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to aiding and abetting falsification of books and records, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to a US Department of Justice Press Release, in \u0022documents filed in U.S. District Court for the Southern District of Texas, Pride International Inc., a Houston-based corporation, and Pride Forasol S.A.S., a wholly owned French subsidiary of Pride International (collectively \u0022Pride\u0022), admitted that Pride paid a total of approximately $800,000 in bribes directly and indirectly to government officials in Venezuela, India and Mexico. According to court documents, the bribes were paid to extend drilling contracts for three rigs operating offshore in Venezuela; to secure a favorable administrative judicial decision relating to a customs dispute for a rig imported into India; and to avoid the payment of customs duties and penalties relating to a rig and equipment operating in Mexico. During the course of the investigation, Pride provided information and substantially assisted in the investigation of Panalpina.  Pride International was charged in a criminal information filed today with conspiring to violate the anti-bribery and books and records provisions of the FCPA; violating the anti-bribery provisions of the FCPA; and violating the books and records provisions of the FCPA. The department and Pride International agreed to resolve the charges by entering into a deferred prosecution agreement. The department also filed a criminal information charging Pride Forasol with conspiring to violate the anti-bribery provisions of the FCPA; violating the anti-bribery provisions of the FCPA; and aiding and abetting the violation of the books and records provisions of the FCPA. Pride Forasol has agreed to plead guilty to the charges. The agreements require the payment of a $32.625 million criminal penalty.\u0022 (Source: US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010.)  According to the Judgment in US v. Pride Forasol S.A.S., Case No. 4:10-cr-771 (S.D. Tex.), filed December 7, 2010, Pride Forsol was ordered to pay $32,625,000 in crimina penalties. ","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. United States v. Pride Forasol S.A.S. Case No. 4:10-cr-771 (S.D.Tex.), Criminal Information filed November 4, 2010, accessed at  www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pride-forasol\/11-04-10pride-forasol-info.pdf; Plea Agreement accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pride-forasol\/12-07-10pride-forasol-plea-agree.pdf; Judgment of December 7, 2010, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pride-forasol\/11-04-10pride-forasol-judgement.pdf.  US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/November\/10-crm-1251.html","Documents":""},{"Case ID":"ST-93","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Venezuela,  India, Mexico","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Aiding and abetting falsification of books and records","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Aiding and abetting falsification of books and records","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to a US Department of Justice Press Release, in \u0022documents filed in U.S. District Court for the Southern District of Texas, Pride International Inc., a Houston-based corporation, and Pride Forasol S.A.S., a wholly owned French subsidiary of Pride International (collectively \u0022Pride\u0022), admitted that Pride paid a total of approximately $800,000 in bribes directly and indirectly to government officials in Venezuela, India and Mexico. According to court documents, the bribes were paid to extend drilling contracts for three rigs operating offshore in Venezuela; to secure a favorable administrative judicial decision relating to a customs dispute for a rig imported into India; and to avoid the payment of customs duties and penalties relating to a rig and equipment operating in Mexico. During the course of the investigation, Pride provided information and substantially assisted in the investigation of Panalpina.  Pride International was charged in a criminal information filed today with conspiring to violate the anti-bribery and books and records provisions of the FCPA; violating the anti-bribery provisions of the FCPA; and violating the books and records provisions of the FCPA. The department and Pride International agreed to resolve the charges by entering into a deferred prosecution agreement. The department also filed a criminal information charging Pride Forasol with conspiring to violate the anti-bribery provisions of the FCPA; violating the anti-bribery provisions of the FCPA; and aiding and abetting the violation of the books and records provisions of the FCPA. Pride Forasol has agreed to plead guilty to the charges. The agreements require the payment of a $32.625 million criminal penalty.\u0022 (Source: US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010.)  According to the Deferred Prosecution Agreement in the case, \u0022Finally, the parties agree that any criminal penalty that might be imposed by the Court on, or otherwise paid by, Pride Forasol in connection with its guilty plea and plea agreement entered into simultaneously herewith will be deducted from the $32,625,000 fine contemplated by this Agreement.\u0022  (US v. Pride International, Inc. Case No. 4:10-cr-00766 (S.D. Tex.), Deferred Prosecution Agreeement, para 9.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Pride International, Inc., Case No. 4:10-cr-766 (S.D. Tex.), Criminal Information filed November 4, Nov 2010, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pride-intl\/11-04-10pride-intl-info.pdf; Deferred Prosecution Agreement, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pride-intl\/11-04-10pride-intl-dpa.pdf.  US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/November\/10-crm-1251.html","Documents":""},{"Case ID":"ST-94","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Venezuela, India, Mexico, Kazakhstan, Saudi Arabia, the Republic of the Congo, and Libya","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$23,529,718.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$19,341,870","Civil Prejudgment Interest (US$) ":"$4,187,848","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission Litigation Release, on November 4, 2010, the Commission \u0022charged one of the world\u0027s largest offshore drilling companies with violating the Foreign Corrupt Practices Act (FCPA) by paying approximately $2 million to foreign officials in eight countries. The SEC\u0027s complaint, filed in federal district court in Houston, alleges that from 2001 through 2006 Pride International, Inc. and its subsidiaries bribed government officials in Venezuela, India, Mexico, Kazakhstan, Nigeria, Saudi Arabia, the Republic of the Congo, and Libya. The bribery schemes allowed Pride and its subsidiaries to extend drilling contracts, obtain the release of drilling rigs and other equipment from customs officials, reduce customs duties, extend the temporary importation status of drilling rigs, lower various tax assessments, and obtain other improper benefits.  [ ]  According to the SEC\u0027s complaint, from 2003 through 2005, Pride\u0027s former Venezuela country manager authorized bribes totaling approximately $384,000 to an official of Venezuela\u0027s state-owned oil company to secure extensions of three drilling contracts. In addition, the country manager authorized a bribe of approximately $30,000 to an employee of Venezuela\u0027s state-owned oil company to secure the payment of receivables. The SEC alleges that in 2003 a French subsidiary of Pride paid three bribes totaling approximately $500,000, believing that the funds would be given to an Indian judge to influence customs litigation relating to the importation of a drilling rig. According to the complaint, a Pride employee in the U.S. had knowledge of the payments at the time they were made.  The complaint alleges that in 2004 a former Pride vice president authorized a $10,000 bribe to a Mexican customs official in return for favorable treatment regarding customs deficiencies identified during an inspection of a supply boat. The SEC\u0027s complaint also alleges that from 2001 through 2006 numerous improper payments made by Pride subsidiaries operating in Mexico, Kazakhstan, Nigeria, Saudi Arabia, the Republic of the Congo, and Libya were not correctly recorded in those subsidiaries\u0027 books and records. As a result, the complaint alleges that Pride failed to make and keep accurate books and records and failed to devise and maintain appropriate internal controls.\u0022 (Source:  US Securities and Exchange Commission, Litigation Release No. 21726 \/ November 4, 2010, SEC v. Pride International, Inc., Civil Action No. 4:10-cv-4335 (S.D. Texas, November 4, 2010), \u0022SEC Charges Pride International with Violating the Foreign Corrupt Practices Act.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Securities and Exchange Commission, Litigation Release No. 21726 \/ November 4, 2010, SEC v. Pride International, Inc., Civil Action No. 4:10-cv-4335 (S.D. Texas, November 4, 2010), \u0022SEC Charges Pride International with Violating the Foreign Corrupt Practices Act,\u0022 accessed at www.sec.gov\/litigation\/litreleases\/2010\/lr21726.htm; Complaint accessed at www.sec.gov\/litigation\/complaints\/2010\/comp21726.pdf.","Documents":""},{"Case ID":"ST-95","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Mexico, Venezuela","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/09","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$40,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$40,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art, 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations, Aiding and abetting Pride\u0027s falsification of books and records, Aiding and abetting of Pride\u0027s internal controls violations, False representation to accountants","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission Litigation Release, on December 11, 2009, the Commission charged Mr. Benton, Pride\u0027s former vice president for the Western Hemisphere Operations, alleging that in December 2004, Benton authorized the bribery of a Mexican customs official in return for favorable treatment regarding customs deficiencies identified during an inspection of a supply boat. The complaint further alleges that Benton had knowledge of a second bribe paid to a different Mexican customs official that same month. It is also alleged that from approximately 2003 to 2005, a manager of a Pride subsidiary in Venezuela authorized the bribery of an official of Venezuela\u0027s state-owned oil company in order to secure extensions of three drilling contracts. Benton, in an effort to conceal these payments, redacted references to bribery in an action plan responding to an internal audit report and signed two false certifications in connection with audits and reviews of Pride\u0027s financial statements denying any knowledge of bribery.\u0022 (Source:  US securities and Exchange Commission, Litigation Release No. 21335 \/ December 14, 2009, SEC v. Bobby Benton, Civil Action No. 4:09-CV-03963 (S.D. Texas, December 11, 2009), \u0022SEC Charges Former Officer of Pride International with Violating the Foreign Corrupt Practices Act,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21335.htm.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Securities and Exchange Commission, Litigation Release No. 21726 \/ November 4, 2010, SEC v. Pride International, Inc., Civil Action No. 4:10-cv-4335 (S.D. Texas, November 4, 2010), \u0022SEC Charges Pride International with Violating the Foreign Corrupt Practices Act,\u0022 accessed at www.sec.gov\/litigation\/litreleases\/2010\/lr21726.htm; US securities and Exchange Commission, Litigation Release No. 21335 \/ December 14, 2009, SEC v. Bobby Benton, Civil Action No. 4:09-CV-03963 (S.D. Texas, December 11, 2009), \u0022SEC Charges Former Officer of Pride International with Violating the Foreign Corrupt Practices Act,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21335.htm; Complaint filed December 11, 2009, accessed at www.sec.gov\/litigation\/complaints\/2009\/comp21335.pdf","Documents":""},{"Case ID":"ST-96","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/09","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$25,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$25,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations, Aiding and Abetting Pride\u0027s bribery of foreign officials, Aiding and Abetting Pride\u0027s falsification of books and records, Aiding and Abetting Pride\u0027s internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission Litigation Release, \u0022On August 5, 2010, the Securities and Exchange Commission charged a former employee of Pride International, Inc. (Pride) with violations relating to bribes paid to foreign officials in Venezuela. The Commission\u0027s complaint names Joe Summers of John Day, Oregon, Pride\u0027s former Venezuela Country Manager.  The complaint alleges that from approximately 2003 to 2005, Summers authorized or allowed payments totaling approximately $384,000 to third-party companies believing that all or a portion of the funds would be given to an official of Venezuela\u0027s state-owned oil company in order to secure extensions of three drilling contracts. The complaint further alleges that Summers authorized the payment of approximately $30,000 to a third party believing that all or a portion of the funds would be given to an employee of Venezuela\u0027s state-owned oil company in order to obtain the payment of receivables.\u0022 (Source: US Securities and Exchange Commission, Litigation Release No. 21617 \/ August 5, 2010, SEC v. Joe Summers, Civil Action No. 4:10-cv-02786 (S.D. Texas, August 5, 2010), \u0022SEC Charges Former Employee of Pride International with Violating the Foreign Corrupt Practices Act.\u0022) ","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Securities and Exchange Commission, Litigation Release No. 21726 \/ November 4, 2010, SEC v. Pride International, Inc., Civil Action No. 4:10-cv-4335 (S.D. Texas, November 4, 2010), \u0022SEC Charges Pride International with Violating the Foreign Corrupt Practices Act,\u0022 accessed at www.sec.gov\/litigation\/litreleases\/2010\/lr21726.htm; US Securities and Exchange Commission, Litigation Release No. 21617 \/ August 5, 2010, SEC v. Joe Summers, Civil Action No. 4:10-cv-02786 (S.D. Texas, August 5, 2010), \u0022SEC Charges Former Employee of Pride International with Violating the Foreign Corrupt Practices Act,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21617.htm; Complaint filed August 5, 2010, accessed at www.sec.gov\/litigation\/complaints\/2010\/comp21617.pdf","Documents":""},{"Case ID":"ST-97","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"[Nigeria - secondary source]","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$18,149,459.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$14,153,536","Civil Prejudgment Interest (US$) ":"$3,995,923","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission Order Instituting Cease and Desist Proceedings, \u0022This matter concerns violations of the anti-bribery provisions of the Foreign Corrupt Practices Act (\u0022FCPA\u0022) by Respondent [Shell Nigeria Exploration and Production Company] and the record keeping and internal controls provisions of the FCPA by Respondent Shell. From September 2002 through November 2005, SIEP [Shell International Exploration and Production, Inc.], on behalf of Shell, authorized the reimbursement or continued use of services provided by a company acting as a customs broker that involved suspicious payments of approximately $3.5 million to officials of the Nigerian Customs Service in order to obtain preferential treatment during the customs process for the purpose of assisting Shell in obtaining or retaining business in Nigeria on Shell\u0027s Bonga Project. As a result of these payments, Shell profited in the amount of approximately $14 million. None of the improper payments was accurately reflected in Shell\u0027s books and records, nor was Shell\u0027s system of internal accounting controls adequate at the time to detect and prevent these suspicious payments.\u0022  (Source:  In Re: Royal Dutch Shell plc and Shell Nigeria Exploration and Production Company, US Securities and Exchange Commission Order Instituting Cease and Desist Proceedings, Administrative Proceeding File No. 3-14107, November 4, 2010, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2010\/34-63243.pdf.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  In Re: Royal Dutch Shell plc and Shell Nigeria Exploration and Production Company, US Securities and Exchange Commission Order Instituting Cease and Desist Proceedings, Administrative Proceeding File No. 3-14107, November 4, 2010, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2010\/34-63243.pdf","Documents":""},{"Case ID":"ST-98","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"[Nigeria - secondary source]","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$30,000,000.00","Criminal Fine\/Penalty (US$) ":"$30,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Aiding and abetting falsification of books and records","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Aiding and abetting falsification of books and records","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Department of Justice Press Release, on November 4, 2010, \u0022A criminal information was also filed today charging SNEPCO, a Nigerian subsidiary of Royal Dutch Shell plc (collectively \u0022Shell\u0022), with conspiring to violate the anti-bribery and books and records provisions of the FCPA, and with aiding and abetting a violation of the books and records provisions. Royal Dutch Shell is the owner of a global group of energy and petrochemicals companies. The charges relate to approximately $2 million SNEPCO paid to its subcontractors with the knowledge that some or all of the money would be paid as bribes to Nigerian customs officials by Panalpina to import materials and equipment into Nigeria. To resolve the matter, the department and Shell have entered into a deferred prosecution agreement that requires, among other things, SNEPCO to pay a $30 million criminal penalty.\u0022  (Source:  US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  United States v. Shell Nigeria Exploration and Production Company Ltd, Case No. 4:10-cr-767 (S.D. Tex.), Information filed November 4, 2010, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/snepco\/11-04-10snepco-info.pdf; Deferred Prosecution Agreement filed November 4, 2010, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/snepco\/11-04-10snepco-dpa.pdf; US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/November\/10-crm-1251.html","Documents":""},{"Case ID":"ST-99","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Azerbaijan, Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$8,321,362.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$7,223,216.00","Civil Prejudgment Interest (US$) ":"$881,146","Civil Fine \/ Penalty (US$)":"$217,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs, Tax)","Summary":"According to the US Securities and Exchange Commission Litigation Release, on November 4, 2010, the Commission \u0022charged New Orleans-based shipping company Tidewater Inc. with violating the Foreign Corrupt Practices Act (FCPA) for paying bribes to foreign government officials in Azerbaijan disguised as payments for legitimate services. Tidewater is also charged with authorizing improper payments to customs officials in Nigeria that were inaccurately recorded as legitimate expenses in the Company\u0027s books and records. The SEC alleges that Tidewater, directly or through its subsidiaries and agents, paid $160,000 in bribes to foreign government officials in Azerbaijan in 2001, 2003 and 2005 in order to influence acts and decisions by Azeri tax officials to resolve local audits in favor of a Tidewater subsidiary. The SEC further alleges that from January 2002 through March 2007, Tidewater, through a subsidiary, reimbursed approximately $1.6 million to its customs broker in Nigeria used to make improper payments to local Nigerian customs officials. These improper payments were made in order to induce the Nigerian officials to disregard regulatory requirements in Nigeria relating to the temporary importation of Tidewater\u0027s vessels into Nigerian waters. Tidewater improperly recorded these payments as legitimate expenses in its books and records.\u0022 (Source:  US Securities and Exchange Commission, Litigation Release No. 21729 \/ November 4, 2010, Securities and Exchange Commission v. Tidewater Inc., Civil Action No. 2:10-CV-04180 (U.S. District Court for the Eastern District of Louisiana).)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21729 \/ November 4, 2010, Securities and Exchange Commission v. Tidewater Inc., Civil Action No. 2:10-cv-04180 (U.S. District Court for the Eastern District of Louisiana), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21729.htm; Complaint filed November 4, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21729.pdf","Documents":""},{"Case ID":"ST-100","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Azerbaijan, Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$7,350,000.00","Criminal Fine\/Penalty (US$) ":"$7,350,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Falsification of books and records","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"No (Customs, Tax)","Summary":"According to the US Department of Justice Press Release, on November 4, 2010, the Department \u0022filed a criminal information charging Tidewater Marine International Inc., a Cayman Island subsidiary of Tidewater Inc. (collectively \u0022Tidewater\u0022), with conspiring to violate the anti-bribery and books and records provisions of the FCPA, and with violating the books and records provisions of the FCPA. Tidewater Inc. is a global operator of offshore service and supply vessels for energy exploration headquartered in New Orleans. The charges filed against Tidewater Marine relate to approximately $160,000 in bribes paid through its employees and agents to tax inspectors in Azerbaijan to improperly secure favorable tax assessments and approximately $1.6 million in bribes paid through Panalpina to Nigerian customs officials to induce the officials to disregard Nigerian customs regulations relating to the importation of vessels into Nigerian waters. To resolve the matter, the department and Tidewater have entered into a deferred prosecution agreement that requires, among other things, Tidewater Marine to pay a $7.35 million criminal penalty.\u0022 (Source:  US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Tidewater Marine International Inc., Case No. 4:10-cr-00770 (S.D. Tex.), Information filed November 4, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tidewater-intl\/11-04-10tidewater-info.pdf; Deferred Prosecution Agreement filed November 4, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tidewater-intl\/11-04-10tidewater-dpa.pdf.  US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/November\/10-crm-1251.html","Documents":""},{"Case ID":"ST-101","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"Nigeria","Jurisdiction of Settlement \/ Enforcement Agency":"Economic and Financial Crimes Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"03\/03","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Unspecified","Total Monetary Sanctions (US$)":"$6,300,000.00","Criminal Fine\/Penalty (US$) ":"$6,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"$300,000 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$6,300,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Improper payments","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to Tidwater Inc.\u0027s March 3, 2011 Form 8-K filed with the US Securities and Exchange Commission, pursuant to a settlement agreement announced that day, Tidewater agreed to settle allegations that the Nigerian affiliate of a Swiss-based freight forwarder had made improper payments to government officials in Nigeria on behalf of Tidewater\u0027s foreign subsidiaries.  The Nigerian investigation revolved around the same 2007 conduct detailed in Tidewater\u0027s settlements with the US Department of Justice and the Securities and Exchange Commission. Tidewater agreed to pay $6 million to the Government of Nigeria and an additional $300,000 for the Government of Nigeria\u0027s attorneys and other expenses. (Source:  Technip Inc., SEC Form 8-K filed March 3, 2011.)  Tidewater\u0027s settlements with the US Department of Justice and the Securities and Exchange Commission are detailed in: US v. Tidewater Marine International, Inc., Case No. 4:10-cr-00770 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts filed November 4, 2010; and US Securities and Exchange Commission, Litigation Release No. 21729 (November 4, 2010), in SEC v. Tidewater, Inc., Case No. 2:10-cv-04180 (E.D. La.), Complaint filed November 4, 2010.   Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.","Sources ":"Tidewater, Inc., US Securities and Exchange Commission Form 8-K filed March 3, 2011, at http:\/\/www.sec.gov\/Archives\/edgar\/data\/98222\/000119312511055141\/d8k.htm; US v. Tidewater Marine International, Inc., Case No. 4:10-cr-00770 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts filed November 4, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tidewater-intl\/11-04-10tidewater-dpa.pdf; US Securities and Exchange Commission, Litigation Release No. 21729 (November 4, 2010), in SEC v. Tidewater, Inc., Case No. 2:10-cv-04180 (E.D. La.), Complaint filed November 4, 2010, both accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21729.htm and http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21729.pdf.","Documents":""},{"Case ID":"ST-102","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$13,440,000.00","Criminal Fine\/Penalty (US$) ":"$13,440,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to falsify books and records, Conspiracy to aiding and abetting falsification of books and records","Offenses - Settled":"Conspiracy to falsify books and records, Conspiracy to aiding and abetting falsification of books and records","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Department of Justice Press Release, \u0022Transocean Inc., a Caymans Island subsidiary of Transocean Ltd. (collectively \u0022Transocean\u0022), was charged today in a criminal information with conspiring to violate the anti-bribery and books and records provisions of the FCPA; violating the anti-bribery provision of the FCPA; and aiding and abetting the violation of the books and records provisions of the FCPA. Transocean Ltd. is a global provider of offshore oil drilling services and equipment based in Vernier, Switzerland. The charges relate to approximately $90,000 in bribes paid by Transocean Inc.\u0027s freight forwarding agents in Nigeria to Nigerian customs officials to circumvent Nigerian customs regulations regarding the import of goods and materials and the import of Transocean\u0027s deep-water oil rigs into Nigerian waters. The department and Transocean have agreed to enter into a deferred prosecution agreement that requires, among other things, Transocean Inc. to pay a $13.44 million criminal penalty.\u0022 (Source: US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Transocean Inc., Case No. 4:10-cr-00768 (S.D. Tex.), Information filed November 4, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/transocean-inc\/11-04-10transocean-info.pdf; Deferred Prosecution Agreement filed November 4, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/transocean-inc\/11-04-10transocean-dpa.pdf.  US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/November\/10-crm-1251.html","Documents":""},{"Case ID":"ST-1","Case Cluster ":"AB Volvo","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"03\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$12,602,649.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$7,299,208","Civil Prejudgment Interest (US$) ":"$1,303,441","Civil Fine \/ Penalty (US$)":"$4,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On March 20, 2008, AB Volvo, a Swedish company, entered into a deferred prosecution agreement with the Department of Justice and a settlement agreement with the SEC in connection with payments made by two of its subsidiaries to obtain contracts administered by the United Nations Oil for Food Program (OFFP). The subsidiaries, Renault Trucks SAS (Renault Trucks) and Volvo Construction Equipment AB (VCE), were charged in separate conspiracies to commit wire fraud and violate the books and records provision of the FCPA.According to the court documents, between November 2000 and April 2003, employees and agents of Renault Trucks paid a total of approximately $5 million in kickbacks to the Iraqi government for a total of approximately $61 million worth of contracts with various Iraqi ministries. To pay the kickbacks, Renault Trucks inflated the price of contracts by approximately 10 percent before submitting them to the U.N. for approval and concealed from the U.N. the fact that the contract prices contained a kickback to the Iraqi government. In some cases, Renault Trucks paid inflated prices to companies that outfitted the chassis and cabs produced by Renault Trucks. Those companies then used the excess funds to pay the kickbacks to the Iraqi government on behalf of Renault Trucks.  Between December 2000 and January 2003, Volvo Construction Equipment International AB (VCEI), the predecessor to VCE, and its distributors were awarded a total of approximately $13.8 million worth of contracts. During the same time period, employees, agents and distributors of VCEI paid a total of approximately $1.3 million in kickbacks to the Iraqi government by inflating the price of contracts by approximately 10 percent before submitting them to the U.N. for approval. Similar to Renault Trucks, VCE concealed from the U.N. the fact that the contract prices contained a kickback to the Iraqi government.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, AB Volvo Case Summary at 82-83.)   AB Volvo\u0027s settlement agreement with the US SEC is summarized in the SEC Litigation Release No. 20504 \/ March 20, 2008. ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, AB Volvo Case Summary at 82-83, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 20504 \/ March 20, 2008, Securities \u0026 Exchange Commission v. AB Volvo, Civil Action No. 08 CV 00473 (D.D.C.) (JB), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against AB Volvo For Improper Payments to Iraq Under the U.N. Oil for Food Program -- Company Agrees to Pay Over $12.6 Million in Civil Penalties, Disgorgement of Profits, and Interest,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20504.htm; SEC Complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20504.pdf.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/AB%20Volvo_SEC_Litigation_Release_Mar_20_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/AB_Volvo_SEC_Complaint_Mar_20_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/AB_Volvo_Settlement_DOJ_PR_Mar_8_2008_1.pdf"},{"Case ID":"ST-2","Case Cluster ":"AB Volvo","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"03\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$7,000,000.00","Criminal Fine\/Penalty (US$) ":"$7,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud","Offenses - Settled":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On March 20, 2008, AB Volvo, a Swedish company, entered into a deferred prosecution agreement with the Department of Justice and a settlement agreement with the SEC in connection with payments made by two of its subsidiaries to obtain contracts administered by the United Nations Oil for Food Program (OFFP). The subsidiaries, Renault Trucks SAS (Renault Trucks) and Volvo Construction Equipment AB (VCE), were charged in separate conspiracies to commit wire fraud and violate the books and records provision of the FCPA.  According to the court documents, between November 2000 and April 2003, employees and agents of Renault Trucks paid a total of approximately $5 million in kickbacks to the Iraqi government for a total of approximately $61 million worth of contracts with various Iraqi ministries. To pay the kickbacks, Renault Trucks inflated the price of contracts by approximately 10 percent before submitting them to the U.N. for approval and concealed from the U.N. the fact that the contract prices contained a kickback to the Iraqi government. In some cases, Renault Trucks paid inflated prices to companies that outfitted the chassis and cabs produced by Renault Trucks. Those companies then used the excess funds to pay the kickbacks to the Iraqi government on behalf of Renault Trucks.Between December 2000 and January 2003, Volvo Construction Equipment International AB (VCEI), the predecessor to VCE, and its distributors were awarded a total of approximately $13.8 million worth of contracts. During the same time period, employees, agents and distributors of VCEI paid a total of approximately $1.3 million in kickbacks to the Iraqi government by inflating the price of contracts by approximately 10 percent before submitting them to the U.N. for approval. Similar to Renault Trucks, VCE concealed from the U.N. the fact that the contract prices contained a kickback to the Iraqi government.  Criminal Case Disposition:  To resolve its criminal liability in connection with this bribery scheme, AB Volvo, on behalf of itself and its subsidiaries, entered into a three-year deferred prosecution agreement with the Department, whereby AB Volvo agreed to pay a criminal fine of $7 million.\u0022 (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, AB Volvo Case Summary at 82-83.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, AB Volvo Case Summary at 82-83, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Volvo Construction Equipment, AB, Case No. 08-CR-069-RJL (D.D.C.), Information filed on March 20, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/volvo-ab\/03-20-08volvo-info.pdf;  US v. Renault Trucks SAS, Case No. 08-CR-068-RJL (D.D.C.), Information filed on March 20, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/renault-trucks\/03-20-08renault-trucks-info.pdf;  In Re: AB Volvo et al, US Department of Justice, Deferred Prosecution Agreement and Statement of Facts, filed March 20, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/volvo-ab\/03-18-08volvo-dpa.pdf.  US Department of Justice Press Release, \u0022AB Volvo to Pay $7 Million Penalty for Kickback Payments to the Iraqi Government under the U.N. Oil for Food Program,\u0022 March 20, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/March\/08_crm_220.html. ","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/AB_Volvo_Deferred_Prosecution_Agreement_Mar_18_2008_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/AB_Volvo_Renault_Trucks_Information_March_20_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/AB_Volvo_Settlement_DOJ_PR_Mar_8_2008_0.pdf"},{"Case ID":"ST-3","Case Cluster ":"ABB Ltd. (Matter #15)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico, Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"09\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, in 2005 ABB Ltd. self-reported to the US authorities that its Texan subsidiary ABB Inc. (which did business as ABB Network Management) may have made corrupt payments to public officials in Mexico to obtain contracts with the Comision Federal de Electricidad, a Mexican state-owned utility company.  The bribe payments were allegedly funnelled through a Mexican company that ABB NM hired, as well as through a company controlled by its representatives.  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39.)  According to the Plea Agreement, the Department of Justice recommended as part of the sentence, \u0022Fine. Assuming ABB Inc. accepts responsibility as explained above, the parties will recommend the imposition of a fine in the amount of $28,500,000 payable to the Clerk of the Court for the United States District Court for the Southern District of Texas.\u0022 (Source: US v. ABB Inc., Case No. 4:10-cr-00664 (S.D. Tex.), Plea Agreement filed September 29, 2010, para 10.)  According to the Judgement in the case, ABB Inc. was fined $17,100,000. (Source: US v. ABB Inc., Case No. 4:10-cr-00664 (S.D. Tex.), Judgment in a Criminal Case, filed October 1, 2010.)   According to the Deferred Prosecution Agreement in US v. ABB Ltd. (Parent company), \u0022ABB Ltd agrees to pay a total monetary penalty in the amount of $30,420,000, or the bottom of the applicable combined Sentencing Guidelines fine range for ABB Inc. and ABB Ltd - Jordan. ABB Ltd will pay $28,500,000 on behalf of ABB Inc. in connection with ABB Inc.\u0027s guilty plea and $1,920,000 on behalf of ABB Ltd - Jordan.\u0022  (US v. ABB Ltd., Case No. 4_10-cr-00665 (S.D. Tex.), Deferred Prosecution Agreement filed September 29, 2010.)  The US Department of Justice press release stated that ABB Ltd. resolved the cases involving its two subsidiaries by agreeing to pay $19 million in fines. (Source: US Department of Justice Press Release, \u0022ABB Ltd and Two Subsidiaries Resolve Foreign Corrupt Practices Act Investigation and Will Pay $19 Million in Criminal Penalties,\u0022 September 29, 2010.)  Please note that the settlement amounts in this entry are $0 as the amounts have been recorded in the appropriate entries for the subsidiaries.","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. ABB Inc., Case No. 4:10-cr-00664 (S.D. Tex.), Plea Agreement and Statement of Facts filed September 29, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/09-29-10abbinc-plea.pdf; US v. ABB Ltd., Case No. 4:10-cr-00665 (S.D. Tex.), Deferred Prosecution Agreement filed September 29, 2010, accessed at www.fcpa.shearman.com;  US Department of Justice Press Release, \u0022ABB Ltd and Two Subsidiaries Resolve Foreign Corrupt Practices Act Investigation and Will Pay $19 Million in Criminal Penalties,\u0022 September 29, 2010.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Ltd_Deferred_Prosecution_Agreement_Sep_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Settlement_DOJ_PR_Sep_29_2010.pdf"},{"Case ID":"ST-4","Case Cluster ":"ABB Ltd. (Matter #15)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Mexico, Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"09\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$39,314,262.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$17,141,474","Civil Prejudgment Interest (US$) ":"$5,662,788","Civil Fine \/ Penalty (US$)":"$16,510,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Books and records violations, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Litigation Release by the Securities and Exchange Commission, \u0022The SEC alleges that ABB, through its subsidiaries, paid bribes to government officials in Mexico to obtain business with government owned power companies, and paid kickbacks to the former regime in Iraq to obtain contracts under the United Nations Oil for Food Program. As alleged in the complaint, ABB\u0027s subsidiaries made at least $2.7 million in illicit payments in these schemes to obtain contracts that generated more than $100 million in revenues for ABB.  In the Mexican bribery scheme, the SEC alleges that from 1999 through 2004, ABB Network Management (\u0022ABB NM\u0022), a business unit within ABB\u0027s U.S. subsidiary, ABB, Inc., bribed officials in Mexico to obtain and retain business with two government owned electric utilities, Comision Federal de Electricidad (\u0022CFE\u0022) and Luz y Fuerza del Centro (\u0022LyFZ\u0022). [  ]  The SEC further alleges that from approximately 2000 to 2004 ABB participated in the United Nations Oil for Food Program (the \u0022Program\u0022). [  ]  According to the complaint, ABB participated in the Program through six subsidiaries: ABB Near East Trading Ltd. (\u0022ABB Jordan\u0022), ABB Automation, ABB Industrie AC Machines and ABB Solyvent-Ventec (collectively referred to as \u0022ABB France\u0022), ABB AG (\u0022ABB Austria\u0022), and ABB Elektrik Sanayi AS (\u0022ABB Turkey\u0022). The SEC alleges that these subsidiaries developed various schemes to pay secret kickbacks to Iraq to obtain contracts under the Program. ABB\u0027s Jordanian subsidiary acted as a conduit for other ABB subsidiaries by making the kickback payments on their behalf. Some of the kickbacks were made in the form of bank guarantees and cash payments. ABB improperly recorded the kickbacks on its books as legitimate payments for after sales services, consultation costs, and commissions.\u0022 (Source:  US Securities \u0026 Exchange Commission, Litigation Release No. 21673 \/ September 29, 2010, U.S. Securities and Exchange Commission v. ABB Ltd, Civil Action No. 1:10-CV-01648 (DDC) (PLF), \u0022SEC Charges ABB for Bribery Schemes in Mexico and Iraq - ABB to Pay $39 Million in Disgorgement and Civil Penalties.\u0022)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Securities \u0026 Exchange Commission, Litigation Release No. 21673 \/ September 29, 2010, U.S. Securities and Exchange Commission v. ABB Ltd, Civil Action No. 1:10-CV-01648 (DDC) (PLF), \u0022SEC Charges ABB for Bribery Schemes in Mexico and Iraq - ABB to Pay $39 Million in Disgorgement and Civil Penalties,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21673.htm; US v. ABB Ltd., Case No. 1:10-cv-01648-PLF (D.D.C.), Complaint filed on September 29, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp-pr2010-175.pdf","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_SEC_Litigation_Release_Sep_29_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_SEC_Complaint_Sep_29_2010.pdf"},{"Case ID":"ST-5","Case Cluster ":"ABB Ltd. (Matter #15)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico, Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"09\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$17,100,000.00","Criminal Fine\/Penalty (US$) ":"$17,100,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, in 2005 ABB Ltd. self-reported to the US authorities that its Texan subsidiary ABB Inc. (which did business as ABB Network Management) may have made corrupt payment sto public officials in Mexico to obtain contracts with the Comision Federal de Electricidad, a Mexican state-owned utility company.  The bribe payments were allegedly funnelled through a Mexican company that ABB NM hired, as well as through a company controlled by its representatives.  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39.)  According to the Plea Agreement, the Department of Justice recommended as part of the sentence, \u0022Fine. Assuming ABB Inc. accepts responsibility as explained above, the parties will recommend the imposition of a fine in the amount of $28,500,000 payable to the Clerk of the Court for the United States District Court for the Southern District of Texas.\u0022 (Source: US v. ABB Inc., Case No. 4:10-cr-00664 (S.D. Tex.), Plea Agreement filed September 29, 2010, para 10.)  According to the Judgement in the case, ABB Inc. was fined $17,100,000. (Source: US v. ABB Inc., Case No. 4:10-cr-00664 (S.D. Tex.), Judgment in a Criminal Case, filed October 1, 2010.)   According to the Deferred Prosecution Agreement in US v. ABB Ltd. (Parent company), \u0022ABB Ltd agrees to pay a total monetary penalty in the amount of $30,420,000, or the bottom of the applicable combined Sentencing Guidelines fine range for ABB Inc. and ABB Ltd - Jordan. ABB Ltd will pay $28,500,000 on behalf of ABB Inc. in connection with ABB Inc.\u0027s guilty plea and $1,920,000 on behalf of ABB Ltd - Jordan.\u0022  (US v. ABB Ltd., Case No. 4_10-cr-00665 (S.D. Tex.), Deferred Prosecution Agreement filed September 29, 2010.)  The US Department of Justice press release stated that ABB Ltd. resolved the cases involving its two subsidiaries by agreeing to pay $19 million in fines. (Source: US Department of Justice Press Release, \u0022ABB Ltd and Two Subsidiaries Resolve Foreign Corrupt Practices Act Investigation and Will Pay $19 Million in Criminal Penalties,\u0022 September 29, 2010.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. ABB Inc., Case No. 4:10-cr-00664 (S.D. Tex.), Plea Agreement and Statement of Facts filed September 29, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/09-29-10abbinc-plea.pdf; US v. ABB Ltd., Case No. 4_10-cr-00665 (S.D. Tex.), Deferred Prosecution Agreement filed September 29, 2010, accessed at www.fcpa.shearman.com;  US Department of Justice Press Release, \u0022ABB Ltd and Two Subsidiaries Resolve Foreign Corrupt Practices Act Investigation and Will Pay $19 Million in Criminal Penalties,\u0022 September 29, 2010.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Ltd_Deferred_Prosecution_Agreement_Sep_2010_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_US_Settlement_DOJ_PR_Sept_29_2010.pdf"},{"Case ID":"ST-6","Case Cluster ":"ABB Ltd. (Matter #15)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"09\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,920,000.00","Criminal Fine\/Penalty (US$) ":"$1,920,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud, Money laundering","Offenses - Settled":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud, Money laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On September 29, 2010, the Department also charged ABB Ltd\u0027s Jordanian subsidiary, ABB Ltd - Jordan, with one count of conspiracy to commit wire fraud and to violate the books and records provisions of the FCPA. According to court documents, from 2000 to 2004, ABB Ltd - Jordan and other ABB subsidiaries paid, or caused to be paid, more than $800,000 in kickbacks to the former Iraqi government to secure 27 contracts under the U.N. Oil-for-Food Program (OFFP). For example, from 2001 to 2002, ABB Ltd - Jordan paid more than $300,000 in kickbacks to three regional companies of the Iraqi Electricity Commission, an Iraqi government agency, in order to secure 11 purchase orders worth more than $5.9 million. All together, ABB subsidiaries allegedly earned more than $13,500,000 in revenue and $3,800,000 in profits from contracts obtained through illegal kickbacks under the OFFP.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US v. ABB Ltd., Case No. 4:10-cr-00665 (S.D. Tex.), Criminal Information filed September 29, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/09-29-10abbjordan-info.pdf; Deferred Prosecution Agreement (in US v. ABB Ltd. which pertains to ABB Ltd. - Jordan), filed September 29, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/09-29-10abbjordan-dpa.pdf; US Department of Justice Press Release, \u0022ABB Ltd and Two Subsidiaries Resolve Foreign Corrupt Practices Act Investigation and Will Pay $19 Million in Criminal Penalties,\u0022 September 29, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/September\/10-crm-1096.html.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Jordan_Information_Sep_29_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Ltd_Deferred_Prosecution_Agreement_Sep_2010_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_US_Settlement_DOJ_PR_Sept_29_2010_0.pdf"},{"Case ID":"ST-7","Case Cluster ":"ABB Ltd. (Matter #15)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Mexico, Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits","Total Monetary Sanctions (US$)":"$234,357.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$234,357","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Books and records violations, Internal controls violations, Aiding and abetting ABB\u0027s falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Litigation Release by the US Securities and Exchange Commission, \u0022As alleged in the complaint, Hozhabri was a project manager for ABB Network Management (\u0022ABB NM\u0022), a division of a U.S. based ABB subsidiary, which provides products and services for managing power generation and transmission networks. The Commission alleges that, from 2002 through 2004, Hozhabri fraudulently submitted approximately $468,714 in cash and check disbursement requests to ABB NM for purported business expenses associated with projects in Brazil, Paraguay, and the United Arab Emirates. As alleged in the complaint, these purported expenses were phony, and inaccurately recorded as legitimate business expenses in ABB\u0027s books and records. The Commission further alleges that the funds disbursed by ABB NM as a result of these requests were not used to pay any business expenses, but rather were embezzled by Hozhabri and the former General Manager of ABB NM. According to the complaint, Hozhabri personally kept $234,357 of the embezzled funds.\u0022  (Source: US Securities and Exchange Commission, Litigation Release No. 20671 \/ August 6, 2008, SEC v. Ali Hozhabri, Civil Action No. 08 CV 1359 (D.D.C.), \u0022SEC Charges Former ABB Project Manager for Falsifying Company\u0027s Books and Records.\u0022)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Securities and Exchange Commission, Litigation Release No. 20671 \/ August 6, 2008, SEC v. Ali Hozhabri, Civil Action No. 08 CV 1359 (D.D.C.), \u0022SEC Charges Former ABB Project Manager for Falsifying Company\u0027s Books and Records,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20671.htm and Complaint filed August 6, 2008, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20671.pdf.  ABB Ltd. Case Documents: US Securities \u0026 Exchange Commission, Litigation Release No. 21673 \/ September 29, 2010, U.S. Securities and Exchange Commission v. ABB Ltd, Civil Action No. 1:10-CV-01648 (DDC) (PLF), \u0022SEC Charges ABB for Bribery Schemes in Mexico and Iraq - ABB to Pay $39 Million in Disgorgement and Civil Penalties,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21673.htm; US v. ABB Ltd., Case No. 1:10-cv-01648-PLF (D.D.C.), Complaint filed on September 29, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp-pr2010-175.pdf","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Hozhabri_SEC_Complaint_Aug_6_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Ali_Hozhabri_SEC_Litigation_Release_Aug_6_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Settlement_DOJ_PR_Sep_29_2010_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_SEC_Litigation_Release_Sep_29_2010_0.pdf"},{"Case ID":"ST-8","Case Cluster ":"ABB Ltd. (Matter #15)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"11\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$2,030,076.74","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$2,030,076.74 ","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to commit currency transfer structuring, Conspiracy to commit international money laundering, Conspiracy to falsify records in a federal investigation, Bribery of foreign officials, Currency transaction structuring","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to commit money laundering, Falsification of records in a federal investigation","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, in 2005 ABB Ltd. self-reported to the US authorities that its Texan subsidiary ABB Inc. (which did business as ABB Network Management) may have made corrupt payments to public officials in Mexico to obtain contracts with the Comision Federal de Electricidad, a Mexian state-owned utility company.  The bribe payments were allegedly funnelled through a Mexican company that ABB NM hired, as well as through a company controlled by its representatives.  Mr. Basurto was an agent\/intermediary; he pleaded guilty to charged offenses on November 16, 2009. (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39.)  According to his plea agreement, Mr. Basurto \u0022agrees to forfeit to the United States in the form of a money judgment against him, voluntarily and immediately, all of his right, title and interest to all assets, and\/or their substitutes, which are subject to forfeiture pursuant to Title 18, United States Code, Section 981(a)(1)(C), Title 21 United States Code, Section 853, and Title 28, United States Code, Section 2461 as follows: the sum of $2,030,076.74. The defendant\u0027s forfeiture obligation shall be joint and several with that of his co-conspirators.\u0022  (Source: US v. Basurto, Case No. 4:09-cr-325 (S.D. Tex.), Plea Agreement filed November 23, 2009, para 10.)  On April 11, 2012, the $2,030,076.74 was forfeited to the United States.  (Source: US v. Basurto, Case No. 4_09-cr-325 (S.D. Tex.), Order of Forfeiture filed April 11, 2012 and Judgment in a Criminal Case filed April 5, 2012.)  The US Department of Justice Press Release acknowledged the assistance of the \u0022Federal Republic of Germany for supplying evidence in connection with this investigation.\u0022 (Source: US Department of Justice Press Release, \u0022Former General Manager of Texas Business Arrested for Role in Alleged Scheme to Bribe Officials at Mexican State-Owned Electrical Utility \/ Mexican Intermediary Pleads Guilty for His Role in Foreign Bribery Scheme,\u0022 November 23, 2009.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Basurto, Case No. 4:09-cr-325 (S.D. Tex.), Superseding Information filed November 23, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/basurto\/11-16-09basurto-supersed-info.pdf; Plea Agreement filed November 23, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/basurto\/11-23-09basurto-plea-agree.pdf and Order of Forfeiture filed April 11, 2012 and Judgment in a Criminal Case filed April 5, 2012, both accessed via PACER; US Department of Justice Press Release, \u0022Former General Manager of Texas Business Arrested for Role in Alleged Scheme to Bribe Officials at Mexican State-Owned Electrical Utility \/ Mexican Intermediary Pleads Guilty for His Role in Foreign Bribery Scheme,\u0022 November 23, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/November\/09-crm-1265.html.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Basurto_Plea_Agreement_Nov_23_2009.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Basurto_Plea_DOJ_PR_Nov_23_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Basurto_Judgment_Apr_5_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Basurto_Forfeiture_Order_Apr_11_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Basurto_Supeseding_Information_Nov_16_2009.pdf"},{"Case ID":"ST-9","Case Cluster ":"ABB Ltd. (Matter #76)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Kazakhstan, Angola","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"07\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Pofits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$5,915,405.64","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$5,501,157","Civil Prejudgment Interest (US$) ":"$414,248.64","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Books and records violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, \u0022On July 6, 2004, the Securities and Exchange Commission filed a settled enforcement action in the United States District Court for the District of Columbia charging ABB Ltd, a global provider of power and automation technologies headquartered in Zurich, Switzerland, with violating the anti-bribery, books-and-records, and internal-accounting-controls provisions of the Foreign Corrupt Practices Act (FCPA). Simultaneously with the filing of the complaint, and without admitting or denying its allegations, ABB consented to the entry of a final judgment enjoining it from future FCPA violations, and requiring it (i) to pay $5.9 million in disgorgement and prejudgment interest, (ii) to pay a $10.5 million penalty, which would be deemed satisfied by two of its affiliates\u0027 payments of criminal fines totaling the same amount in parallel criminal proceedings brought by the Department of Justice; and (iii) to retain an independent consultant to review the company\u0027s FCPA compliance policies and procedures.  In its complaint, the Commission charged that, from 1998 through early 2003, ABB\u0027s U.S. and foreign-based subsidiaries doing business in Nigeria, Angola and Kazakhstan, offered and made illicit payments totaling over $1.1 million to government officials in these countries. According to the complaint, all of the payments were made to influence acts and decisions by the foreign officials receiving the payments, in order to assist ABB\u0027s subsidiaries in obtaining and retaining business.\u0022 (Source: US Securities and Exchange Commission, Litigation Release No. 18775 \/ July 6, 2004, \u0022SEC SUES ABB LTD IN FOREIGN BRIBERY CASE \/ ABB SETTLES FEDERAL COURT ACTION AND AGREES TO DISGORGE $5.9 MILLION IN ILLICIT PROFITS \/ TWO ABB AFFILIATES ALSO PLEAD GUILTY AND AGREE TO PAY $10.5 MILLION IN FINES IN CRIMINAL CASE BROUGHT BY THE DEPARTMENT OF JUSTICE,\u0022 Securities and Exchange Commission v. ABB Ltd, Case No. 1:04-cv-1141 [RBW] (U.S.D.C., D.D.C.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  U.S. Securities and Exchange Commission, Litigation Release No. 18775 \/ July 6, 2004, \u0022SEC SUES ABB LTD IN FOREIGN BRIBERY CASE \/ ABB SETTLES FEDERAL COURT ACTION AND AGREES TO DISGORGE $5.9 MILLION IN ILLICIT PROFITS \/ TWO ABB AFFILIATES ALSO PLEAD GUILTY AND AGREE TO PAY $10.5 MILLION IN FINES IN CRIMINAL CASE BROUGHT BY THE DEPARTMENT OF JUSTICE,\u0022 Securities and Exchange Commission v. ABB Ltd, Case No. 1:04-cv-1141 [RBW] (U.S.D.C., D.D.C.), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr18775.htm; Final Judgment accessed at http:\/\/fcpa.shearman.com\/files\/83d\/83df1e6aaa984cd891ff6c8fadd5b441.pdf?i=d05688136f3cad2123104221e06a2b26.","Documents":""},{"Case ID":"ST-10","Case Cluster ":"ABB Ltd. (Matter #76)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"07\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$5,250,000.00","Criminal Fine\/Penalty (US$) ":"$5,250,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022The criminal information charges that the two companies [Vetco Gray, Inc. and Vetco Gray UK Ltd.] paid bribes to officials of NAPIMS, a Nigerian government agency that evaluates and approves potential bidders for contract work on oil exploration projects in Nigeria, including bidders seeking subcontracts with foreign oil and gas companies. According to the stipulated statement of facts, the companies paid more than $1 million in exchange for obtaining confidential bid information and favorable recommendations from Nigerian government agencies in connection with seven oil and gas construction contracts in Nigeria from which the companies expected to realize profits of almost $12 million.\u0022  The companies entered guilty pleas and agreed to each pay $5.25 million in criminal fines. (Source:  US Department of Justice Press Release, \u0022ABB Vetco Gray, Inc. and ABB Vetco Gray UK Ltd. Plead Guilty to Foreign Bribery Charges,\u0022 July 6, 2004.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. ABB Vetco Gray, Inc. and ABB Vetco Gray UK Ltd., Case No. 04-cr-279 (S.D. Tex.), Information filed on June 22, 2004, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/06-22-04abbvetco-info.pdf;  Vetco Gray, Inc. Plea Agreement (July 6, 2004), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/07-06-04abbvetco-plea.pdf; Vetco Gray UK Ltd. Plea Agreement (July 6, 2004), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/07-06-04abbvetco-plea-uk.pdf; US Department of Justice Press Release, \u0022ABB VETCO GRAY, INC. AND ABB VETCO GRAY UK LTD. PLEAD GUILTY TO FOREIGN BRIBERY CHARGES,\u0022  July 6, 2004, accessed at http:\/\/www.justice.gov\/opa\/pr\/2004\/July\/04_crm_465.htm","Documents":""},{"Case ID":"ST-11","Case Cluster ":"ABB Ltd. (Matter #76)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"07\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$5,250,000.00","Criminal Fine\/Penalty (US$) ":"$5,250,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022The criminal information charges that the two companies [Vetco Gray, Inc. and Vetco Gray UK Ltd.] paid bribes to officials of NAPIMS, a Nigerian government agency that evaluates and approves potential bidders for contract work on oil exploration projects in Nigeria, including bidders seeking subcontracts with foreign oil and gas companies. According to the stipulated statement of facts, the companies paid more than $1 million in exchange for obtaining confidential bid information and favorable recommendations from Nigerian government agencies in connection with seven oil and gas construction contracts in Nigeria from which the companies expected to realize profits of almost $12 million.\u0022  The companies entered guilty pleas and agreed to each pay $5.25 million in criminal fines. (Source:  US Department of Justice Press Release, \u0022ABB Vetco Gray, Inc. and ABB Vetco Gray UK Ltd. Plead Guilty to Foreign Bribery Charges,\u0022 July 6, 2004.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. ABB Vetco Gray, Inc. and ABB Vetco Gray UK Ltd., Case No. 04-cr-279 (S.D. Tex.), Information filed on June 22, 2004, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/06-22-04abbvetco-info.pdf;  Vetco Gray, Inc. Plea Agreement (July 6, 2004), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/07-06-04abbvetco-plea.pdf; Vetco Gray UK Ltd. Plea Agreement (July 6, 2004), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/07-06-04abbvetco-plea-uk.pdf; US Department of Justice Press Release, \u0022ABB VETCO GRAY, INC. AND ABB VETCO GRAY UK LTD. PLEAD GUILTY TO FOREIGN BRIBERY CHARGES,\u0022  July 6, 2004, accessed at http:\/\/www.justice.gov\/opa\/pr\/2004\/July\/04_crm_465.htm","Documents":""},{"Case ID":"ST-12","Case Cluster ":"ABB Ltd. (Matter #76)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"07\/05","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$40,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0.00","Civil Fine \/ Penalty (US$)":"$40,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, False accounting violations, Aiding and abetting ABB\u0027s internal controls violations, Aiding and abetting ABB\u0027s falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, regarding the ABB Ltd. case, \u0022In a related case, on July 5, 2006, the Commission filed a settled civil complaint charging four former employees of ABB Ltd. subsidiaries with violating the anti-bribery provisions of the FCPA. The Commission\u0027s complaint alleged that the four former employees -- John Samson, a former regional sales manager for West Africa, John G. A. Munro, a former senior vice president of operations, Ian N. Campbell, a former vice president of finance, and John H. Whelan, a former vice president of sales -- participated in a scheme to offer, approve, and\/or pay bribes to Nigerian government officials in furtherance of ABB\u0027s bid to obtain a $180 million contract to provide equipment for an oil drilling project in Nigeria\u0027s offshore Bonga Oil Field. [  ] On July 5, 2006, Without admitting or denying the allegations in the complaint, Samson, Munro, Campbell, and Whelan consented to the entry of final judgments that: (1) permanently enjoined each of them from future violations of the FCPA; (2) ordered each to pay a civil monetary penalty ($50,000 as to Samson, and $40,000 each as to Munro, Campbell and Whelan); and (3) ordered Samson to pay $64,675 in disgorgement and prejudgment interest.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-13","Case Cluster ":"ABB Ltd. (Matter #76)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"07\/05","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$40,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0.00","Civil Fine \/ Penalty (US$)":"$40,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, False accounting violations, Aiding and abetting ABB\u0027s internal controls violations, Aiding and abetting ABB\u0027s falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, regarding the ABB Ltd. case, \u0022In a related case, on July 5, 2006, the Commission filed a settled civil complaint charging four former employees of ABB Ltd. subsidiaries with violating the anti-bribery provisions of the FCPA. The Commission\u0027s complaint alleged that the four former employees -- John Samson, a former regional sales manager for West Africa, John G. A. Munro, a former senior vice president of operations, Ian N. Campbell, a former vice president of finance, and John H. Whelan, a former vice president of sales -- participated in a scheme to offer, approve, and\/or pay bribes to Nigerian government officials in furtherance of ABB\u0027s bid to obtain a $180 million contract to provide equipment for an oil drilling project in Nigeria\u0027s offshore Bonga Oil Field. [  ] On July 5, 2006, Without admitting or denying the allegations in the complaint, Samson, Munro, Campbell, and Whelan consented to the entry of final judgments that: (1) permanently enjoined each of them from future violations of the FCPA; (2) ordered each to pay a civil monetary penalty ($50,000 as to Samson, and $40,000 each as to Munro, Campbell and Whelan); and (3) ordered Samson to pay $64,675 in disgorgement and prejudgment interest.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-14","Case Cluster ":"ABB Ltd. (Matter #76)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"07\/05","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$40,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0.00","Civil Fine \/ Penalty (US$)":"$40,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, False accounting violations, Aiding and abetting ABB\u0027s internal controls violations, Aiding and abetting ABB\u0027s falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, regarding the ABB Ltd. case, \u0022In a related case, on July 5, 2006, the Commission filed a settled civil complaint charging four former employees of ABB Ltd. subsidiaries with violating the anti-bribery provisions of the FCPA. The Commission\u0027s complaint alleged that the four former employees -- John Samson, a former regional sales manager for West Africa, John G. A. Munro, a former senior vice president of operations, Ian N. Campbell, a former vice president of finance, and John H. Whelan, a former vice president of sales -- participated in a scheme to offer, approve, and\/or pay bribes to Nigerian government officials in furtherance of ABB?s bid to obtain a $180 million contract to provide equipment for an oil drilling project in Nigeria\u0027s offshore Bonga Oil Field. [  ] On July 5, 2006, Without admitting or denying the allegations in the complaint, Samson, Munro, Campbell, and Whelan consented to the entry of final judgments that: (1) permanently enjoined each of them from future violations of the FCPA; (2) ordered each to pay a civil monetary penalty ($50,000 as to Samson, and $40,000 each as to Munro, Campbell and Whelan); and (3) ordered Samson to pay $64,675 in disgorgement and prejudgment interest.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-15","Case Cluster ":"ABB Ltd. (Matter #76)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"07\/05","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$114,675.72","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$50,000","Civil Prejudgment Interest (US$) ":"$14,675.72","Civil Fine \/ Penalty (US$)":"$50,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, False accounting violations, Aiding and abetting ABB\u0027s internal controls violations, Aiding and abetting ABB\u0027s falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, regarding the ABB Ltd. case, \u0022In a related case, on July 5, 2006, the Commission filed a settled civil complaint charging four former employees of ABB Ltd. subsidiaries with violating the anti-bribery provisions of the FCPA. The Commission\u0027s complaint alleged that the four former employees -- John Samson, a former regional sales manager for West Africa, John G. A. Munro, a former senior vice president of operations, Ian N. Campbell, a former vice president of finance, and John H. Whelan, a former vice president of sales -- participated in a scheme to offer, approve, and\/or pay bribes to Nigerian government officials in furtherance of ABB?s bid to obtain a $180 million contract to provide equipment for an oil drilling project in Nigeria\u0027s offshore Bonga Oil Field. [  ] On July 5, 2006, without admitting or denying the allegations in the complaint, Samson, Munro, Campbell, and Whelan consented to the entry of final judgments that: (1) permanently enjoined each of them from future violations of the FCPA; (2) ordered each to pay a civil monetary penalty ($50,000 as to Samson, and $40,000 each as to Munro, Campbell and Whelan); and (3) ordered Samson to pay $64,675 in disgorgement and prejudgment interest.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-16","Case Cluster ":"AGA Medical Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"06\/03","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,000,000.00","Criminal Fine\/Penalty (US$) ":"$2,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials, bribery of foreign officials ","Offenses - Settled":"Conspiracy to bribe foreign officials; bribery of foreign officials ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release (June 3, 2008), there is no mention of an enforcement action by the Securities and Exchange Commission. (Source: US Department of Justice Press Release, \u0022AGA Medical Corporation Agrees to Pay $2 Million Penalty and Enter Deferred Prosecution Agreement for FCPA Violations,\u0022 June 3, 2008.).   The June 30, 2008 Deferrred Prosecution Agreement  outlines terms of the agreement, including: continued cooperation in investigations by DOJ and other domestic and foreign law enforcement authorities (para 5); Requirement on company not to withhold from DOJ any information, document, records, facilities and\/or employees on the basis of attorney-client privilege or work product claim (para 5.c); Company consent to DOJ disclosures to other (domestic and foreign) governmental authorities; and Agreement does not cover past or future misconduct.  (Source: US v. AGA Medical Corporation, Case no. 08-cr-00172 (D.C. Minn, 2008), Deferred Prosecution Agreement filed June 3, 2008.). According to DOJ Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Location and Time Period of Misconduct is China, 1997-2005, specifically corrupt payments by AGA, a high-ranking officer of AGA and other AGA employees to doctors in China who were employed at government-owned hospitals. Payments were made through AGA\u0027s local Chinese distributor. In exchange for the payments, the doctors directed government-owned hospitals to purchase AGA products rather than thoseof the company\u0027s competitors.  The Criminal Information also alleged that from 2000 through 2002, SGA sought patents on several products from the PRC State Intellectual Property Office, and as part of this effort made payments through their local Chinese disrtibutor to government officials employed at the State Intellectual Property Office.  AGA Medical admitted and accepted the allegations as part of its Deferred Prosecution Agreement with the Department of Justice. (Source: US v. AGA Medical Corporation, Case No. 08-cr-00172 (D.D.C.), Deferred Prosecution Agreement filed on June 3, 2008.)","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 AGA Medical Corporation, at 59-60, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response-appx-c\/pdf;      www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: US Department of Justice Press Release, \u0022AGA Medical Corporation Agrees to Pay $2 Million Penalty and Enter Deferred Prosecution Agreement for FCPA Violations,\u0022 June 3, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/June\/08-crm-491.html (accessed on September 14, 2011).  US v. AGA Medical Corporation, Case no. 08-cr-00172 (D.C. Minn, 2008), Information and Deferred Prosecution Agreement (including Attachment A: Statement of Facts and other attachments), filed June 3, 2008. ","Documents":""},{"Case ID":"ST-17","Case Cluster ":"AGCO Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"09\/30","Other Jurisdictions of Settlement":"Denmark","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$18,307,393.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$13,907,393","Civil Prejudgment Interest (US$) ":"$2,000,000","Civil Fine \/ Penalty (US$)":"$2,400,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission\u0027s Litigation Release, the SEC\u0027s \u0022complaint alleges that from 2000 through 2003, certain AGCO subsidiaries made approximately $5.9 million in kickback payments in connection with their sales of equipment to Iraq under the United Nations Oil for Food Program (the \u0022Program\u0022). The kickbacks were characterized as \u0022after sales service fees\u0022 (\u0022ASSFs\u0022), but no bona fide services were performed. The Program was intended to provide humanitarian relief for the Iraqi population, which faced severe hardship under international trade sanctions. The Program required the Iraqi government to purchase humanitarian goods through a U.N. escrow account; however, AGCO\u0027s subsidiaries\u0027 kickbacks diverted funds out of the escrow account and into Iraqi-controlled accounts at banks in Jordan.\u0022 (Source: US Securities and Exchange Commission, Litigation Release No. 21229 \/ September 30, 2009, SEC v. AGCO Corporation, Civil Action No. 1:09-CV-01865-RMU (D.D.C.), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against AGCO Corporation For Improper Payments to Iraq Under the U.N. Oil for Food Program - AGCO Agrees to Pay Over $18.3 Million in Disgorgement, Interest, and Penalties.\u0022)   Please note that as part of its settlement with the SEC, AGCO Corporation did not admit or deny the agency\u0027s allegations against it.","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, AGCO Corporation Case Summary at 58-59, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21229 \/ September 30, 2009, SEC v. AGCO Corporation, Civil Action No. 1:09-CV-01865-RMU (D.D.C.), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against AGCO Corporation For Improper Payments to Iraq Under the U.N. Oil for Food Program -  AGCO Agrees to Pay Over $18.3 Million in Disgorgement, Interest, and Penalties,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21229.htm; SEC v. AGCO Corporation, Civil Action No. 1:09-CV-01865-RMU (D.D.C.),  Complaint filed September 30, 2009, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp21229.pdf.","Documents":""},{"Case ID":"ST-18","Case Cluster ":"AGCO Corporation","Jurisdiction of Settlement":"Denmark","Jurisdiction of Settlement \/ Enforcement Agency":"State Prosecutor for Serious Economic Crime","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"09\/30","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Criminal Confiscation","Total Monetary Sanctions (US$)":"$630,000.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$630,000","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, on September 30, 2009, AGCO settled an ongoing investigation by the Danish State Prosecutor\u0027s Office for Serious Economic Crime: \u0022The charges were based on two Oil-for-Food contracts executed by AGCO\u0027s Danish subsidiary, AGCO Denmark A\/S.  AGCO agreed to pay approximately $630,000 in disgorgement of profits in connection with those charges.\u0022  (Source: US Department of Justice Press Release, \u0022AGCO Corp. to Pay $1.6 Million in Connection with Payments to the Former Iraqi Government Under the U.N. Oil-For-Food Program,\u0022 September 30, 2009.)  ","Sources ":"US Department of Justice Press Release, \u0022AGCO Corp. to Pay $1.6 Million in Connection with Payments to the Former Iraqi Government Under the U.N. Oil-For-Food Program,\u0022 September 30, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/September\/09-crm-1056.html ","Documents":""},{"Case ID":"ST-19","Case Cluster ":"AGCO Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"09\/30","Other Jurisdictions of Settlement":"Denmark","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,600,000.00","Criminal Fine\/Penalty (US$) ":"$1,600,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud","Offenses - Settled":"Conspiracy to bribe foreign officials; bribery of foreign officials ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a US Department of Justice Press Release, on September 30, 2009, AGCO Limited, the wholly owned UK subsidiary of AGCO Corp (US Corporation based in Georgia) was charged with one count of conspiracy to commit wire fraud and to violate the books and records provisions of the Foreign Corrupt Practices Act.  As part of its Deferred Prosecution Agreement with the Department of Justice, AGCO Corp admitted that between 2000 and 2003, AGCO Ltd. with the assistance of a Jordanian agent, paid approximately $553,000to the former government of Iraq to secure three contracts under the purview of the UN Oil-for-Food Programme.  The contract price was inflated from 13 to 21 percent and the additional funds were then used to pay kickback to the former Iraqi Ministry of Agriculture.  (Source: US Department of Justice Press Release, \u0022AGCO Corp. to Pay $1.6 Million in Connection with Payments to the Former Iraqi Government Under the U.N. Oil-For-Food Program,\u0022 September 30, 2009.).  The Department of Justice acknowledged the assistance of the Danish State Prosecutor\u0027s Office for Serious Economic Crime. (Source: Ibid.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, AGCO Corporation Case Summary at 58-59, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   US Department of Justice Press Release, \u0022AGCO Corp. to Pay $1.6 Million in Connection with Payments to the Former Iraqi Government Under the U.N. Oil-For-Food Program,\u0022 September 30, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/September\/09-crm-1056.html; US v. AGCO Limited, Case No. 1:09-cr-00249-RJL (D.D.C.), Information filed September 30, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/agco-corp\/09-30-09agco-info.pdf","Documents":""},{"Case ID":"ST-20","Case Cluster ":"Akzo Nobel, N.V.","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Rijksrecherche (Dutch Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/15","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unspecified   ","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Unknown","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Nonprosecution Agreement, \u0022It is understood that AKZO NOBEL will pay no monetary penalty in connection with this Agreement, based on AKZO NOBEL\u0027s representation that its former subsidiary, N.V. Organon, has agreed to enter into a criminal disposition with the Dutch National Public Prosecutor\u0027s Office for Financial, Economic and Environmental Offences (the \u0022Dutch Public Prosecutor\u0022). AKZO NOBEL represents that, pursuant to this contemplated disposition with the Dutch Public Prosecutor, N.V. Organon will admit criminal liability and pay a criminal fine of no less than \u20ac 381,602.  It is understood that if there is no such criminal disposition with the Dutch Public Prosecutor within 180 days of the signing of this Agreement, then AKZO NOBEL shall pay a monetary penalty of $800,000 to the United States Treasury. It is further understood that if the criminal fine paid as part of the criminal disposition with the Dutch Public Prosecutor is less than \u20ac 381,602, then AKZO NOBEL shall pay to the United States Treasury the difference between the amount of the fine paid as part of the criminal disposition with the Dutch Public Prosecutor and $800,000, at the currency exchange rate prevailing as ofthe date of the execution of the agreement between AKZO NOBEL and the Dutch Public Prosecutor.\u0022 (Source: US Department of Justice Nonprosecution Agreement, In re: Akzo Nobel N.V., December 20, 2007.)","Sources ":"US Department of Justice, In Re: Akzo Nobel N.V., Non-Prosecution Agreement of December 20, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/akzo-noble\/12-20-07akzo-noble-agree.pdf","Documents":""},{"Case ID":"ST-21","Case Cluster ":"Akzo Nobel, N.V.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"12\/20","Other Jurisdictions of Settlement":"Netherlands","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Penalty (contingent upon settlement with Dutch Public Prosecutor)","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown [Criminal Penalty (contingent upon settlement with Dutch Public Prosecutor]","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records ","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release of December 20, 2007, \u0022Akzo Nobel, a Dutch company with its headquarters in Arnhem, Netherlands, has acknowledged responsibility for the actions of two of its subsidiaries whose employees and agents made improper payments to the Iraqi government in order to obtain contracts with Iraqi ministries. According to the agreement, between 2000 and 2002, the two subsidiaries, N.V. Organon and Intervet International B.V., sold by Akzo Nobel earlier this year, paid a total of approximately $280,000 to the Iraqi government by inflating the price of contracts, usually by adding 10% before submitting the contracts to the United Nations for approval, and concealing from the United Nations the fact that the prices contained a kickback to the Iraqi government.\u0022 (Source: US Department of Justice Press Release, \u0022Akzo Nobel Acknowledges Improper Payments Made by its Subsidiaries to Iraqi Government Under the U.N. Oil for Food Program, Enters Agreement with Department of Justice,\u0022 December 20, 2007.)  According to the US Department of Justice Nonprosecution Agreement, \u0022It is understood that AKZO NOBEL will pay no monetary penalty in connection with this Agreement, based on AKZO NOBEL\u0027s representation that its former subsidiary, N.V. Organon, has agreed to enter into a criminal disposition with the Dutch National Public Prosecutor\u0027s Office for Financial, Economic and Environmental Offences (the \u0022Dutch Public Prosecutor\u0022). AKZO NOBEL represents that, pursuant to this contemplated disposition with the Dutch Public Prosecutor, N.V. Organon will admit criminal liability and pay a criminal fine of no less than \u20ac381,602.  It is understood that if there is no such criminal disposition with the Dutch Public Prosecutor within 180 days ofthe signing ofthis Agreement, then AKZO NOBEL shall pay a monetary penalty of $800,000 to the United States Treasury. It is further understood that if the criminal fine paid as part ofthe criminal disposition with the Dutch Public Prosecutor is less than \u20ac381,602, then AKZO NOBEL shall pay to the United States Treasury the difference between the amount of the fine paid as part of the criminal disposition with the Dutch Public Prosecutor and $800,000, at the currency exchange rate prevailing as ofthe date of the execution of the agreement between AKZO NOBEL and the Dutch Public Prosecutor.\u0022  (Source: US Department of Justice Nonprosecution Agreement, In re: Akzo Nobel N.V., December 20, 2007.)","Sources ":"US Department of Justice Nonprosecution Agreement, In re: Akzo Nobel N.V., December 20, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/akzo-noble\/12-20-07akzo-noble-agree.pdf;  US Department of Justice Press Release, \u0022Akzo Nobel Acknowledges Improper Payments Made by its Subsidiaries to Iraqi Government Under the U.N. Oil for Food Program, Enters Agreement with Department of Justice,\u0022 December 20, 2007, accessed at http:\/\/www.justice.gov\/opa\/pr\/2007\/December\/07_crm_1024.html; US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Akzo Nobel, N.V. at 69-70, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.","Documents":""},{"Case ID":"ST-22","Case Cluster ":"Akzo Nobel, N.V.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"12\/20","Other Jurisdictions of Settlement":"Netherlands","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty ","Total Monetary Sanctions (US$)":"$2,981,513.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,647,363","Civil Prejudgment Interest (US$) ":"$584,150","Civil Fine \/ Penalty (US$)":"$750,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, the agency \u0022filed Foreign Corrupt Practices Act books and records and internal controls charges against Akzo Nobel N.V., a Netherlands-based pharmaceutical company, in the U.S. District Court for the District of Columbia. The Commission\u0027s complaint alleges that from 2000 to 2003, two of Akzo Nobel\u0027s subsidiaries [also incorporated in the Netherlands] authorized and made $279,491 in kickback payments in connection with their sales of humanitarian goods to Iraq under the U.N. Oil for Food Program (the \u0022Program\u0022). The kickbacks were characterized as \u0022after-sales service fees\u0022 (\u0022ASSFs\u0022), but no bona fide services were performed. The Program was intended to provide humanitarian relief for the Iraqi population, which faced severe hardship under international trade sanctions. It allowed the Iraqi government to purchase humanitarian goods through a U.N. escrow account. The kickbacks paid in connection with Akzo Nobel\u0027s subsidiaries\u0027 sales to Iraq bypassed the escrow account and were paid by third parties to Iraqi-controlled accounts in Lebanon and Jordan.\u0022 (Source: US Securities and Exchange Commission, Litigation Release No. 20410 \/ December 20, 2007, Securities and Exchange Commission v. Akzo Nobel, N.V., Civil Action No. 07-CV-02293 (D.D.C.) (HHK), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Akzo Nobel N.V. For Improper Payments to Iraq Under the U.N. Oil for Food Program --Company Agrees to Pay Over $2.9 Million.\u0022)  According to the SEC\u0027s complaint, the Akzo Nobel\u0027s subsidiary N.V. Organon  allegedly paid the additional \u0022commission\u0022 payments to an entity called \u0022Sabbah Drugstore\u0022 and that the payments from both schemes were allegedly paid to officials of (1) unnamed Iraqi ministry and (2) Iraqi Ministry of Health. (Source: Securities and Exchange Commission v. Akzo Nobel, N.V., Civil Action No. 07-CV-02293-HHK (D.D.C.), Complaint filed December 20, 2007.)","Sources ":"US Securities and Exchange Commission, Litigation Release No. 20410 \/ December 20, 2007, Securities and Exchange Commission v. Akzo Nobel, N.V., Civil Action No. 07-CV-02293 (D.D.C.) (HHK), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Akzo Nobel N.V. For Improper Payments to Iraq Under the U.N. Oil for Food Program ? Company Agrees to Pay Over $2.9 Million,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20410.htm; Securities and Exchange Commission v. Akzo Nobel, N.V., Civil Action No. 07-CV-02293-HHK (D.D.C.), Complaint filed December 20, 2007, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2007\/comp20410.pdf","Documents":""},{"Case ID":"ST-23","Case Cluster ":"Alcatel-Lucent S.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Costa Rica","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"06\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$261,500.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$261,500","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a September 23, 2008 US Department of Justice Press Release on sentencing of Christian Sapsizian, a French citizen and deputy vice president of Latin America for Alcatel CIT, Sapsizian admitted that between 2000 and September 2004, he conspired with Edgar Valverde Acosta, Alcatel\u0027s senior officer in Costa Rica, and others to make more than $2.5 million in bribe payments to Costa Rican officials to obtain a telecommunications contract on behalf of Alcatel. In addition to a sentence of 30 months\u0027 imprisonment, Sapsizian was ordered by the U.S. District Court for the Southern District of Florida in Miami to forfeit $261,500.  The Department of Justice Press Release noted that \u0022Substantial assistance was provided by the Southeast Regional Branch of the U.S. Securities and Exchange Commission, the Office of the Attorney General in Costa Rica, the Fiscalia de Delitos Economicos, Corrupcion y Tributarios in Costa Rica and French law enforcement authorities.\u0022  (Sources: US Department of Justice Press Release, \u0022Former Alcatel CIT Executive Sentenced for Paying $2.5 million in Bribes to Senior Costa Rican Officials,\u0022 September 23, 2008 and US v. Christian Sapsizian, Case No. 1:06-cr-20797-PAS (S.D.Fla.), Judgment in a Criminal Case filed September 25, 2008.)   According to the June 2011 United States Report to the OECD, Valverde Acosta \u0022is currently a fugitive.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Alcatel CIT (Matter #73) Case Summary at 111-112, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.)  A May 31, 2011 Sworn Declaration by Edgar Valverde Acosta filed by the Institute Costarricense de Electricidad (ICE) noted that he was serving jail time in Costa Rica following his recent conviction in Costa Rica\u0027s criminal court, in connection with the Alcatel-Lucent case.  (Source: US v. Alcatel-Lucent France S.A. et al, Case No. 1:10-cr-20906 and U.S. v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907 (S.D.Fla.), Sworn Declaration of Edgar Valverde Acosta, May 31, 2011).  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Alcatel CIT (Matter #73) Case Summary at 111-112, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Christian Sapsizian, Case No. 1:06-cr-20797-PAS (S.D.Fla.), Criminal Information filed December 5, 2006, accessed at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/sapsizianc\/12-05-06sapsizian-complaint.pdf; Superseding Indictment filed March 20, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/sapsizianc\/03-22-07sapsizian-indict.pdf; Plea Agrement of June 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/sapsizianc\/06-06-07sapsizian-plea.pdf; Factual Basis for the Plea, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/sapsizianc\/06-06-07sapsizian-fact.pdf; Judgment in a Criminal Case filed September 25, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/sapsizianc\/09-25-08sapsizian-judgment.pdf.  US Department of Justice Press Release, \u0022Former Alcatel CIT Executive Sentenced for Paying $2.5 million in Bribes to Senior Costa Rican Officials,\u0022 September 23, 2008, accessed at www.justice.gov\/opa\/pr\/2008\/September\/08-crm-848.html.  US v. Alcatel-Lucent France S.A. et al, Case No. 1:10-cr-20906 and U.S. v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907 (S.D.Fla.), Sworn Declaration of Edgar Valverde Acosta, May 31, 2011 (accessed via Pacer).","Documents":""},{"Case ID":"ST-25","Case Cluster ":"Alcatel-Lucent S.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Costa Rica","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/27","Other Jurisdictions of Settlement":"Costa Rica","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"Falsification of Books and Records, Internal Control Violations ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, Alcatel-Lucent and its subsidiaries engaged in the following: \u0022Specifically, Alcatel CIT won three contracts in Costa Rica worth a combined total of more than $300 million as a result of corrupt payments to government officials and from which Alcatel reaped a profit of more than $23 million, according to court documents. Alcatel CIT wired more than $18 million to two consultants in Costa Rica, which had been retained by Alcatel Standard, in connection with obtaining business in that country. According to court documents, more than half of this money was then passed on by the consultants to various Costa Rican government officials for assisting Alcatel CIT and Alcatel de Costa Rica in obtaining and retaining business. As part of the scheme, the consultants created phony invoices that they then submitted to Alcatel CIT. According to court documents, senior Alcatel executives approved the retention of and payments to the consultants despite obvious indications that the consultants were performing little or no legitimate work.  In addition, according to court documents, Alcatel Standard hired a consultant in Honduras who was a perfume distributor with no experience in telecommunications. The consultant was retained after being personally selected by the brother of a senior Honduran government official. Alcatel CIT executives knew that a significant portion of the money paid to the consultant would be paid to the family of the senior Honduran government official in exchange for favorable treatment of Alcatel CIT. As a result of these payments, Alcatel CIT was able to retain contracts worth approximately $47 million and from which Alcatel earned $870,000.  In addition, according to court documents, Alcatel Standard retained two consultants on behalf of another Alcatel subsidiary in Taiwan to assist in obtaining an axle counting contract worth approximately $19.2 million. Alcatel and its joint venture paid these two consultants more than $950,000 despite the fact that neither consultant had telecommunications experience. In fact, according to court documents, Alcatel Standard\u0027s purpose for hiring the consultants was so that Alcatel SEL could funnel payments through the consultants to Taiwanese legislators who had influence in the award of the contract. Alcatel earned approximately $4.34 million from this contract.\u0022 (Source: US Department of Justice Press Release, \u0022Alcatel-Lucent S.A. and Three Subsidiaries Agree to Pay $92 Million to Resolve Foreign Corrupt Practices Act Investigation,\u0022 December 27, 2010.)  According to the Deferred Prosecution Agreement, Alcatel-Lucent S.A. and the Department \u0022agree that any criminal penalties that might be im,posed by the Court on Alcatel-Lucent\u0027s wholly owned subsidiaries in connection with their guilty pleas and plea agreements entered into simultaneously herewith will be deducted from the $92,000,000 penalty agreed to under this Agreement.\u0022 (Source: US v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907-PAS (S.D. Fla.), Deferred Prosecution Agreement filed February 22, 2011.)   According to their respective Judgments, Alcatel-Lucent France S.A., Alcatel-Lucent Trade International and Alcatel Centroamerica were each ordered to a $500,000 fine; however, these sums are not recorded in this entry, so as to avoid double-counting along wtih the $92 million total ordered in this case.  (Sources: US v. Alcatel-Lucent France S.A., Case No. 1:10-cr-20906-MGC (S.D. Fla.), Judgment filed June 2, 2011; US v. Alcatel-Lucent Trade International, Case No. 1:10-cr-20906-MGC (S.D. Fla.), Judgment filed June 2, 2011; US v. Alcatel Centroamerica, Case No. 1:10-cr-20906-MGC (S.D. Fla.), Judgment filed June 2, 2011.) ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Alcatel-Lucent S.A. (Matter #11) Case Summary at 27-29, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Alcatel-Lucent France, S.A. f\/k\/a \u0022Alcatel CIT, S.A.,\u0022 Alcatel-Lucent Trade International, A.G. f\/k\/a \u0022Alcatel Standard, A.G.,\u0022 and Alcatel Centroamerica, S.A. f\/k\/a \u0022Alcatel de Costa Rica, S.A.,\u0022 Case No. 1:10-cr-20906-PAS (S.D.Fla.), Information filed on December 27, 2010, Plea Agreements (filed February 22, 2011) and Judgments (filed June 2, 2011) for each subsidiary, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/alcatel-lucent-sa-etal.html. US Department of Justice Press Release, \u0022Alcatel-Lucent S.A. and Three Subsidiaries Agree to Pay $92 Million to Resolve Foreign Corrupt Practices Act Investigation,\u0022 December 27, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/December\/10-crm-1481.html.","Documents":""},{"Case ID":"ST-26","Case Cluster ":"Alcatel-Lucent S.A.","Jurisdiction of Settlement":"Costa Rica","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General; Fiscalia [Prosecutor] de Delitos Economicos, Corrupcion y Tributarios; Office of the Public Ethics Prosecutor","Jurisdiction of Foreign Public Official(s) ":"Costa Rica  ","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"01\/20","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Settlement Agreement ","Monetary Sanctions  (Types)":"Civil Restitution","Total Monetary Sanctions (US$)":"$10,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"$10,000,000","Other Civil Monetary Sanctions (Explanation)":"Restitution","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$10,000,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Corrupt Payments; Causing Social Damage to Costa Rica","Offenses - Settled":"Causing Social Damage to Costa Rica","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, in addition to the settlements in the US, Alcatel-Lucent also \u0022agreed to pay $10 million to settle a corruption case brought by the Government of Costa Rica arising out of the bribery of Costa Rican officials by the company. The settlement marked the first time in Costa Rica\u0027s history that a foreign corporation agreed to pay the govenrment damages for corruption.\u0022 (Source: US Department of Justice Press Release, \u0022Alcatel-Lucent S.A. and Three Subsidiaries Agree to Pay $92 Million to Resolve Foreign Corrupt Practices Act Investigation,\u0022 December 27, 2010.)  Alcatel-Lucent had also issued a statement that the payment was made to the Costa Rican government for \u0022social damages,\u0022 to settle a civil suit filed on November 25, 2004 (amended subsequently) by the Attorney General of Costa Rica.  (Source: Alcatel-Lucent company statement, \u0022Controversies: Costa Rica,\u0022 September 10, 2010, at http:\/\/www.alcatel-lucent.com\/csr\/htm\/en\/home.html.).  The Settlement is detailed in Office of the Attorney General of the Republic, Request for Recognition of Settlement Agreement, filed in Case No. 04-6835-647-PE, Criminal Court of the II Judicial Circuit of San Jose (signed January 20, 2010), which was attached as Exhibit 1 of Government\u0027s Response to ICE\u0027s Petition for Victim Status and Restitution, in US v. Alcatel-Lucent France, S.A., et al, Case No. 1:10-cr-20906-MGC and US v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907-MGC (S.D. Fla. May 23, 2011).  According to the Request for Recognition of Settlement Agreement, \u0022civil claim as well as the criminal prosecution against the other civil and criminal defendants in the case - including the former employees of Alcatel - just as indicated in the agreement, remain intact.\u0022  The Settlement Agreement was undertaken pursuant to Article 219 of the Code of Civil Procedure, Articles 7 and 36 of the Code of Criminal Procedure, and Articles 1367 et seq. of the Civil Code.  See also report by the Attorney General of Costa Rica: Procuradora General de la Republica, Informe de Gestion 2004-2010, at 32-33, accessed at http:\/\/www.pgr.go.cr\/Informacion_General\/Informe%20de%20Gestion%202004-2010.pdf [which states 13 million dollars obtained in both Fischel and Alcatel cases]","Sources ":"US Department of Justice Press Release, \u0022Alcatel-Lucent S.A. and Three Subsidiaries Agree to Pay $92 Million to Resolve Foreign Corrupt Practices Act Investigation,\u0022 December 27, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/December\/10-crm-1481.html; US v. Alcatel-Lucent France, S.A., et al, Case No. 1:10-cr-20906-MGC and US v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907-MGC (S.D. Fla.), Office of the Attorney General of the Republic, Request for Recognition of Settlement Agreement, filed in Case No. 04-6835-647-PE, Criminal Court of the II Judicial Circuit of San Jose (signed January 20, 2010), which was attached as Exhibit 1 of Government\u0027s Response to ICE\u0027s Petition for Victim Status and Restitution filed May 23, 2011; Alcatel-Lucent Company Statement, \u0022Controversies: Costa Rica,\u0022 September 10, 2010, at http:\/\/www.alcatel-lucent.com\/csr\/htm\/en\/home.html; report by the Attorney General of Costa Rica: Procuradora General de la Republica, Informe de Gestion 2004-2010, at 32-33, accessed at http:\/\/www.pgr.go.cr\/Informacion_General\/Informe%20de%20Gestion%202004-2010.pdf.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ICE_US_Opposition_Exhibit_1_Costa_Rica_Settlement_SDFLA_May_23_2011.pdf"},{"Case ID":"ST-27","Case Cluster ":"Alcatel-Lucent S.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Costa Rica, Honduras, Malaysia, Taiwan","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/27","Other Jurisdictions of Settlement":"Costa Rica","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$92,000,000.00","Criminal Fine\/Penalty (US$) ":"$92,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"Falsification of Books and Records, Internal Control Violations ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, Alcatel-Lucent and its subsidiaries engaged in the following: \u0022Specifically, Alcatel CIT won three contracts in Costa Rica worth a combined total of more than $300 million as a result of corrupt payments to government officials and from which Alcatel reaped a profit of more than $23 million, according to court documents. Alcatel CIT wired more than $18 million to two consultants in Costa Rica, which had been retained by Alcatel Standard, in connection with obtaining business in that country. According to court documents, more than half of this money was then passed on by the consultants to various Costa Rican government officials for assisting Alcatel CIT and Alcatel de Costa Rica in obtaining and retaining business. As part of the scheme, the consultants created phony invoices that they then submitted to Alcatel CIT. According to court documents, senior Alcatel executives approved the retention of and payments to the consultants despite obvious indications that the consultants were performing little or no legitimate work.  In addition, according to court documents, Alcatel Standard hired a consultant in Honduras who was a perfume distributor with no experience in telecommunications. The consultant was retained after being personally selected by the brother of a senior Honduran government official. Alcatel CIT executives knew that a significant portion of the money paid to the consultant would be paid to the family of the senior Honduran government official in exchange for favorable treatment of Alcatel CIT. As a result of these payments, Alcatel CIT was able to retain contracts worth approximately $47 million and from which Alcatel earned $870,000.  In addition, according to court documents, Alcatel Standard retained two consultants on behalf of another Alcatel subsidiary in Taiwan to assist in obtaining an axle counting contract worth approximately $19.2 million. Alcatel and its joint venture paid these two consultants more than $950,000 despite the fact that neither consultant had telecommunications experience. In fact, according to court documents, Alcatel Standard\u0027s purpose for hiring the consultants was so that Alcatel SEL could funnel payments through the consultants to Taiwanese legislators who had influence in the award of the contract. Alcatel earned approximately $4.34 million from this contract.\u0022 (Source: US Department of Justice Press Release, \u0022Alcatel-Lucent S.A. and Three Subsidiaries Agree to Pay $92 Million to Resolve Foreign Corrupt Practices Act Investigation,\u0022 December 27, 2010.)  According to the Deferred Prosecution Agreement, Alcatel-Lucent S.A. and the Department \u0022agree that any criminal penalties that might be im,posed by the Court on Alcatel-Lucent\u0027s wholly owned subsidiaries in connection with their guilty pleas and plea agreements entered into simultaneously herewith will be deducted from the $92,000,000 penalty agreed to under this Agreement.\u0022 (Source: US v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907-PAS (S.D. Fla.), Deferred Prosecution Agreement filed February 22, 2011.)  ICE Petition: In May and June 2011, the Instituto Costarricense de Electriciad (ICE) petitioned the District Court for the Southern District of Florida considering the Alcatel-Lucent SA criminal cases for relief\/restitution and to obejct to the Alcatel-Lucent\u0027s plea agreement and deferred prosecution agreement with the US Government. ICE petitioned the court to be recognized as a victim and entitled to restitution, pursuant to the Crime Victims\u0027 Rights Act (18 USC Section 1651), US Federal Rules on Criminal Procedure and the Mandatory Victim Restitution Act (18 USC Section 3663A).  ICE argued that it had suffered direct and proximate damage from Alcatel-Lucent\u0027s conduct and refuted the argument by the US and Alcatel-Lucent (later supported by the court) that it had been a co-conspirator or co-participant in the bribery scheme.  (Sources: US v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907 (S.D. Fla.), Petition for Relief Pursuant to 18 U.S.C. Section 3771(d)(3) and Objection to Plea Agreements and Deferred Prosecution Agreement filed May 3, 2011 and Petition for Writ of Mandamus Pursuant to the Crime Victims\u0027 Rights Act, 18 USC Section 3771(d)(3) filed June 15, 2011.) The US Government\u0027s Response to ICE\u0027s Petition for Victim Status and Restitution, filed May 23, 2011, argued that \u0022Under the facts and circumstances in the instant matter, which reflect profound and pervasive corruption at the highest levels of ICE, the government does not believe it is appropriate to consider ICE a victim in these cases. [ ] Moreover, regardless of whether ICE is considered a victim, the government does not believe that restitution should be ordered in this matter, because, under the facts and circumstances present in this case, any restitution calculation woul dbe netirely speculative and would unduly prolong and complicate the sentencing process - something that the law does not support.\u0022  The US Government cited the involvement of the ICE board members and high level officers in the Alcatel scheme and as legal basis, US v. Lazarenko, 624 F.3d 1247, 1250-52 (9th Cir. 2010) (an individual who is both a victim and a participant in a money-laundering scheme who profited from the conspiracy cannot qualify as a \u0022victim\u0022 under restitution statutes), and in footnote 8, refuted ICE\u0027s contention that the DOJ had stated that foreign governments or instrumentalities could never be victims, much less that that was Department [of Justice] policy. ICE appealed the district court\u0027s ruling to the 11th Circuit Appeals Court, but its petition was also denied. The appeals court held that the \u0022district court did not clearly err in finding that \u0027Instituto Costarricense de Electricidad\u0027 (\u0022ICE\u0022), here seeking to be deemed a \u0022crime victim,\u0022 actually functions as the offenders\u0027 coconspirator.  The district court identified the pervasive, constant, and consistent illegal conduct by the \u0022principals\u0022 (i.e. members of the Board of Directors and management) of ICE, the organization claiming status as a victim under the CVRA.  Neither did the district court err in finding that ICE failed to establish that it was directly and proximately harmed by the offenders\u0027 criminal conduct.\u0022 (Sources:  In re: Instituto Costarricense de Electricidad, No. 11-12707-G and No. 11-12708-G (11th Cir.), On Petititon for Writ of Mandamus to the United States District Court for the Southern District of Florida filed June 17, 2011 and September 2, 2011 denial of ICE\u0027s motion for Petition for Rehearing En Banc; see also Consolidated Opposition of Alcatel-Lucent, S.A., Alcatel-Lucent France, S.A., Alcatel-Lucent Trade International, A.G. and Alcatel Centroamerica, S.A. to Petitions for Writs of Mandamus Pursuant to the Crime Victims Rights Act, 18 U.S.C. Section 3771 filed June 17, 2011.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alcatel-Lucent, S.A. Case Summary at 27-29, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   US v. Alcatel-Lucent, SA, Case No. 1:10-cr-20907 (S.D. Fla.), Information filed December 27, 2010 and copies of the Deferred Prosecution Agreement and Order, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/alcatel-lucent-sa.html; US Department of Justice Press Release, \u0022Alcatel-Lucent S.A. and Three Subsidiaries Agree to Pay $92 Million to Resolve Foreign Corrupt Practices Act Investigation,\u0022 December 27, 2010, at http:\/\/www.justice.gov\/opa\/pr\/2010\/December\/10-crm-1481.html.  ICE Petition: US v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907 (S.D. Fla.), Petition for Relief Pursuant to 18 U.S.C. Section 3771(d)(3) and Objection to Plea Agreements and Deferred Prosecution Agreement filed May 3, 2011 and Petition for Writ of Mandamus Pursuant to the Crime Victims\u0027 Rights Act, 18 USC Section 3771(d)(3) filed June 15, 2011; US Government\u0027s Response to ICE\u0027s Petition for Victim Status and Restitution, filed May 23, 2011; In re: Instituto Costarricense de Electricidad, No. 11-12707-G and No. 11-12708-G (11th Cir.), On Petititon for Writ of Mandamus to the United States District Court for the Southern District of Florida filed June 17, 2011 and September 2, 2011 denial of ICE\u0027s motion for Petition for Rehearing En Banc; see also Consolidated Opposition of Alcatel-Lucent, S.A., Alcatel-Lucent France, S.A., Alcatel-Lucent Trade International, A.G. and Alcatel Centroamerica, S.A. to Petitions for Writs of Mandamus Pursuant to the Crime Victims Rights Act, 18 U.S.C. Section 3771 filed June 17, 2011.","Documents":""},{"Case ID":"ST-28","Case Cluster ":"Alexander Yakovlev","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Southern District of New York ","Jurisdiction of Foreign Public Official(s) ":"United Nations","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/22","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$900,000.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$900,000","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art.1, Art. 7","Offenses - Alleged":"Conspiracy to commit wire fraud, wire fraud and conspiracy to commit money laundering","Offenses - Settled":"Conspiracy to commit wire fraud, wire fraud and conspiracy to commit money laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US court documents, former United Nations officials Vladimir Kuznetsov and Alexander Yakovlev were charged with corruption and money laundering in U.S. federal court for their respective roles in the United Nations Oil-for-Food Programme case.  Mr. Kuznetsov was convicted of one count of money laundering following a jury trial in the U.S. District Court for Southern District of New York and ordered to pay a criminal fine of $73,671.  He satisfied this judgment on November 18, 2008.  His co-conspirator Alexander Yakovlev pleaded guilty in 2005 to three counts of wire fraud and money laundering.  As part of his plea agreement, Mr. Yakovlev had agreed to forfeit $900,000 held in bank accounts in Liechtenstein.  On December 22, 2010, the federal court for the Southern District of New York ordered the following accounts forfeited to the U.S. (pending any assertions of third-party claims):  (1) Liechtensteinische Landesbank AG and LLB Treuhand AG, 9490 Vaduz, Accounts numbered 208.63898 and 213.042.67, in the name of Alexander Yakovlev or Olga Yakoleva; and (2) LLB AG and LLB Treuhand AG, 9490 Vaduz, Accounts numbered 212.440.51 and 213.036.32 in the name of Angelus Finance Ltd, for which Alexander Yakovlev is the financial beneficiary.  On February 10, 2011, the court ented a Satisfaction of Forfeiture Money Judgment, noting that the accounts had been forfeited by the Principality of Liechtenstein.  (Sources: U.S. v. Kuznetsov, Case No. 1:05-cr-00916-DAB (S.D.N.Y.), Judgment filed in a criminal case, filed October 19, 2007; U.S. v. Yakovlev, Case No. 1:05-cr-00819-DAB (S.D.N.Y.), Consent Order of Forfeiture filed on December 22, 2010; Satisfaction of Forfeiture Money Judgment, filed February 10, 2011.)","Sources ":"U.S. v. Kuznetsov, no. 1:05-cr-00916-DAB (S.D.N.Y., Oct. 19, 2007), Judgment; US Department of Justice Press Release. \u0022U.S. Judge Sends Former High-Ranking United Nations Official to Prison for Money Laundering.\u0022 Oct. 12, 2007; Consent Order of Forfeiture, U.S. v. Yakovlev, no. 1:05-cr-00819-DAB, (Dec. 22, 2010); Order, U.S. v. Yakovlev, no. 05 Cr. 819 DAB (S.D.N.Y. Sept. 25, 2008); Independent Inquiry Committee into the United Nations Oil-for-Food Programme, Third Interim Report: The Conduct of Benon Sevan, The Conduct of Alexander Yakovlev, accessed at http:\/\/www.iic-offp.org\/documents\/Third%20Interim%20Report.pdf","Documents":""},{"Case ID":"ST-29","Case Cluster ":"Alfasan International BV Woerden","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Rijksrecherche (Dutch Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unknown form of out of court settlement","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$66,915.00","Criminal Fine\/Penalty (US$) ":"$50,684","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$16,230.90","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Unknown","Offenses - Settled":"Sanctions legislation by paying kickbacks when implementing UN Oil-for-Food Programme","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Netherlands Phase 2 Report of the OECD Anti-Bribery Working Group (December 17, 2008): \u0022As of October 2008, no foreign bribery cases had been brought before the Dutch courts. Nevertheless, the prosecution authorities have concluded out-of-court transactions with seven companies for paying kickbacks in the context of the Oil-for-Food Programme in Iraq, although the offence charged was the violation of sanctions legislation and not the foreign bribery offence.\u0022 (para 2); \u0022 the Prosecution Department reports that it has concluded financial transactions (out of court settlements) with 7 companies for violating sanction legislation by paying kickbacks when implementing the Oil for Food Programme. Criminal gains have also been confiscated. In July 2008 a press release has been issued about these settlements. Together with the names of the companies (Alfasan International B.V., N.V. Organon, Flowserve B.V., OPW Fluid Transfer Group Europe B.V., Prodetra B.V. Solvochem Holland B.V., Stet Holland B.V.) the settlements have been made public. For the following Oil-for-food transactions out-of-court settlements have been reached: 1. Alfasan International BV Woerden, fine: \u20ac 31.800,-- and confiscation \u20ac 10.183,55 2. NV Organon Oss, fine: \u20ac 381.602 3. Flowerserve bv te Etten-Leur, fine: \u20ac 76.274 and confiscation \u20ac180.260 4. OPW Fluid Transfer Group Europe BV, Nieuw Vennep, fine \u20ac 57.204 and confiscation \u20ac 24.600 5. Prodetra bv,Wadinxveen, fine: 64.751 and confiscation \u20ac 34.485,95 6. Solvochem Holland bv, Rotterdam, fine \u20ac 136.000 and confiscation \u20ac 144.592 7. Stet Holland bv,Emmeloord, fine \u20ac 119.712 and confiscation \u20ac 54.458.\u0022 (Source: Ibid., at 14.)","Sources ":"OECD Anti-Bribery Working Group, The Netherlands Phase 2 Report (December 17, 2008), accessed at http:\/\/www.oecd.org\/dataoecd\/61\/59\/41919004.pdf; Melissa Lipman, \u0022Cos. Settle Dutch Probe Into Oil-For-Food For \u20ac1.3M,\u0022 Law 360, July 16, 2008, accessed at http:\/\/www.law360.com\/articles\/62486\/cos-settle-dutch-probe-into-oil-for-food-for-1-3m (partial article, gives date of Dutch Public Prosecution Service press release.)","Documents":""},{"Case ID":"ST-30","Case Cluster ":"Alliance One International, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Kyrgyzstan, Thailand, Malawi, Greece, Indonesia, Mozambique, China","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits ","Total Monetary Sanctions (US$)":"$10,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$10,000,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to DOJ Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Resulting Criminal Enforcement Actions: In Re Alliance One International, Inc. (August 6, 2010); U.S. v. Alliance One Tobacco Osh, LLC: Docket No. 10-CR-016-JLK (W.D. Va., August 6, 2010); U.S. v. Alliance One International AG: Docket No. 10-CR-017-JLK (W.D. Va., August 6, 2010); U.S. v. Bobby Jay Elkin, Jr.: Docket No. 10-CR-015-JLK (W.D. Va., August 3, 2010); Resulting Civil\/Administrative Enforcement Action(s): SEC v. Alliance One International, Inc. (D.D.C., August 6, 2010); SEC v. Bobby Jay Elkin, Jr., et al. (D.D.C., April 28, 2010),  Please note that the court docket numbers are from DOJ\/Fraud\/FCPA Enforcement Actions website (http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/a.html) and complete list of entities and individuals charged are in DOJ Report to Congress Appendix C, \u0022Alliance One International, Inc.\u0022 at 9-11, which also notes Location and Time Period of Misconduct: Kyrgystan, 1996-2004; Thailand, 2000-2004; Malawi, 2002-2003; Greece, 2003; Indonesia, 2003; Mozambique, 2004-2007; China and Thailand, 2005.","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Alliance One International, Inc. at 9-11, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, AGCO Corporation Case Summary at 58-59, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21618 \/ August 6, 2010, SECURITIES AND EXCHANGE COMMISSION v. UNIVERSAL CORPORATION, INC., Civil Action No. 01:10-cv-01318 (RWR) (D.D.C.) (filed August 6, 2010), SECURITIES AND EXCHANGE COMMISSION v. ALLIANCE ONE INTERNATIONAL, INC., Civil Action No. 01:10-cv-01319 (RMU) (D.D.C.) (filed August 6, 2010), \u0022SEC FILES ANTI-BRIBERY CHARGES AGAINST TWO GLOBAL TOBACCO COMPANIES,\u0022 http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21618.htm; Complaint filed August 6, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21618-alliance-one.pdf","Documents":""},{"Case ID":"ST-31","Case Cluster ":"Alliance One International, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Kyrgyzstan, Thailand, Malawi, Greece, Indonesia, Mozambique, China","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement ","Monetary Sanctions  (Types)":"None ","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On August 6, 2010, two foreign subsidiaries of Alliance One International, Inc. (Alliance One), a global tobacco leaf merchant headquartered in Morrisville, N.C., were charged in separate three-count criminal informations with conspiring to violate the FCPA, violating the anti-bribery provisions of the FCPA, and violating the books and records provisions of the FCPA. On the same date, the SEC filed a settled civil action against Alliance One in the U.S. District Court for the District of Columbia. [  ] Previously, on August 3, 2010, Bobby Jay Elkin, Jr., Dimon?s former Kyrgyzstan country manager, was charged with one-count of conspiring to violate the FCPA\u0027s anti-bribery provisions. Elkin, along with three other former Alliance One employees, was also charged by the SEC in a settled civil enforcement action filed on April 28, 2010.The criminal and civil charges filed against Alliance One, its subsidiaries, and former employees stem from bribery schemes in multiple countries,\u0022 including from 1996 to 2004, $3 million in bribes to various officials in the Republic of Kyrgyzstan, including officials of the Kyrgyz Tamekisi, a government entity which controlled and regulated the tobacco industry in Kyrgyzstan as well as provincial and tax officials; from 2000 to 2004, more than $1.2 millionin bribes to the Thailand Tobacco Monopoly officials; in China and Thailand, gifts and entertainment to government officials; in Greece, $96,000 cash payment to a Greek tax official which resulted in a reduced tax payment from EUR 2.5 million to approximately EUR 600,000; in Indonesia, cash payment of approximately $44,000 to an Indonesian tax official in exchange for terminating an audit and obtaining a tax refund of $67,000.  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. In Re: Alliance One International, Inc., Non-Prosecution Agreement dated August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/alliance-one\/08-06-10alliance-one-npa.pdf","Documents":""},{"Case ID":"ST-32","Case Cluster ":"Alliance One International, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Kyrgyzstan, Thailand, Malawi, Greece, Indonesia, Mozambique, China","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$5,251,200.00","Criminal Fine\/Penalty (US$) ":"$5,250,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"$1,200","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials, Falsification of books and records","Offenses - Settled":"Conspiracy to bribe foreign officials, Bribery of foreign officials, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On August 6, 2010, two foreign subsidiaries of Alliance One International, Inc. (Alliance One), a global tobacco leaf merchant headquartered in Morrisville, N.C., were charged in separate three-count criminal informations with conspiring to violate the FCPA, violating the anti-bribery provisions of the FCPA, and violating the books and records provisions of the FCPA. On the same date, the SEC filed a settled civil action against Alliance One in the U.S. District Court for the District of Columbia. [  ] Previously, on August 3, 2010, Bobby Jay Elkin, Jr., Dimon?s former Kyrgyzstan country manager, was charged with one-count of conspiring to violate the FCPA\u0027s anti-bribery provisions. Elkin, along with three other former Alliance One employees, was also charged by the SEC in a settled civil enforcement action filed on April 28, 2010.The criminal and civil charges filed against Alliance One, its subsidiaries, and former employees stem from bribery schemes in multiple countries,\u0022 including from 1996 to 2004, $3 million in bribes to various officials in the Republic of Kyrgyzstan, including officials of the Kyrgyz Tamekisi, a government entity which controlled and regulated the tobacco industry in Kyrgyzstan as well as provincial and tax officials; from 2000 to 2004, more than $1.2 million in bribes to the Thailand Tobacco Monopoly officials; in China and Thailand, gifts and entertainment to government officials; in Greece, $96,000 cash payment to a Greek tax official which resulted in a reduced tax payment from EUR 2.5 million to approximately EUR 600,000; in Indonesia, cash payment of approximately $44,000 to an Indonesian tax official in exchange for terminating an audit and obtaining a tax refund of $67,000.  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Alliance One International, AG, Case No. 4:10-cr-017-JLK (W.D. Va.), Plea Agreement filed August 6, 2010; Amended Judgment against Alliance One International AG (October 22, 2010), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/alliance-one\/10-22-10alliance-one-intl-amended.pdf","Documents":""},{"Case ID":"ST-33","Case Cluster ":"Alliance One International, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Kyrgyzstan, Thailand, Malawi, Greece, Indonesia, Mozambique, China","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$4,201,200.00","Criminal Fine\/Penalty (US$) ":"$4,200,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"$1,200","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials, Aiding and abetting falsification of books and records","Offenses - Settled":"Conspiracy to bribe foreign officials, Bribery of foreign officials, Aiding and abetting falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On August 6, 2010, two foreign subsidiaries of Alliance One International, Inc. (Alliance One), a global tobacco leaf merchant headquartered in Morrisville, N.C., were charged in separate three-count criminal informations with conspiring to violate the FCPA, violating the anti-bribery provisions of the FCPA, and violating the books and records provisions of the FCPA. On the same date, the SEC filed a settled civil action against Alliance One in the U.S. District Court for the District of Columbia. [  ] Previously, on August 3, 2010, Bobby Jay Elkin, Jr., Dimon\u0027s former Kyrgyzstan country manager, was charged with one-count of conspiring to violate the FCPA\u0027s anti-bribery provisions. Elkin, along with three other former Alliance One employees, was also charged by the SEC in a settled civil enforcement action filed on April 28, 2010.The criminal and civil charges filed against Alliance One, its subsidiaries, and former employees stem from bribery schemes in multiple countries,\u0022 including from 1996 to 2004, $3 million in bribes to various officials in the Republic of Kyrgyzstan, including officials of the Kyrgyz Tamekisi, a government entity which controlled and regulated the tobacco industry in Kyrgyzstan as well as provincial and tax officials; from 2000 to 2004, more than $1.2 millionin bribes to the Thailand Tobacco Monopoly officials; in China and Thailand, gifts and entertainment to goernmetn officials; in Greece, $96,000 cash payment to a Greek tax official which resulted in a reduced tax payment from EUR 2.5 million to approximately EUR 600,000; in Indonesia, cash payment of approximately $44,000 to an Indonesian tax official in exchange for terminating an audit and obtaining a tax refund of $67,000.  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Alliance One Tobacco Osh LLC, Case No. 4:10-cr-016-JLK (W.D. Va.), Plea Agreement filed August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/alliance-one\/08-06-10alliance-tobacco-plea-agree.pdf; Judgment (October 21, 2010), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/alliance-one\/10-21-10alliance-one-tobacco-judgment.pdf","Documents":""},{"Case ID":"ST-34","Case Cluster ":"Alliance One International, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Kyrgyzstan, Thailand, Malawi, Greece, Indonesia, Mozambique, China","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"04\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction  ","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$80,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$80,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Aiding and abetting Alliance\u0027s books and records violations, Aiding and abetting Alliance\u0027s internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On August 6, 2010, two foreign subsidiaries of Alliance One International, Inc. (Alliance One), a global tobacco leaf merchant headquartered in Morrisville, N.C., were charged in separate three-count criminal informations with conspiring to violate the FCPA, violating the anti-bribery provisions of the FCPA, and violating the books and records provisions of the FCPA. On the same date, the SEC filed a settled civil action against Alliance One in the U.S. District Court for the District of Columbia. [  ] Previously, on August 3, 2010, Bobby Jay Elkin, Jr., Dimon\u0027s former Kyrgyzstan country manager, was charged with one-count of conspiring to violate the FCPA\u0027s anti-bribery provisions. Elkin, along with three other former Alliance One employees, was also charged by the SEC in a settled civil enforcement action filed on April 28, 2010.The criminal and civil charges filed against Alliance One, its subsidiaries, and former employees stem from bribery schemes in multiple countries,\u0022 including from 1996 to 2004, $3 million in bribes to various officials in the Republic of Kyrgyzstan, including officials of the Kyrgyz Tamekisi, a government entity which controlled and regulated the tobacco industry in Kyrgyzstan as well as provincial and tax officials; from 2000 to 2004, more than $1.2 millionin bribes to the Thailand Tobacco Monopoly officials; in China and Thailand, gifts and entertainment to goernmetn officials; in Greece, $96,000 cash payment to a Greek tax official which resulted in a reduced tax payment from EUR 2.5 million to approximately EUR 600,000; in Indonesia, cash payment of approximately $44,000 to an Indonesian tax official in exchange for terminating an audit and obtaining a tax refund of $67,000. The Report noted that \u0022On April 28, 2010, the SEC filed a settled civil action against Elkin, Myers, Reynolds, and Williams, which permanently enjoined them from future violations of the FCPA. Myers and Reynolds were each required to pay a $40,000 civil penalty. The settlement against Elkin takes into account his cooperation with the Commission?s investigation.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21509 \/ April 29, 2010, Securities and Exchange Commission v. Bobby J. Elkin, Jr., Baxter J. Myers, Thomas G. Reynolds, and Tommy L. Williams, Civil Action No. 1:10-cv-00661 (RMU) (D.D.C.) (filed April 28, 2010), \u0022SEC Files Anti-Bribery Charges Against Former Finance Executives and Senior Employees Of Global Tobacco Company,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21509.htm","Documents":""},{"Case ID":"ST-35","Case Cluster ":"Alliance One International, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Kyrgyzstan","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$5,000.00","Criminal Fine\/Penalty (US$) ":"$5,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On August 6, 2010, two foreign subsidiaries of Alliance One International, Inc. (Alliance One), a global tobacco leaf merchant headquartered in Morrisville, N.C., were charged in separate three-count criminal informations with conspiring to violate the FCPA, violating the anti-bribery provisions of the FCPA, and violating the books and records provisions of the FCPA. On the same date, the SEC filed a settled civil action against Alliance One in the U.S. District Court for the District of Columbia. [  ] Previously, on August 3, 2010, Bobby Jay Elkin, Jr., Dimon\u0027s former Kyrgyzstan country manager, was charged with one-count of conspiring to violate the FCPA\u0027s anti-bribery provisions. Elkin, along with three other former Alliance One employees, was also charged by the SEC in a settled civil enforcement action filed on April 28, 2010.The criminal and civil charges filed against Alliance One, its subsidiaries, and former employees stem from bribery schemes in multiple countries,\u0022 including from 1996 to 2004, $3 million in bribes to various officials in the Republic of Kyrgyzstan, including officials of the Kyrgyz Tamekisi, a government entity which controlled and regulated the tobacco industry in Kyrgyzstan as well as provincial and tax officials; from 2000 to 2004, more than $1.2 millionin bribes to the Thailand Tobacco Monopoly officials; in China and Thailand, gifts and entertainment to goernmetn officials; in Greece, $96,000 cash payment to a Greek tax official which resulted in a reduced tax payment from EUR 2.5 million to approximately EUR 600,000; in Indonesia, cash payment of approximately $44,000 to an Indonesian tax official in exchange for terminating an audit and obtaining a tax refund of $67,000.  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Bobby Jay Elkin, Jr., Case No. 4:10-cr-015-JLK (W.D. Va.), Plea Agreement filed August 3, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/elkin\/08-03-10elkin-plea-agmt.pdf; Judgment filed October 21, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/elkin\/10-21-10elkin-judgment.pdf","Documents":""},{"Case ID":"ST-36","Case Cluster ":"Allied Products Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Russia","Year of Settlement":"2001","Month\/Day of Settlement (or Notes)":"06\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea ","Monetary Sanctions  (Types)":"None ","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8 ","Offenses - Alleged":"Falsification of books and records","Offenses - Settled":"Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Allied Products Corporation, at 120-121, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf and Information in US v. David Ray Rothrock, Case No. 5:01-cr-00343-OLG (W.D. Tex., June 13, 2001): Rothrock was the vice president of the Cooper Division of Allied Products Corporation with responsibility for international sales.  He pleaded guilty to one count of falsifying his employer\u0027s corporate books and records.  The Cooper Division agreed to pay a sales commission of $282,076 to a third party company (Trading and Business Services Ltd., an entity with principal business in Moscow; Biel, Switzerland; and Houston and co-owned by \u0022Nestro\u0022 and Comco Holding AG, a Swiss company) for ultimate benefit of the Director General of RVO Zarubezhneftstroy (\u0022Nestro\u0022), a Soviet government purchasing agency, in order to obtain a contract for the sale of 20 workover rigs to Nestro. Rothrock, in 2002, created false invoice that was purported to come from a company called \u0022Educa\u0022 in Vienna, Austria but that he knew was for TBS. Rothrock pleaded guilty and on September 20, 2001, he was sentenced to one year probation and ordered to pay court assessment of $100.  His presentencing report was sealed on September 24, 2001. (Sources: US v. Daniel Ray Rothrock, Case No. 5:01-cr-00343-OLG (W.D. Tex.), Information filed on June 13, 2001; Plea agreement filed June 13, 2011 and Judgment of September 20, 2001 and Court Docket Report, all accessed at Fcpa.Shearman.com, Case Summary Page, US v. David Ray Rothrock, http:\/\/fcpa.shearman.com\/index.php.","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Allied Products Corporation, at 120-121, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/rothrock.html; US v. Daniel Ray Rothrock, Case No. 5:01-cr-00343-OLG (W.D. Tex.), Information filed on June 13, 2001; Plea agreement filed June 13, 2011 and Judgment of September 20, 2001 and Court Docket Report, all accessed at Fcpa.Shearman.com, Case Summary Page, US v. David Ray Rothrock, http:\/\/fcpa.shearman.com\/index.php","Documents":""},{"Case ID":"ST-37","Case Cluster ":"Alstom S.A.","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Latvia, Malaysia, Tunisia","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"11\/22","Other Jurisdictions of Settlement":"World Bank","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Payment of Reparation (Art. 53 Swiss Criminal Code)","Monetary Sanctions  (Types)":"Reparation","Total Monetary Sanctions (US$)":"$1,089,510.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$1,089,510","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$1,089,510","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Reparations via International Committee of the Red Cross","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8, Art. 9","Offenses - Alleged":"Art. 102 Criminal Code (Liability for acts committed by subsidiary) ","Offenses - Settled":"Art. 53 Criminal Code (Costs of Prosecution)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Press Release issued by the Swiss Office of Attorney General, \u0022As far as the proceedings were also brought against Alstom SA, based in France, they have been dismissed with regard to the actions in Latvia, Tunisia and Malaysia based on Art. 53 SCC, imposing on the company the costs of the proceedings allotted to Alstom SA in this regard. In the opinion of the OAG, Alstom SA as the senior holding company is responsible in part for the organizational deficiencies identified. However, after payment of CHF 1 m as reparation and bearing the remaining costs of the proceedings by Alstom SA, the OAG refrained from sanctioning Alstom SA in addition to Alstom Network Schweiz AG regarding the established acts of bribery. It did so particularly considering the demonstrated willingness to cooperate and the considerable improvements in the internal compliance procedures before and after the opening of the investigations.Within the proceedings against Alstom Network Schweiz AG and Alstom SA, the OAG in close cooperation with the Federal Criminal Police investigated further twelve projects in the power station sector, divided over all continents. In this regard, it in some part detected additional breaches of internal compliance regulations. Despite considerable investigative efforts however, no additional acts of bribery could be established for the time after article 102 SCC had come into effect. The proceedings against the two defendant Alstom entities for these additionally investigated twelve projects were dismissed due to the lack of any criminal conduct (Art. 319(1)(a) Swiss Code of Criminal Procedure) and due to the lack of criminal liability of the companies prior to October 2003 (Art. 319(1)(b) Swiss Code of Criminal Procedure), without granting compensation and by imposing the costs allotted for this part of the proceedings on the two Alstom companies. [  ]  The amount of CHF 1 m paid by Alstom SA as reparation under Art. 53 SCC was transferred to the International Committee of the Red Cross. One-third of these funds each shall be used in projects of the ICRC in Tunisia, Latvia and Malaysia respectively. The costs allotted for the part of the proceedings resulting in the dismissal amount to about CHF 90,000 and have been imposed on the two Alstom companies for which they are jointly liable.  Due to Alstom renouncing to appeal, this decision also has become legally binding.\u0022 (Source: The Office of the Attorney General Press Release, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)  Please note that the CHF 90,000 in costs of the proceedings have been included only in the Alstom Network Schweiz AG entry so as to prevent double counting of the sum. ","Sources ":"Organisation of Economic Co-operation and Development, Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland, Adopted by the OECD Working Group on Bribery on December 16, 2011, para 40, accessed at http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf    http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf; The [Swiss] Office of the Attorney General Press Release, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011, accessed at http:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=42300","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Alstom_SA_Swiss_Attorney_General_Summary_Punishment_Order_PR_Nov_22_2011.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Alstom_Company_Statement_Nov_2011.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Switzerland_OECD_Phase_3_Report_Dec_2011.pdf"},{"Case ID":"ST-38","Case Cluster ":"Alstom S.A.","Jurisdiction of Settlement":"","Jurisdiction of Settlement \/ Enforcement Agency":"Integrity Vice Presidency","Jurisdiction of Foreign Public Official(s) ":"Zambia","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"02\/22","Other Jurisdictions of Settlement":"Switzerland","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Negotiated Resolution Agreement","Monetary Sanctions  (Types)":"Restitution","Total Monetary Sanctions (US$)":"$9,500,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"$9,500,000","Other Civil Monetary Sanctions (Explanation)":"Restitution","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$9,500,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to World Bank","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Improper payment to an entity controlled by a former senior government official ","Offenses - Settled":"Improper payment to an entity controlled by a former senior government official ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According  to the Workd Bank press release dated February 22, 2012, \u0022The World Bank Group today announced the debarment of Alstom Hydro France and Alstom Network Schweiz AG (Switzerland) - in addition to their affiliates - for a period of three years following Alstom?s acknowledgment of misconduct in relation to a Bank-financed hydropower project.  The debarment is part of a Negotiated Resolution Agreement between Alstom and the World Bank which also includes a restitution payment by the two companies totaling approximately $9.5 million. The debarment can be reduced to 21 months - with enhanced oversight - if the companies comply with all conditions of the agreement. [ ] In 2002, Alstom made an improper payment of \u20ac110,000, to an entity controlled by a former senior government official for consultancy services in relation to the World Bank-financed Zambia Power Rehabilitation Project. During the debarment period of Alstom Hydro France and Alstom Network Schweiz AG, Alstom SA and its other affiliates are conditionally non-debarred. Under the Agreement, Alstom SA, Alstom Hydro France, Alstom Network Schweiz AG and their affiliates commit to cooperating with the World Bank?s Integrity Vice Presidency and continuing to improve their internal compliance program. The debarment of Alstom Hydro France and Alstom Network Schweiz qualifies for cross-debarment by other MDBs under the Agreement of Mutual Recognition of Debarments that was signed on April 9, 2010.\u0022  (Source: The World Bank Press Release No: 2012\/282\/INT, \u0022Enforcing Accountability: World Bank Debars Alstom Hydro France, Alstom Network Schweiz AG, and their Affiliates,\u0022 February 22, 2012.)","Sources ":"The World Bank Press Release No: 2012\/282\/INT, \u0022Enforcing Accountability: World Bank Debars Alstom Hydro France, Alstom Network Schweiz AG, and their Affiliates,\u0022 February 22, 2012, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,print:Y~isCURL:Y~contentMDK:23123315~pagePK:34370~piPK:34424~theSitePK:4607,00.html","Documents":""},{"Case ID":"ST-39","Case Cluster ":"Alstom S.A.","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Latvia, Malaysia, Tunisia","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"11\/22","Other Jurisdictions of Settlement":"World Bank","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Summary Punishment Order ","Monetary Sanctions  (Types)":"Criminal Fine, Confiscation of Profits, Legal Costs","Total Monetary Sanctions (US$)":"$42,485,594.00","Criminal Fine\/Penalty (US$) ":"$2,723,790","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$39,658,300","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"$103,504 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"$0","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8, Art. 9","Offenses - Alleged":"Bribery of foreign officials, Not take all necessary and reasonable organizational precautions to prevent bribery of foreign officials in the course of its business operations (Art. 102 Section 2 Swiss Criminal Code in conjunction with Art. 322 of the Swiss Criminal Code)","Offenses - Settled":"Bribery of foreign officials, Not take all necessary and reasonable organizational precautions to prevent bribery of foreign officials in the course of its business operations (Art. 102 Section 2 Swiss Criminal Code in conjunction with Art. 322 of the Swiss Criminal Code)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Summary Punishment Order of the Office of the Swiss Attorney General, dated November 22, 2011, \u0022In complete disregard of the internal provisions [for selecting and using consultants] . . . the Defendant [Alstom] through its representatives signed consultancy agreements with pure offshore and shell companies in the cases relevant to the current proceedings. [   ] The fact that payments were carried out and made by the Defendant on the basis of such consultancy agreements into the accounts of offshore and shell companies both nationally and abroad, i.e. into accounts located outside the project country, meant that there was a higher risk, as a matter of principle not tolerated by internal guidelines, that such payments could be used for bribery or for other illegal purposes.\u0022 (Source: Summary Punishment Order at para 10.)  According to the Summary Punishment Order, this misconduct continued after active foreign bribery sanctions entered into effect, and \u0022It must be held in the OAG\u0027s [Office of the Attorney General\u0027s] consideration that the company did not take all necessary and reasonable precautions to prevent the bribery of foreign public officials, as a result of which bribery of foreign public officials did in fact occur in three cases.\u0022  (Source: Summary Punishment Order at para 11.)  (1) In Latvia, from 2006 onwards, bribe payments were funnelled to legal entities SIA Energy Consulting (Latvia) and Kenmore OU (Estonia) controlled by Andrejs Livanovics, a former Alstom business development manager for the Baltics but the beneficiaries of the success fees were executives of the state owned company LATVENERGO AS who were decisively involved in decisions related to awarding contracts; (2) in Tunisia, \u0022consultancy\u0022 payments to companies controlled by Slim CHIBOUB, a son-in-law of the former President of Tunisia; the companies were Roserton Overseas SA (Panama) and Dalmel Trading, Inc. (BVI); and (3) in Malaysia, in connection with the state-licensed Teknologi Tenaga Perlis Consortium Sdtn Bhd, Alstom companies were used as intermediary companies for \u0022consulting agreements\u0022 for which the beneficiaries were TTPC executives Chee Liang TI and Abdul Hamid PAWANTEH (latter was also a local politician in the constituent state of Perlis where the power station was to be built).  The involved Alstom companies were: in Latvia - Alstom Power Sweden AB and Alstom Hydro Sweden AB; in Tunisia - Alstom Power Centrales; in Malaysia - Alstom Schweiz AG and Alstom power O\u0026M AG.  Alstom was fined CHF 2.5 million; compensatory claim of CHF 36.4 million; and CHF 95,217,70 in procedural fees.  (Source: Office of the Swiss Attorney General, Summary Punishment Order, in the Investigation of Alstom Network Schweiz AG, November 22, 2011.)  According to a statement by Alstom, the Swiss Attorney General issued a dismissal order regarding any other proceedings against Alstom; and the company decided not to challenge the decision of the Attorney General. (Source: Alstom Company Statement, \u0022The Swiss Office of Attorney General confirms the absence of any bribery system at Alstom. It fines the company for \u0027corporate negligence\u0027 in three isolated cases,\u0022 November 22, 2011.)\t\t\t\t","Sources ":"Office of the Swiss Attorney General, Summary Punishment Order, in the Investigation of Alstom Network Schweiz AG, November 22, 2011, accessed at scribd.com (link provided at Samuel Rubenfeld, Wall Street Journal Corruption Currents, \u0022Alstom Fined By Switzerland in Bribery Case,\u0022 November 22, 2011, at http:\/\/blogs.wsj.com\/corruption-currents\/2011\/11\/22\/alstom-fined-by-switzerland-in-bribery-case\/; The [Swiss] Office of the Attorney General Press Release, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011, accessed at http:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=42300; Alstom Company Statement, \u0022The Swiss Office of Attorney General confirms the absence of any bribery system at Alstom. It fines the company for \u0027corporate negligence\u0027 in three isolated cases,\u0022 November 22, 2011, accessed at http:\/\/www.alstom.com\/news-and-events\/press-releases\/The-Swiss-Office-of-Attorney-General-confirms-the-absence-of-any-bribery-system-at-Alstom\/.  See also, Organisation of Economic Co-operation and Development, Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland, Adopted by the OECD Working Group on Bribery on December 16, 2011, at 55 and throughout, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf","Documents":""},{"Case ID":"ST-40","Case Cluster ":"AMAC International","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"04\/07","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$386,740.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$386,740","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of foreign officials, Unlawful export of a defense article","Offenses - Settled":"Bribery of foreign officials, Unlawful export of a defense article","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 AMAC International, at 56-57, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf:  Time period of misconduct in China 2003-2007; native Chinese physicist Shu Quan-Sheng allegedly offered illicit payments worth $189,300 to officials within the PRC\u0027s 101st Research Institute, a component of the China Academy of Launch Vehicle Technology prior to the awarding of a $4 million project contract and that the successful brokering of the deal between AMAC and a French company (identified only as \u0022French Company A\u0022 in criminal information) earned Shu and AMAC a commission.  Resulting criminal enforcement action: US v. Shu Quan-Sheng (E.D. Va., November 12, 2008). ","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 AMAC International, at 56-57, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Department of Justice Press Release, \u0022Virginia Physicist Pleads Guilty to Illegally Exporting Space Launch Data to China and Offering Bribes to Chinese Officials,\u0022 November 17, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/November\/08-nsd-1020.html (accessed September 15, 2011); US v. Shu Quan-Sheng, Case 2:08-cr-00194-HCM-TEM (E.D. Va., 2008), Criminal Information filed on November 12, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/quan-shengs\/11-12-08sheng-info.pdf.","Documents":""},{"Case ID":"ST-41","Case Cluster ":"AMEC plc","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"10\/26","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Civil Recovery Order (Proceeds of Crime Act)","Monetary Sanctions  (Types)":"Civil Recovery Order, Legal Costs","Total Monetary Sanctions (US$)":"$8,057,800.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$8,057,800","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Inaccurate books and records, in violation of Section 221 of Companies Act 1985","Offenses - Settled":"Inaccurate books and records, in violation of Section 221 of Companies Act 1985","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the October 26, 2009 press release by the UK Serious Fraud Office (SFO), AMEC made a referral to the SFO in March 2008, following an internal investigation into the receipt of irregular payments made between November 2005 and March 2007, and associated with a project [unnamed] in which AMEC is a shareholder. SFO investigated and in a Consent Order agreed before the High Court on October 26, 2009, AMEC agreed to a settlement payment of GBP 4,943,648 plus the costs incurred [amount not given; unable to add to entry] as a result of the Civil Recovery proceedings. The press release stated that \u0022It is not possible to make any further comment as there is an ongoing criminal investigationinto related matters.\u0022  (Source: UK Serious Fraud Office Press Release, \u0022SFO Obtains Civil Recovery Order against AMEC plc,\u0022 October 26, 2009, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2009\/sfo-obtains-civil-recovery-order-against-amec-plc.aspx.)  AMEC\u0027s announcement on the settlement noted that the payments totalled some US $9 million and was associated with the last remaining Private-Public Partnership project and the division it belonged to was divested in mid-2007. (Source: AMEC plc, \u0022AMEC plc - Statement on civil recovery order,\u0022 October 26, 2009, accessed at http:\/\/www.amec.com\/media\/news_releases\/2009\/AMEC_statement_on_civil_recovery_order.htm).  Media reports that the project in question was the Incheon Bridge project in South Korea. (Source: Simon Bowers, \u0022Amec and Serious Fraud Office settle $9m \u0027irregular receipts\u0027 case,\u0022 The Guardian, October 26, 2009, accessed at http:\/\/www.guardian.co.uk\/business\/2009\/oct\/26\/amec-sfo-settlement\/print.)","Sources ":"UK Serious Fraud Office Press Release, \u0022SFO obtains Civil Recovery Order against AMEC plc,\u0022 October 26, 2009, accessed at http:\/\/www.sfo.gov.uk\/press-room\/press-release-archive\/press-releases-2009\/sfo-obtains-civil-recovery-order-against-amec-plc.aspx; AMEC plc, \u0022AMEC plc - Statement on civil recovery order,\u0022 October 26, 2009, accessed at http:\/\/www.amec.com\/media\/news_releases\/2009\/AMEC_statement_on_civil_recovery_order.htm; Simon Bowers, \u0022Amec and Serious Fraud Office settle $9m \u0027irregular receipts\u0027 case,\u0022 The Guardian, October 26, 2009, accessed at http:\/\/www.guardian.co.uk\/business\/2009\/oct\/26\/amec-sfo-settlement\/print.","Documents":""},{"Case ID":"ST-42","Case Cluster ":"AMEC plc","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; General Services Administration Inspector General","Jurisdiction of Foreign Public Official(s) ":"United Kingdom, United States ","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"02\/02","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Agree to Civil Penalties, Forfeit previous claim","Monetary Sanctions  (Types)":"Civil Penalty, Forfeit Previous Claim","Total Monetary Sanctions (US$)":"$19,040,256.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"$19,040,256","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Fraud, False Claims, Kickbacks; Excessive re-procurement costs","Offenses - Settled":"Fraud, False Claims, Kickbacks; Excessive re-procurement costs","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a US Department of Justice Press Release, AMEC Construction Management Inc. agreed to pay $19 million to settle litigation regarding fraud, false claims, kick-backs and re-procurement costs on US federal construction projects.  In one of the counterclaims filed in the US Court of Federal Claims, the US had sought damages and penalties under the False Claims Act, the Anti-Kickback Act and common law theories for false bond reimbursement claims submitted by AMEC Construction Management Inc. (ACMI) to the US General Services Administration (GSA) and bond premium kickbacks paid by the company\u0027s bond broker to ACMI\u0027s United Kingdom parent company, AMEC plc, on four federal contracts. (Source: US Department of Justice, U.S. Recovers $19 Million from AMEC Construction Management to Settle Litigation Regarding Fraud, False Claims, Kickbacks \u0026 Re-Procurement Costs on Federal Construction Contracts,\u0022 February 2, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/February\/09-civ-085.html). Additional details also in US General Services Administration Inspector General Press Release, \u0022GSA OIG Recovers Over $19 Million in False Claims from GSA Contractor -- Contractor Also Forfeits $83.5 Million in Pending Claims,\u0022 accessed at http:\/\/www.gsaig.gov\/index.cfm\/news\/gsa-oig-recovers-over-19-million-in-false-claims-from-gsa-contractor-contractor-also-forfeits-83,5-million-in-pending-claims\/.","Sources ":"US Department of Justice Press Release, \u0022U.S. Recovers $19 Million from AMEC Construction Management to Settle Litigation Regarding Fraud, False Claims, Kickbacks \u0026 Re-Procurement Costs on Federal Construction Contracts,\u0022 February 2, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/February\/09-civ-085.html; US General Services Administration Inspector General Press Release, \u0022GSA OIG Recovers Over $19 Million in False Claims from GSA Contractor -- Contractor Also Forfeits $83.5 Million in Pending Claims,\u0022 accessed at http:\/\/www.gsaig.gov\/index.cfm\/news\/gsa-oig-recovers-over-19-million-in-false-claims-from-gsa-contractor-contractor-also-forfeits-835-million-in-pending-claims\/.","Documents":""},{"Case ID":"ST-43","Case Cluster ":"American Bank Note Holographics, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2001","Month\/Day of Settlement (or Notes)":"07\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$75,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$75,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 American Bank Note Holographics, Inc. at 114-115 and Information filed in US v. Joshua Cantor:  On July 17, 2001, Cantor pleaded guilty to a 4-count information charging him with conspiracy to commit securities fraud, falsify books and records, lie to auditors and conspiracy to violate the FCPA.  Cantor was the president of American Bank Note Holographics, and the company was approached by the Saudi Arabian Monetary Agency with the opportunity to be the supplier of the hologram for a commemorative Saudi Arabian banknote.  In May 1998, one of ABNH\u0027s overseas agents informed ABNH that its bid would need to include \u0022an additional sum to cover consultancy fees.\u0022 ABNH eventually won the bid and consultancy fees in the amount of $239,000 were transferred to Bank Account #47377V at Credit Agricol Indosuez in Geneva, Switzerland held in the name of an entity \u0022Satapco\u0022 and the Saudi foreign official, who served as Director of the Issues and Vaults Department of SAMA, received at least a portion of the $238,000 consultancy fee. As of July 11, 2012, Cantor had not yet been sentenced. (Source: US v. Cantor, Case No. 1:01-cr-687-BSJ (S.D.N.Y.), Information, Plea and transcript of Plea Hearing, all July 17, 2001, accessed at fcpa.shearman.com; court docket report as of July 11, 2012 accessed via PACER.) ABNH settled with the SEC without admitting or denying the charges in the complaint and agreed to pay $75,000 in civil penalties. (Source: SEC v. American Bank Note, Case No. 1:01-cv-06453-JSR (S.D.N.Y.), Court Docket Report, entry of Judgment on July 20, 2001.). In addition to criminal case against Joshua Cantor, related civil enforcement actions: SEC v. Joshua Cantor (S.D.N.Y., April 10, 2003); SEC v. American Bank Note Holographics, Inc. (S.D.N.Y., July 18, 2001); and In the Matter of American Bank Note Holographics, Inc. (S.D.N.Y., July 18, 2001) ","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 American Bank Note Holographics, Inc. at 114-115, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf;  http:\/\/www.justice.gov\/opa\/pr\/2005\/March\/05_crm_090.htm; US v. Joshua C. Cantor, Case No. 1:01-cr-687-BSJ (S.D.N.Y.), Information, Plea and transcript of Plea Hearing, all July 17, 2001, accessed at fcpa.shearman.com; court docket report as of October 12, 2011, obtained via Pacer; SEC v. American Bank Note, Case No. 1:01-cv-06453-JSR (S.D.N.Y.), Court Docket Report, entry of Judgment on July 20, 2001, accessed at fcpa.shearman.com","Documents":""},{"Case ID":"ST-44","Case Cluster ":"American Bank Note Holographics, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2003","Month\/Day of Settlement (or Notes)":"04\/11","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"None ","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 American Bank Note Holographics, Inc. at 114-115 and Information filed in US v. Joshua Cantor:  On July 17, 2001, Cantor pleaded guilty to a 4-count information charging him with conspiracy to commit securities fraud, falsify books and records, lie to auditors and conspiracy to violate the FCPA.  Cantor was the president of American Bank Note Holographics, and the company was approached by the Saudi Arabian Monetary Agency with the opportunity to be the supplier of the hologram for a commemorative Saudi Arabian bank note.  In May 1998, one of ABNH\u0027s overseas agents informed ABNH that its bid would need to include \u0022an additional sum to cover consultancy fees.\u0022 ABNH eventually won the bid and consultancy fees in the amount of $239,000 were transferred to Bank Account #47377V at Credit Agricol Indosuez in Geneva, Switzerland held in the name of an entity \u0022Satapco\u0022 and the Saudi foreign official, who served as Director of the Issues and Vaults Department of SAMA, received at least a portion of the $238,000 consultancy fee.  (Source: SEC v. American Bank Note, Case No. 1:01-cv-06453-JSR (S.D.N.Y.), Court Docket Report, entry of Judgment on July 20, 2001.)   According to the Final Judgment in Mr. Cantor\u0027s SEC case, without admitting or denying the alleged offenses, he consented to the entry of a Cease and Desist Order. (Source: US SEC v. Joshua Cantor, Case No. 03-cv-2488 (S.D.N.Y.), Final Judgment filed April 11, 2011.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 American Bank Note Holographics, Inc. at 114-115, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf. SEC v. American Bank Note, Case No. 1:01-cv-06453-JSR (S.D.N.Y.), Court Docket Report, entry of Judgment on July 20, 2001, accessed at fcpa.shearman.com; US SEC v. Joshua Cantor, Case No. 03-cv-2488 (S.D.N.Y.), Final Judgment filed April 11, 2011, accessed at fcpa.shearman.com","Documents":""},{"Case ID":"ST-45","Case Cluster ":"American Rice, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Haiti","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"12\/30","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$11,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$11,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.27","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Aiding and abetting co-defendants\u0027 bribery of foreign officials","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"No (Customs) ","Summary":"According to the US Securities and Exchange Commission\u0027s Litigation Release, on December 30, 2004, the US District Court for the Southern District of Texas entered a Final Judgment enjoining Mr. Theriot from future FCPA violations and ordered him to pay a $11,000 civil penalty.  Mr. Theriot, a consultant to American Rice, Inc. consented to the Final Judgment without admitting or denying the SEC\u0027s allegations.  The SEC had alleged that Mr. Theriot aided and abetted a bribery scheme in violation of the FCPA, namely that from 1998 to 1999, an American Rice vice president authorized and the company made at least 12 separate bribery payments to Haitian customs officials, totalling approximately $500,000.  In exchange, Haitian customs officials permitted American Rice to illegally avoid approximately $1.5 million in Haitian import taxes.  (Source:  US Securities and Exchange Commission, Litigation Release No. 19026 \/ January 7, 2005, SEC v. Douglas A. Murphy, David G. Kay and Lawrence H. Theriot, Civil Action No. H-02-2908 (S.D. Texas), \u0022Lawrence H. Theriot Consents to Permanent Inunction and Payment of Civil Penalty for Aiding and Abetting Violations of the Foreign Corrupt Practices Act\u0022).  According to the June 2011 US Report to the OECD on the Enforcement of the Anti-Bribery Convention, \u0022The civil matter against [co-defendants] Kay and Murphy were suspended until sentencing, and the SEC has not yet moved to reopen the case.\u0022 The same report noted that Kay and Murphy were convicted on October 6, 2004.  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, American Rice, Inc. Case,  at 126-127.)  ","Sources ":"US Securities and Exchange Commission, Litigation Release No. 19026 \/ January 7, 2005, SEC v. Douglas A. Murphy, David G. Kay and Lawrence H. Theriot, Civil Action No. H-02-2908 (S.D. Texas),\u0022Lawrence H. Theriot Consents to Permanent Injunction and Payment of Civil Penalty for Aiding and Abetting Violations of the Foreign Corrupt Practices Act,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr19026.htm; copy of complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/comp17651.htm; US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, American Rice, Inc. at 126-127, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf","Documents":""},{"Case ID":"ST-46","Case Cluster ":"Aon Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Bangladesh, Bulgaria, Costa Rica, Egypt, Indonesia, Myanmar, Panama, the United Arab Emirates, and Vietnam","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"12\/20","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$1,764,000.00","Criminal Fine\/Penalty (US$) ":"$1,764,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"Falsification of books and records, Internal controls violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022Aon Corporation, a publicly traded corporation headquartered in Chicago and one of the largest insurance brokerage firms in the world, has entered into an agreement with the Department of Justice to pay a $1.76 million penalty to resolve violations of the Foreign Corrupt Practices Act (FCPA). [ ] According to the non-prosecution agreement, Aon\u0027s United Kingdom subsidiary, Aon Limited, administered certain training and education funds in connection with its reinsurance business with Instituto Nacional De Seguros (INS), Costa Rica\u0027s state-owned insurance company.   The supposed purpose of the funds was to provide education and training for INS officials.   However, between 1997 and 2005, Aon Limited used a significant portion of the funds to reimburse INS officials for non-training related activity, including travel with spouses to overseas tourist destinations, or for uses that could not be determined from Aon\u0027s books and records.   Many of the invoices and other records for trips taken by INS officials did not provide any business purpose for the expenditures, or showed that the expenses were clearly not related to a legitimate business purpose.   As part of the agreement, Aon admitted that Aon Limited\u0027s accounting books and records related to the funds, which were consolidated into Aon\u0027s books and records, did not accurately and fairly reflect the purpose for which the expenses were incurred.   Aon also admitted that it failed to devise and maintain an adequate system of internal accounting controls with respect to foreign sales activities sufficient to ensure compliance with the FCPA.\u0022 (Source: US Department of Justice Press Release, \u0022Aon Corporation Agrees to Pay $1.76 Million Criminal Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 December 20, 2011.)  The Non-Prosecution Agreement stated that \u0022The Department enters into this Non-Prosecution Agreement based, in part, on the following factors: (a) Aon\u0027s extraordinary cooperation with the Department and the U.S. Securities and Exchange Commission (\u0022SEC\u0022); (b) Aon\u0027s timely and complete disclosure of the facts described in Appendix A as well as facts relating to Aon\u0027s improper payments in Bangladesh, Bulgaria, Egypt, Indonesia, Myanmar, Panama, the United Arab Emirates, and Vietnam that it discovered during its thorough investigation of its global operations; (c) the early and extensive remedial efforts undertaken by Aon, including the substantial improvements the company has made to its anti-corruption compliance procedures; (d) the prior financial penalty of [GBP] 5.25 million paid to the United Kingdom\u0027s Financial Services Authority (\u0022FSA\u0022) by Aon Limited, a U.K. subsidiary of Aon, in 2009, covering the conduct in Bangladesh, Bulgaria, Indonesia, Myanmar, the United Arab Emirates, and Vietnam; and (c) the FSA\u0027s close and continuous supervisory oversight over Aon Limited.\u0022 (US Department of Justice, In Re: Aon Corporation, Non-Prosecution Agreement of December 20, 2011.)","Sources ":"US Department of Justice, In Re: Aon Corporation, Non-Prosecution Agreement, December 20, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/aon\/2011-12-20-aon-final-executed-npa.pdf; US Department of Justice Press Release, \u0022Aon Corporation Agrees to Pay $1.76 Million Criminal Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 December 20, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/December\/11-crm-1678.html","Documents":""},{"Case ID":"ST-47","Case Cluster ":"Aon Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Costa Rica, Egypt, Vietnam, Indonesia, United Arab Emirates, Myanmar, Bangladesh and other unspecified countries","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"12\/20","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest ","Total Monetary Sanctions (US$)":"$14,545,020.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$11,416,814","Civil Prejudgment Interest (US$) ":"$3,128,206","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Securities and Exchange Commission Litigation Release, on December 20, 2011, the Commission \u0022today filed a settled enforcement action in the U.S. District Court for the District of Columbia against Aon Corporation (Aon), an Illinois-based global provider of risk management services, insurance and reinsurance brokerage, alleging violations of the books and records and internal controls provisions of the Foreign Corrupt Practices Act (FCPA). Aon will pay a total of approximately $14.5 million in disgorgement and prejudgment interest to the SEC. In a related action, Aon will pay a $1.764 million criminal fine to the U.S. Department of Justice (DOJ).  The Commission\u0027s complaint alleges that Aon\u0027s subsidiaries made over $3.6 million in improper payments to various parties between 1983 and 2007 as a means of obtaining or retaining insurance business in those countries. The complaint alleges that some of the improper payments were made directly or indirectly to foreign government officials who could award business directly to Aon subsidiaries, who were in position to influence others who could award business to Aon subsidiaries, or who could otherwise provide favorable business treatment for the company\u0027s interests. The complaint alleges that these payments were not accurately reflected in Aon\u0027s books and records, and that Aon failed to maintain an adequate internal control system reasonably designed to detect and prevent the improper payments.  According to the Commission\u0027s complaint, the improper payments made by Aon\u0027s subsidiaries fall into two general categories: (i) training, travel, and entertainment provided to employees of foreign government-owned clients and third parties; and (ii) payments made to third-party facilitators. Aon subsidiaries made these payments in various countries around the world, including Costa Rica, Egypt, Vietnam, Indonesia, United Arab Emirates, Myanmar, and Bangladesh. The complaint alleges that Aon realized over $11.4 million in profits from these improper payments.\u0022  The SEC Litigation Release acknowledged the assistance of the UK Financial Services Authority in this matter. (Source: US Securities and Exchange Commission, Litigation Release No. 22203 \/ December 20, 2011, Securities and Exchange Commission vs. Aon Corporation, Civil Action No. 1:11-cv-02256 (D.D.C.) (filed Dec. 20, 2011), \u0022SEC Files Settled FCPA Charges against Aon Corporation.\u0022) ","Sources ":"US Securities and Exchange Commission, Litigation Release No. 22203 \/ December 20, 2011, Securities and Exchange Commission vs. Aon Corporation, Civil Action No. 1:11-cv-02256 (D.D.C.) (filed Dec. 20, 2011), \u0022SEC Files Settled FCPA Charges against Aon Corporation,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr22203.htm; Copy of Complaint (filed December 20, 2011), accessed at http:\/\/www.scribd.com\/doc\/76161974\/SEC-Complaint-Aon.","Documents":""},{"Case ID":"ST-48","Case Cluster ":"Aon Corporation","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Financial Services Authority","Jurisdiction of Foreign Public Official(s) ":"[payments to third parties in Bahrain, Bangladesh, Bulgaria, Burma, Indonesia, and Vietnam]","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"1\/6","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Final Notice (of Penalty)","Monetary Sanctions  (Types)":"Civil Penalty  ","Total Monetary Sanctions (US$)":"$7,632,400.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$7,632,400","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Financial Services Authority Principle 3 (reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems)","Offenses - Settled":"Financial Services Authority Principle 3 (reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Financial Services Authority\u0027s Final Notice of January 6, 2009 to Aon Limited, the FSA issued the penalty of GBP 5.25 million (US $7,864,970) in respect to Aon Limited\u0027s breach of Principle 3 of the FSA\u0027s Principles for Businesses which occurred between January 2005 and September 2007.  The Final Notice stated that the company qualified for a 30% discount under the FSA\u0027s settlement discount scheme and that without the discount the fine would have been GBP 7.5 million. As a result of the systems and controls failings at Aon Limited, this gave rise to unacceptable risk that Aon Ltd could become involved in potentially corrupt payments to win or retain busines.  During the relevant period, 66 suspicious payments amounting to US$2.5 million and EUR 3.4 million were paid to nine \u0022Overseas Third Parties\u0022 (and a number of other suspicious payments to those Overseas Third Parties were made prior to the 2005, before Aon became regulated by the FSA).  The Final Oder stated that as a result of the suspicious payments, business that may have been secured or retained amounted to approximately US $7.2 million and EUR 1 million. An Explanatory Note of February 27, 2009 to the Final Order noted that while certain payments were made through Aon\u0027s Bahraini business (Aon Re Middle East WLL) during the Relevant Period, the Final Notice relates solely to Aon Ltd in the UK and the FSA\u0027s investigation did not identify any payments made to Bahraini individuals or companies. (Source: UK Financial Services Authority, Final Notice of January 6, 2009 to AON Limited and \u0022Explanatory Note to the Final Notice for Aon Limited dated 6 January 2009,\u0022 February 27, 2009, accessed at http:\/\/www.fsa.gov.uk\/pubs\/final\/aon.pdf and UK Financial Services Authority Press Release, \u0022FSA fines AON Limited [GBP] 5.25m for failings in its anti-bribery and corruption systems and controls,\u0022 FSA\/PN\/004\/2009, January 8, 2009, accessed at http:\/\/www.fsa.gov.uk\/pages\/Library\/Communication\/PR\/2009\/004.shtml.)  ","Sources ":"UK Financial Services Authority, Final Notice of January 6, 2009 to AON Limited and \u0022Explanatory Note to the Final Notice for Aon Limited dated 6 January 2009,\u0022 February 27, 2009, accessed at http:\/\/www.fsa.gov.uk\/pubs\/final\/aon.pdf and UK Financial Services Authority Press Release, \u0022FSA fines AON Limited [GBP] 5.25m for failings in its anti-bribery and corruption systems and controls,\u0022 FSA\/PN\/004\/2009, January 8, 2009, accessed at http:\/\/www.fsa.gov.uk\/pages\/Library\/Communication\/PR\/2009\/004.shtml; see also, United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf","Documents":""},{"Case ID":"ST-49","Case Cluster ":"Armor Holdings, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"United Nations","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"07\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$10,290,000.00","Criminal Fine\/Penalty (US$) ":"$10,290,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Failure to maintain books and records, Internal controls violations","Offenses - Settled":"Failure to maintain books and records, Internal controls violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release regarding its Non-Prosecution Agreement with Armor Holdings, the company \u0022accepts responsibility for its subsidiary\u0027s payment of more than $200,000 in commissions to a third-party sales agent, a portion of which it knew was to be passed on to a U.N. procurement official to induce the official to award two separate U.N. contracts to Armor?s subsidiary. The contracts were for the sale of approximately $6 million of body armor.   Armor also acknowledged that it falsely recorded the commission payments on its books and records. In addition, Armor admitted that it kept off its books and records approximately $4.4 million in additional payments to agents and other third-party intermediaries used by its Products Group to assist it in obtaining business from foreign government customers.   Armor acknowledged that it failed to devise and maintain an appropriate system of internal accounting controls.  In a related matter, Armor reached a settlement today with the U.S. Securities and Exchange Commission (SEC) and agreed to pay more than $5.69 million in disgorgement of profits, including pre-judgment interest, and a civil money penalty.\u0022 (Source:  US Department of Justice Press Release, \u0022Armor Holdings Agrees to Pay $10.2 Million Criminal Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 July 13, 2011.)","Sources ":"US Department of Justice, In Re: Armor Holdings, Inc., Non-Prosecution Agreement (July 13, 2011), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/armor\/07-31-11armor-holdings.pdf; US Department of Justice Press Release, \u0022Armor Holdings Agrees to Pay $10.2 Million Criminal Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 July 13, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/July\/11-crm-911.html","Documents":""},{"Case ID":"ST-50","Case Cluster ":"Armor Holdings, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"United Nations","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"07\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$5,690,744.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,552,306","Civil Prejudgment Interest (US$) ":"$458,438","Civil Fine \/ Penalty (US$)":"$3,680,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Failure to maintain books and records, Internal controls violations","Offenses - Settled":"Failure to maintain books and records, Internal controls violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release regarding its Non-Prosecution Agreement with Armor Holdings, the company \u0022accepts responsibility for its subsidiary\u0027s payment of more than $200,000 in commissions to a third-party sales agent, a portion of which it knew was to be passed on to a U.N. procurement official to induce the official to award two separate U.N. contracts to Armor\u0027s subsidiary. The contracts were for the sale of approximately $6 million of body armor.   Armor also acknowledged that it falsely recorded the commission payments on its books and records. In addition, Armor admitted that it kept off its books and records approximately $4.4 million in additional payments to agents and other third-party intermediaries used by its Products Group to assist it in obtaining business from foreign government customers.   Armor acknowledged that it failed to devise and maintain an appropriate system of internal accounting controls.\u0022  (Source:  US Department of Justice Press Release, \u0022Armor Holdings Agrees to Pay $10.2 Million Criminal Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 July 13, 2011.)  According to the US Securities and Exchange Commission Litigation Release, Without admitting or denying the allegations in the Commission\u0027s complaint, Armor Holdings has consented to a court order permanently enjoining it from violating Sections 30A, 13(b)(2)(A), and 13(b)(2)(B) of the Exchange Act; ordering it to pay disgorgement of $1,552,306, together with prejudgment interest of $458,438; imposing on it a civil penalty of $3,680,000 [  ] The proposed settlement is subject to court approval.\u0022 (Source: US Securities and Exchange Commission, Litigation Release No. 22037 \/ July 13, 2011, Securities and Exchange Commission v. Armor Holdings, Inc., Case No. 1:11-cv-01271(D. D.C.)(ESH) (filed July 13, 2011), \u0022SEC FILES SETTLED ANTI-BRIBERY, BOOKS AND RECORDS, AND INTERNAL CONTROLS CHARGES AGAINST ARMOR HOLDINGS, INC.\u0022)   Please note that according to the Court Docket Report, as of December 28, 2011, the case had been reassigned to another judge in July 2011 and no judgment ordered yet in this case. (Source: SEC v. Armor Holdings, Inc. Case No. 1:11-cv-01271 (D.D.C.), Court Docket Report as of December 28, 2011.)","Sources ":"US Department of Justice, In Re: Armor Holdings, Inc., Non-Prosecution Agreement (July 13, 2011), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/armor\/07-31-11armor-holdings.pdf; US Departmento of Justice Press Release, \u0022Armor Holdings Agrees to Pay $10.2 Million Criminal Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 July 13, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/July\/11-crm-911.html; US Securities and Exchange Commission, Litigation Release No. 22037 \/ July 13, 2011, Securities and Exchange Commission v. Armor Holdings, Inc., Case No. 1:11-cv-01271 (D. D.C.)(ESH) (filed July 13, 2011), \u0022SEC FILES SETTLED ANTI-BRIBERY, BOOKS AND RECORDS, AND INTERNAL CONTROLS CHARGES AGAINST ARMOR HOLDINGS, INC.,\u0022 accessed at  http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr22037.htm; Complaint filed July 13, 2011, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp22037.pdf; SEC v. Armor Holdings, Inc. Case No. 1:11-cv-01271 (D.D.C.), Court Docket Report as of December 28, 2011 (accessed via Pacer).","Documents":""},{"Case ID":"ST-51","Case Cluster ":"Avery Dennison Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China and several (unnamed) countries","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"07\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$518,470.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$273,213","Civil Prejudgment Interest (US$) ":"$45,257","Civil Fine \/ Penalty (US$)":"$200,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal Controls Violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Avery Dennison Corporation, at 39-40: Misconduct in China took place 2002-2005; (1) the Reflective Division of Avery (China) Co. Ltd. (Avery China) paid or authorized the payments of approximately $300,000 in kickbacks, sightseeing trips, and gifts to Chinese government officials; In one transaction, Avery China secured a sale to a state-owned end user by agreeing to pay a Chinese official a kickback of nearly $25,000 through a distributor. Avery China realized $273,313 in profits from this transaction. (2) illegal payments of approximately $51,000 by an Avery-acquired company, after acquisition, of making illegal petty cash payments to customs or other officials in several countries. Civil disposition: In administrative proceeding, SEC ordered Avery to cease and desist from such violations and to disgorge $273,213, with $45,257 in prejudgment interest. In federal civil action, Avery agreed to the entry of a final judgment requiring it to pay a civil penalty in the amount of $200,000.  Cases are: SEC v. Avery Dennison Corporation (C.D. Cal., July 28, 2009), In the Matter of Avery Dennison Corporation (July 28, 2009).","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Avery Dennison Corporation, at 39-40, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; In the Matter of Avery Dennison Corporation, Administrative Proceeding, File No. 3-13564, Order Instituting Cease-and-Desist Proceedings Pursuant to Section 21 C of the Securities Exchange Act of 1934, Making Findings, and Imposing a Cease-and-Desist Order (July 28, 2009), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2009\/34-60393.pdf; Litigation Release No. 21156 \/ July 28, 2009, accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21156.htm; SEC v. Avery Dennison, Corporation, Case No. 09-cv-5493-DSF (C.D. Cal.), Complaint filed July 28, 2009, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp21156.pdf","Documents":""}]}
{"arw":[{"Case ID":"ARW-255","Case Title (Name of Public Official or Entity Allegedly Involved)":"Diezani Alison-Madueke","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Minister of Petroleum (2010-2015)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"(1) Jurisdiction initiated legal action to recover assets \r\n(2) Jurisdiction of Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2017","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdictions","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"$114,000,000 (not confirmed)","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"In a 2017 civil forfeiture complaint, the U.S. DOJ alleges that from 2011 to 2015, Nigerian businessmen Kolawole Akanni Aluko and Olajide Omokore conspired with others to pay bribes to Nigeria\u2019s former Minister for Petroleum Resources, Diezani Alison-Madueke, who oversaw Nigeria\u2019s state-owned oil company. Diezani Alison-Madueke, a former President of OPEC, allegedly used her influence to steer lucrative oil contracts to two Nigerian shell companies set up and controlled by Aluko and Omokore.\nThe U.S. Department of Justice seeks recovery of $144 million in assets connected to Diezani Alison-Madueke, Kolawole Aluko, and Olajide Omokore, which it says are the proceeds of corruption in Nigeria. The assets subject to forfeiture include a $50 million condominium in One57 - 157 W. 57th Street - one of Manhattan\u2019s most expensive buildings, and an $80 million yacht, known as Galactica Star.\nThe U.S. government further alleges that Aluko, Omokore and others funded a lavish lifestyle for Alison-Madueke, conspiring to purchase millions of dollars in real estate in and around London for Alison-Madueke and her family members, then renovated and furnished these homes with millions of dollars in furniture, artwork and other luxury items purchased at two Houston-area furniture stores at Alison-Madueke\u2019s direction. Aluko and Omokore also laundered proceeds into and through the U.S, and used it to purchase U.S. real estate. During the period from March 2012 through January 2015, Aluko purchased more than $87 million dollars\u2019 worth of real property in the United States and an $82 million luxury yacht, according to the DOJ complaint.","Disposition of Criminal Case(s)":"According to the U.S. DOJ\u2019s civil forfeiture complaint, in return for the bribes, Alison-Madueke allegedly used her influence as Petroleum Minister to direct a subsidiary of the Nigerian National Petroleum Corporation to award contracts to two shell companies created by Aluko and Omokore: Atlantic Energy Drilling Concepts Nigeria Ltd. and Atlantic Energy Brass Development Ltd, in 2011 and 2012. The companies were incorporated in Nigeria in 2010 and 2013 respectively, and were both owned by holding companies incorporated in the British Virgin Islands, beneficially owned by Aluko and Omokore. Omokore acted as a registered director of both Nigerian companies.\nUnder the contracts, the two companies were required to finance the exploration and production operations of eight on-shore oil and gas blocks. However, according to the DOJ complaint, the companies provided only a fraction of the agreed upon financing or, in some instances, failed entirely to provide it. The companies also failed to meet other contractual obligations, including the payment of a $120 million entry fee. Nevertheless, the companies were allegedly permitted to lift and sell more than $1.5 billion worth of Nigerian crude oil.\nA February 2014 report prepared by the then-governor of the Central Bank of Nigeria determined that Atlantic Energy Drilling Concepts Nigeria Ltd \u201chad neither the technical expertise nor the capital to develop the joint venture, but [was] none-the-less able to lift crude and retain the proceeds . . . up to 70% of the profit of the Joint Venture.\u201d The report concluded that the arrangement was set up \u201cfor the purpose of acquiring assets belonging to the [Federal Republic of Nigeria] and transferring the income to private hands.\u201d\nAtlantic Energy Brass Development Ltd allegedly sold $811 million worth of crude oil over the course of one year to a UK subsidiary of Glencore, \u201cdespite failing to meet any obligations\u201d under its contract with the Nigerian state-owned oil company, according to the DOJ.\nIn addition to the Nigerian companies and its BVI holding companies, the conspirators also set up a number of other BVI-registered companies and at least three companies incorporated in the Seychelles that were used by Aluko and Omokore to purchase real estate in the United Kingdom, allegedly for the benefit of Alison-Madueke. The $82 million yacht was bought by a company incorporated in the British Virgin Islands that was controlled and beneficially owned by Kolawore Aluko; the sale was brokered by a financial and corporate services company based in Guernsey. At least three companies incorporated in U.S. states \u2013 Nevada, Delaware, and California \u2013 were used by conspirators to spend corrupt funds at a furniture store in Houston, pay for transportation services, and purchase a property in Santa Barbara, California.\nAlison-Madueke is also under investigation by the National Crime Agency in the U.K., where she currently resides, for corruption and money laundering. In Nigeria, the former Petroleum minister is under investigation by the Economic and Financial Crimes Commission (EFCC) for diverting money from the Nigerian National Petroleum Corporation, (NNPC), but as of September 2017, no charges had been filed against her related to this case. She has been charged for money laundering in connection to a separate election-bribery case. Local Nigerian media reports say that EFCC recently blocked her application to travel to Nigeria and join the trial against her associate Omokore as a defendant, arguing that it was a ploy to escape prosecution in the U.K.","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission (EFCC). \r\nAccording to media reports, the Central Bank of Nigeria announced in May 2016 that it was participating in the investigation into corruption targeting the former oil minister.","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"FBI\u2019s International Corruption Squads in Washington, D.C. and Los Angeles and the IRS-CI","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. DOJ Criminal Division\u2019s Money Laundering and Asset Recovery Section","Jurisdiction of Asset Recovery: Courts Involved":"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/DOJ-Galactica-Complaint.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/DOJ%20Press%20Release%20-%20Alison-Madueke%20-%2014%20July%202017.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/U.S.%20Seeks%20%24144%20Million%20in%20Laundered%20Nigerian%20Oil%20Funds%20-%20Risk%20%26%20Compliance%20Journal.pdf","Sources ":"U.S.\u00a0DOJ Press Release, 14 July 2017\u00a0 https:\/\/www.justice.gov\/opa\/pr\/department-justice-seeks-recover-over-100...\n"},{"Case ID":"ARW-254","Case Title (Name of Public Official or Entity Allegedly Involved)":"1Malaysia Development Berhad (1MDB) (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Malaysia, Saudi Arabia, United Arab Emirates","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"(1) Jurisdiction that initiated legal action to recover assets; \r\n(2) Jurisdiction of asset location","Asset Recovery Start":"2016","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdictions","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"over $1.6 billion","Assets Adjudicated, Not Yet Returned (USD)":"$30 million","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"","Case Summary":"Members of an international conspiracy allegedly diverted \u201cmore than $4.5 billion\u201d in state funds from 1Malaysia Development Berhad (1MDB), a state investment fund wholly owned by the government of Malaysia, according to a series of civil forfeiture complaints filed in 2016 and 2017 under the U.S. DOJ Kleptocracy Asset Recovery Initiative. The United States is seeking to recover \u201calmost $1.7 billion\u201d of 1MDB funds that were allegedly laundered through the United States and are traceable to the conspiracy in \u201cthe largest single action ever brought under the [U.S. DOJ\u2019s] Kleptocracy Asset Recovery Initiative.\u201d In August 2017, the U.S. DOJ asked for a stay of the civil forfeiture cases pending the conclusion of a related federal criminal investigation.\nThe DOJ complaints allege that \u201cusing fraudulent documents and representations, the co-conspirators allegedly laundered the funds through a series of complex transactions and fraudulent shell companies with bank accounts located in the Singapore, Switzerland, Luxembourg and the United States. These transactions were allegedly intended to conceal the origin, source and ownership of the funds, and were ultimately processed through U.S. financial institutions and were used to acquire and invest in assets located in the United States.\u201d\nU.S. assets that were allegedly purchased with diverted 1MDB funds and are subject to forfeiture actions include high end real estate and hotel properties in New York, Los Angeles, and London; a $35 million jet airplane; a 300-foot luxury yacht; works of art by Vincent Van Gogh, Pablo Picasso, and Claude Monet; a substantial interest in the music publishing rights of EMI Music; the production of the 2013 film The Wolf of Wall Street; shares in Tech company Palantir and fitness company Flywheel; gambling expenses at Las Vegas casinos; and over $27.3m worth of diamond jewelry.\nAs of June 2018, U.S. authorities have frozen or restrained over $1.6 billion in assets related to this case. These assets are subject to ongoing, active litigation. Around $30 million in assets forfeited by U.S. authorities have been fully adjudicated. The restrained assets are located in the United States, Switzerland, Indonesia, Singapore, and London.\nProsecutors portray a Malaysian national called Jho Low as the mastermind of the complex embezzlement scheme. Although he held no official position with 1MDB, he de facto conducted extensive business for the state fund and set up a myriad of opaque shell companies around the world through which 1MDB funds were diverted and ultimately channeled into the United States, for the personal benefit of members of the conspiracy. Other conspirators allegedly implicated include a group of high-ranking Malaysian officials at 1MDB, two high-ranking UAE officials at an investment fund owned by Abu Dhabi government (Khadem Abdulla Al-Qubaisi and Mohamed Ahmed Badawy Al-Husseiny), and two Saudi nationals affiliated with a little-known Saudi oil company (PetroSaudi International). Malaysia\u2019s former prime minister Najib Razak and his stepson Riza Aziz are allegedly\u00a0implicated in the scheme and benefitted from diverted 1MDB funds, with Razak receiving funds totaling approximately $681 million directly into a bank account in his name, according to the U.S. DOJ\u2019s forfeiture complaints. One of the conspirators, Al-Husseiny, served as chairman of Falcon Bank, a private bank in Singapore and Switzerland, that was allegedly extensively used for moving and laundering funds in the scheme.\nTo divert funds from the 1MDB fund, disguise their origin, disguise the identity of the conspirators, and launder funds into the United States, prosecutors claim that the members of the conspiracy set up a vast network of corporate vehicles in offshore secrecy jurisdictions around the world. Corporate vehicles employed in this scheme were incorporated in jurisdictions including Seychelles, British Virgin Islands, Hong Kong, United Arab Emirates, Cura\u00e7ao, Malaysia, Cayman Islands, Luxembourg, and the United States (New York, Delaware). The diverted funds were allegedly transferred through bank accounts belonging to these companies in, among others, Singapore, Switzerland, USA, Netherlands, Luxembourg, Germany, and Barbados, with a majority of the money at some point passing through Singapore accounts, according to the forfeiture complaints.\nProsecutors further claim that several corporate vehicles were deceptively named to mimic an affiliation with a genuine, operational entity that 1MDB was doing business with or to mimic an affiliation with well-known global financial service companies, when in fact no such affiliation existed. Two shell companies, both called \u201cAabar Investments PJS Ltd\u201d, one registered in BVI and the other in the Seychelles, were named to give the impression that the CV was associated with Aabar Investments PJS, a legitimate subsidiary of Abu Dhabi investment company IPIC, which entered into a joint venture agreement with 1MDB. \u201cBlackstone Asia Real Estate Partners Ltd\u201d, \u201cAffinity Equity International Partners Limited\u201d, \u201cVista Equity International Partners Ltd\u201d were all named to mimic well-known global financial service companies. Also of note is the alleged use of an Interest on Lawyer Account (IOLA) and another attorney trust account held by U.S. law firms to launder diverted funds into the U.S. by purchasing real estate assets. Transfers totaling $368 million were made directly from an account of a Seychelles shell company to an IOLA account of a U.S. law firm.\nThe U.S. DOJ forfeiture complaints outline four distinct phases of the complex corruption scheme, named after key corporate vehicles that were employed: (1) the \u201cGood Star\u201d Phase, 2009-2011; (2) the \u201cAabar-BVI\u201d Phase, 2012; (3) the \u201cTanore\u201d Phase, 2013; and (4) the \u201cOptions Buyback\u201d Phase, 2014.\nDuring the \u201cGood Star\u201d Phase, 1MDB officials entered a joint venture agreement with PetroSaudi International, a little-known Saudi oil company founded in 2005 by a son of the late King Abdullah, for the stated purpose of exploiting certain energy concessions in Turkmenistan and Argentina. Under the terms of the agreement, 1MDB agreed to invest $1 billion in the newly created joint venture in exchange for a forty percent equity interest. 1MDB only transferred US$300 million into the account of the \u201clegitimate\u201d joint venture company and allegedly diverted US$700 million into a bank account at RBS Coutts, Switzerland, that was held by Good Star Limited, a Seychelles-registered corporate vehicle\u00a0beneficially owned by Jho Low. Conspirators made false representations to banks that Good Star was a wholly-owned subsidiary of PetroSaudi.\nDuring the \u201cAabar-BVI\u201d Phase, 1MDB raised additional funds through two separate bond offerings arranged and underwritten by Goldman Sachs. The bonds were guaranteed by both 1MDB and International Petroleum Investment Company (IPIC), an investment fund wholly-owned by the government of Abu Dhabi in the United Arab Emirates. 1MDB officials allegedly caused approximately $1.367 billion (40% of the bond proceeds) to be wire transferred to a Swiss bank account belonging to a British Virgin Islands entity that was deceptively named to mimic a legitimate subsidiary of IPIC.\nDuring the \u201cTanore\u201d Phase, several individuals, including 1MDB officials, allegedly diverted more than $1.26 billion out of a total of $3 billion in principal that 1MDB raised through a third bond offering arranged by Goldman Sachs in March 2013, via two bank accounts in Singapore held by a BVI-registered company.\nDuring the \u201cOptions Buyback\u201d phase, an additional $850 million in 1MDB funds was allegedly misappropriated under the guise of paying an IPIC subsidiary to relinquish certain options 1MDB had given in return for IPIC\u2019s guarantee of the 2012 bonds. To fund this options buyback, 1MDB borrowed a total of $1.225 billion from a syndicate of banks led by Deutsche Bank in Singapore, of which more than $850 million was allegedly diverted via two companies\u00a0incorporated in BVI and in the Seychelles.","Disposition of Criminal Case(s)":"In August 2017, the U.S. DOJ asked for a temporary stay of the civil forfeiture cases related to the 1MDB case, pending conclusion of related federal criminal investigations. In an affidavit supporting the government\u0027s motion to stay the forfeiture cases, a\u00a0FBI special agent wrote: \u0022The related criminal investigation is global in scope because the underlying crimes were committed over several years in numerous jurisdictions. Perpetrators, which includes both entities and individuals acting in individual and representative capacities, are believed to have committed violations of both U.S. and foreign laws. A significant amount of the evidence and\u00a0witnesses with knowledge of these violations are located in foreign jurisdictions, and will take time to pursue.\u0022 The FBI agent warned\u00a0that any further disclosure of information in the civil cases would risk revealing \u0022potential targets and subjects of the investigation and the investigative techniques that have been and will be used in the investigation.\u0022 No further information about the criminal cases is\u00a0publicly available, as of June 2018.\u00a0","Jurisdiction of Origin: Investigative Agency":"Malaysian Anti-Corruption Commission (referenced in the FBI\u0027s press release, 20 July 2016)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"FBI\u2019s International Corruption Units in New York and Los Angeles\r\nInternal Revenue Service\u2019s Criminal Investigative Division","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"This case is part of the U.S. DOJ\u0027s Kleptocracy Asset Recovery Initiative, led by a team of prosecutors in the Criminal Division\u2019s Asset Forfeiture and Money Laundering Section. Deputy Chief Woo S. Lee and Trial Attorney Kyle R. Freeny of the U.S. DOJ\u0027s Criminal Division\u2019s Asset Forfeiture and Money Laundering Section and Assistant U.S. Attorneys John Kucera and Christen Sproule of the Central District of California prosecuted the case. The Criminal Division\u2019s Office of International Affairs provided additional assistance.","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Central District of California","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/DOJ%20Press%20Release%20-%20July%202016.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/DOJ%20Press%20Release%20-%20June%202017.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/FBI%20Press%20Release%20-%2020%20July%202016.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Viceroy_complaint.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/wolf_of_wall_street_complaint.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/van_gogh_drawing_complaint.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/park_laurel_complaint.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/oriole_drive_complaint.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/park_lane_complaint.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/lermitage_complaint.pdf","Sources ":"U.S. DOJ Kleptocracy Asset Recovery Initiative - Documents\nhttps:\/\/www.justice.gov\/archives\/kleptocracy-enforcement-action\n"},{"Case ID":"ARW-253","Case Title (Name of Public Official or Entity Allegedly Involved)":"Teodoro Nguema Obiang Mangue (11 luxury cars seized in Geneva)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Equatorial Guinea","Position of Public Official(s) (yrs in office)":"Vice President of Equatorial Guinea (2012-2018) and son of President Teodoro Obiang Nguema Mbasogo (1979 - current)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"(1) Jurisdiction initiated legal action to recover assets \r\n(2) Jurisdiction of Asset Location","Asset Recovery Start":"2016","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdictions","Intl.Cooperation: MLAT\/Letter of Request?":"NA","Basis for Intl Cooperation":"N\/A - The related criminal investigation was initiated by the Swiss Public Prosecutor. ","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"\u0022more than $8 million\u0022 (estimate) ","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"In November 2016, Swiss authorities seized 11 luxury cars as part of criminal proceedings opened against Teodoro Nguema Obiang Mangue, the son of Equatorial Guinea\u2019s longtime leader, on suspicions of money laundering. The prosecutor\u2019s office said in an e-mailed statement to Reuters: \u201cThe Geneva public prosecutor confirms the opening of criminal proceedings against Teodorin Obiang. The latter is accused of money laundering.\u201d \u201cAs part of the procedure, 11 vehicles were effectively sequestered in the cargo area of \u200b\u200bGeneva airport on behalf of the prosecution.\u0022\nThe cars seized by the Geneva police were a Bugatti Veyron, four Ferraris including an Enzo and 599GTB, a Porsche 918 Spyder, a Lamborghini Veneno, a Maybach, a Koenigesegg, an Aston Martin and a McLaren P1, the Geneva prosecutor\u2019s office said. According to media reports, the Bugatti Veyron is worth $2 million and the Swedish-made Koenigegg One is one of only seven ever produced for $2.8 million.\u00a0The total value of the 11 cars has not been reported - but the value of only two of the 11 cars (Bugatti Veyron \u0026 Koenigegg One) totals $4.8 million. Media reports estimate the total value to be \u0022more than $8 million\u0022.\nEquatorial Guinea filed a legal challenge to the seizure, arguing that the cars do not belong to Obiang but to a state company and were only in Geneva for repairs. In July 2017, the Swiss Federal Court rejected the request from the government of Equatorial Guinea to release the luxury cars.\u00a0","Disposition of Criminal Case(s)":"","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Public Prosecutor\u0027s Office in Geneva, Switzerland","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Public Prosecutor\u0027s Office in Geneva, Switzerland","Jurisdiction of Asset Recovery: Courts Involved":"Swiss Federal Court, Switzerland","Documents":"","Sources ":"Swiss seize 11 cars in probe of Equatorial Guinea\u0027s VP, Reuters, 03 November 2016:https:\/\/www.reuters.com\/article\/us-equatorial-swiss-idUSKBN12Y28B\nCorruption trial against \u0027playboy\u0027 son of Equatorial Guinea\u0027s president opens in France, Deutsche Welle, 02 January 2017:http:\/\/www.dw.com\/en\/corruption-trial-against-playboy-son-of-equatorial-...\nEquatorial Guinea\u0027s VP Obiang\u0027s cars seized in Switzerland, BBC, 03 November 2016:http:\/\/www.bbc.com\/news\/world-africa-37861795\nSwiss refuse to release Obiang luxury cars, SWI Swissinfo, 25 July 2017:https:\/\/www.swissinfo.ch\/eng\/politics\/corruption-case_swiss-refuse-to-re...\n"},{"Case ID":"ARW-252","Case Title (Name of Public Official or Entity Allegedly Involved)":"Teodoro Nguema Obiang Mangue (\u0022Ebony Shine\u0022 yacht)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Equatorial Guinea","Position of Public Official(s) (yrs in office)":"Vice President of Equatorial Guinea (2012-2018) and son of President Teodoro Obiang Nguema Mbasogo (1979 - current)","Jurisdiction of Asset Recovery":"Netherlands, Switzerland","Jurisdiction of Asset Description":"(1) Jurisdiction initiated legal action to recover assets (Switzerland)\r\n(2) Jurisdiction of Asset Location\/Alleged Asset Location (Netherlands)","Asset Recovery Start":"2016","Asset Recovery End":"","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdictions","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"$120,000,000","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to a Dutch court order (ECLI: NL: RBOVE: 2017: 1630), on 2 December 2016, the Public Prosecutor\u0027s Office in Geneva, Switzerland, submitted a request for legal assistance to the Dutch Public Prosecution Service, Zwolle location. The reason for this request was the start of an investigation by the Public Prosecution Service in Geneva on 31 October 2016 against Obiang, Vice President of Equatorial Guinea and son of the President, in connection with money laundering. According to the Public Prosecutor\u0027s Office in Geneva, the defendant bought a yacht, Ebony Shine, that was docked in (near) Makkum at the time of the start of the investigation. The Swiss prosecution had a strong suspicion that the yacht was bought through acts of misconduct in a public office and bribery, with funds from Equatorial Guinea, that the defendant uses the yacht exclusively for private purposes and that jure imperii activities of the state of Equatorial Guinea are not involved. The Geneva Public Prosecutor requested that the yacht be seized.\nOn December 2, 2016, at the request of the Swiss authorities, the Dutch authorities seized Mr. Obiang\u2019s 250-foot, $120 million yacht, \u201cEbony Shine,\u201d as it was about to sail to Equatorial Guinea. Mr. Obiang has denied ownership of the yacht, and the government of Equatorial Guinea started legal proceedings in Zwolle, Netherlands to release and return the yacht to the government of Equatorial Guinea. Government lawyers argued in a Dutch court that the yacht belonged to his country\u2019s government and was used for defense purposes. In April 2017, the yacht was placed in sequestration in Den Helder port after a judge in Zwolle ruled that the vessel be held by the Dutch Public Prosecution Service (openbaar ministerie) while its owner is investigated under charges of corruption in Switzerland and France.\nBy a letter of 5 December 2016, the Public Prosecution Service in Geneva additionally requested to seize all available private and public documents relating to the Ebony Shine.\u00a0 On the basis of a decision of 6 December 2016 of the examining magistrate, the Ebony Shine was searched on 8 December 2016, in which a number of goods were seized.\nDuring the proceedings, it was revealed that the yacht is formally owned by a company Named Dara Ltd, registered in the Marshall Islands. Lawyers representing Equatorial Guinea in the Dutcg court stated that Dara Ltd is owned 100% by the Ministry of Defense of Equatorial Guinea. The vessel, built by Feadship in Makkum, has two jaccuzis, a spa, a pool and gym, a helipad, several jetskis and a cinema seating 12.\nSwiss prosecutors had opened their investigation into Obiang in 2016. in July 2017, a Swiss Federal Court turned down a demand by the government of Equatorial Guinea to release the impounded yacht, which is moored in the Netherlands.\u00a0\nEleven luxury cars were seized at Geneva airport in October\/November 2016 as part of the same investigation - see ARW-253","Disposition of Criminal Case(s)":"","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Public Prosecutor\u0027s Office in Geneva, Switzerland","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Public Prosecutor\u0027s Office in Geneva, Switzerland","Jurisdiction of Asset Recovery: Courts Involved":"RECHTBANK OVERIJSSEL (Overijssel District Court), Netherlands","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_Yacht_Dutch%20court%20order%20%231_ECLI_NL_RBOVE_2017_1630.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_Yacht_Dutch%20court%20order%20%232_ECLI_NL_RBOVE_2017_1631.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_Yacht_Equatorial%20Guinea%27s%20Teodorin%20Obiang%20has%20had%20his%20luxury%20yacht%20seized%20in%20the%20Netherlands%20%E2%80%94%20Quartz.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_Yacht_Het%20superjacht%20blijft%20aan%20de%20ketting%20-%20NRC.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_yacht_Superyacht%20seized%20in%20Den%20Helder%20port%20as%20part%20of%20corruption%20probe%20-%20DutchNews.pdf","Sources ":""},{"Case ID":"ARW-250","Case Title (Name of Public Official or Entity Allegedly Involved)":"Family of former President Sani Abacha","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Sani Abacha: President (1993-1998)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"(1) Jurisdiction that initiated legal action to recover assets; (2) Jurisdiction of asset location","Asset Recovery Start":"2014","Asset Recovery End":"2017","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdictions","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"The MOU references: the letter of intent signed by Nigeria and Switzerland in March 2016; Article 25 of the Addis Ababa Action Agenda which encourage the international community to develop good practices on asset return; goal 16 of the 2030 UN agenda for sustainable development that highlights corruption as one of the main factors preventing a supportive and sustainable socioeconomic development; and chapter V of UNCAC, the international legal framework for asset recovery.  ","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$321,000,000","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"The Nigerian authorities requested the funds be used to support a program of targeted cash transfers to poor and vulnerable Nigerians under the National Social Safety Net Project financed by a credit extended by the World Bank. The responsibility for the use of the funds is with the Federal Government of Nigeria. The World Bank\u2019s role is to provide institutional support and monitoring of the use of these funds. The parties have agreed to establish monitoring framework for the use of the repatriated funds that will enhance transparency and accountability. To that end, the Federal Government of Nigeria will engage civil society organizations to help monitor the use of the funds. See MOU attached to this entry for details.","Case Summary":"The Federal Government of Nigeria, the Swiss Federal Council and the World Bank signed a Memorandum of Understanding (MOU) on the repatriation and monitoring of $321 million of funds illicitly acquired by the family of the late former President of Nigeria, General Sani Abacha on 04 December 2017. The MOU was signed during the Global Forum on Asset Recovery, a three-day forum hosted by the United Kingdom and the United States with support from the Stolen Asset Recovery (StAR) Initiative. It was signed by Nigeria\u2019s Attorney-General and Minister of Justice, Mr. Abubakar Malami; Switzerland\u2019s Secretary of State and Head of the Directorate of International Law at the Federal Department of Foreign Affairs, Ambassador Roberto Balzaretti; and the World Bank\u2019s country director for Nigeria, Rachid Benmessaoud.\nThe MOU captures the tripartite agreement on the World Bank\u2019s monitoring role and the proposed modalities of the funds repatriation and disbursement. The signing of the MOU followed a December 2014 Swiss court order that the funds be repatriated, on the condition that the World Bank would monitor their use.\nThis MOU followed through on a Letter of Intent that was signed by Nigeria and Switzerland in March 2016 in Abuja, aimed at regulating the return to Nigeria of assets totaling USD 321 million stolen by Nigeria\u0027s former dictator Sani Abacha. The letter of intent was signed by the Swiss Foreign Minister Didier Burkhalter and Nigeria\u2019s Attorney-General and Minister of Justice, Mr. Abubakar Malami.\nThis return of stolen assets was made possible after the Attorney General of the Canton of Geneva confiscated these assets, which had originally been deposited in bank accounts in Luxembourg, pursuant to a forfeiture order dated 11 December 2014.\u00a0\nThe Nigerian authorities requested the funds be used to support a program of targeted cash transfers to poor and vulnerable Nigerians under the\u00a0National Social Safety Net Project\u00a0financed by a credit extended by the World Bank. The responsibility for the use of the funds is with the Federal Government of Nigeria. The World Bank\u2019s role is to provide institutional support and monitoring of the use of these funds. According to the World Bank\u2019s press release, the parties have agreed to establish monitoring framework for the use of the repatriated funds that will enhance transparency and accountability. To that end, the Federal Government of Nigeria will engage civil society organizations to help monitor the use of the funds.\nAccording to media reports, Nigeria\u2019s minister of finance Kemi Adeosun through her special advisor Oluyinka Akintunde confirmed the receipt of money from Switzerland in December 2017, with $1.5 million in interest. Akintunde said: \u0022We state that $322,515,931.83 (N116,105,735,458.80) was received into a Special Account in the Central Bank of Nigeria (CBN) on Dec. 18, 2017, from the Swiss government\u0022.\nIn 2006, the World Bank was involved in a similar framework, providing institutional support for the return and use of approx. $723 million in public funds that had been corruptly diverted by General Abacha. See case entry ARW-167 and the attached World Bank Fact Sheet.\u00a0","Disposition of Criminal Case(s)":"","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General of the Canton of Geneva","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/MOU_Dec%202017.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Swiss%20Federal%20Council%20press%20release%20-%20Restitution%20of%20USD%20321%20million%20by%20Switzerland%20to%20Nigeria%20under%20World%20Bank%20oversight.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Swiss%20Federal%20Council%20press%20release%20-%20Letter%20of%20Intent.%20March2016.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Nigeria_%20World%20Bank%20to%20Help%20Monitor%20Repatriated%20Abacha%20Funds.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/World%20Bank%20Monitoring%20of%20Repatriated%20Abacha%20Funds.pdf","Sources ":"Information about the National Social Safety Net Project for Nigeria: http:\/\/projects.worldbank.org\/P151488?lang=en\nWorld Bank press release about the National Social Safety Net Project for Nigeria:\u00a0http:\/\/www.worldbank.org\/en\/news\/press-release\/2016\/06\/07\/world-bank-com...\nBBC News.\u00a0\u0027Abacha loot\u0027: Switzerland to return $320m to Nigeria:\u00a0https:\/\/www.bbc.com\/news\/world-africa-42237752\nDaily Trust.\u00a0We returned $322.5m Abacha loot with $1.5m interest in 2017:\u00a0https:\/\/www.dailytrust.com.ng\/we-returned-322-5m-abacha-loot-with--1-5m-...\n"},{"Case ID":"ARW-238","Case Title (Name of Public Official or Entity Allegedly Involved)":"Unnamed Uzbek \u0022Government Official A\u0022\/ Mobile Telesystems and Vimpelcom Telecom Case (Luxembourg)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Uzbekistan","Position of Public Official(s) (yrs in office)":"\u0022Several Positions\u0022 in Uzbek Government, including during 2005-2011; a \u0022relative of the President of Uzbekistan\u0022","Jurisdiction of Asset Recovery":"Luxembourg","Jurisdiction of Asset Description":"","Asset Recovery Start":"2015","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Forfeiture (in US)","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"See related entry, civil asset forfeiture actions by the United States. \u00a0In one of the two civil asse forfeiture actions filed against assets related to unnamed Uzbek official and VimpelCom bribery case, including assets held in accounts in Luxembourg, at Clearstream Banking SA. \u00a0(Source: \u00a0US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015 and Partial Default Judgment and Order of Forfeiture filed January 11, 2016; Court Docket Report as of June 27, 2016.)","Disposition of Criminal Case(s)":"According to the US Department of Justice complaint filed in the case, Gayane Avakyan and Rustan Madumarov, close associates of \u0022Government Official A\u0022 were arrested in 2014 and subsequently convicted and of multiple criminal offenses in relation to the case and sentenced to prison terms. \u00a0(Source: \u00a0US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015, paragraphs 18-19; See also, US v. All Assets Held in Accounts [by First Global Accounts, Case No. 15-cv-05063 (SDNY), January 26, 2016.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"Tashkent Regional Criminal Court in the Republic of Uzbekistan","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/VimpelCom%20Limited%20and%20Unitel%20LLC_DOJ_PR_Resolution_Feb2016_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/NCB_First%20Global%20Accts_Partial%20Default%20Judgment_01112016_1.pdf","Sources ":"US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015 and Partial Default Judgment and Order of Forfeiture filed January 11, 2016; Court Docket Report as of June 27, 2016; See also US Department of Justice Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million\u037e United States Seeks $850 Million\n\tForfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016.\n"},{"Case ID":"ARW-237","Case Title (Name of Public Official or Entity Allegedly Involved)":"Unnamed Uzbek \u0022Government Official A\u0022\/ Mobile Telesystems and Vimpelcom Telecom Case (Ireland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Uzbekistan","Position of Public Official(s) (yrs in office)":"\u0022Several Positions\u0022 in Uzbek Government, including during 2005-2011; a \u0022relative of the President of Uzbekistan\u0022","Jurisdiction of Asset Recovery":"Ireland","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2015","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Asset Forfeiture (in US)","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"See related entry, civil asset forfeiture actions by the United States. \u00a0In one of the two civil asset forfeiture actions filed against assets related to unnamed Uzbek official and VimpelCom bribery case, including assets held in Ireland at Bank of New York Mellon Investment Servicing (International) Limited held by or benefit of SWISDORN Limited, Takilant Limite and Expoline Limited and other portfolio funds. (Source: US v. Any and all assets held on Behalf of Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015 and Partial Default Judgment and Order of Forfeiture filed January 11, 2016; Court Docket Report as of June 27, 2016.)","Disposition of Criminal Case(s)":"According to the US Department of Justice complaint filed in the case, Gayane Avakyan and Rustan Madumarov, close associates of \u0022Government Official A\u0022 were arrested in 2014 and subsequently convicted and of multiple criminal offenses in relation to the case and sentenced to prison terms. \u00a0(Source: \u00a0US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015, paragraphs 18-19; See also, US v. All Assets Held in Accounts [by First Global Accounts, Case No. 15-cv-05063 (SDNY), January 26, 2016.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"Tashkent Regional Criminal Court in the Republic of Uzbekistan","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015 and Partial Default Judgment and Order of Forfeiture filed January 11, 2016; Court Docket Report as of June 27, 2016; See also US Department of Justice Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million\u037e United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016.\n"},{"Case ID":"ARW-235","Case Title (Name of Public Official or Entity Allegedly Involved)":"Unnamed Uzbek \u0022Government Official A\u0022\/ Mobile Telesystems and Vimpelcom Telecom Case (Belgium)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Uzbekistan","Position of Public Official(s) (yrs in office)":"\u0022Several Positions\u0022 in Uzbek Government, including during 2005-2011; a \u0022relative of the President of Uzbekistan\u0022","Jurisdiction of Asset Recovery":"","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2015","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Forfeiture (in US)","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"See related entry, civil asset forfeiture actions by the United States. \u00a0In one of the two civil asset forfeiture actions filed against assets related to unnamed Uzbek official and VimpelCom bribery case, including assets held in accounts at Bank of New York Mellon SA\/NV in Brussels, Belgium on behalf of First Global Investments SPC Limited Funds. (Source: \u00a0US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015 and Partial Default Judgment and Order of Forfeiture filed January 11, 2016; Court Docket Report as of June 27, 2016.)","Disposition of Criminal Case(s)":"According to the US Department of Justice complaint filed in the case, Gayane Avakyan and Rustan Madumarov, close associates of \u0022Government Official A\u0022 were arrested in 2014 and subsequently convicted and of multiple criminal offenses in relation to the case and sentenced to prison terms. \u00a0(Source: \u00a0US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015, paragraphs 18-19; See also, US v. All Assets Held in Accounts [by First Global Accounts, Case No. 15-cv-05063 (SDNY), January 26, 2016.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"Tashkent Regional Criminal Court in the Republic of Uzbekistan","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/VimpelCom%20Limited%20and%20Unitel%20LLC_DOJ_PR_Resolution_Feb2016.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/NCB_First%20Global%20Accts_Partial%20Default%20Judgment_01112016.pdf","Sources ":"US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015 and Partial Default Judgment and Order of Forfeiture filed January 11, 2016; Court Docket Report as of June 27, 2016; See also US Department of Justice Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million\u037e United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016.\n\u00a0\n"},{"Case ID":"ARW-247","Case Title (Name of Public Official or Entity Allegedly Involved)":"Jose Luis Ramos Castillo \/ Petroleos de Venezuela S.A. (PDVSA)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Venezuela","Position of Public Official(s) (yrs in office)":"Superintendent of Purchasing and other purchasing related positions (Ramos, about 2002-Sept 2013)","Jurisdiction of Asset Recovery":"","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2015","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Forfeiture (by the United States)","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the Information filed in his case, Mr. Ramos, a resident of Venezuela and then Texas, was employed by the Venezulan state-owned oil company Petroleos de Venezuela S.A. or its affiliates from 2002 to 2013. \u00a0During that time he held various positions related to purchasing including as Superintendent of Purchasing and Purchasing Manager with responsibility for selecting companies for bidding panels. \u00a0(US v. Jorge Luis Ramos Castillo, Case No. 15-cr-636 (SD Tex), Information filed November 24, 2015.) \u00a0 As of June 2016, three US based businessmen and three former employees of PDVSA have pleaded guilty to various charges relating to a scheme in which the businessmen paid bribes in order to win contracts at the state-owned oil company. \u00a0(Source: US Department of Justice, \u0022Businessman Pleads Guilty to Foreign Bribery and Tax Charges in Connection with Venezuela Bribery Scheme,\u0022 June 16, 2016.) \u00a0In April 2016, a \u00a0supplement to notice of forfeiture was filed against four real properties in Miami-Dade County, Florida and funds (unspecified amount) held in deposit in an account at Royal Skandia Life Assurance Limited, held at Isle of Man. \u00a0(Source: \u00a0US v. Ramos Castillo, Case No. 15-cr-636 (SD Tex), United States Supplement to Notice of Forfeiture in the Information, filed April 29, 2016.)","Disposition of Criminal Case(s)":"According to the Court Docket Report in his case, Mr. Ramos pleaded guilty to 2 counts of conspiracy and awaits sentencing scheduled for September 30, 2016. (Source: US v. Jose Luis Ramos-Castillo, Case No. 15-cr-636 (SDTEX), Court Docket Report as of June 23, 2016.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ramos-Castillo_SDTEX_Information_Nov24_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ramos-Castillo_SDTEX_Supplement_Forfeiture%20Notice_04292016.pdf","Sources ":"US v. Ramos Castillo, Case No. 15-cr-636 (SD Tex), Information filed November 24, 2015; United States Supplement to Notice of Forfeiture in the Information, filed April 29, 2016; Court Docket Report as of June 23, 2016; US Department of Justice Press Release, \u0022Businessman Pleads Guilty to Foreign Bribery and Tax Charges in Connection with Venezuela Bribery Scheme,\u0022 June 16, 2016.\n"},{"Case ID":"ARW-246","Case Title (Name of Public Official or Entity Allegedly Involved)":"Janet Lim Napoles \/ Arthur Pingoy, and many others \/ Philippines Development Assistance Fund (PDAF) Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"Napoles (Businesswoman); Congressman (Pingoy)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2015","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation ","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the US Department of Justice, from 2004-2012 Philippines businesswoman Janet Lim-Napoles paid tens of million dollars in bribes and kickbacks to Philippines politicians and other government officials, in exchange for over $200 million in purported development and disaster relief. In July 2015, the DOJ Kleptocracy Asset Recovery Initiative filed a civil asset forfeiture complaint to recover approximately $12.5 million in assets (mainly real properties in Los Angeles and Orange counties) allegedly derived from the kickback scheme which were funnelled through her non-governmental organizations. \u00a0Accordind to the DOJ Press Release, \u0022The complaint alleges that Napoles transferred over $12 million in Philippine government awarded funds to bank accounts in the United States in the names of, or controlled by, her family members. According the complaint, Napoles used the money to purchase numerous assets, including a condominium at the Ritz-Carlton in Los Angeles for her 21 year-old daughter. The complaint seeks to forfeit the proceeds from the sale of the Los Angeles condominium, along with several other assets, including a motel near Disneyland in Anaheim, California\u037e properties in Covina and Irvine, California\u037e a 19 percent stake in a California-based consulting company\u037e and a Porsche Boxster that was purchased for another daughter.\u0022 (Source: US DOJ Press Release, \u0022U.S. Seeks to Recover $12.5 Million Obtained from High Level Corruption in the Philippines,\u0022 July 14, 2015; See also US v. Proceeds from the sale of a condominium located at Ritz-Carlton in Los Angeles, et al, Case No. 8:15-cv-1110 (CDCA), First Amended Verified Complaint of Forfeiture filed March 21, 2016). \u00a0As of June 21, 2016, a settlement conference was scheduled for December 14, 2016. \u00a0","Disposition of Criminal Case(s)":"According to the US Department of Justice, Janet Lim Napoles is serving a sentence of life imprisonment in the Philippines for her role in the kidnapping and detention of her cousin, Benhur Luy, \u0022who served as Napoles\u2019s finance officer and tracked her schemes.\u0022 \u00a0(Source: DOJ Press Release, \u0022U.S. Seeks to Recover $12.5 Million Obtained from High Level Corruption in the Philippines,\u0022 July 14, 2015.) \u00a0 According to the Philippines Office of the Ombudsman, on May 6, 2016, \u0022Ombudsman Conchita Carpio Morales has affirmed the indictment of ex-Representative Arthur Pingoy of the second district of South Cotabato for Malversation of Public Funds, violation of Section 3(e) of the Anti-Graft and Corrupt Practices Act (RA 3019) and Direct Bribery for the misappropriation of his 2007-2008 Priority Development Assistance Fund (PDAF) totaling P20.91M. \u00a0In a 36-page Order, Ombudsman Morales directed the filing of Informations against Pingoy with the Sandiganbayan for 2 counts of Direct Bribery and 4 counts each of Malversation and violation of the anti-graft law. \u00a0Charged alongside Pingoy are Technology Resource Center (TRC) officials Antonio Ortiz, Dennis Cunanan, Francisco Figura and Marivic Jover, Department of Budget and Management officials Mario Relampagos, Rosario Nu\u00f1ez, Marilou Bare and Lalaine Paule, National Agribusiness Corporation (NABCOR) officials Alan Javellana, Rhodora Mendoza, Maria Ninez Guanizo and Victor Cacal, Philippine Social Development Foundation, Inc. (PSDFI) employees Evelyn de Leon, Noel Macha, John Raymund De Asis and John Bernardo, together with Janet Lim Napoles and former Energy Regulatory Commission Chairperson Zenaida Ducut.\u0022 \u00a0(Source: Office of the Ombudsman Press Release, \u0022Ombudsman charges ex-Rep. Pingoy, Napoles for PDAF scam,\u0022 May 6, 2016.)","Jurisdiction of Origin: Investigative Agency":"Office of the Ombudsman","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Ombudsman","Jurisdiction of Origin: Courts Involved":"Sandiganbayan","Jurisdiction of Asset Recovery: Investigative Agency":"FBI, Los Angeles Field Office; US Marshalls Service; Department of Justice Office of International Affairs","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Kleptocracy Asset Recovery Initiative; US Attorney\u0027s Office - Central District of Los Angeles","Jurisdiction of Asset Recovery: Courts Involved":"District Court for the Central District of California","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Napoles_CDCA_First%20Amended%20Complaint_Mar2016.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Napoles_Philippines_Ombudsman_Charges%20against%20five%20Lawmakers_Jul2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Napoles_Philippines_Ombudsman_Charges%20Filed%20PEPs_May2016.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/NapolesCDCA_DOJ%20PR_Complaint_Jul2015.pdf","Sources ":"Office of the Ombudsman (Philippines) Press Release, \u0022Ombudsman charges ex.Rep Pingoy, Napoles for PDAF scam,\u0022 May 6, 2016, at http:\/\/www.ombudsman.gov.ph\/index.php?home=1\u0026pressId=ODQ3; \u00225 more Congressman et.al. indicted for PDAF Scam,\u0022 July 1, 2015, at http:\/\/www.ombudsman.gov.ph\/index.php?home=1\u0026pressId=Njc4;\n\t\u00a0\n\tUS v. Proceeds from the sale of a condominium located at the Ritz-Carlton in Los Angeles, Case No. 15-cv-1110 (CDCA), First Amended Verified Complaint for Forfeiture In Rem, filed March 21, 2016 and Court Docket Report as of June 21, 2016; \u00a0US Department of Justice Press Release, \u0022U.S. Seeks to Recover $12.5 Million Obtained from HighLevel Corruption in the Philippines,\u0022 July 14, 2015.\n"},{"Case ID":"ARW-245","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pavel Lazarenko (United States Civil Asset Forfeiture Case) \/ Lithuania","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Member of Parliament (1998); Prime Minister (1996-1997); First Vice Prime Minister (1995-1996); various government and political positions, Dnepropetrovsk region (1992-1995)","Jurisdiction of Asset Recovery":"Lithuania","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.18, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"As of June 2016, the civil asset forfeiture case in the United States was ongoing against accounts held in a number of financial institutions around the world, including Vilnius Bankas in Lithuania. \u00a0The amounts held are not specified. \u00a0(Source: U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Court Docket Report as of June 20, 2016.)\n\t\u00a0\n\tOn May 14, 2004, the U.S. filed a civil asset forfeiture suit, seeking to forfeit more than $250 million which the government alleged were illegal proceeds of criminal activities by Mr. Lazarenko and his associates. \u00a0The U.S. government also alleged that the assets were obtained through the abuse of public office and illegally transported and\/or laundered through the abuse of financial institutions in the United States, and were located in in foreign bank accounts in Guernsey, Antigua \u0026 Barbuda, Switzerland, Lithuania and Liechtenstein.(Source: U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Verified Claim for Forfeiture In Rem filed on May 14, 2004 and First Amended Verified Claim for Forfeiture In Rem filed on June 30, 2005.) \u00a0 On May 20, 2004, a Restraining Order was issued against the defendant accounts. \u00a0(Source: U.S. v. All Assets Held in Julis Baer, et al, Case No. 1:04-cv-00798-PLF (D.D.C.), which stipulated that \u0022terms of Order shall remain in full force and effect until the judgment rendered in the case or further Order of the court.\u0022) \u00a0Actions against some of the assets were terminated in June 2005.","Disposition of Criminal Case(s)":"According to the U.S. Department of Justice Press Release dated November 19, 2009, Mr. Lazarenko was sentenced to 97 months in prison, subsequent to his conviction on eight counts of money laundering. \u00a0(Source: U.S. Department of Justice, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison,\u0022 November 19, 2009.) According to \u00a0BBC News, Mr. Lazarenko was convicted in Switzerland, in June 2000, on money laundering charges. (Sources: \u00a0BBC News, \u0022The case against Lazarenko,\u0022 \u00a0August 25, 2006. \u00a0See also, Swiss court decisions: BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court).\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Lazarenko_Amended%20Complaint_June%202005_0.pdf","Sources ":"U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Verified Claim for Forfeiture In Rem filed on May 14, 2004; First Amended Verified Claim for Forfeiture In Rem filed on June 30, 2005 and Notice of Errata for First Amended Verified Claim for Forfeiture In Rem filed on January 21, 2011; Restraining Order filed on May 20, 2004; and Court Docket Report as of June 20, 2016.\n"},{"Case ID":"ARW-242","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pavel Lazarenko (United States Civil Asset Forfeiture Case) \/ Liechtenstein","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Member of Parliament (1998); Prime Minister (1996-1997); First Vice Prime Minister (1995-1996); various government and political positions, Dnepropetrovsk region (1992-1995)","Jurisdiction of Asset Recovery":"Liechtenstein","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.18, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"\u00a0As of June 2016, the civil asset forfeiture case in the United States was ongoing against accounts held in a number of financial institutions around the world, including Verwaltungs-und Privatbank and LGT banks in Liechtenstein. \u00a0The amounts held are not specified. \u00a0(Source: U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Court Docket Report as of June 20, 2016.)\n\t\u00a0\n\tOn May 14, 2004, the U.S. filed a civil asset forfeiture suit, seeking to forfeit more than $250 million which the government alleged were illegal proceeds of criminal activities by Mr. Lazarenko and his associates. \u00a0The U.S. government also alleged that the assets were obtained through the abuse of public office and illegally transported and\/or laundered through the abuse of financial institutions in the United States, and were located in in foreign bank accounts in Guernsey, Antigua \u0026 Barbuda, Switzerland, Lithuania and Liechtenstein.(Source: U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Verified Claim for Forfeiture In Rem filed on May 14, 2004 and First Amended Verified Claim for Forfeiture In Rem filed on June 30, 2005.) \u00a0 On May 20, 2004, a Restraining Order was issued against the defendant accounts. \u00a0(Source: U.S. v. All Assets Held in Julis Baer, et al, Case No. 1:04-cv-00798-PLF (D.D.C.), which stipulated that \u0022terms of Order shall remain in full force and effect until the judgment rendered in the case or further Order of the court.\u0022)\u00a0","Disposition of Criminal Case(s)":"According to the U.S. Department of Justice Press Release dated November 19, 2009, Mr. Lazarenko was sentenced to 97 months in prison, subsequent to his conviction on eight counts of money laundering. \u00a0(Source: U.S. Department of Justice, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison,\u0022 November 19, 2009.) According to \u00a0BBC News, Mr. Lazarenko was convicted in Switzerland, in June 2000, on money laundering charges. (Sources: \u00a0BBC News, \u0022The case against Lazarenko,\u0022 \u00a0August 25, 2006. \u00a0See also, Swiss court decisions: BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court).\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Lazarenko_Amended%20Complaint_June%202005.pdf","Sources ":"\u00a0U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Verified Claim for Forfeiture In Rem filed on May 14, 2004; First Amended Verified Claim for Forfeiture In Rem filed on June 30, 2005 and Notice of Errata for First Amended Verified Claim for Forfeiture In Rem filed on January 21, 2011; Restraining Order filed on May 20, 2004; and Court Docket Report as of June 20, 2016.\n"},{"Case ID":"ARW-244","Case Title (Name of Public Official or Entity Allegedly Involved)":"Standard Bank\/ Enterprise Growth Market Advisors \/ Tanzania Sovereign Note Private Placement","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Tanzania","Position of Public Official(s) (yrs in office)":"Harry Kitilya, Commissioner of the Tanzanian Revenue Authority (resigned December 2013); Fratern Mboya, CEO of Tanzania Capital Markets and Securities Authority (1995-2011)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort","Asset Recovery Start":"2013","Asset Recovery End":"2016","UNCAC Offenses Implicated":"Art.16, Art.18, Art.19","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Deferrred Prosecution Agreement\/Settlement","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"The case was triggered by a self disclosure by Standard Bank.  The UK SFO also acknowledged working with the US Department of Justice and Securities and Exchange Commission, the UK Foreign and Commonwealth Office and the Financial Conduct Authority. (Source: UK SFO Press Release, \u0022 SFO agrees first UK DPA with Standard Bank,\u0022 November 30, 2015)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"According to the UK Serious Fraud Office, \u0022The money due to the Government of Tanzania will be returned in line with advice being received from the Department for International Development.\u0022 (Source:  SFO Press Release, \u0022SFO agrees first UK DPA with Standard Bank,\u0022 November 30, 2015)","Case Summary":"According to a news article by the British High Commission Dar es Salaam, \u0022The UK has recently transferred to the Tanzanian Government the $7m fine that Standard Bank paid as a result of its failure to prevent bribery.\u0022 (Source: British High Commission Dar es Salaam, \u0022UK, Tanzania close partners in fighting corruption scourge,\u0022 May 17, 2016.)\n\t\t\t\u00a0\n\t\t\tAccording to the UK Serious Fraud Office and the Statement of Facts in the case, in 2012-2013, Standard Bank and its Tanzanian subsidiary Stanbic Bank were involved in a US$600 million soveeign note private placement for the Government of Tanzania, which was seeking to raise funds in support of its \u0022Five Year Development Plan\u0022 to finance various infrastructure projects. \u00a0As part of the deal, the fees to be paid to the bank was increased to 2.4%, with the \u0022local partner\u0022 Enterprise Growth Market Advisors receiving a consulting fee of 1% although according to the Statement of Facts, there was \u0022no evidence of payment represented reasonable consideration for services rendered on this transaction.\u0022 \u00a0(Source: Statement of Facts, para 28; See also Final Judgment, paras 6 and 7). \u00a0The chairman of Enterprise Growth Market Advisors (EGMA) was Mr. Harry Kitilya, who was also one of its three directors and shareholders, and at the same time serving as the Commission of the Tanzanian Revenue Authority. \u00a0EGMA\u0027s Managing Director was Dr. Fratern Mboya, who had been the Chief Executive Officer of the Tanzanian Capital Markets and Securities Authority (a government agency), 1995-2011. \u00a0The Statement of Facts in the case also lists (in paras 56-57) the involvement of other Tanzanian government officials in the deal, including two successive Ministers of Finance. \u00a0\u00a0\n\t\t\t\u00a0\n\t\t\tThe case was triggered by a disclosure to the SFO by Standard Bank\u0027s legal counsel. \u00a0The SFO noted that despite \u0022obvious red flags for bribery\u0022 Standard Bank and Stanbic Bank \u0022team not appears to have recognized possibility of the arrangement being corrupt.\u0022 \u00a0(Source: Statement of Facts, paras 153-154). The Statement of Facts notes that within days and weeks of being paid $6 million into an account opened specifically to receive the fees, Dr. Mboya of EGMA made four withdrawals in cash of nearly all of the amounts paid, with the assistance of bank personnel. \u00a0The Statement of Facts noted that \u0022The cash withdrawals prevents any further tracing of the US$6 million.\u0022 (Statement of Facts, paras 178-185, 30). \u00a0\n\t\t\t\u00a0\n\t\t\tAs part of the Deferred Prosecution Agreement, Standard Bank will pay $25.2 million in total financial penalty, consisting of $16.8 million financial penalty, $8.4 million disgorgement of profits.\u00a0\n\t\t\t\u00a0\n\u00a0","Disposition of Criminal Case(s)":"According to the UK Serious Fraud Office, in November 2015, the Southwark Crown Court approved the SFO\u0027s first Deferred Prosecution Agreement with the Standard Bank, which was the subject of an indictment alleging failure to prevent bribery contrary to section 7 of the Bribery Act 2010. \u00a0As a result of the Deferred Prosecution Agreement, the charge against Standard Bank has been suspended for three years. \u00a0(Sources: \u00a0UK SFO Press Release, \u0022SFO agrees first UK DPA with Standard Bank,\u0022 November 30, 2015; Deferred Prosecution Agreement, November 2015; Between Serious Fraud Office and Standard Bank, Case U20150854, Approved Judgment, November 30, 2015)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Serious Fraud Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Serious Fraud Office","Jurisdiction of Asset Recovery: Courts Involved":"Southwark Crown Court","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/UK%20SFO%20agrees%20first%20UK%20DPA%20with%20Standard%20Bank%20_%20Nov302015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/deferred%20prosecution%20agreement%20-%20standard%20bank_Nov2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/sfo%20v%20icbc%20sb%20plc%20-%20statement%20of%20facts_Nov2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/sfo-v-standard-bank_Preliminary_judgment_Nov2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/sfo-v-standard-bank_Final%20judgment_Nov2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Standard%20Bank_UK%2C%20Tanzania%20close%20partners%20in%20fighting%20corruption%20scourge_May2016.pdf","Sources ":"UK Serious Fraud Office Press Release, \u0022 SFO agrees first UK DPA with Standard Bank,\u0022 November 30, 2015, at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-20... (which also provides links to the Deferred Prosecution Agreement, Statement of Facts, Preliminary Judgment and Final Judgment); \u00a0 British High Commission Dar es Salaam, \u0022UK, Tanzania close partners in fighting corruption scourge,\u0022 May 17, 2016, at https:\/\/www.gov.uk\/government\/world-location-news\/uk-tanzania-close-part....\n"},{"Case ID":"ARW-241","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pavel Lazarenko (United States Civil Asset Forfeiture Case) \/ Guernsey","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Member of Parliament (1998); Prime Minister (1996-1997); First Vice Prime Minister (1995-1996); various government and political positions, Dnepropetrovsk region (1992-1995)","Jurisdiction of Asset Recovery":"Guernsey","Jurisdiction of Asset Description":"Location of Assets \/ Alleged Assets","Asset Recovery Start":"2004","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.18, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"Approximately US$150 million","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"As of June 2016, the civil asse forfeiture case in the United States was ongoing against three accounts totalling approximately US$150 million: \u00a0(1) Credit Suisse (Guernsey) Limited - Balford Trust account of US$147.9 million, (2) Credit Suisse (Guernsey) - Credit Suisse Trust Limited - Escrow Account Re BT of approximately GBP14,308 and (3) Bank Julius Baer Company Guernsey Branch, about $2 million in account of P. Lazarenko. \u00a0(Source: U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Court Docket Report as of June 20, 2016.)\n\u00a0\nOn May 14, 2004, the U.S. filed a civil asset forfeiture suit, seeking to forfeit more than $250 million which the government alleged were illegal proceeds of criminal activities by Mr. Lazarenko and his associates. \u00a0The U.S. government also alleged that the assets were obtained through the abuse of public office and illegally transported and\/or laundered through the abuse of financial institutions in the United States, and were located in in foreign bank accounts in Guernsey, Antigua \u0026 Barbuda, Switzerland, Lithuania and Liechtenstein.(Source: U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Verified Claim for Forfeiture In Rem filed on May 14, 2004 and First Amended Verified Claim for Forfeiture In Rem filed on June 30, 2005.) \u00a0 On May 20, 2004, a Restraining Order was issued against the defendant accounts. \u00a0(Source: U.S. v. All Assets Held in Julis Baer, et al, Case No. 1:04-cv-00798-PLF (D.D.C.), which stipulated that \u0022terms of Order shall remain in full force and effect until the judgment rendered in the case or further Order of the court.\u0022) \u00a0Actions against some of the assets were terminated in June 2005.","Disposition of Criminal Case(s)":"According to the U.S. Department of Justice Press Release dated November 19, 2009, Mr. Lazarenko was sentenced to 97 months in prison, subsequent to his conviction on eight counts of money laundering. \u00a0(Source: U.S. Department of Justice, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison,\u0022 November 19, 2009.) According to \u00a0BBC News, Mr. Lazarenko was convicted in Switzerland, in June 2000, on money laundering charges. (Sources: \u00a0BBC News, \u0022The case against Lazarenko,\u0022 \u00a0August 25, 2006. \u00a0See also, Swiss court decisions: BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court).\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Verified Claim for Forfeiture In Rem filed on May 14, 2004; First Amended Verified Claim for Forfeiture In Rem filed on June 30, 2005 and Notice of Errata for First Amended Verified Claim for Forfeiture In Rem filed on January 21, 2011; Restraining Order filed on May 20, 2004; and Court Docket Report as of June 20, 2016.\n"},{"Case ID":"ARW-243","Case Title (Name of Public Official or Entity Allegedly Involved)":"Mahamoud Adam Bechir and Nouracham Niam; Ikram Mahamt Saleh \/ United Kingdom (Caracal Energy [formerly Griffiths Energy] shares case)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Chad","Position of Public Official(s) (yrs in office)":"Ambassador to South Africa (current); former Ambassador to Canada and the United States (Bechir); Wife of Ambassador (Niam); Wife of Chad\u0027s Deputy Chief of Mission Youssouf Hamid Takane. 2007-2015 (Saleh)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort; Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.18, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation; Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the US Department of Justice press release, \u0022As alleged in the complaint, in 2009, Bechir and Takane agreed to use their official positions to influence the award of oil development rights in Chad to Griffiths Energy International Inc., a Canadian oil company, in exchange for shares in the company. \u00a0Thereafter, in or about October 2009, Griffiths Energy issued four million shares to the wives of Bechir and Takane and to another associate.\n\t\u00a0\n\tThe complaint further alleges that Griffiths Energy agreed with Bechir and his wife that the company would pay a $2 million \u201cconsulting fee\u201d to Bechir\u2019s wife to influence the award of oil development rights in Chad. \u00a0After securing the desired oil development rights in February 2011, Griffiths Energy allegedly transferred $2 million to an account held by a shell company created by Bechir\u2019s wife. \u00a0This bribe payment was commingled and laundered through U.S. bank accounts and real property, and eventually was transferred to Bechir\u2019s bank account in South Africa, where he is now serving as Chad\u2019s Ambassador. \u00a0In 2013, Griffiths Energy pleaded guilty in Canadian court to bribing Bechir.\n\t\u00a0\n\tThe $34 million that the United States seeks in forfeiture represents the cash value of the four million shares in Griffiths Energy that were provided to the wives of Bechir and Takane and to their associate. \u00a0In a separate action filed in 2014, the United States also is seeking the civil forfeiture of over $100,000 in allegedly laundered funds traceable to the $2 million bribe payment. \u00a0Takane resides in the United States.\u0022 (Source: US Department of Justice Press Release, \u0022Department of Justice Seeks Forfeiture of $34 Million in Bribe Payments to the Republic of Chad\u2019s Former Ambassador to the U.S. and Canada,\u0022 June 30, 2015.)\n\t\u00a0\n\tAccording to the civil asset forfeiture complaint in the case, the alleged bribery proceeds are held in accounts in the UK\u0027s Royal bank of Scotland in the name of Mrs. Niam and Mrs. Saleh, who have both filed claims, along with Ms. Niam\u0027s former attorney in Canada for unpaid fees arising out of canadian court proceedings, to the assets in the US District Court for the District of Columbia. \u00a0(Source: \u00a0US v. Approximately \u00a322 million in British Pounds representing the value of 4,000,000 shares of common stock in Caracal Energy Inc., formerly Griffiths Energy International, Inc., Case No. 1:15-cv-01018 (D.D.C.), Verfied Complaint filed June 30, 2015; Verfied Claim filed by Ms. NIma on August 14; Verified Claim filed by Mrs. Saleh on August 17; Verified Claim filed by CESPC.) \u00a0The Government of Chad also filed a claim on October 16, stating that the \u0022funds [were] paid wrongfully to representatives of Chad in an effort to obtain rights belonging to Chad.\u0022 \u00a0The Claim was signed by the Deputy General Secretary of the Republic of Chad. (Source: \u00a0US v. Approximately \u00a322 million in British Pounds representing the value of 4,000,000 shares of common stock in Caracal Energy Inc., formerly Griffiths Energy International, Inc., Case No. 1:15-cv-01018 (D.D.C.), Verified Claim filed by Government of Chad, at para 6, October 16, 2015; Answer by Government of Chad to Verified Claim, filed October 26, 2015). As of June 23, 2016, the case was ongoing.\u00a0\n\t\u00a0\n\tAccording to the UK High Court Judgment issued in July 2015, Mrs. Saleh\u0027s application to discharge the Property Freezing Order pursuant to the Proceeds of Crime Act (POCA) issued against the GBP 4.4 million and interest held at Royal Bank of Scotland in proceeds of sale of 800,000 shares in Caracal Energy (formerly known as Griffiths Energy Inc. [GEI]) was denied. \u00a0The Court stated in part that \u0022Although GEI made no admission in the Agreed Statement of Facts that the shares allotted to Mrs Saleh and Mr Hassan were a part of the corrupt incentives provided by GEI, there is easily sufficient circumstantial evidence to raise a good arguable case that they were, and that the GEI shares are \u0027recoverable property\u0027 as defined in POCA. \u00a0It is unnecessary for the purposes of POCA to show that the person who is the lawful owner of the \u201crecoverable property\u201d was himself or herself guilty of any criminal offence.\u0022 \u00a0(Source: \u00a0Between Serious Fraud Office and Ikram Mahamed Saleh, [2015] EWHC 2119 QB (July 21, 2015), para 61.)","Disposition of Criminal Case(s)":"NA (civil asset forfeiture case in the US); Civil Recovery Order Property Freezing Order (Mrs. Saleh\u0027s shares)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Serious Fraud Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Serious Fraud Office","Jurisdiction of Asset Recovery: Courts Involved":"England and Wales High Court - Queens Bench","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths%20Energy%20Stock%20Forfeiture%20Case_PR_Jun30%202015_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths_Energy_Complaint_Jun30%202015_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths%20Energy%20Certif_Arrests%20in%20Rem%20Order_June30%202015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths%20Energy%20Stock_Niam%20Claim_Aug%2014%202015_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths%20Energy%20Stock_Saleh%20Claim_Aug2015_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths%20Energy%20Stock_Rep%20of%20Chad%20Claim_Oct%202015_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_UK_SALEH_PFO_2015%20EWHC2119QB.pdf","Sources ":"US Department of Justice Press Release, \u0022Department of Justice Seeks Forfeiture of $34 Million in Bribe Payments to the Republic of Chad\u2019s Former Ambassador to the U.S. and Canada,\u0022 June 30, 2015, at http:\/\/www.justice.gov\/opa\/pr\/department-justice-seeks-forfeiture-34-mil... Source: \u00a0US v. Approximately \u00a322 million in British Pounds representing the value of 4,000,000 shares of common stock in Caracal Energy Inc., formerly Griffiths Energy International, Inc., Case No. 1:15-cv-01018 (D.D.C.), Verified Complaint filed June 30, 2015, and accessed at http:\/\/www.justice.gov\/opa\/file\/624266\/download; Verfied Claim filed by Ms. NIma on August 14; Verified Claim filed by Mrs. Saleh on August 17; Verified Claim filed by CESPC; Verified Claim filed by Government of Chad, October 16, 2015 and Answer by Government of Chad to Verified Complaint; Court Docket Report as of June 23, 2016; Between Serious Fraud Office and Ikram Mahamed Saleh, [2015] EWHC 2119 QB (July 21, 2015).\n"},{"Case ID":"ARW-240","Case Title (Name of Public Official or Entity Allegedly Involved)":"Mahamoud Adam Bechir and Nouracham Niam; Ikram Mahamat Saleh \/ United States (Caracal Energy [formerly Griffths Energy] shares case)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Chad","Position of Public Official(s) (yrs in office)":"Ambassador to South Africa (current); former Ambassador to Canada and the United States (Bechir); Wife of Ambassador (Niam); Wife of Chad\u0027s Deputy Chief of Mission Youssouf Hamid Takane. 2007-2015 (Saleh)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Asset Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty (between US and UK - for freeze of assets)","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the US Department of Justice press release, \u0022As alleged in the complaint, in 2009, Bechir and Takane agreed to use their official positions to influence the award of oil development rights in Chad to Griffiths Energy International Inc., a Canadian oil company, in exchange for shares in the company. \u00a0Thereafter, in or about October 2009, Griffiths Energy issued four million shares to the wives of Bechir and Takane and to another associate.\n\t\u00a0\n\tThe complaint further alleges that Griffiths Energy agreed with Bechir and his wife that the company would pay a $2 million \u201cconsulting fee\u201d to Bechir\u2019s wife to influence the award of oil development rights in Chad. \u00a0After securing the desired oil development rights in February 2011, Griffiths Energy allegedly transferred $2 million to an account held by a shell company created by Bechir\u2019s wife. \u00a0This bribe payment was commingled and laundered through U.S. bank accounts and real property, and eventually was transferred to Bechir\u2019s bank account in South Africa, where he is now serving as Chad\u2019s Ambassador. \u00a0In 2013, Griffiths Energy pleaded guilty in Canadian court to bribing Bechir.\n\t\u00a0\n\tThe $34 million that the United States seeks in forfeiture represents the cash value of the four million shares in Griffiths Energy that were provided to the wives of Bechir and Takane and to their associate. \u00a0In a separate action filed in 2014, the United States also is seeking the civil forfeiture of over $100,000 in allegedly laundered funds traceable to the $2 million bribe payment. \u00a0Takane resides in the United States.\u0022 (Source: US Department of Justice Press Release, \u0022Department of Justice Seeks Forfeiture of $34 Million in Bribe Payments to the Republic of Chad\u2019s Former Ambassador to the U.S. and Canada,\u0022 June 30, 2015.)\n\t\u00a0\n\tAccording to the civil asset forfeiture complaint in the case, the alleged bribery proceeds are held in accounts in the UK\u0027s Royal bank of Scotland in the name of Mrs. Niam and Mrs. Saleh, who have both filed claims, along with Ms. Niam\u0027s former attorney in Canada for unpaid fees arising out of canadian court proceedings, to the assets in the US District Court for the District of Columbia. \u00a0(Source: \u00a0US v. Approximately \u00a322 million in British Pounds representing the value of 4,000,000 shares of common stock in Caracal Energy Inc., formerly Griffiths Energy International, Inc., Case No. 1:15-cv-01018 (D.D.C.), Verfied Complaint filed June 30, 2015; Verfied Claim filed by Ms. NIam on August 14; Verified Claim filed by Mrs. Saleh on August 17; Verified Claim filed by CESPC.) \u00a0The Government of Chad also filed a claim on October 16, stating that the \u0022funds [were] paid wrongfully to representatives of Chad in an effort to obtain rights belonging to Chad.\u0022 \u00a0The Claim was signed by the Deputy General Secretary of the Republic of Chad. (Source: \u00a0US v. Approximately \u00a322 million in British Pounds representing the value of 4,000,000 shares of common stock in Caracal Energy Inc., formerly Griffiths Energy International, Inc., Case No. 1:15-cv-01018 (D.D.C.), Verified Claim filed by Government of Chad, at para 6, October 16, 2015; Answer by Government of Chad to Verified Claim, filed October 26, 2015). As of June 23, 2016, the case was ongoing.\u00a0","Disposition of Criminal Case(s)":"N\/A; Civil asset forfeiture case in US","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"US law firms representing Office of the President of the republic of Chad:  Stein Mitchell Cipollone Beato \u0026 Missner LLP; Hellring Lindeman Goldstein \u0026 Siegal LLP","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Kleptocracy Asset Recovery Initiative, Department Justice, Criminal Division\u2019s Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the District of Columbia","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths%20Energy%20Stock%20Forfeiture%20Case_PR_Jun30%202015_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths_Energy_Complaint_Jun30%202015_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths%20Energy%20Stock_Niam%20Claim_Aug%2014%202015_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths%20Energy%20Stock_Saleh%20Claim_Aug2015_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_USDOJ_Griffiths%20Energy%20Stock_Rep%20of%20Chad%20Claim_Oct%202015_0.pdf","Sources ":"US Department of Justice Press Release, \u0022Department of Justice Seeks Forfeiture of $34 Million in Bribe Payments to the Republic of Chad\u2019s Former Ambassador to the U.S. and Canada,\u0022 June 30, 2015, at http:\/\/www.justice.gov\/opa\/pr\/department-justice-seeks-forfeiture-34-mil... Source: \u00a0US v. Approximately \u00a322 million in British Pounds representing the value of 4,000,000 shares of common stock in Caracal Energy Inc., formerly Griffiths Energy International, Inc., Case No. 1:15-cv-01018 (D.D.C.), Verified Complaint filed June 30, 2015, and accessed at http:\/\/www.justice.gov\/opa\/file\/624266\/download; Verfied Claim filed by Ms. NIam on August 14; Verified Claim filed by Mrs. Saleh on August 17; Verified Claim filed by CESPC; Verified Claim filed by Government of Chad, October 16, 2015; Aswer by Governmen of Chad fiiled October 26, 2015; Court Docket Report as of June 23, 2016.)\n"},{"Case ID":"ARW-30","Case Title (Name of Public Official or Entity Allegedly Involved)":"Carlos F. Garcia \/ Ian Carl and Juan Paulo Depakakibo Garcia (Northern California Case)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"Former Comptroller of the Philippine Armed Forces (Carlos Garcia, 1990-2004), Sons (Ian Carl and Juan Paulo Depakakibo)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location\/ Alleged Asset Location","Asset Recovery Start":"2003","Asset Recovery End":"2012","UNCAC Offenses Implicated":"Art.15, Art.17, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$100,000","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"One-hundred thousand dollars in U.S. currency had been seized from Ian Carl and Juan Paulo Depakakibo when they tried to enter the U.S. with the cash.  In January 2011, the U.S. District Court for the District of Northern California forfeited the confiscated funds to the U.S. Government. The brothers had agreed, as part of their plea, to forfeit the $100,000 seized from them at the time of their arrest on December 19, 2003.  (Source:  U.S. v. Ian Carl Depakakibo and Juan Paulo Depakakibo, Case No. 08-cr-00888-MHP (N.D. Cal.), Final Order of Forfeiture, filed January 7, 2011); U.S. Immigration and Customs Service Press Release, \u0022Sons of former Philippine military comptroller charged with bulk cash smuggling,\u0022 February 25, 2009.)   \nAccording to a June 3, 2015 statement by the Philippines Office of the Ombudsman, \u0022In January 2012, the United States government through then US Ambassador to the Philippines Harry Thomas, Jr. initially turned over to the Office of the Ombudsman $100,000, representing cash seized by U.S. Customs authorities from the two sons of  General Garcia upon their entry in California in December 2003, which seizure triggered the investigations into the transactions entered into by General Garcia.\u0022  (Source:  Office of the Ombudsman, \u0022US turns over $1.38M proceeds of Garcia\u2019s forfeited assets,\u0022 June 3, 2015.)","Disposition of Criminal Case(s)":"According to a June 3, 2015 statement by the Ombudsman of the Philippines, \u0022the Office of the Ombudsman filed criminal cases of perjury, money laundering and plunder against [Carlos] Garcia who eventually was convicted of perjury by the Sandiganbayan.\u00a0 In the last two criminal cases, Garcia pleaded to the lesser offenses of Indirect Bribery and Facilitating Money Laundering, which plea bargaining is the subject of review by the Supreme Court.\u00a0 Meanwhile, forfeiture proceedings are pending with the Sandiganbayan.\u0022\u00a0 (Source:\u00a0 Office of the Ombudsman, \u0022US turns over $1.38M proceeds of Garcia\u2019s forfeited assets,\u0022 June 3, 2015.)\nAccording to the April 5, 2005 Information against former Mr. Garcia, his wife Clarita Garcia and their sons Ian Carl, Juan Paulo and Timothy Mark D. Garcia, the Philippines Ombudsman\u0027s Office had charged them with committing the crime of Plunder.\u00a0 (Source:\u00a0 In the Matter of Extradition of Clarita Depakakibo Garcia, Case No. 2:09-mc-50231 (E.D. Mich.), Annex A to Extradition compaint filed on March 4, 2009).\u00a0 In November 2010, Ian Carl and Juan Paulo Depakakibo were sentenced to time served by U.S. District Court for the Northern District of California, subsequent to their guilty plea on bulk cash smuggling charge.\u00a0\u00a0 (Source: U.S. v. Ian Carl Depakakibo and Juan Paulo Depakakibo, Case No. 08-cr-00888-MHP (N.D. Cal.), Judgment in a Criminal Case, filed on December 1, 2010.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Ombudsman, Office of the Special Prosecutor","Jurisdiction of Origin: Courts Involved":"Sandiganbayan, Supreme Court (Third Division)","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Customs and Border Protection, San Francisco International Airport","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Northern District of California","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the Northern District of California","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Gacria_US_SDNY_Asset%20Return_USEmbassy%20Manila%20Press_Jun3_2015_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Garcia_US%20Asset%20Return_Phil%20Ombudsman_statement_Jun3_2015_1.pdf","Sources ":"U.S. v. Ian Carl Depakakibo and Juan Paulo Depakakibo, Case No. 08-cr-00888-MHP (N.D. Cal.), Indictment filed on December 9, 2008; Order Granting Motion for Preliminary Order of Forfeiture, filed on November 2, 2010; Judgment in a Criminal Case, filed on December 1, 2010; and Final Order of Forfeiture filed January 7, 2011.  See also, U.S. Immigration and Customs Service Press Release, \u0022Sons of former Philippine military comptroller charged with bulk cash smuggling,\u0022 February 25, 2009, accessed at http:\/\/www.ice.gov\/news\/releases\/0902\/090225sanfrancisco.htm; U.S. Department of Justice Press Release, \u0022Sons of Former Philippine General Plead Guilty to Bulk Cash Smuggling,\u0022 September 9, 2010, accessed at http:\/\/www.justice.gov\/usao\/can\/press\/2010\/2010_09_09_garcias.guiltyplea....  Philippines Complaint and Arrest Warrant in the Plunder case, included as Annex A in extradition complaint filed on March 4, 2009, In the Matter of Extradition of Clarita Depakakibo Garcia, Case No. 2:09-mc-50231 (E.D. Mich.)\nUS Embassy Manila, \u0022U.S. Helps Philippines Recover \u0027Ill-Gotten Gains\u0027\u201d, June 3, 2015, athttp:\/\/manila.usembassy.gov\/press-photo-releases-2015\/us-helps-philippin... Office of the Ombudsman, \u0022US turns over $1.38M proceeds of Garcia\u2019s forfeited assets,\u0022 June 3,2015, at http:\/\/www.ombudsman.gov.ph\/index.php?home=1\u0026pressId=NjU3\n"},{"Case ID":"ARW-239","Case Title (Name of Public Official or Entity Allegedly Involved)":"Gulnara Karimova \/ Swiss asset recovery case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Uzbekistan","Position of Public Official(s) (yrs in office)":"Permanent Representative of Uzbekistan to UN Mission in Geneva; daughter of President of Uzbekistan","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort; Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2012","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal prosecution and forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to a press statement by the Public Ministry of the Swiss Confederation, a criminal investigation had been launched against Ms. Gulnara Karimova, the daughter of the Uzbek president, on suspicion of money laundering. \u00a0The Ministry stated that it had commenced its criminal investigation in July 2012 following a communication from the Reporting Office for Money Laundering (MROS), initially against four Uzbek nationals alleged to be involved in corrupt activities in the Uzbek telecom sector. \u00a0 Over 800 million Swiss francs were frozen in Switzerland. \u00a0As part of its investigation, the Public Ministry has sent legal requests for assistance to several countries and is the source of several searches in France which took place during the summer of 2013 and triggered on-site investigations. Furthermore, based on a mutual legal assistance request by Switzerland, the Swedish prosecution authorities have also taken action by opening a corruption investigation in connection with various acquisitions of a Swedish company on the Uzbek telecommunications market. \u00a0In late August 2013, the Ministry searched, with the help of the Federal Judicial Police and the Geneva police, Ms. Karimova\u0027s villa in Geneva to gather new evidence. \u00a0The statement also noted that in her capacity as Permanent Representative of Uzbekistan to the United Nations and other international organizations in Geneva, Ms. Karimova had benefited from diplomatic immunity until last summer.\u0022 \u00a0 (Source: \u00a0Minist\u00e8re public de la Conf\u00e9d\u00e9ration, \u0022La fille du pr\u00e9sident ouzbek dans la ligne de mire de la justice suisse,\u0022 March 14, 2014; See also, Swiss Office of Federal Police Annual Report 2014, at 29.)","Disposition of Criminal Case(s)":"According to a press statement by the Swiss Public Ministry, the money laundering investigation against Ms. Karimova was initiated in 2013. (Source: \u00a0Minist\u00e8re public de la Conf\u00e9d\u00e9ration, \u0022La fille du pr\u00e9sident ouzbek dans la ligne de mire de la justice suisse,\u0022 March 14, 2014)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Minist\u00e8re public de la Conf\u00e9d\u00e9ration; Office of Federal Police; Geneva authorities; Money Laundering Reporting Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Karimova_Swiss%20News%20Admin_Freeze%20Assets_Mar12%202014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Swiss%20Federal%20Police%20Annual%20Report%202014_Pub%20May%202015_0.pdf","Sources ":"Minist\u00e8re public de la Conf\u00e9d\u00e9ration, \u0022La fille du pr\u00e9sident ouzbek dans la ligne de mire de la justice suisse,\u0022 March 14, 2014, at https:\/\/www.news.admin.ch\/message\/index.html?lang=fr\u0026msg-id=52278\n\t\u00a0\n\t\u00a0\n\tSwiss Office of Federal Police Annual Report 2014, at 29, at http:\/\/www.ejpd.admin.ch\/dam\/data\/fedpol\/publiservice\/publikationen\/beri...\n"},{"Case ID":"ARW-234","Case Title (Name of Public Official or Entity Allegedly Involved)":"Petrobras \/ Swiss asset return","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Brazil","Position of Public Official(s) (yrs in office)":"Unnamed senior executives of Petrobras","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort; Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"2015, In part","UNCAC Offenses Implicated":"Art.15, Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal forfeiture; Settlement agreement with account holders","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"MLAT","Contributing Factors in Asset Recovery":"Ongoing, but the Swiss Office of the Attorney General stated that, \u0022The Brazilian bribery scandal affects Switzerland\u0027s financial centre and its anti-money-laundering strategy, with result that the OAG has a close interest in contributing fully to the resolution of the scandal through its own investigations. Attorney General Lauber therefore discussed opportunities for mutual support in the ongoing criminal proceedings with his counterpart, Mr Janot.\u0022 (Source:  Office of the Attorney General of Switzerland, \u0022Petrobras scandal: USD 120 million released to Brazil, March 18, 2015.)","Status of Asset Recovery ":"Completed (in part) and Ongoing (in part)","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction (in part), Investigation\/Asset Tracing\/Asset Restraint (in part)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"Petrobras is majority owned by the Federal Government of Brazil. (Source: \u00a0Petrobras, Corporate Governance, \u0022Capital Ownership Composition,\u0022 at http:\/\/www.investidorpetrobras.com.br\/en\/ corporate-governance\/capital-ownership, last accessed September 14, 2015.) \u00a0\n\t\u00a0\n\tIn March 2016, the Office of the Attorney General (OAG) of Switzerland announced plans to unblock additional US$70 million and return the Petrobras related assets to Brazil: \u00a0\u0022So far the OAG has received reports of around 340 suspicious banking relations from the Money Laundering Reporting Office (MROS) in relation to the international corruption affair involving the semi-state-owned Brazilian company Petrobras. In response, the OAG has since April 2014 opened some 60 investigations on suspicion of aggravated money laundering (Art. 305bis Sec. 2 Swiss Criminal Code (SCC)) and in numerous cases on suspicion of bribery of foreign public officials (Art. 322septies SCC). The OAG has requested the handover of documents relating to over 1,000 banking accounts from over 40 banking institutions. In view of the complexity of the investigations, a task force made up of various specialists from the OAG and supported by fedpol is conducting the proceedings. Two of the investigations opened by the OAG have been taken over by the Brazilian authorities and have already led to charges in Brazil. The OAG plans to request the Brazilian authorities to take over other investigations that have been opened in Switzerland.\n\t\u00a0\n\tIn the course of these 60 investigations, around USD 800 million of assets held in Switzerland have been frozen. In spring 2015, USD 120 million of these assets were unblocked with the consent of the account holders concerned and arrangements made for the assets to be returned to the parties who have incurred related losses.\n\t\u00a0\n\tThe beneficial owners of the Swiss accounts, for the most part ostensibly held by domiciliary companies, are senior executives of Petrobras and of its suppliers, financial intermediaries, Brazilian politicians and directly or indirectly Brazilian or other foreign companies.\u0022 \u00a0(Source: \u00a0 Office of the Attorney General of Switzerland media release, \u0022Petrobras affair: Further USD 70 million of frozen assets to be unblocked and returned to Brazil,\u0022 March 17, 2016.)","Disposition of Criminal Case(s)":"In March 2016, the Office of the Attorney General (OAG) of Switzerland announced that \u0022So far the OAG has received reports of around 340 suspicious banking relations from the Money Laundering Reporting Office (MROS) in relation to the international corruption affair involving the semi-state-owned Brazilian company Petrobras. In response, the OAG has since April 2014 opened some 60 investigations on suspicion of aggravated money laundering (Art. 305bis Sec. 2 Swiss Criminal Code (SCC)) and in numerous cases on suspicion of bribery of foreign public officials (Art. 322septies SCC). (Source: \u00a0Office of the Attorney General of Switzerland media release, \u0022Petrobras affair: Further USD 70 million of frozen assets to be unblocked and returned to Brazil,\u0022 March 17, 2016.)","Jurisdiction of Origin: Investigative Agency":"Attorney General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General\u0027s Office","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Office of the Attorney General (OAG) of Switzerland; Money Laundering Reporting Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Office of the Attorney General (OAG) of Switzerland","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Petrobras_Swiss_OAG_Asset%20Return_Mar2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Petrobras_Swiss_discussion_unblock%20additional%2070m_Mar2016.pdf","Sources ":"Petrobras website, \u0022Capital Ownership Composition,\u0022 at http:\/\/www.investidorpetrobras.com.br\/en\/corporate-governance\/capital-ow..., last accessed September 14, 2015);\n\t\u00a0\n\tOffice of the Attorney General of Switzerland media releases, \u0022Petrobras affair: Further USD 70 million of frozen assets to be unblocked and returned to Brazil,\u0022 March 17, 2016, at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=61034; \u00a0\u0022Petrobras scandal: USD 120 million released to Brazil, March 18, 2015; at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=56605.\n"},{"Case ID":"ARW-232","Case Title (Name of Public Official or Entity Allegedly Involved)":"Unnamed Uzbek \u0022Government Official A\u0022\/ Mobile Telesystems and Vimpelcom Telecom Case (US)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Uzbekistan","Position of Public Official(s) (yrs in office)":"\u0022Several Positions\u0022 in Uzbek Government, including during 2005-2011; a \u0022relative of the President of Uzbekistan\u0022","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location","Asset Recovery Start":"2015","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty (by United States with Uzbekistan and Switzerland)","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the US Department of Justice Press Release in the FCPA case against VimpelCom, \u0022The department has also filed two civil complaints seeking a total of $850 million in forfeiture. A complaint filed today seeks forfeiture of approximately $550 million in proceeds of illegal bribes paid, or property involved in the laundering of those payments, to the Uzbek official by VimpelCom and two other telecommunications companies operating in Uzbekistan. The $550 million is currently located in Swiss bank accounts. The department also filed a prior complaint seeking forfeiture of an additional $300 million in proceeds of illegal bribes paid, or property involved in the laundering of those payments, to the same Uzbek official. The assets sought to be forfeited in that complaint are restrained in Belgium, Luxembourg and Ireland. In that case, on Jan. 11, 2016, the U.S. District Court for the Southern District of New York entered a partial default judgment against all potential claimants other than the Republic of Uzbekistan.\n\t\tAs alleged in the complaints and as is part of the criminal resolutions announced today, the telecom companies paid a total of more than $800 million in bribes so that the Uzbek official would assist VimpelCom and other telecommunications companies in obtaining and retaining business in Uzbekistan. Thereafter, the official\u2019s associates laundered the corruption proceeds through accounts held in Latvia, the United Kingdom, Hong Kong, Ireland, Belgium, Luxembourg and Switzerland. The illicit funds were transmitted through financial institutions in the United States before they were deposited into accounts in these countries, thereby subjecting them to U.S. jurisdiction.\u0022 \u00a0(Source: US Department of Justice Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million\u037e United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016.) \u00a0As of June 27, 2016, the case against assets held in accounts belonging to First Global is stayed, pending settlement discussions by the Department of Justice and involved parties. (US v. All Assets Held in Accounts [belonging to First Global], Case No. 15-cv-05063 (SDNY), Stipulation filed April 27, 2016 and Court Docket Report as of June 26, 2016.) while a partial default judgment motion was filed in late June 2016 in case against assets held on behalf of Takilant Limited and Tozian Limited. (Source: \u00a0US v. All Funds Held in accounts at Lombard Odier Darier Hentsch and Cie Bank et al, Case No. 16-cv-01256 (SDNY), Partial Default Judgment motion filed June 23, 2016.)\n\u00a0","Disposition of Criminal Case(s)":"According to the US Department of Justice complaint filed in the case, Gayane Avakyan and Rustan Madumarov, close associates of \u0022Government Official A\u0022 were arrested in 2014 and subsequently convicted and of multiple criminal offenses in relation to the case and sentenced to prison terms. \u00a0(Source: \u00a0US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015, paragraphs 18-19; See also, US v. All Assets Held in Accounts [by First Global Accounts, Case No. 15-cv-05063 (SDNY), January 26, 2016.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"Tashkent Regional Criminal Court in the Republic of Uzbekistan","Jurisdiction of Asset Recovery: Investigative Agency":"Internal Revenue Service (Criminal Investigations and Global Illicit Financial team); Immigration and Customs Enforcement, DHS","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"DOJ Criminal Division\u0027s Asset Forfeiture and Money Laundering Section, Kleptocracy Asset Recovery Initiative","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the Southern District of New York","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Uzbek_Telecom_Verified_Complaint_Jun2015_4-1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Uzbek_Telecom_SDNY_DOJ_Letter_Request_Arrest%20in%20Rem_Jul1_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Uzbek_Telecom_SDNY_Order_Arrest%20in%20rem_Doc5.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Uzbek_Telecom_SDNY_Order_Arrest%20in%20rem_Doc6.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Uzbek_Telecom_SDNY_Order_Arrest%20in%20rem_Doc7.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Uzbek_Ltr_Uzbek%20Govt%20Counsel_Doc16-main.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Uzbek_Min%20Justice%20Ltr_Doc%2016-1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Uzbek_Partial%20Default%20Judgment_Jan2016.pdf","Sources ":"US v. Any and all assets held in account numbers ... at Bank of New York Mellon SA\/NV, Brussels, Belgium, on behalf of First Global Investments SPC Limited, et al, Case No. 15-cv-05063 (SDNY), Verified Complaint filed on June 29, 2015; \u00a0Letter dated July 1, 2015 by Department of Justice to the Court; Orders issued for Arrest Warrant in rem, filed July 9, 2015; Letter by Uzbek Minister of Justice filed January 4, 2016 and Partial Default Judgment filed January 11, 2016; Stipulation filed April 27, 2016 and Court Docket Report as of June 27, 2016; Related case: US v. All Funds Held at accounts [held at Lombard Odier Darier Hentsch and Cie Bank and Union Bancaire Privee of Switzerland on behalf of Takilant Limited and Tozian Limited, Case No. 16-cv-01257 (SDNY), Verified Complaint filed on February 18, 2016, at https:\/\/www.justice.gov\/opa\/file\/826636\/download; Court Docket Report as of June 27, 2016.\n"},{"Case ID":"ARW-231","Case Title (Name of Public Official or Entity Allegedly Involved)":"Lansana Conte \/ Mamadie Toure","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"","Position of Public Official(s) (yrs in office)":"President (Conte: 1984-2008, deceased), First Lady (Toure: 2000-2008)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location\/Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.18, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"Unknown amount","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"In February 2016, Ms. Toure and the US authorities entered into a settlement agreement whereby Ms. Toure acknowledged that the defendant properties were proceeds of criminal conduct, namely bribery, as alleged in the forfeiture complaint. \u00a0Ms. Toure agreed to forfeit the Pierce Arrow and Fern Hammock properties and the restaurant equipment while the US dismissed without prejudice its claim against the Yacht Basin Property. \u00a0A Consent Order of Forfeiture was filed in April 2016. \u00a0(Source: US v. Real Property located at 4866 Yacht Basin Drive, et al, Case No. 3:14-cv-01428 (M.D. Fla), Settlement Agreement filed February 1, 2016 and Consent Order for Judgment of Forfeiture filed April 4, 2016.)\n\u00a0\nIn May 2015, an order for interlocutory sale of substitute property and judgment of forfeiture was granted for the restaurant \u00a0located at 132 Everest Lane, Suite 1, St. Johns, St. Johns County, Florida, 32259, and an adjacent restaurant, located at 164 Everest Lane, Suite 5, St. Johns, St. Johns County, Florida, 32259 and related equipment. \u00a0The government requested the sale, in part because the restaurant\u0027s \u0022value is fast depreciating. \u00a0The Verified Complaint alleges that the Defendant Restaurant and Market Equipment was purchased for approximately $278,000 in 2013. \u00a0The United States\u2019 appraisal valued the property at less than one-third that amount \u2013 approximately $87,000 \u2013 in January, 2015. \u00a0Waiting to sell the property will only result in further deterioration of its value.\u0022 (Sources: Order for Interlocutory Sale and Judgment of Forfeiture filed May 7, 2015 and Consent Motion filed May 4, 2015, in US v. Real Property located at 4866 Yacht Basin Drive, et al, Case No. 3:14-cv-01428 (M.D. Fla).\u00a0\n\u00a0\nAccording to the Complaint in US v. Real Property located at 4866 Yacht Basin Drive, et al, the US is seeking to forfeit three real properties and restaurant and market equipment located in Jacksonville, Florida. \u00a0The US Department of Justice Complaint states that Ms. Toure admitted to receiving at least $5.3 million in bribery payments from a foreign mining corporation to influence her husband\u0027s decision as to the granting of Simandou project mining rights. \u00a0The complaint alleges that the properties that are being sought to be forfeited were paid with the bribery proceeds and are being held by or for the benefit of Ms. Toure, including through Florida incorporated entities. (Source: US v. Real Property located at 4866 Yacht Basin Drive, et al, Case No. 3:14-cv-01428 (M.D. Fla), Verified Complaint filed November 21, 2014; Amended Verified Complaint filed March 18, 2015.)","Disposition of Criminal Case(s)":"Mr. Conte passed away in 2008. \u00a0There appears to be no criminal proceedings against Ms. Toure.\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the Middle District of Florida","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Toure_US_Asset_Forfeit_Complaint_Nov_21_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Toure_MDFLA_Amended%20Complaint_Mar2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Toure_Consent%20Motion_May4%202015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Toure_MDFLA_Order%20Interlocutory%20Sale%20and%20Judgment_May2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Toure_US_MDFLA_Status%20Report_Jul30_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Toure_MDFLA_Settlement%20Agreement_02012016.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Toure_MDFLA_Consent%20Order%20Forfeiture_April2016.pdf","Sources ":"US v. Real Property located at 4866 Yacht Basin Drive, et al, Case No. 3:14-cv-01428 (M.D. Fla), Verified Complaint filed November 21, 2014; Amended Verified Complaint filed March 18, 2015;Order for Interlocutory Sale and Judgment of Forfeiture filed May 7, 2015; Settlement Agreement filed February 1, 2016 and Consent Order for Judgment of Forfeiture filed April 4, 2016; Court Docket Report as of June 27, 2016.\n"},{"Case ID":"ARW-233","Case Title (Name of Public Official or Entity Allegedly Involved)":"Tomas Yarrington \/ Pablo Zarate Juarez","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mexico","Position of Public Official(s) (yrs in office)":"Yarrington: Former Mayor of Matamoros, Mexico (1992- 1995); Governor of Tamaulipas state (1999-2004); Presidential candidate (2005); Zarate: former political appointee Director of Instituto Tamaulipeco De Vivienda Y Urbanismo (ITAVU)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort; Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Forfeiture; Non-Conviction Based Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"The indictment filed in March 2015, in the US District Court for the Southern District of Texas, against Mr. Zarate contains forfeiture allegations: 1) 2005 Pilatus aircraft (Tail #N679PE) and a personal monetary judgment of US $2 million which the US Government alleges are the proceeds of his corruption while he was the director of the Instituto Tamaulipeco De Vivienda Y Urbanismo (ITAVU) in the State of Tamaulipas, Mexico. \u00a0ITAVU is the Tamaulipas Institute for Housing and Urban Development. Zarate Juarez was appointed to the position of director of ITAVU by former Tamaulipas Governor Tomas Yarrington Ruvalcaba. ITAVU is the department in Tamaulipas responsible for supporting lower income residents with housing programs and financing programs. The plane is also subject of civil forfeiture action filed in the case of former governor Tomas Yarrington. \u00a0(Sources: United States Attorney\u0027s Office for the Southern District of Texas, \u0022Former Mexican Governor\u2019s Political Appointee Indicted,\u0022 March 12, 2015, at http:\/\/www.fbi.gov\/houston\/press-releases\/2015\/former-mexican-governors-... US v. Zarate, Case No. 2:15-cr-216 (S.D. Tex), Indictment filed March 11, 2015).","Disposition of Criminal Case(s)":"Mr. Pablo Zarate Juarez is under indictment in the US on charges of money laundering, bank fraud and attempt and conspiracy to commit mail fraud. (Source: US v. Zarate, Case No. 2:15-cr-216 (S.D. Tex), Indictment filed March 11, 2015).","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Organized Crime Drug Enforcement Task Force investigation conducted in San Antonio, Brownsville, Houston and Corpus Christi by the Drug Enforcement Administration, Homeland Security Investigations, Internal Revenue Service - Criminal Investigation and the Texas Attorney General\u2019s Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney\u0027s Office for the Southern District of Texas","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the Southern District of Texas","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_Arrest_West_Palm_Beach_Post_Jun_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_Extradition_Approved_Hotnews.com_Mar_2_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_Extradition_US_Embassy_Press_Release_Apr_20_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_ICE_Senate_Testimony_Feb_4_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_Interpol_Arrest_Press_Release_Jun_19_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Nicolaiciuc_MDFLA_Extradition_Certification_Mar_1_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Zarate_US_Indictment_FBI_PR_Mar_12_2015.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_Arrest_West_Palm_Beach_Post_Jun_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_Extradition_Approved_Hotnews.com_Mar_2_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_Extradition_US_Embassy_Press_Release_Apr_20_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_ICE_Senate_Testimony_Feb_4_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Necolaicius_Interpol_Arrest_Press_Release_Jun_19_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Nicolaiciuc_MDFLA_Extradition_Certification_Mar_1_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Zarate_SDTex_Indictment_Mar_11_2015.pdf","Sources ":"United States Attorney\u0027s Office for the Southern District of Texas, \u0022Former Mexican Governor\u2019s Political Appointee Indicted,\u0022 March 12, 2015, at http:\/\/www.fbi.gov\/houston\/press-releases\/2015\/former-mexican-governors-...\n\t\u00a0\n\tUS v. Zarate, Case No. 2:15-cr-216 (S.D. Tex), Indictment filed March 11, 2015;\n\t\u00a0\n\tSee related case, Tomas Yarrington.\n\t\u00a0\n"},{"Case ID":"ARW-236","Case Title (Name of Public Official or Entity Allegedly Involved)":"Qiao Jian Jun \/ Zhao Shilan","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"China","Position of Public Official(s) (yrs in office)":"Qiao: Director of government grain storage facility in Central China; Zhao: Ex-wife of Qiao","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort; Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2015","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"US \u0022Investigators also acknowledge the assistance provided by the Supreme People\u0027s Procuratorate and Ministry of Public Security of the People\u0027s Republic of China.\u0022  (Source: US Attorney\u0027s Office for the Central District of California, \u0022Fugitive Chinese Official And Former Wife Named In Grand Jury Indictment Charging Immigration Fraud And Money Laundering,\u0022 March 17, 2015)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to a press release by the United States Attorney\u0027s Office for the Central District of California, \u0022the indictment also alleges that Qiao engaged in fraudulent grain transactions while serving as the grain storehouse director, and Qiao and Zhao had money transferred out of China, with approximately $500,000 being used to purchase the [Seattle suburb] Newcastle property.\u0022 \u00a0 Ms. Zhao was arrested in March 2015 in the U.S. \u00a0Mr. Qiao is a fugitive. (Source: US Department of Justice, \u0022Fugitive Chinese Official And Former Wife Named In Grand Jury Indictment Charging Immigration Fraud And Money Laundering,\u0022 March 17, 2015)","Disposition of Criminal Case(s)":"According to a press release by the United States Attorney\u0027s Office for the Central District of California, Mr. Qiao and Ms. Zhao are \u0022charged in a federal grand jury indictment unsealed today with conspiracy to commit immigration fraud and international transport of stolen funds, as well as conspiracy to commit money laundering. Zhao is additionally charged with one count of immigration fraud.\u0022 (Source: \u00a0US Department of Justice, \u0022Fugitive Chinese Official And Former Wife Named In Grand Jury Indictment Charging Immigration Fraud And Money Laundering,\u0022 March 17, 2015)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Immigration and Customs Enforcement\u2019s (ICE) Homeland Security Investigations (HSI) and Internal Revenue Service - Criminal Investigation, which received assistance from U.S. Citizenship and Immigration Services","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney\u0027s Office for the Central District of California","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Central District of California","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aleman_Nicaragua_SCt_Overturn_Conviction_Jurist_Jan_19_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aleman_Nuevo_Diario_July_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aleman_Panama_SCt_Canal15_Dec_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aleman_Panama_World-check_Jul_23_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Qiao_Zhao_US_Indictment_DOJ_PR_Mar_17_2015.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aleman_Nicaragua_SCt_Overturn_Conviction_Jurist_Jan_19_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aleman_Nuevo_Diario_July_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aleman_Panama_SCt_Canal15_Dec_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aleman_Panama_World-check_Jul_23_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Qiao_Zhao_US_Indictment_The%20Seattle%20Times_Mar_17_2015.pdf","Sources ":"US Department of Justice, \u0022Fugitive Chinese Official And Former Wife Named In Grand Jury Indictment Charging Immigration Fraud And Money Laundering,\u0022 March 17, 2015, at http:\/\/www.justice.gov\/usao\/cac\/Pressroom\/2015\/028.html;\n\t\u00a0\n\tSanjay Bhatt, \u0022Newcastle woman charged with fraud in immigrant-investor visas,\u0022 The Seattle Times, March 17, 2015, at http:\/\/www.seattletimes.com\/business\/real-estate\/newcastle-woman-charged....\n"},{"Case ID":"ARW-229","Case Title (Name of Public Official or Entity Allegedly Involved)":"Viktor Yanukovych \/ Austria","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"President (2010-2014)","Jurisdiction of Asset Recovery":"Austria","Jurisdiction of Asset Description":"Location of Recovery Effort","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to a February 2014 press statement by the Austrian Federal Ministry, Austria imposed a freeze on accounts of eighteen individuals: Mr. Yanukovych, his son and top members of his government. \u00a0The statement noted that Austria had taken the step at the request of the Ukrainian government as the EU was considering sanctions against these individuals, so as to prevent the assets from being withdrawn from the country. \u00a0(Source: \u00a0Austrian Federal Ministry, \u0022APA: \u00d6sterreich friert heimische Konten von 18 Ukrainern ein \/ Auf Ersuchen der neuen Regierung in Kiew - Hintergrund sind m\u00f6gliche Menschenrechtsverletzungen und Korruptionsverdacht,\u0022 February 28, 2014; See also \u00a0\u0022Statement on Ukraine by Federal Minister Sebastian Kurz at the plenary session of the Austrian Parliament, 24.2.2014,\u0022 and Austrian Financial Market Authority Press Release, \u0022FMA draws attention to enhanced customer due diligence in the context of business relationships with politically exposed persons from Ukraine,\u0022 February 21, 2014.). \u00a0 The National Bank of Austria Regulation DevG 1\/2014 lists the individuals. (Source: \u00a0Stolen Asset Recovery Initiative, Asset Recovery Actions for Ukraine, at http:\/\/star.worldbank.org\/star\/sites\/star\/files\/verordnung_devg_1-2014fi...)","Disposition of Criminal Case(s)":"According to the INTEROL wanted list, Mr. Yanukovych is \u0022Wanted by the Judicial Authorities of Ukraine for Prosecution \/ to serve a sentence\u0022 with the following charges listed: \u0022Misappropriation, embezzlement or conversion of property by malversation, if committed in respect of an especially gross amount, or by an organized group.\u0022 \u00a0(Source: INTERPOL, \u0022Viktor Yanukovych,\u0022 at http:\/\/www.interpol.int\/notice\/search\/wanted\/2014-13031 (last accessed January 21, 2015).\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_Interpol_Wanted_List_Jan_21_2015_2.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_Austria_Asset_Freeze_Fed_Min_Speech_Feb_24_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_Austria_Natl_Bank_Sanctions_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_Austria_FMA_EDD_Notice_Feb_21_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_Austria_Asset_Freeze_Fed_Min_PR_Feb_28_2014.pdf","Sources ":"\n\tAustrian Federal Ministry, \u0022APA: \u00d6sterreich friert heimische Konten von 18 Ukrainern ein \/ Auf Ersuchen der neuen Regierung in Kiew - Hintergrund sind m\u00f6gliche Menschenrechtsverletzungen und Korruptionsverdacht,\u0022 February 28, 2014, at http:\/\/www.bmeia.gv.at\/das-ministerium\/presse\/aussendungen\/2014\/apa-oest... and \u0022Statement on Ukraine by Federal Minister Sebastian Kurz at the plenary session of the Austrian Parliament, 24.2.2014,\u0022 at http:\/\/www.bmeia.gv.at\/en\/the-ministry\/press\/speeches-and-interviews\/201...\n\n\t\u00a0\n\n\tNational Bank of Austria Regulation DevG 1\/2014, at http:\/\/star.worldbank.org\/star\/sites\/star\/files\/verordnung_devg_1-2014fi...\n\n\t\u00a0\n\n\tAustrian Financial Market Authority Press Release, \u0022FMA draws attention to enhanced customer due diligence in the context of business relationships with politically exposed persons from Ukraine,\u0022 February 21, 2014, at https:\/\/www.fma.gv.at\/fileadmin\/media_data\/1_Ueber_die_FMA\/3_Presse\/1_Pr...\n\n\t\u00a0\n"},{"Case ID":"ARW-230","Case Title (Name of Public Official or Entity Allegedly Involved)":"Viktor Yanukovych \/ European Union","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"President (2010-2014)","Jurisdiction of Asset Recovery":"European Union","Jurisdiction of Asset Description":"Location of Recovery Effort","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"","Money laundering Implicated":"","Legal Basis for Asset Recovery":"","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the European Council Council Regulation (EU) No 208\/2014 of 5 March 2014 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Ukraine, the EU has imposed an asset freeze against a total of 18 individuals including the former President Yanjukovych, senior members of his government, associates and family members. \u00a0(Source: \u00a0European Council Council Regulation (EU) No 208\/2014 of 5 March 2014 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Ukraine; See also, The Guardian, \u0022Ukraine: EU freezes assets of Yanukovych\u0027s former hierarchy,\u0022 March 5, 2014.)","Disposition of Criminal Case(s)":"According to the INTEROL wanted list, Mr. Yanukovych is \u0022Wanted by the Judicial Authorities of Ukraine for Prosecution \/ to serve a sentence\u0022 with the following charges listed: \u0022Misappropriation, embezzlement or conversion of property by malversation, if committed in respect of an especially gross amount, or by an organized group.\u0022 \u00a0(Source: INTERPOL, \u0022Viktor Yanukovych,\u0022 at http:\/\/www.interpol.int\/notice\/search\/wanted\/2014-13031 (last accessed January 21, 2015).\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_Interpol_Wanted_List_Jan_21_2015_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_EU_Council_Reg_208_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_EU_Asset_Freeze_The%20Guardian_Mar_2014.pdf","Sources ":"Council Regulation (EU) No 208\/2014 of 5 March 2014 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Ukraine, at http:\/\/eur-lex.europa.eu\/legal-content\/EN\/TXT\/?uri=CELEX:32014R0208; \u00a0he Guardian, \u0022Ukraine: EU freezes assets of Yanukovych\u0027s former hierarchy,\u0022 March 5, 2014, at http:\/\/www.theguardian.com\/world\/2014\/mar\/06\/ukraine-eu-freezes-assets-y...\n"},{"Case ID":"ARW-225","Case Title (Name of Public Official or Entity Allegedly Involved)":"Carlos Fragoso","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mozambique","Position of Public Official(s) (yrs in office)":"National Director, National Directorate of Roads and Bridges (1997-1999); President of the Board of Directors, National Roads Administration (1999-2003)","Jurisdiction of Asset Recovery":"Jersey","Jurisdiction of Asset Description":"Location of Recovery Effort; Asset Location\/Alleged Asset Location","Asset Recovery Start":"2010","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Asset Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Judgment held that the trustee of a Trust Fund held the funds deemed to be illicit proceeds as constructive trustee for the Government of Mozambique, stating in part that \u0022there are important reasons of policy for this Court to follow [the UK Privy Court decision in Attorney General for Hong Kong v.] Reid, namely the need to deter fraud and corruption and to have the ability to strip fiduciaries who have channelled their illicit funds through this jurisdiction of all benefits.\u0022  (Source: Lloyds Trust Co. (CI) Ltd. v. Fragoso and others, [2013] JRC 211, para 28.)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"$645,182 (Value of trust as of October 31, 2013 Judgment)","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"","Case Summary":"According to the October 31, 2013 Judgment by the Isle of Jersey Royal Court in Lloyds Trust Co (Channel Islands) Ltd. v. Fragoso, Hoy, Government of Mozambique and HM Attorney General {[2013] JRC 211), the funds held in The Rex Trust formed by Mr. Fragoso was ordered to be paid to the Government of Mozambique. \u00a0 In so doing, the Court held that Lloyds Trust Co as the trustee of the Rex Trust held the funds as constructive trustee for the Government of Mozambique. \u00a0As described in the Judgment, the Trust was established in 1999 by Mr. Fragoso who had described himself as a civil engineer and he informed the Lloyds TSB Offshore Trust Limited that the funds settled into the Trust were the proceeds of civil engineering consultancy contracts. \u00a0\u0022He did not disclose that he held public office in Mozambique.\u0022 (para 3) \u00a0In 2010, Lloyds Trust became aware of the conviction of the UK engineering firm Mabey \u0026 Johnson on charges of foreign bribery and that the Prosecution\u0027s Opening Statement included mention of bribes paid by the company to Mr. Fragoso in 1997 and 2000. \u00a0In 2010, Lloyds filed a Suspicious Activity Report to the Jersey Financial Crimes Unit and informed Mr. Fragoso of its concerns and \u0022required him to provide evidence as to the source of the funds, and specifically, that the funds were not the proceeds of crime.\u0022 (para 6). \u00a0Lloyds, joined by the Government of Mozambique, sought an order from the Jersey Royal Court that the trust fund, net of costs, be paid to the Government of Mozambique. \u00a0The Court held that \u0022It is true that it is not possible to trace all of the funds within the Trust back to Mabey \u0026 Johnson, but we find that, on the balance of probabilities, all of the funds within the Trust represent bribes received by Mr. Fragoso in his role as a public officer for Mozambique\u0022 including for the reasons that he lied to Lloyds as to his occupation and source of funds when the Trust was established and his inability to produce any evidence as to the source of the remaining funds within the Trust which cannot be traced back to Mabey \u0026 Johnson and that his legitimate source of income during the material period was his salary [which according to the information provided by the Government of Mozambique was equivalent to 1,500 Euros per month] (paras 12 and 18). \u00a0","Disposition of Criminal Case(s)":"Unknown","Jurisdiction of Origin: Investigative Agency":"National Roads Administration","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Jersey Financial Crimes Unit","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"Royal Court (Samedi Division)","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Fragoso_Jersey_Lloyds_Constructive_Trust_2013_JRC_211.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Fragoso_Jersey-Court-Endorses-Proprietary-Claim-to-Proceeds-of-Corruption_Baker_Partners.pdf","Sources ":"Bet. Lloyds Trust Company (Channel Islands) Limited and Carlos Fragoso and others, [2013] JRC 211, at http:\/\/www.jerseylaw.je\/judgments\/unreportedjudgments\/documents\/display....(CI)_Ltd_211.htm;\n\t\u00a0\n\tBaker \u0026 Partners, \u0022Jersey Court Endorses Proprietary Claim to Proceeds of Corruption in re: the Representation of Lloyds TSB Offshore Trust Company Limited,\u0022 (undated), at http:\/\/www.bakerandpartners.com\/media\/18948\/Jersey-Court-Endorses-Propri...\n"},{"Case ID":"ARW-226","Case Title (Name of Public Official or Entity Allegedly Involved)":"Mario Roberto Zelaya Rojas","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Honduras","Position of Public Official(s) (yrs in office)":"Executive Director, Honduran Institute of Social Security (2010-2014)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Alleged Asset Location\/Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.19, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"","Case Summary":"According to the US Department of Justice (DOJ) Press Release, \u0022From 2010 to 2014, Dr. Mario Roberto Zelaya Rojas, 46, of Tegucigalpa, Honduras, served as the Executive Director of the Honduran Institute of Social Security (HISS), a Honduran Government agency that provides social security services, including workers\u2019 compensation, retirement, maternity, and death benefits. \u00a0According to allegations in the forfeiture complaint, Zelaya solicited and accepted $2.08 million in bribes from Compania De Servicios Multiples, S. de R. L. (COSEM) in exchange for prioritizing and expediting payments owed to COSEM under a $19 million contract with HISS. \u00a0Zelaya also allegedly instructed COSEM to make bribe payments to two members of the Board of Directors of HISS charged with overseeing the COSEM contract. \u00a0To conceal the illicit payments, COSEM allegedly sent the bribes through its affiliate company, CA Technologies.\u00a0\n\t\u00a0\n\tAs further alleged in the complaint, the bribe proceeds were then laundered into the United States and used by Zelaya and his brother, Carlos Alberto Zelaya Rojas, to acquire real estate in the New Orleans area. \u00a0Certain properties were titled in the name of companies nominally controlled by Zelaya\u2019s brother in an effort to conceal the illicit source of the funds as well as the beneficial owner. \u00a0The current action seeks forfeiture of nine properties acquired with the proceeds of Zelaya\u2019s alleged bribery scheme.\u0022 \u00a0(Source: US Department of Justice Press Release, \u0022Department of Justice Seeks Recovery of Approximately $1,528,000 in Bribes Paid to a Honduran Official,\u0022 January 13, 2015.)\n\t\u00a0\n\tIn late January 2015, the defendant properties filed an Answer in the case, requesting the case be dropped for lack of sufficient evidence. \u00a0As of May 22, 2016, the case was ongoing. \u00a0(Sources: \u00a0Answer filed January 27, 2015 and Court Docket report as of May 22, 2016.)\u00a0","Disposition of Criminal Case(s)":"NA","Jurisdiction of Origin: Investigative Agency":"Assistance by Public Ministry of the Republic of Honduras","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Homeland Security Investigations\u0027 New Orleans and Miami Field Offices and Attache Tegucigalpa; Assistance by DOJ Criminal Division\u0027s Office of Overseas Prosecutorial Development, Assistance and Training Resident Legal Advisor (Tegucigalpa)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"DOJ Criminal Division\u0027s Asset Forfeiture and Money Laundering Section, Kleptocracy Asset Recovery Initiative; United States Attorney\u0027s Office, Eastern District of Louisiana","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the Eastern District of Louisiana","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Zelaya_US_Forfeiture_DOJ_PR_Jan_13_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Zelaya_US_Forfeiture_Complaint_Jan_13_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Zalaya_Answer_Jan27_2015.pdf","Sources ":"US Department of Justice Press Release, \u0022Department of Justice Seeks Recovery of Approximately $1,528,000 in Bribes Paid to a Honduran Official,\u0022 January 13, 2015, at http:\/\/www.justice.gov\/opa\/pr\/department-justice-seeks-recovery-approxim... (includes link to Complaint filed January 13, 2015 in US v. Real Property Located at 1404 North Highway 190, Covington, Louisiana 70433, et al, Case No. 2:15-cv-74 (EDLA); Answer filed January 27, 2015 and Court Docket Report as of May 22, 2016.)\n"},{"Case ID":"ARW-224","Case Title (Name of Public Official or Entity Allegedly Involved)":"Mahamoud Adam Bechir and Nouracham Niam \/ South Africa","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Chad","Position of Public Official(s) (yrs in office)":"Ambassador to South Africa (current); former Ambassador to Canada and the United States (Bechir); Wife of Ambassador (Niam)","Jurisdiction of Asset Recovery":"South Africa","Jurisdiction of Asset Description":"Alleged Asset Location \/ Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.18, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Action Initiated by Foreign Jurisdiction ","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the US Department of Justice Press Release, in November 2014, a civil asset forfeiture case was brought under the Kleptocracy Asset Recovery Initiative against alleged bribery proceeds belonging to Mr. Bechir. \u00a0The US government alleges that Mr. Bechir \u0022agreed to use his position to influence the award of oil development rights in Chad in exchange for $2 million and other valuable interests from Griffiths Energy International Inc., a Canadian company. \u00a0In order to conceal the bribe, Bechir and his wife, Nouracham Niam, 44, allegedly entered into a series of agreements with Griffiths Energy that provided for the payment of a $2 million \u201cconsulting fee\u201d if the company secured the oil rights in Chad. \u00a0After securing these oil rights in February 2011, Griffiths Energy allegedly transferred $2 million to an account located in Washington, D.C. held by a shell company created by Niam. \u00a0In 2013, Griffiths Energy pleaded guilty in Canadian court to bribing Bechir.\n\t\u00a0\n\tThe complaint further alleges that, after commingling the bribe payment with other funds and laundering these funds through U.S. bank accounts and real property, Bechir transferred $1,474,517 of the criminal proceeds traceable to the bribe payment to his account in South Africa, where he is now serving Chad\u2019s Ambassador to South Africa. \u00a0The current action seeks forfeiture of $106,488.31, which is the current balance of Bechir\u2019s accounts in South Africa. \u00a0Those funds have been seized pursuant to the complaint unsealed today. \u00a0The Department of Justice is also seeking additional assets from Bechir and Niam.\u0022 \u00a0(Source: US Department of Justice Press Release, \u0022Department of Justice Seeks Recovery of Approximately $100,000 in Bribes Paid to Former Chad Ambassador,\u0022 November 7, 2014, at http:\/\/www.justice.gov\/opa\/pr\/department-justice-seeks-recovery-approxim....) \u00a0\n\t\u00a0\n\tIn May 2015, Mr. Bechir filed an Amended Answer to the complaint, admitting that Griffiths Energy paid $2 million to Niam\u0027s company but that he had no sufficient knowledge to form a belief as to the truth of the bribery allegations. \u00a0As of May 9, 2016, the case was ongoing. (Source: US v. All Funds up to and including $1,474,517 in Interbank accounts held by or for the benefit of Nedbank, Ltd, Case No. 1:14-cv-1178 (D.D.C.), Amended Answer filed May 20, 2015 Court Docket Report as of June 23, 2016.)\u00a0","Disposition of Criminal Case(s)":"NA","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_US_DOJ_PR_Nov_7_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_US_Complaint_Jul_8_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_US_DDC_Verified_CLaim_Dec_11_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_US_Amended%20Answer_May%2020%202015_0.pdf","Sources ":"US Department of Justice Press Release, \u0022Department of Justice Seeks Recovery of Approximately $100,000 in Bribes Paid to Former Chad Ambassador,\u0022 November 7, 2014, at http:\/\/www.justice.gov\/opa\/pr\/department-justice-seeks-recovery-approxim....) \u00a0\n\t\u00a0\n\tUS v. All Funds up to and including $1,474,517 in Interbank accounts held by or for the benefit of Nedbank, Ltd, Case No. 1:14-cv-1178 (D.D.C.), Verified Complaint for Forfeiture in rem filed July 8, 2014, Amended Answer (Bechir) filed May 20, 2015 and Court Docket Report as of June 23, 2016.\n\t\u00a0\n\tSee also, Wall Street Journal Blog, \u0022U.S. Seeks Bribes Paid by Griffiths Energy,\u0022 November 7, 2014, at http:\/\/blogs.wsj.com\/riskandcompliance\/2014\/11\/07\/u-s-seeks-bribes-paid-... The Globe and Mail, \u0022Read the letter from Mahamoud Adam Bechir,\u0022 Published Wednesday, Jan. 30 2013, at http:\/\/www.theglobeandmail.com\/report-on-business\/international-business...\n"},{"Case ID":"ARW-223","Case Title (Name of Public Official or Entity Allegedly Involved)":"Mahamoud Adam Bechir and Nouracham Niam \/ United States (South Africa account)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Chad","Position of Public Official(s) (yrs in office)":"Ambassador to South Africa (current); former Ambassador to Canada and the United States (Bechir); Wife of Ambassador (Niam)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Alleged Asset Location\/Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.18, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Asset Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case ","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the US Department of Justice Press Release, in November 2014, a civil asset forfeiture case was brought under the Kleptocracy Asset Recovery Initiative against alleged bribery proceeds belonging to Mr. Bechir. \u00a0The US government alleges that Mr. Bechir \u0022agreed to use his position to influence the award of oil development rights in Chad in exchange for $2 million and other valuable interests from Griffiths Energy International Inc., a Canadian company. \u00a0In order to conceal the bribe, Bechir and his wife, Nouracham Niam, 44, allegedly entered into a series of agreements with Griffiths Energy that provided for the payment of a $2 million \u201cconsulting fee\u201d if the company secured the oil rights in Chad. \u00a0After securing these oil rights in February 2011, Griffiths Energy allegedly transferred $2 million to an account located in Washington, D.C. held by a shell company created by Niam. \u00a0In 2013, Griffiths Energy pleaded guilty in Canadian court to bribing Bechir.\n\t\u00a0\n\tThe complaint further alleges that, after commingling the bribe payment with other funds and laundering these funds through U.S. bank accounts and real property, Bechir transferred $1,474,517 of the criminal proceeds traceable to the bribe payment to his account in South Africa, where he is now serving Chad\u2019s Ambassador to South Africa. \u00a0The current action seeks forfeiture of $106,488.31, which is the current balance of Bechir\u2019s accounts in South Africa. \u00a0Those funds have been seized pursuant to the complaint unsealed today. \u00a0The Department of Justice is also seeking additional assets from Bechir and Niam.\u0022 \u00a0(Source: US Department of Justice Press Release, \u0022Department of Justice Seeks Recovery of Approximately $100,000 in Bribes Paid to Former Chad Ambassador,\u0022 November 7, 2014, at http:\/\/www.justice.gov\/opa\/pr\/department-justice-seeks-recovery-approxim....) \u00a0\n\t\u00a0\n\tIn May 2015, Mr. Bechir filed an Amended Answer to the complaint, admitting that Griffiths Energy paid $2 million to Niam\u0027s company but that he had no sufficient knowledge to form a belief as to the truth of the bribery allegations. \u00a0As of October 28, 2015, the case was ongoing. (Source: US v. All Funds up to and including $1,474,517 in Interbank accounts held by or for the benefit of Nedbank, Ltd, Case No. 1:14-cv-1178 (D.D.C.), Amended Answer filed May 20, 2015 Court Docket Report as of June 23, 2016.)","Disposition of Criminal Case(s)":"NA","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Kleptocracy Asset Recovery Initiative, Department Justice, Criminal Division\u2019s Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the District of Columbia","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_US_DOJ_PR_Nov_7_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_US_Complaint_Jul_8_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_US_DDC_Verified_CLaim_Dec_11_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bechir_US_Amended%20Answer_May%2020%202015.pdf","Sources ":"US Department of Justice Press Release, \u0022Department of Justice Seeks Recovery of Approximately $100,000 in Bribes Paid to Former Chad Ambassador,\u0022 November 7, 2014, at http:\/\/www.justice.gov\/opa\/pr\/department-justice-seeks-recovery-approxim....) \u00a0\n\t\u00a0\n\tUS v. All Funds up to and including $1,474,517 in Interbank accounts held by or for the benefit of Nedbank, Ltd, Case No. 1:14-cv-1178 (D.D.C.), Verified Complaint for Forfeiture in rem filed July 8, 2014, Amended Answer (Bechir) filed May 20, 2015 and Court Docket Report as of June 23, 2016.\n\t\u00a0\n\tSee also, Wall Street Journal Blog, \u0022U.S. Seeks Bribes Paid by Griffiths Energy,\u0022 November 7, 2014, at http:\/\/blogs.wsj.com\/riskandcompliance\/2014\/11\/07\/u-s-seeks-bribes-paid-... The Globe and Mail, \u0022Read the letter from Mahamoud Adam Bechir,\u0022 Published Wednesday, Jan. 30 2013, at http:\/\/www.theglobeandmail.com\/report-on-business\/international-business...\n"},{"Case ID":"ARW-228","Case Title (Name of Public Official or Entity Allegedly Involved)":"Viktor Yanukovych \/ Switzerland","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"President (2010-2014)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.19, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Swiss Federal Council Ordinance","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"","Case Summary":"According to the 2014 Annual Report (published May 2015) by the Swiss Office of the Federal Police, US$175 million in Yanukovych related assets have been frozen in Switzerland. \u00a0The report indicated that the funds had passed through accounts in numerous jurisdictions, including Cyprus, British Virgin Islands, Austria, Liechtenstein, Great Britain, the Netherlands and Switzerland. \u00a0(Original text, at pages 28-29: \u0022Les renseignements disponibles indiquent un flux de fonds pass ant par de nombreux comptes off-shore, notamment \u00e0 Chypre et dans les Iles Vierges britanniques ainsi qu\u2019en Autriche, au Liechtenstein, en Grande-Bretagne, aux Pays-Bas et en Suisse. Se concertant avec l\u2019UE, la Suisse a bloqu\u00e9 \u00a0pr\u00e9ventivement des valeurs patrimoniales \u00e0 hau- teur de 75 millions de dollars environ appartenant \u00e0 M. Ianoukovytch et \u00e0 son entourage, afin de laisser suffisamment de temps aux autorit\u00e9s ukrainiennes de poursuite p\u00e9nale pour pr\u00e9senter des demandes \u00e9ventuelles d\u2019entraide judiciaire. Dans le m\u00eame temps, le MPC et les autorit\u00e9s cantonales genevoises ont ou vert des enqu\u00eates pour abus de confiance, corruption, abus d\u2019autorit\u00e9 et blanchiment d\u2019argent, bloquant \u00e0 cet \u00e9gard 100 autres millions de dollars.\u0022)\n\t\t\u00a0\n\t\tAn earlier media release by the Swiss Foreign Ministry on February 28, 2014 had stated, \u0022[t]he Federal Council has decided to block all assets Viktor Yanukovych and his entourage might have in Switzerland. The corresponding ordinance enters into force today, Friday 28 February. In taking this measure, the Federal Council wishes to avoid any risk of misappropriation of Ukrainian state assets. [ ]\u00a0\n\t\t\u00a0\n\t\tIn view of the most recent developments, the Federal Council wishes to take all measures necessary to avoid the risk of any misappropriation of financial assets of the Ukrainian state. It has therefore decided, in conjunction with other financial centres, to block all assets Viktor Yanukovych and his entourage might have in Switzerland. The Federal Council has also prohibited the sale and any disposal of assets, namely property, of these persons. The aim of this measure is to prevent these assets being taken out of Switzerland before they can be blocked through the ordinary channels of mutual legal assistance in cooperation with the Ukrainian authorities.\n\t\t\u00a0\n\t\tShould such assets subsequently be proved through criminal proceedings to have been obtained illegally, they can thus be returned to Ukraine following criminal conviction of the former leaders and their entourage. The Swiss authorities are prepared to cooperate closely with the Ukrainian authorities.\u0022 \u00a0(Source: Switzerland Ministry of Foreign Affairs media release, \u0022Federal Council blocks all assets Viktor Yanukovych and his entourage might have in Switzerland,\u0022 February 28, 2014.)\n\u00a0","Disposition of Criminal Case(s)":"According to the INTEROL wanted list, Mr. Yanukovych is \u0022Wanted by the Judicial Authorities of Ukraine for Prosecution \/ to serve a sentence\u0022 with the following charges listed: \u0022Misappropriation, embezzlement or conversion of property by malversation, if committed in respect of an especially gross amount, or by an organized group.\u0022 \u00a0(Source: INTERPOL, \u0022Viktor Yanukovych,\u0022 at http:\/\/www.interpol.int\/notice\/search\/wanted\/2014-13031 (last accessed January 21, 2015).\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General\u0027s Office","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Office of Federal Police\u0027 Ministere Public de la Confederation; Geneva cantonal authorities","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_Interpol_Wanted_List_Jan_21_2015_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_Switzerland_Fed_Council_Freeze_Feb_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Swiss%20Federal%20Police%20Annual%20Report%202014_Pub%20May%202015.pdf","Sources ":"Switzerland Office of Federal Police Annual Report for 2014 (Published May 2015), at http:\/\/www.ejpd.admin.ch\/dam\/data\/fedpol\/publiservice\/publikationen\/beri...\n\t\u00a0\n\tSwitzerland Ministry of Foreign Affairs media release, \u0022Federal Council blocks all assets Viktor Yanukovych and his entourage might have in Switzerland,\u0022 February 28, 2014, at https:\/\/www.news.admin.ch\/dokumentation\/00002\/00015\/index.html?lang=en\u0026m...\n\t\u00a0\n\tSwiss Federal Department of Foreign Affairs, \u0022FAQ on frozen assets of Politically Exposed Persons (PEPs) originating from Ukraine \u2013 ordinance of the Federal Council,\u0022 April 2014, at https:\/\/www.eda.admin.ch\/content\/dam\/eda\/en\/documents\/topics\/FAQ-frozen-...\n\t\u00a0\n\tSwiss Federal Council Ordinances Instituting measures against certain persons from Ukraine (Ordonnance\u00a0\n\tinstituant des mesures \u00e0 l\u2019encontre de certaines personnes originaires de l\u2019Ukraine), February 26, 2014 and modified March 7, 2014, accessed at http:\/\/www.admin.ch\/bundesrecht\/aop\/00724\/index.html?lang=fr;\n\t\u00a0\n\tSwissinfo.ch, \u0022Swiss investigate Yanukovych for money laundering,\u0022 February 28, 2014, at http:\/\/www.swissinfo.ch\/eng\/swiss-investigate-yanukovych-for-money-laund...\n\t\u00a0\n\tThe Economist, \u0022\u0022A Long, Hard Slog: Ukraine\u0027s stolen assets,\u0022 March 5, 2014, at http:\/\/www.economist.com\/blogs\/easternapproaches\/2014\/03\/ukraine-s-stole...\n"},{"Case ID":"ARW-227","Case Title (Name of Public Official or Entity Allegedly Involved)":"Viktor Yanukovych \/ Liechtenstein","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"President (2010-2014)","Jurisdiction of Asset Recovery":"Liechtenstein","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.19, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"","Case Summary":"According to the June 2014 statement by Liechtenstein\u0027s Prosecutor General and Director of the Financial Intelligence Unit, the jurisdiction froze assets of \u0022approximately 27 million Swiss francs that can be attributed to former Ukrainian politicians. The Liechtenstein Office of the Public Prosecutor has instituted criminal proceedings for money laundering in this connection. Shortly after the appointment of a new Ukrainian government in February 2014, criminal investigations were instituted in Ukraine against the former president, members of the former government, and family members of those persons on grounds of corruption. Consequently, Liechtenstein ordered on 28 February 2014 that potential assets of those persons be frozen and that any such assets be notified to the authorities.\u00a0\n\tThe goal of these measures is to ensure that assets of those persons can be identified. Reports to this effect were then submitted to the Financial Intelligence Unit (FIU) for evaluation. In one group of cases, there is an initial suspicion that a criminal offence was committed, so the FIU notified the Office of the Public Prosecutor. The Office of the Public Prosecutor has applied to the investigating judge to carry out preliminary investigations against four suspects on suspicion of the crime of money laundering as referred to in \u00a7 165 paragraphs 1, 2, and 3 of the Liechtenstein Criminal Code (StGB).\u0022 \u00a0(Source: \u00a0\u0022Ukraine: Liechtenstein freezes CHF 27 million and institutes criminal proceedings for money laundering,\u0022 at http:\/\/star.worldbank.org\/star\/sites\/star\/files\/liechtenstein_-_ukraine_....)\n\t\u00a0","Disposition of Criminal Case(s)":"According to the INTEROL wanted list, Mr. Yanukovych is \u0022Wanted by the Judicial Authorities of Ukraine for Prosecution \/ to serve a sentence\u0022 with the following charges listed: \u0022Misappropriation, embezzlement or conversion of property by malversation, if committed in respect of an especially gross amount, or by an organized group.\u0022 \u00a0(Source: INTERPOL, \u0022Viktor Yanukovych,\u0022 at http:\/\/www.interpol.int\/notice\/search\/wanted\/2014-13031 (last accessed January 21, 2015)).","Jurisdiction of Origin: Investigative Agency":"Prosecutor General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor-General\u0027s Office","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Financial Intelligence Unit","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General\u0027s Office","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovych_Interpol_Wanted_List_Jan_21_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yanukovich_Liechtenstein_Asset_Freeze_PR_June_2014.pdf","Sources ":"\u0022Ukraine: Liechtenstein freezes CHF 27 million and institutes criminal proceedings for money laundering,\u0022 at http:\/\/star.worldbank.org\/star\/sites\/star\/files\/liechtenstein_-_ukraine_... INTERPOL, \u0022Viktor Yanukovych,\u0022 at http:\/\/www.interpol.int\/notice\/search\/wanted\/2014-13031 (last accessed January 21, 2015).\n"},{"Case ID":"ARW-93","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha \/ Ireland (Freezing Injunction on US Claim)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"Ireland","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"","Case Summary":"In August 2014, the US Department of Justice announced that more than US$480 million in Abacha corruption proceeds had been forfeited to the US: approximately US$303 million in two bank accounts in Bailiwick of Jersey, $144 million in 2 bank accounts in France [note: arrest in rem notes amount as US$159,374,531.89], and at least US$27 million in accounts in the UK and Ireland. \u00a0Please note that the amount held in Ireland was not specified in the press release. The Department of Justice also noted that claims against US$148 million in four investment portfolios in the UK are pending. (Sources: \u00a0US Department of Justice, \u0022U.S. Forfeits Over $480 Million Stolen by Former Nigerian Dictator in Largest Forfeiture Ever Obtained Through a Kleptocracy Action,\u0022 August 7, 2014; warrants for arrest in rem filed July 11, 2014 in US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, et al, Case No. l:13-cv-01832-JDB (D.D.C.).) \u00a0According to a Status Report filed by the US on August 18, 2014, the Government has until September 26, 2014 to respond to the claimants\u0027 (members of the Abacha family and others\u0027) Motion to Dismiss. \u00a0(US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Status Report filed August 18, 2014.) \u00a0According to the Department of Justice, the restraint of funds includes approximately $313 million in the name of Mohammed Sani and Doraville Properties Corporation in two bank accounts in the Bailiwick of Jersey and $145 million in the name of Rayville International SA and Standard Alliance Financial Services Limited in two bank accounts in France. In addition, four investment portfolios (all assets held in name of Blue Holding traceable to Ridley Group limited) and three bank accounts in the name of Mecosta Securities and Mohammed Sani in the United Kingdom with an expected value of at least $100 million have also been restrained [ ] [and] also seeks to forfeit five corporate entities registered in the British Virgin Islands (Doraville Properties Corporation, Mecosta Securities Inc., Rayville International SA, Ridley group Limited, Standard Alliance Financial Services Limited). (Source: US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, Limited in Jersey, Channel Islands, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Verified Complaint for Civil Asset Forfeiture).The complaint alleged that General Abacha, his son Mohammed Sani Abacha, their associate Abubakar Atiku Bagudu and others embezzled, misappropriated and extorted billions from the government of Nigeria and the Central Bank of Nigeria on the false pretense that the funds were necessary for national security, then laundered their criminal proceeds through the purchase of bonds backed by the United States using U.S. financial institutions. (Source: Department of Justice, Press release, \u0022U.S. Freezes More Than $458 Million Stolen by Former Nigerian Dictator in Largest Kleptocracy Forfeiture Action Ever Brought in the U.S..\u0022 March 5, 2014.) \u00a0","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate. \u00a0(Source: \u00a0Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_Forfeit_480_mil_DOJ_PR_Aug_7_2014_2.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_DDC_Order_Default_Aug_6_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_Mtn_Default_Judgment_Aug_4_2014.pdf","Sources ":"US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, Limited in Jersey, Channel Islands, Case No. l:13-cv-01832-JDB (D.D.C.), Verified Complaint for Civil Asset Forfeiture, unsealed on March 5, 2014 and available at:http:\/\/www.justice.gov\/iso\/opa\/resources\/765201435135920471922.pdf; US \u00a0Department of Justice, Press releases, \u0022U.S. Freezes More Than $458 Million Stolen by Former Nigerian Dictator in Largest Kleptocracy Forfeiture Action Ever Brought in the U.S.,\u0022 March 5, 2014, available at: http:\/\/www.justice.gov\/opa\/pr\/2014\/March\/14-crm-230.html and \u0022U.S. Forfeits Over $480 Million Stolen by Former Nigerian Dictator in Largest Forfeiture Ever Obtained Through a Kleptocracy Action,\u0022 August 7, 2014, at http:\/\/www.justice.gov\/opa\/pr\/2014\/August\/14-crm-835.html.\n"},{"Case ID":"ARW-13","Case Title (Name of Public Official or Entity Allegedly Involved)":"Aluminum Bahrain B.S.C. \/ Bruce Alan Hall UK SFO Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Bahrain","Position of Public Official(s) (yrs in office)":"Chief Executive Officer of State-Owned Entity, 2001-2005","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2009","Asset Recovery End":"2014","UNCAC Offenses Implicated":"Art.16, Art.18, Art.21","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Compensation","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"Extradition from Australia and \u0022liaison with foreign authorities.\u0022   (Source: UK Serious Fraud Office press release, \u0022Bruce Hall sentenced to 16 months in prison,\u0022 22 July 2014.) ","Contributing Factors in Asset Recovery":"Compensation to Alba ordered as part of Mr. Hall\u0027s sentence.","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$853,987","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the July 22, 2014 press release by the UK\u0027s Serious Fraud Office, Mr. Hall was sentenced to imprisonment for \u0022conspiracy to corrupt, in relation to contracts for the supply of goods and services to a Bahrain company, Aluminum Bahrain B.S.C. (Alba). \u00a0[ \u00a0] \u00a0[The Court] heard how Mr. Hall received [GBP] 2.9 million in corrupt payments between 2002 and 2005, including 10,000 Bahraini dinars in cash from Sheikh Isa bin Ali Al Khalifa, a member of the Bahraini royal family and at the time Bahrain\u0027s minister of finance and Alba\u0027s chairman. \u00a0The payments were made in exchange for Mr. Hall agreeing to and allowing corrupt arrangements that Sheikh Isa had been involved in before Mr. Hall\u0027s appointment as CEO to continue.\u0022 \u00a0(Source: UK Serious Fraud Office Press Release, \u0022Bruce Hall sentenced to 16 months in prison,\u0022 22 July 2014.) \u00a0 As part of his sentence, Mr. Hall was ordered to pay a confiscation order of GBP3,070,106.03; (US$5,243,560) and in addition, pay Alba compensation in the amount of GBP500,010 (US$853,987) and pay GBP 100,000 (US$170,794) as a contribution to prosecution costs.\u00a0\n\t\u00a0\n\tThe SFO also stated that, \u0022As part of Mr. Hall\u0027s mitigation he also agreed to divest himself of other corrupt payments he received during his time as the CEO of Alba. \u00a0These payments were not part of the indictment as the SFO did not have the jurisdiction to prosecute for the conduct acknowledged by Mr. Hall. \u00a0In order to recover these payments received by Mr. Hall, which amount to US$900,000, the Director of the SFO electd to launch proceedings under Part 5 of the Proceeds of Crime Act 2002 in the High Court. \u00a0These proceedings were finalised at the High Court on 17 July 2014.\u0022 \u00a0(Source: UK Serious Fraud Office Press Release, \u0022Bruce Hall sentenced to 16 months in prison,\u0022 22 July 2014.) \u00a0 On July 31, 2014, the SFO announced that the confiscation and compensation orders had been paid in full. (Source: \u00a0UK SFO Press Release, \u0022Bruce Hall confiscation order paid in full: 31 July 2014.\u0022)\n\t\u00a0\n\tSee related entry, Aluminum Bahrain B.S.C. \/ Alcoa Case (Private Civil Action)","Disposition of Criminal Case(s)":"According to the July 22, 2014 press release by the UK\u0027s Serious Fraud Office, Mr. Hall was sentenced to 16 months\u0027 inprisonment; he had entered a guilty plea to charge of Conspiracy to corrupt contrary to Section 1, Criminal Law Act 1977 and Section 1, Prevention of Corruption Act 1906. \u00a0(Source: UK Serious Fraud Office Press Release, \u0022Bruce Hall sentenced to 16 months in prison,\u0022 22 July 2014.) \u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Serious Fraud Office; City of London Police Overseas Anti-Corruption Unit","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Serious Fraud Office","Jurisdiction of Asset Recovery: Courts Involved":"City of Westminster Magistrates\u0027 Court; High Court Queens Bench","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/ALBA_UK_SFO_Hall_Sentence_Jul_22_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/ALBA_UK_SFO_Hall_Consent_Order_Jul_17_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/ALBA_UK_SFO_Hall_Civil_Recovery_Consent_Form.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/ALBA_UK__Hall_Paid_SFO_PR_Jul_31_2014.pdf","Sources ":"\n\tUK Serious Fraud Office Press Release, \u0022Bruce Hall sentenced to 16 months in prison,\u0022 22 July 2014, at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-20...\n\n\t\u00a0\n\n\tBruce Hall Civil Recovery Consent Order Claim Form, at http:\/\/www.sfo.gov.uk\/media\/269993\/140717%20sealed%20claim%20form%20and%... (last accessed and downloaded on July 27, 2014);\u00a0\n\n\t\u00a0\n\n\tUK SFO Press Release, \u0022Bruce Hall confiscation order paid in full: 31 July 2014, at http:\/\/www.sfo.gov.uk\/our-work\/our-cases\/case-progress\/bruce-hall-and-vi...\n\n\t\u00a0\n\n\tHigh Court Queens Bench Consent Order of 17 July 2014, at http:\/\/www.sfo.gov.uk\/media\/270013\/140717%20sealed%20consent%20order.pdf\n"},{"Case ID":"ARW-221","Case Title (Name of Public Official or Entity Allegedly Involved)":"Tomas Yarrington","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mexico","Position of Public Official(s) (yrs in office)":"Former Mayor of Matamoros, Mexico (1992- 1995); Governor of Tamaulipas state (1999-2004); Presidential candidate (2005)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort; Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2012","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.19, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Asset Forfeiture; Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty (US-Mexico)","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance (in part), Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"$640,000","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"In December 2012, the US District Court for the Southern District of Texas issued a final agreed judgment in a civil asset forfeiture case filed by the US Government, forfeiting a condominium at 334 South Padre Boulevard, South Padre Island. \u00a0The condominium, valued at $640,000, had been alleged to be proceeds of corrupt payments received by Mr. Yarrington from the Gulf Cartel, headquartered in Tamaulipas state, Mexico where he had been governor, in exchange for no interference in their criminal enterprise by public officials and law enforcement. \u00a0(Source: US v. Real Property Known as 334 South Padre Boulevard, South Padre Island, Case No. 12-cv-167 (S.D. Tex), Final Agreed Judgment filed December 10, 2012) \u00a0In May 2012, the US Government had also filed a criminal indictment and a superseding indictment on May 22, 2013 against Mr. Yarrington which included extensive criminal asset forfeiture allegations, including: (1) 2005 Pilatus aircraft; (2) 46.175 acre tract of land in Bexar County, Texas; (3) residence on Windward Drive, Port Isabel, Texas; and (4) over $183 million in joint and several liability with his co-defendant. \u00a0Mr. Yarrington is alleged to have funnelled bribery and embezzlement funds through use of shell companies and nominees to real properties and other assets in Mexico and the U.S. \u00a0As of June 2016 an arrest warrant had been issued and his case is pending. (Source: US v. Yarrington Ruvalcaba, et al, Case No. 1:12-cr-435 (S.D. Tex.), Superseding Indictment filed May 22, 2013; Court Docket Report as of June 27, 2016).","Disposition of Criminal Case(s)":"As of June 27, 2016, Mr. Yarrington remained under indictment on Racketeering and Money Laundering conspiracy, bank fraud and other charges. \u00a0(Source: \u00a0US v. Yarrington Ruvalcaba, Case No. 1:12-cr-435 (S.D. Tex), Court Docket Report as of June 27, 2016.)\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General of the Republic of Mexico","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Organized Crime Drug Enforcement Task Force investigation conducted in San Antonio, Brownsville, Houston and Corpus Christi by the Drug Enforcement Administration, Homeland Security Investigations, Internal Revenue Service - Criminal Investigation and the Texas Attorney General\u2019s Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney\u0027s Office for the Southern District of Texas","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the Southern District of Texas","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yarrington_SDTEX_Civil_Asset_Forfeit_Complaint_May_22_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yarrington_SDTEX_Civil_Asset_Final_Judgment_Dec_10_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yarrington_SDTEX_Supersed_Indictment_May_22_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yarrington_SDTEX_Civil_Asset_Forfeit_DOJ_PR_Dec_11_2012.pdf","Sources ":"US v. Real Property Known as 334 South Padre Boulevard, South Padre Island, Case No. 12-cv-167 (S.D. Tex), Final Agreed Judgment filed December 10, 2012 and Verified Complaint for Forfeiture in rem filed May 22, 2012; US v. Yarrington Ruvalcaba, et al, Case No. 1:12-cr-435 (S.D. Tex.), Superseding Indictment filed May 22, 2013 and Court Docket Report as of June 27, 2016.\n"},{"Case ID":"ARW-222","Case Title (Name of Public Official or Entity Allegedly Involved)":"Chun Doo Hwan \/ US Asset Forfeiture cases","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"South Korea","Position of Public Official(s) (yrs in office)":"President (1980-1988)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort; Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"2015","UNCAC Offenses Implicated":"Art.15, Art.18, Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Asset Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"The Department of Justice credited the significant assistance provided by the Seoul Central District Public Prosecutor\u0027s Office, Korea\u0027s Supreme Prosecutor\u0027s Office - Anti-Corruption Supervisory Division and the Ministry of Justice\u0027s International Criminal Affairs Division in investigating and forfeiting the corruption proceeds.  (Source: US Department of Justice Press Release, \u0022Justice Department Returns Forfeited Assets Derived from Public Corruption Scheme to Korean Minister of Justice,\u0022 November 10, 2015.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"According to a knowledgeable source, half of the funds were recovered as fine in relation to Mr. Chun\u0027s prosecution and first remitted to a fund by the Public Prosecutor\u0027s Office and eventually to a general fund managed by the Ministry of Strategy and Finance; the other half of the recovered assets went towards payment of owed taxes.","Case Summary":"According to the US Department of Justice Press Release, $1,126,951.45 in forfeited corruption proceeds related to the former Korean president Chun Doo Hwan\u0027s case was returned to the Korean Ministry of Justice. \u00a0The funds were forfeited pursuant to a settlement agreement with family members of Mr. Chun, against whom the US Department of Justice Kleptocracy Initiative had filed two asset forfeiture proceedings, in the US District Courts for the Central District of California and the Eastern District of Pennsylvania. \u00a0The Settlement Agreement provided for $100,000 for the claimants and the US DOJ agreed that should Mr. Chun\u0027s daughter in law Sang Ah Park file with the US Department of State an Application to Determine Returning Resident Status, it would not oppose or seek denial of such if filed within 2 years of the Settlement Agreement. (Sources: US Department of Justice Press Release, \u0022Justice Department Returns Forfeited Assets Derived from Public Corruption Scheme to Korean Minister of Justice,\u0022 November 10, 2015; the March 2015 Settlement Agreement is included as a link in US Department of Justice Press Release of March 4, 2015.) \u00a0\u00a0\n\t\t\t\u00a0\n\t\t\tAccording to the US in 2014, \u0022The Department of Justice filed a civil forfeiture complaint in the U.S. District Court for the Central District of California seeking to recover more than $700,000 in alleged corruption proceeds of Chun Doo-hwan, the former president of the Republic of Korea. [ \u00a0] \u00a0As alleged in the forfeiture complaint, President Chun was convicted in Korea in 1997 of receiving more than $200 million in bribes from Korean businesses and companies. \u00a0 President Chun and his relatives laundered some of these corruption proceeds through a web of nominees and shell companies in both Korea and the United States.\n\t\t\t\u00a0\n\t\t\tThrough close cooperation between U.S. and Korean law enforcement and prosecution authorities, the $721,951 sought for forfeiture was identified and seized when President Chun\u2019s relatives sold a home in Newport Beach that previously had been purchased with the laundered proceeds of President Chun\u2019s corruption.\u0022 \u00a0(Source: \u00a0US Department of Justice Press Release, \u0022U.S. Seeks to Recover Over $700,000 in Kleptocracy Proceeds of Former South Korean President Chun Doo-hwan,\u0022 April 24, 2014.)\n\t\t\t\u00a0\n\t\t\tThe complaint details the bribe payments that then-President Chun received from Korean companies, the use of nominees which included family members and close associates, shell companies and trust to conceal the origin and destination of the corruption proceeds including purchase and sale of a Georgia property which was held in a trust with his daughter-in-law\u0027s mother as sole trustee and the Newport Beach property which sold for more than US$2 million. \u00a0(Source: \u00a0US v. $726,951.45 in Uniti Bank Funds, Case No. cv-14-03140 (C.D. Cal), Verified Complaint for Forfeiture In Rem filed April 24, 2014.)\n\t\t\t\u00a0\n\t\t\tOn July 14, 2014, the claimants in the case (members of the Chun family and Port Manleigh Trust) filed an Answer to the complaint, stating that Jae Yong Chun had received bearer bonds from his grandfather and that he and his wife Sang Ah Park subsequently acquired a house in Georgia using funds earned and acquired through legal and legitimate means; they later sold that house and used to the proceeds to purchase the California house that is the subject of the present action. \u00a0(Source: US v. $726,951.45 in Uniti Bank Funds, Case No. cv-14-03140 (C.D. Cal), Answer of Claimants Jae Yong Chun, Sang Ah Park, Yang Ja Yoon, and Port Manleigh Trust to Verified Complaint for Forfeiture In Rem, para 11 and throughout, filed July 14, 2014.) \u00a0\n\t\t\t\u00a0\n\t\t\tIn a second case in the Eastern District of Pennsylvania, in September 2014, the Department of Justice announced that approximately $500,000 had been seized from an investment allegedly made by the former President\u0027s daughter-in-law in a Pennsylvania limited partnership. \u00a0(Source: US Department of Justice, \u0022Justice Department Seizes an Additional $500,000 in Corrupt Assets Tied to Former President of Republic of Korea,\u0022 September 3, 2014; US v. A Limited Partnership Interest held in the Name of or for the Benefit of Sang Ah Park in the Philadelphia U.S. Immigration Investment Fund, Case No. 2:14-mj-833 (E.D. Pa.)).\u00a0\n\u00a0","Disposition of Criminal Case(s)":"According to the April 2014 civil asset forfeiture complaint filed by the US, Mr. Chun was convicted in 1996 by Seoul District Court of accepting domestic bribes and murder and insurrection and was sentenced to death (later commuted) and ordered to pay $229 million. (Source: US v. $726,951.45 in Uniti Bank Funds, Case No. 14-cv-03140, Verified Complaint filed April 24, 2014, paras 16-18)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Supreme Prosecutor\u0027s Office, Ministry of Justice, Seoul Central District Prosecutor\u0027s Office","Jurisdiction of Origin: Courts Involved":"Seoul District Court","Jurisdiction of Asset Recovery: Investigative Agency":"FBI\u2019s Kleptocracy Program of the International Corruption Unit within the Criminal Investigation Division and the West Covina Resident Agency of the Los Angeles Division and HSI Attach\u00e9 Seoul, with assistance from HSI Miami; HSI Philadelphia","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Kleptocracy Asset Recovery Initiative, Department Justice, Criminal Division\u2019s Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"US District Courts for the Central District of California and Eastern District of Pennsylvania","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chun_US_CDCA_Complaint_Apr_24_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chun_US_CDCA_Claimants_Answer_Jul_14_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chun_US_EDPA_Seizure_DOJ_PR_Sep_3_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chun_US_Settlement_DOJ_PR_Mar_4_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chun_US_DOJ_executed_agreement_Mar_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chun_US_CDCA_Notice_of_settlement_Mar_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chun_USDOJ_Settlement%20Agreement_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chun_USDOJ_Asset%20Return_PR_Nov10%202015.pdf","Sources ":"US Department of Justice Press Release, \u0022Justice Department Returns Forfeited Assets Derived from Public Corruption Scheme to Korean Minister of Justice,\u0022 November 10, 2015, at http:\/\/www.justice.gov\/usao-cdca\/pr\/justice-department-returns-forfeited... US Department of Justice Press Release, \u0022United States Assists Korean Authorities in Recovering Over $28.7 million in Corruption Proceeds of Former President of the Republic of Korea,\u0022 March 4, 2015, including links to the Settlement Agreeement, at http:\/\/www.justice.gov\/sites\/default\/files\/opa\/press-releases\/attachment...\n\tUS v. $726,951.45 in Uniti Bank Funds, Case No. 14-cv-03140 (C.D. Cal), Verified Complaint for Forfeiture In Rem filed April 24, 2014 and Answer of Claimants Jae Yong Chun, Sang Ah Park, Yang Ja Yoon, and Port Manleigh Trust to Verified Complaint for Forfeiture In Rem, filed July 14, 2014 and Court Docket Report as of January 26, 2015; US Department of Justice Press Release, \u0022U.S. Seeks to Recover Over $700,000 in Kleptocracy Proceeds of Former South Korean President Chun Doo-hwan,\u0022 April 24, 2014, accessed at http:\/\/www.justice.gov\/opa\/pr\/2014\/April\/14-crm-430.html; Victoria Kim, \u0022Search for S. Korean official\u0027s secret funds leads to O.C.,\u0022 Los Angeles Times, April 24, 2014. \u00a0\n\t\u00a0\n\tUS Department of Justice, \u0022Justice Department Seizes an Additional $500,000 in Corrupt Assets Tied to Former President of Republic of Korea,\u0022 September 3, 2014, at http:\/\/www.justice.gov\/opa\/pr\/justice-department-seizes-additional-50000... US v. A Limited Partnership Interest held in the Name of or for the Benefit of Sang Ah Park in the Philadelphia U.S. Immigration Investment Fund, Case No. 2:14-mj-833 (E.D. Pa.), Court Docket Report;\u00a0\n\t\u00a0\n\tSee also, Korea Times, \u0022Ex-president\u0027s forfeited US assets returned,\u0022 November 10, 2015, at http:\/\/koreatimes.co.kr\/www\/news\/nation\/2015\/11\/113_190621.html\n"},{"Case ID":"ARW-220","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha \/ Jersey (Freezing on US Claim)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"Jersey","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Action Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"Civil Asset Recovery (International Co-operation) (Jersey) Law 2007","Contributing Factors in Asset Recovery":"Ongoing case but the Department of Justice press release on March 5, 2014 noted, \u0022The department appreciates the extensive assistance provided by the Governments of Jersey, France and the United Kingdom in this investigation.\u0022 ","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"See related entry, Sani Abacha \/ United States Civil Asset Forfeiture case. \u00a0According to the US Department of Justice, the civil asset forfeiture complaint filed in November 2013 and unsealed in March 2014, \u0022seeks to forfeit bank accounts and investment portfolios with funds located in Bailiwick of Jersey, France and the United Kingdom. On Feb. 25 and 26, 2014, U.S. arrest warrants for the assets were enforced in Jersey and France though mutual legal assistance requests and in the United Kingdom through litigation brought pursuant to the U.K. Civil Jurisdiction and Judgments Act.\u0022 \u00a0(Sources: US \u00a0Department of Justice, Press release, \u0022U.S. Freezes More Than $458 Million Stolen by Former Nigerian Dictator in Largest Kleptocracy Forfeiture Action Ever Brought in the U.S.,\u0022 March 5, 2014; Royal Court of Jersey, Viscount\u0027s Department, Affidavit of Service, March 12, 2014, filed as exhibit in US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Warrant of Arrest in Rem filed July 11, 2014.)","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate. \u00a0(Source: \u00a0Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Attorney General\u0027s Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"Royal Court of Jersey, Viscount\u0027s Department","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_DDC_Forfeiture_Complaint_Unsealed_Mar_2014_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_DOJ_Asset_Forfeiture_PR_Mar_5_2014_2.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_Forfeit_480_mil_DOJ_PR_Aug_7_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Jersey_Affidavit_Arrest_in_Rem_Mar_2014_0.pdf","Sources ":"US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Verified Complaint for Civil Asset Forfeiture, unsealed on March 5, 2014 and available at:http:\/\/www.justice.gov\/iso\/opa\/resources\/765201435135920471922.pdf and Warrants of Arrest in Rem filed July 11, 2014; US \u00a0Department of Justice, Press release, \u0022U.S. Freezes More Than $458 Million Stolen by Former Nigerian Dictator in Largest Kleptocracy Forfeiture Action Ever Brought in the U.S.,\u0022 March 5, 2014, available at: http:\/\/www.justice.gov\/opa\/pr\/2014\/March\/14-crm-230.html\n"},{"Case ID":"ARW-219","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha \/ France (Seizing on US Claim)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"France","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Action Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Treaty on Mutual Legal Assistance in Criminal Matters Between United States of America and France signed December 10, 1998, U.S.-Fr., Sept. 30, 2004, S. TREATY DOC. NO. 109-13 (2006)","Contributing Factors in Asset Recovery":"Ongoing case but the Department of Justice press release on March 5, 2014 noted, \u0022The department appreciates the extensive assistance provided by the Governments of Jersey, France and the United Kingdom in this investigation.\u0022 ","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"See related entry, Sani Abacha \/ United States Civil Asset Forfeiture case. \u00a0According to the US Department of Justice, the civil asset forfeiture complaint filed in November 2013 and unsealed in March 2014, \u0022seeks to forfeit bank accounts and investment portfolios with funds located in Bailiwick of Jersey, France and the United Kingdom. On Feb. 25 and 26, 2014, U.S. arrest warrants for the assets were enforced in Jersey and France though mutual legal assistance requests and in the United Kingdom through litigation brought pursuant to the U.K. Civil Jurisdiction and Judgments Act.\u0022 \u00a0(Sources: US \u00a0Department of Justice, Press release, \u0022U.S. Freezes More Than $458 Million Stolen by Former Nigerian Dictator in Largest Kleptocracy Forfeiture Action Ever Brought in the U.S.,\u0022 March 5, 2014; see also Order on request of Banque SBA issued by High Court of Paris on April 24, 2014, authorizing the bank to transfer more than $159 million, per criminal seizure order dated February 25, 2014, filed as exhibit in US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Warrants of arrest in rem filed July 11, 2014.)","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate. \u00a0(Source: \u00a0Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"High Court (Paris)","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_DOJ_Asset_Forfeiture_PR_Mar_5_2014_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_DDC_Forfeiture_Complaint_Unsealed_Mar_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_France_Seizure_Order_Apr_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_Forfeit_480_mil_DOJ_PR_Aug_7_2014_3.pdf","Sources ":"US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Verified Complaint for Civil Asset Forfeiture, unsealed on March 5, 2014 and available at:http:\/\/www.justice.gov\/iso\/opa\/resources\/765201435135920471922.pdf and Warrants in rem filed July 11, 2014, Order of High Court of Paris of April 24, 2014; US \u00a0Department of Justice, Press release, \u0022U.S. Freezes More Than $458 Million Stolen by Former Nigerian Dictator in Largest Kleptocracy Forfeiture Action Ever Brought in the U.S.,\u0022 March 5, 2014, available at: http:\/\/www.justice.gov\/opa\/pr\/2014\/March\/14-crm-230.html\n"},{"Case ID":"ARW-216","Case Title (Name of Public Official or Entity Allegedly Involved)":"Paulo Maluf \/ Brazil-Deutsche Bank settlement","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Brazil","Position of Public Official(s) (yrs in office)":"Governor and Mayor of Sao Paulo (Governor,1979-1983; Mayor, 1993-1996); Legislator (as of 2007)","Jurisdiction of Asset Recovery":"Germany","Jurisdiction of Asset Description":"","Asset Recovery Start":"2014","Asset Recovery End":"2014","UNCAC Offenses Implicated":"","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Settlement agreement","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Negotiated settlement","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to press releases by the city of Sao Paulo, the Deutsche Bank AG agreed on February 24, 2014 to pay $20 million to settle allegations that the bank helped manage funds embezzled by former city of S\u00e3o Paulo officials while Paulo Maluf was mayor of the city. On the total sum of the settlement, US $18 million will be paid to the city of Sao Paulo (towards construction of kindergartens), the rest will go to the State of Sao Paulo (US $1.5 million), a government fund dedicated to various interests (US$ 300,000), \u00a0and \u00a0for the payment of the legal fees related to the investigation (US$ 200,000). \u00a0According to public prosecution, settlements for similar allegations with UBS AG of Zurich, Safra National Bank of New York and Citigroup Inc of Geneva could be expected for an amount of US$ 60 million. (Source: \u00a0City of Sao Paulo Press Release, \u0022Prefeitura receber\u00e1 US$ 18 milh\u00f5es de banco envolvido em desvios\u0022, February 24, 2014 and \u0022Justi\u00e7a homologa acordo para banco alem\u00e3o indenizar Prefeitura em R$ 44 milh\u00f5es,\u0022 October 20, 2014, at http:\/\/www.capital.sp.gov.br\/portal\/noticia\/4870.) \u00a0According to a Reuters article, Mr. Silvio Marques, a prosecutor in the case, reported that Deutsche Bank was expected to deposit the proceeds from the settlement within the next 60 days following the settlement. \u00a0(Source: Reuters, \u0022Deutsche Bank to pay $20 mln to settle Brazil charges\u0022, February 24, 2014, available at: http:\/\/www.reuters.com\/article\/2014\/02\/24\/deutschebank-brazil-settlement...).\u00a0","Disposition of Criminal Case(s)":"\u00a0According to the March 8, 2007 press release by the New York County District Attorney\u0027s Office, Mr. Maluf was indicted in New York for his alleged conspiracy in embezzlement of public funds and concealment of such funds, and that charges were also pending against him in Brazil. \u00a0(Source: The People of the State of New York v. Paulo Maluf, Flavio Maluf, Simeao Damasceno de Oliveira, Joel Guedes Fernandes and Vivaldo Alves, Indictment filed on March 8, 2007 in New York state Supreme Court, County of New York and New York County District Attorney\u0027s Office, News Release on the Paulo Maluf case, March 8, 2007.) \u00a0According to Agence France Presse, on November 4, 2013, Mr. Maluf\u0027s conviction on \u0022administrative corruption\u0022 was upheld by a Brazilian court. (Source: Agence France Presse, \u0022Graft sentence upheld for ex-Sao Paulo ex-mayor,\u0022 November 4, 2013.)","Jurisdiction of Origin: Investigative Agency":"Brazilian Financial Intelligence Unit; Ministry of Justice; Federal Police","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General of the State of Sao Paulo, Prosecutor General of the Republic of Brazil","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_Deutschebank_Settlement_Sao_Paolo_State_PR_Feb_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_Brazil_Deutschebank_Settlement_Reuters_Feb_24_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_Brazil_Sao_Paulo_City_PR_Oct_20_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_Interpol_wanted_Feb_6_2015.pdf","Sources ":"City of Sao Paulo Press Releases, \u0022Prefeitura receber\u00e1 US$ 18 milh\u00f5es de banco envolvido em desvios\u0022, February 24, 2014, available at: http:\/\/www.capital.sp.gov.br\/portal\/noticia\/1862#.UyneGNLXbWM and \u0022Justi\u00e7a homologa acordo para banco alem\u00e3o indenizar Prefeitura em R$ 44 milh\u00f5es,\u0022 October 20, 2014, at http:\/\/www.capital.sp.gov.br\/portal\/noticia\/4870\n\tReuters,\u0022Deutsche Bank to pay $20 mln to settle Brazil charges\u0022, February 24, 2014, available at: http:\/\/www.reuters.com\/article\/2014\/02\/24\/deutschebank-brazil-settlement... Interpol Wanted list, at http:\/\/www.interpol.int\/notice\/search\/wanted\/2009-13608 (last accessed February 6, 2015.)\n"},{"Case ID":"ARW-218","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha \/ United Kingdom (Prohibition Order related to US Claim)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Asset Location\/Alleged Asset Location","Asset Recovery Start":"2014","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Actions Initiated by a Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Instrument between the United States and the United Kingdom, signed December 2004, implementing the Agreement on Mutual Legal Assistance between the United States and the European Union","Contributing Factors in Asset Recovery":"Ongoing case; the High Court stated:  \u0022Corruption, like other types of fraud, is a global problem and it and its consequences are only going to be dealt with effectively if there is co-operation and assistance not only between the governments of states but also between the courts of different national jurisdictions. Orders enforcing US arrest warrants issued in the US Claim against property in Jersey and France have been made in those jurisdictions and I have no doubt that this court should follow suit and continue the Freezing Injunction ordered by Teare J on 25 February 2014.\u0022 (Source: para 48, United States of America (USA) v Abacha \u0026 Ors [2014] EWHC 993 (Comm) (08 April 2014)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"Ongoing Case","Case Summary":"In October 2014, the UK Court of Appeals overturned an earlier High Court decision and lifted the freezing injunction on Abacha related assets that are subject of a civil asset forfeiture proceedings in the U.S. (Source: \u00a0Blue Holding (1) Pte Ltd \u0026 Ors v United States of America [2014] EWCA Civ 1291 (09 October 2014)). \u00a0Thereafter a Prohibition Order took into effect against the properties. \u00a0(Source: National Crime Agency v. Abacha, 2015 EWHC 357 Admin, paras 4-10).\n\t\u00a0\n\tIn April 2014, the UK High Court issued a judgment in a case involving an application to continue a Freezing Injunction granted under s.25 of the Civil Jurisdiction and Judgments Act 1982 (\u0022the 1982 Act\u0022) ex parte by Teare J on 25 February 2014 and continued by Walker J on 25 March 2014. \u00a0The claimant was the United States of America, which had filed a civil asset forfeiture complaint against assets alleged to be proceeds of corruption of former Nigerian President Sani Abacha and family and associates. \u00a0The defendants were: (1) Mohammed Sani Abacha; (2) Abubakar Atiku Bagudu; (3) Mecosta Securities, Inc; (4) Ridley Group Limited; (5) Blue Holding (1) Pte Limted; (6) Blue Holding (2) Pte Limited; (7) Standard Bank plc; (8) HSBC Bank plc; (9) HSBC Life (Europe) Limited; (10) Waverton Investment Management Ltd; and (11) James Hambro \u0026 Partners LLP. \u00a0According to the decision, Mr. Abacha and Mr. Bagudu (D1 and D2) are alleged to control the assets which are the subject of a civil asset forfeiture claim in the US; respondents 3-6 are companies owned and\/or controlled by Mr. Abacha and Mr. Bagudu (D1 and D2) and used by them to hold the assets. \u00a0The court noted that D3 and D4 are \u0022BVI companies that have been struck off the BVI Companies Register for non-payment of statutory fees.\u0022 \u00a0(para 8) \u00a0D5 and D6 \u0022(together \u0027Blue Holdings\u0022) are Singaporean companies owned by a trust for the benefit of D2\u0027s family.\u0022 (para 11). \u00a0D7-D11 are \u0022banks and other financial institutions which are believed (as at dates in the last few years) to hold assets which are subject to the [US] forfeiture claim. No allegation of wrongdoing is made against these defendants.\u0022 (para 12) \u00a0According to the judgment, the following accounts and amounts are implicated: \u00a0\u0022(1) Standard Bank, which holds assets totalling US$21.7 million in two accounts in London in the name of D3; (2) the 8th and 9th Defendants (\u0022HSBC\u0022) which hold assets totalling US$1.6 million and [GBP] 940,000 in accounts i the name of the D1; and the 10th and 11th Defendants which it is alleged to hold assets totalling [EUR] 95 million in four accounts in the names of companies owned by a trust for the benefit of D2 and certain members of his family.\u0022 (para 14). \u00a0The Court also notes the 2003 Settlement agreement between the Federal Republic of Nigeria and D2 on behalf of himself and his \u0022affiliates\u0022 which in exchange for transfer of sums by D2 to the Nigerian government in exchange for \u0022renouncement by FRN of any interest whatsoever in certain scheduled assets that would be held by D2 free from any claims by FRN. \u00a0Included in those scheduled assets are assets the foreiture of which the Claimant seeks in the US claim.\u0022 (para 26). \u00a0The Court continues, \u0022It is pertinent to note that (1) although the Nigerian Request for Mutual Assistance addressed to the US Department of Justice under the UN Convention against Corruption [ ] made no mention of the fact that under the settlement with D2 he and his affiliates were permitted to retain free from any claim by the FRN the scheduled assets, and (2) the Claimant was unaware that the FRN had agreed that D2 and his affiliates could retain the scheduled assets until after these proceedings for relief under s. 25 of the 1982 Act were begun.\u0022 (para 27) \u00a0The Court upheld the freeze, stating: \u0022The application under s. 25 is not an application to enforce a foreign judgment but to continue an order designed to hold the ring until a judgment in the US claim can be lawfully enforced under the 2005 Order.\u0022 \u00a0(para 48) (Sources: United States of America (USA) v Abacha \u0026 Ors [2014] EWHC 993 (Comm) (08 April 2014); See also Between National Crime Agency and Mohammed Sani Abacha and others, Claim No. C0\/2986\/14 (High Court, Queen\u0027s Bench Division, Administrative Court), Prohibition Order of July 2, 2014, filed in US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Warrants of Arrest in Rem filed Jul 11, 2014.)","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate. \u00a0(Source: \u00a0Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"National Crime Agency","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"England and Wales Court of Appeals (Civil Division) and High Court (Commercial Court and Queen\u0027s Bench Division)","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/United%20States%20of%20America%20%28USA%29%20v%20Abacha%20%26%20Ors%20%5B2014%5D%20EWHC%20993%20%28Comm%29%20%2808%20April%202014%29.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_DOJ_Asset_Forfeiture_PR_Mar_5_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_Forfeit_480_mil_DOJ_PR_Aug_7_2014_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_UK_Prohibition_Order_Jul_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_UK_Prohibition_Order_Lift_EWCA_Civ_Oct_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_UK_NCA_v_Abacha_2015%20EWHC%20357%20Admin_21Jan2015.docx","Sources ":"\n\tNational Crime Agency v. Abacha, 2015 EWHC 357 Admin; Blue Holding (1) Pte Ltd \u0026 Ors v United States of America [2014] EWCA Civ 1291 (09 October 2014), at http:\/\/www.bailii.org\/cgi-bin\/markup.cgi?doc=\/ew\/cases\/EWCA\/Civ\/2014\/129...\n\n\t\u00a0\n\n\tUnited States of America (USA) v Abacha \u0026 Ors [2014] EWHC 993 (Comm) (08 April 2014), URL: http:\/\/www.bailii.org\/ew\/cases\/EWHC\/Comm\/2014\/993.html; Between National Crime Agency and Mohammed Sani Abacha and others, Claim No. C0\/2986\/14 (High Court, Queen\u0027s Bench Division, Administrative Court), Prohibition Order of July 2, 2014, filed in US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Warrants of Arrest in Rem filed Jul 11, 2014.\n\n\t\u00a0\n\n\tSee also related entry Sani Abacha \/ US Civil Assset Forfeiture case\n"},{"Case ID":"ARW-217","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha \/ United States civil asset forfeiture","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2013","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Asset Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"MLAT (France, UK); International Cooperation Act (Jersey); United Nations Convention against Corruption (Articles 54 and 55, Request by Nigeria to US)","Contributing Factors in Asset Recovery":"Ongoing case but the Department of Justice press release on March 4, 2014 noted, \u0022The department appreciates the extensive assistance provided by the Governments of Jersey, France and the United Kingdom in this investigation.\u0022 ","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance (in part), Investigation\/Asset Tracing\/Asset Restraint (in part)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"In August 2014, the US Department of Justice announced that more than US$480 million in Abacha corruption proceeds had been forfeited to the US: approximately US$303 million in two bank accounts in Bailiwick of Jersey, $144 million in 2 bank accounts in France [note: arrest in rem notes amount as US$159,374,531.89], and at least US$27 million in accounts in the UK and Ireland. \u00a0The Department of Justice also noted that claims against US$148 million in four investment portfolios in the UK are pending. (Sources: \u00a0US Department of Justice, \u0022U.S. Forfeits Over $480 Million Stolen by Former Nigerian Dictator in Largest Forfeiture Ever Obtained Through a Kleptocracy Action,\u0022 August 7, 2014; warrants for arrest in rem filed July 11, 2014 in US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, et al, Case No. l:13-cv-01832-JDB (D.D.C.).) \u00a0According to the Department of Justice, the restraint of funds includes approximately $313 million in the name of Mohammed Sani and Doraville Properties Corporation in two bank accounts in the Bailiwick of Jersey and $145 million in the name of Rayville International SA and Standard Alliance Financial Services Limited in two bank accounts in France. In addition, four investment portfolios (all assets held in name of Blue Holding traceable to Ridley Group limited) and three bank accounts in the name of Mecosta Securities and Mohammed Sani in the United Kingdom with an expected value of at least $100 million have also been restrained [ ] [and] also seeks to forfeit five corporate entities registered in the British Virgin Islands (Doraville Properties Corporation, Mecosta Securities Inc., Rayville International SA, Ridley group Limited, Standard Alliance Financial Services Limited). (Source: US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, Limited in Jersey, Channel Islands, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Verified Complaint for Civil Asset Forfeiture).The complaint alleged that General Abacha, his son Mohammed Sani Abacha, their associate Abubakar Atiku Bagudu and others embezzled, misappropriated and extorted billions from the government of Nigeria and the Central Bank of Nigeria on the false pretense that the funds were necessary for national security, then laundered their criminal proceeds through the purchase of bonds backed by the United States using U.S. financial institutions. (Source: Department of Justice, Press release, \u0022U.S. Freezes More Than $458 Million Stolen by Former Nigerian Dictator in Largest Kleptocracy Forfeiture Action Ever Brought in the U.S..\u0022 March 5, 2014.) \u00a0 Associates and family members of Mr. Abacha have filed Verified Claim and Statement of Interest in the property and filed a motion to dismiss the Government\u0027s Verified Claim and Government of Nigeria is also represented by counsel. As of June 2016, the case was ongoing (Source: US v. US v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, Limited in Jersey, Channel Islands, et al, Case No. l:13-cv-01832-JDB (D.D.C.), Court Docket Report as of June 27, 2016; Appearance of Counsel filed May 12, 2016)\n\t\t\t\u00a0\n\t\t\t\u00a0\n\u00a0","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate. \u00a0(Source: \u00a0Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Criminal Division, Anti-Kleptocracy Intiative, Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"United States District Court for the District of Columbia","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_DDC_Forfeiture_Complaint_Unsealed_Mar_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_DOJ_Asset_Forfeiture_PR_Mar_5_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_DDC_Order_Default_Aug_6_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_Forfeit_480_mil_DOJ_PR_Aug_7_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_US_Warrant_Main_Jul_11_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_France_Seizure_Order_Apr_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Jersey_Affidavit_Arrest_in_Rem_Mar_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_UK_Prohibition_Order_Jul_2014.pdf","Sources ":"\n\tUS v. All Assets Held in Account Number 80020796, in name of Doraville Properties Corporation, at Deutsche Bank International, Limited in Jersey, Channel Islands, Case No. l:13-cv-01832-JDB (D.D.C.), Verified Complaint for Civil Asset Forfeiture, unsealed on March 5, 2014 and available at:http:\/\/www.justice.gov\/iso\/opa\/resources\/765201435135920471922.pdf; Warrants of arrest in rem filed July 11, 2014), and Court Docket Report as of June 27, 2016.\n\n\t\u00a0\n\n\tUS \u00a0Department of Justice, Press releases, \u0022U.S. Freezes More Than $458 Million Stolen by Former Nigerian Dictator in Largest Kleptocracy Forfeiture Action Ever Brought in the U.S.,\u0022 March 5, 2014, available at: http:\/\/www.justice.gov\/opa\/pr\/2014\/March\/14-crm-230.html and \u0022U.S. Forfeits Over $480 Million Stolen by Former Nigerian Dictator in Largest Forfeiture Ever Obtained Through a Kleptocracy Action,\u0022 August 7, 2014, at http:\/\/www.justice.gov\/opa\/pr\/2014\/August\/14-crm-835.html.\n"},{"Case ID":"ARW-212","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hector Javier Villarreal Hernandez \/ US Asset Forfeiture - Western District of Texas (Real Estate and Bank Account)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mexico","Position of Public Official(s) (yrs in office)":"Former Secretary of Finance, State of Coahuila (2005-2011)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort; Asset Location\/Alleged Asset Location","Asset Recovery Start":"2012","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Asset Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty (US-Mexico)","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"\u00a0See related cases involving assets in Bermuda. \u00a0According to the February 18, 2014 Amended Notice of Related Cases filed in US v. Villarreal Hernandez, et al, the following civil asset forfeiture cases have been filed in the US federal court for the Western District of Texas against real properties and bank account with value totalling nearly $23 million: \u00a0 US v. Real Property Known as an Exxon Service Station\/Convenience Store at 4425 E. 14th Street, Brownsville, Texas, Case No. 5:12-cv-377 (value $1,132,128); US v. Real Property Known as Peninsula Island Resort and Spa at 340 South Padre Island Blvd., Unit 602, Building B, South Padre Island, Texas, Case No. 12-cv-379 (value: $280,797); US v. Real Property Known as an Apartment Complex Located at 3454 Boca Chica Blvd., Brownsville, Texas (value: $799,958.00); \u00a0US v. Real Property Known as Javi\u0027s Carwash Located at 1317 W. Tyler, Harlington, Texas, Case No. 12-cv-374 (value: $307,503); US v. Real Property Known as Javi\u0027s Carwash Located at 5215 South Padre Highway, Brownsville, Texas, Case No. 12-cv-375 (value: $309,801); US v. Real Property Known as a Single-family Residence Located at 740 S. Central Ave., Brownsville, Texas, Case No. 12-cv-372 (value: $62,495.90); US v. Real Property Known as Strip\/Shopping Center Located at 3454 Boca Chica Blvd., Brownsville, Texas, Case No. 12-cv-382 (value: $361,147); US v. Real Property Known as White Orchid Apartment Complex Located at 3480 Boca Chica Blvd., Brownsville, Texas, Case No. 12-cv-378 \u00a0(value: $434,734); US v. Real Property Known as a Single-family Residence and Adjacent Lor Located and Situated at 3911 Luz Del Faro, San Antonio, Bexar County, Texas, Case No. 12-cv-383 (value: $1,355,970); US v. Real Property Known as the North Pointe Strip\/Shopping Center, More Fully Described as Lots 42, 43, 44 and 45, Block 6, New City Block 17586, San Antonio, Bexar County, Texas, Case No. 12-cv-381 (value: $6,324,570); US v. Real Property Known as CVS Store No. 8978 and Adjacent Vacant Lots Located and Situated at 20203 Stone Oak Parkway, San Antonio, Bexar County, Texas, Case No. 12-cv-376 (value: $3,943,810); US v. Real Property Known as Centurion Storage, a High Rise Mini-storage Facility Located and Situated at 2310 North Loop 1604 West, San Antonio, Bexar County, Texas, Case No. 12-cv-380 (value: $6,560,000); and US v. $1,214,232.59 seized from JP Morgan Chase Acct. (value: $1,214,232.59) (Sources: \u00a0US v. Villarreal Hernandez and Torres, Case No. 13-cr-01075 (S.D. Tex), Amended Notice of Related Cases filed February 18, 2014).\n\t\u00a0\n\tOn March 1, 2013, the Court granted the US Government\u0027s Motion and Ordered the civil asset forfeiture cases to be stayed pending resolution of all related criminal matters. The cases were reinstated on the Court\u0027s Docket in January 26, 2016 and was ongoing as of May 22, 2016. (Sources: \u00a0Court Docket reports as of May 22, 2016 in the above listed cases.) \u00a0\u00a0","Disposition of Criminal Case(s)":"As of May 22, 2016, Mr. Villareal Hernandez\u0027s sentencing in US Federal Court for the Western District of Texas on money laundering conspiracy charge, to which he had plead guilty, was continued to October 5, 2016. \u00a0(Source: US v. Villarreal Hernandez, Case No. 5:14-cr-00100 (W.D. Tex), Agreed and Unopposed, Sealed Motion for Continuance of Sentencing filed February 8, 2016 and Court Docket Report as of May 22, 2016.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Internal Revenue Service - Criminal Investigations","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney\u0027s Office for the Western District of Texas","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the Western District of Texas","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_Villarreal_SDTEX_Amended_Notice_Related_Cases_Feb_18_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_WDTEX_Apt_Complex_12-cv-373_Dkt_Rept_Jul_30_2014.pdf","Sources ":"US v. Villarreal Hernandez, Case No. 13-cr-01075 (S.D. Tex), Amended Notice of Related Cases filed February 18, 2014 and Court Docket Reports in the civil asset forfeiture cases listed in the summary.\n"},{"Case ID":"ARW-213","Case Title (Name of Public Official or Entity Allegedly Involved)":"Jorge Juan Torres \/ United States","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mexico","Position of Public Official(s) (yrs in office)":"General Director of the Promotion and Development, the Secretary of Finance of Coahuila state, Municipal President of Saltillo state and interim Governor of Coahuila state (1994-2011)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2013","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Non-Conviction Based Asset Forfeiture; Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty (US-Mexico)","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"See also related case, Hector Javier Villarreal Hernandez (United States and Bermuda). \u00a0 In September 2013, the US Government filed a civil asset forfeiture complaint against Old Mutual of Bermuda, Ltd. Contract Number CX4011696 in Bermuda which it alleged constituted proceeds of corruption while Mr. Torres was serving in various government posts including as interm Governor of Coahuila state, Mexico. \u00a0In October 2013, the warrant for arrest in rem was executed by the Bermuda Police Service. \u00a0In March 2014, Mr. Torres and his wife filed an Answer to the complaint, not denying his government employment but denying allegations including that his government positions as sole source of income. \u00a0On August 3, an Order of Default Judgment was granted in the case in favor of the United States. \u00a0(Sources: \u00a0US v. All Funds on Deposit at Old Mutual of Bermuda, Ltd. Contract Number CX4011696 in Bermuda, Case No. 13-cv-00294 (S.D. Tex), Verified Complaint for Civil Forfeiture in Rem filed September 24, 2013; Executed Warrant of Arrest in Rem filed October 29, 2013; Answer (by Torres) filed March 28, 2014 and Court Docket Report as of October 28, 2015.)\n\t\u00a0\n\tIn the criminal case against Mr. Torres, in November 2014, the US Government filed a Supplemental Notice of Forfeiture of two properties located in Montgomery, Texas at 160 Hermitage Drive and 53 Southwind Drive, as having allegedly been acquired with proceeds of crime. \u00a0As of October 28, 2015, the criminal case against Mr. Torres is ongoing. \u00a0(Source: \u00a0US v. Torres, Case No. 2:13-cr-1075-2 (S.D. Tex), Indictment filed November 20, 2013 and Supplemental Notice of Forfeiture filed November 17, 2014.)","Disposition of Criminal Case(s)":"Mr. Torres is under indictment in the US Federal Court for the District of Southern Texas on a charge of money laundering conspiracy. \u00a0(Source: \u00a0US v. Hernandez Villarreal and Torres, Case No. 2:13-cr-1075 (SD Tex), Indictment filed November 20, 2013 and Court Docket Report as of May 22, 2016.\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Origin: Courts Involved":"Unknown","Jurisdiction of Asset Recovery: Investigative Agency":"Internal Revenue Service - Criminal Investigations","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney\u0027s Office for the Southern District of Texas","Jurisdiction of Asset Recovery: Courts Involved":"United States District Court - Southern District of Texas","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_Nigeria_EFCC_High_Profile_Cases.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Charges_Saharareporters_Apr_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Remanded_Custody_BBC_Apr_16_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTEX_Old_Mutual_Bermuda_Acct_Forfeiture_Complaint_Sep_24_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_Nigeria_EFCC_High_Profile_Cases.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Charges_Saharareporters_Apr_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Remanded_Custody_BBC_Apr_16_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTEX_Old_Mutual_Bermuda_Account_Exec_Arrest_in_Rem_Oct_29_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_Nigeria_EFCC_High_Profile_Cases.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Charges_Saharareporters_Apr_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Remanded_Custody_BBC_Apr_16_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTEX_Old_Mutual_Bermuda_Acct_Answer_Mar_28_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_Nigeria_EFCC_High_Profile_Cases.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Charges_Saharareporters_Apr_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Remanded_Custody_BBC_Apr_16_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTex_Suppl_Forfeit_Notice_Nov_17_2014_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_Nigeria_EFCC_High_Profile_Cases.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Charges_Saharareporters_Apr_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ibori_UK_Remanded_Custody_BBC_Apr_16_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTEX_Bermuda_Acct_Default%20Judgment_Aug3%202015_0.pdf","Sources ":"Civil Asset Forfeiture Case: US v. All Funds on Deposit at Old Mutual of Bermuda, Ltd. Contract Number CX4011696 in Bermuda, Case No. 13-cv-00294 (S.D. Tex), Verified Complaint for Civil Forfeiture in Rem filed September 24, 2013; Executed Warrant of Arrest in Rem filed October 29, 2013; Answer (by Torres) filed March 28, 2014; Order of Default Judgment, August 3, 2015. \u00a0 Criminal Case: US v. Hernandez Villarreal and Torres, Case No. 2:13-cr-1075 (SD Tex), Supplemental Notice of Forfeiture filed November 17, 2014 and Court Docket Report as of May 22, 2016.\n"},{"Case ID":"ARW-215","Case Title (Name of Public Official or Entity Allegedly Involved)":"Jorge Juan Torres \/ Bermuda Account","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mexico","Position of Public Official(s) (yrs in office)":"General Director of the Promotion and Development, the Secretary of Finance of Coahuila state, Municipal President of Saltillo state and interim Governor of Coahuila state (1994-2011)","Jurisdiction of Asset Recovery":"Bermuda","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2013","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Execution of Foreign Warrant of Arrest in Rem (Bermuda); Non-Conviction Based Asset Forfeiture (United States)","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"See also related case, Hector Javier Villarreal Hernandez (United States and Bermuda). \u00a0 In September 2013, the US Government filed a civil asset forfeiture complaint against Old Mutual of Bermuda, Ltd. Contract Number CX4011696 in Bermuda which it alleged constituted proceeds of corruption while Mr. Torres was serving in various government posts including as interm Governor of Coahuila state, Mexico. \u00a0In October 2013, the warrant for arrest in rem was executed by the Bermuda Police Service. \u00a0In March 2014, Mr. Torres and his wife filed an Answer to the complaint, not denying his government employment but denying allegations including that his government positions as sole source of income. \u00a0On August 3, 2015, a Default Judgment was entered against the assets in favor of the United States. \u00a0(Sources: \u00a0US v. All Funds on Deposit at Old Mutual of Bermuda, Ltd. Contract Number CX4011696 in Bermuda, Case No. 13-cv-00294 (S.D. Tex), Verified Complaint for Civil Forfeiture in Rem filed September 24, 2013; Executed Warrant of Arrest in Rem filed October 29, 2013; Answer (by Torres) filed March 28, 2014 and Order of Default Judgment of August 3, 2015.","Disposition of Criminal Case(s)":"Mr. Torres is under indictment in the US Federal Court for the District of Southern Texas on a charge of money laundering conspiracy. \u00a0 (Source: \u00a0US v. Hernandez Villarreal and Torres, Case No. 2:13-cr-1075 (SD Tex), Indictment filed November 20, 2013 and Court Docket Report as of May 22, 2016.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Bermuda Police Service (execution of warrant of arrest in rem)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Dahdaleh_UK_SFO_Press_Release_Oct_24_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTEX_Old_Mutual_Bermuda_Account_Exec_Arrest_in_Rem_Oct_29_2013_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Dahdaleh_UK_SFO_Press_Release_Oct_24_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTEX_Old_Mutual_Bermuda_Acct_Forfeiture_Complaint_Sep_24_2013_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Dahdaleh_UK_SFO_Press_Release_Oct_24_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTEX_Old_Mutual_Bermuda_Acct_Answer_Mar_28_2014_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Dahdaleh_UK_SFO_Press_Release_Oct_24_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTEX_Indictment_Nov_20_2013_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Dahdaleh_UK_SFO_Press_Release_Oct_24_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Torres_SDTEX_Bermuda_Acct_Default%20Judgment_Aug3%202015.pdf","Sources ":"Civil Asset Forfeiture Case: US v. All Funds on Deposit at Old Mutual of Bermuda, Ltd. Contract Number CX4011696 in Bermuda, Case No. 13-cv-00294 (S.D. Tex), Verified Complaint for Civil Forfeiture in Rem filed September 24, 2013; Executed Warrant of Arrest in Rem filed October 29, 2013; Answer (by Torres) filed March 28, 2014; Order of Default Judgment, August 3, 2015. \u00a0Criminal Case: US v. Hernandez Villarreal and Torres, Case No. 2:13-cr-1075 (SD Tex), Indictment filed November 20, 2013 and Court Docket Report as of May 22, 2016.)\n"},{"Case ID":"ARW-211","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha (Liechtenstein)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"Liechtenstein","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"2014","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction; Criminal Prosecution","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"\u0022Liechtenstein and Nigeria are States Parties to the United Nations Convention against Corruption (UNCAC). Liechtenstein fully recognizes its obligation to prosecute all forms of corruption together with the other States Parties and to repatriate confiscated assets associated with corruption to the injured States.\u0022  (Source:  Principality of Liechtenstein Press Release, \u0022Return of \u0027Abacha Assets,\u0022 June 18, 2014.);  Investigatory assistance and cooperation by a number of countries, involvement of Stolen Asset Recovery Initiative and World Bank agreement to monitor use of funds (Sources: Ibid., and Emile van der Does de Willebois, \u0022No Statute of Limitations for Corruption:  Liechtenstein returns $225 million in stolen assets to Nigeria,\u0022 Stolen Asset Recovery Initiative Blog, June 19, 2014.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$233,795,000","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"World Bank monitoring of use of returned assets","Case Summary":"In June 2014, the Principality of Liechtenstein announced that it was returning approximately $225 milion in Abacha-related assets to Nigeria: \u00a0\u0022In its meeting on 17 June 2014, the Government approved repatriation to the Federal Republic of Nigeria of the last tranche of the assets associated with the family of the former president of Nigeria, General Abacha, in the amount of EUR 167 million. These assets had been declared forfeited to the Principality of Liechtenstein in a final judgment. At the same time, at the request of Nigeria and in accordance with Liechtenstein the World Bank declared its willingness to monitor the use of the repatriated assets.\n\t\u00a0\n\tOn the basis of suspicious activity reports submitted to the Financial Intelligence Unit of Liechtenstein, the Liechtenstein Office of the Public Prosecutor launched corruption investigations in 2000. In 2008, the Criminal Court sentenced several companies attributed to the Abacha family to the payment of a sum of money proven to have been taken from the national budget of Nigeria. With the judgment of the Constitutional Court in 2012, the recovery of the assets became final. Since several companies did not surrender the assets subject to the recovery order, enforcement proceedings had to be carried out.\n\t\u00a0\n\tUpon conclusion of these proceedings, the assets held by one of the companies in the amount of EUR 7.5 million were repatriated to Nigeria at the end of 2013.\n\t\u00a0\n\tHowever, four of the companies affected by the Abacha case filed a complaint against the Principality of Liechtenstein at the European Court of Human Rights (ECtHR) in Strasbourg in August 2012, leading to a further delay in the repatriation of the remaining assets on liability grounds. In January 2014, talks were held at the governmental level in this regard between Nigeria and Liechtenstein. In May 2014, the complaint pending in Strasbourg was withdrawn by the four Abacha companies, clearing the path for repatriation of the assets once and for all.\u0022 \u00a0(Source: \u00a0Principality of Liechtenstein Press Release, \u0022Return of \u0027Abacha Assets,\u0022 June 18, 2014.) \u00a0 \u00a0","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate. \u00a0(Source: \u00a0Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"Special Panel established to investigate Abacha looting","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Financial Intelligence Unit; Office of the Public Prosecutor","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Office of the Public Prosecutor","Jurisdiction of Asset Recovery: Courts Involved":"Criminal Court; Constitutional Court","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/StGH2012187_3753_140110033700_Liechtenstein_Abacha_Mar_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Liechtenstein_StGH2010_125.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Liechtenstein_StGH2011_078.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Liechtenstein_StGH2011_098.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Liechtenstein_Nigeria%20fights%20to%20recover%20Abacha%20funds_%20FT_Oct_10_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Liechtenstein_Okonjo-Iweala_%E2%82%AC185m%20Abacha%20loot_Vanguard%20News_Oct_14_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Liechtenstein_Repatriation_Assets_PR_Jun_18_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Liechtenstein_AR_Return_Vanderdoes_StAR_blog_Jun_19_2014_0.pdf","Sources ":"Principality of Liechtenstein Press Release, \u0022Return of \u0027Abacha Assets,\u0022 June 18, 2014, at http:\/\/www.regierung.li\/en\/press-releases\/press-releases\/english-press-r...\n\t\u00a0\n\tEmile van der Does de Willebois, \u0022No Statute of Limitations for Corruption: \u00a0Liechtenstein returns $225 million in stolen assets to Nigeria,\u0022 Stolen Asset Recovery Initiative Blog, June 19, 2014, at https:\/\/star.worldbank.org\/star\/content\/no-statute-limitations-corruption;\n\t\u00a0\n\tFinancial Times, \u0022Nigeria fights to recover Abacha funds from Liechtenstein\u0022, October 10, 2013, accessed at:http:\/\/www.ft.com\/intl\/cms\/s\/0\/2dac07c8-31bd-11e3-a16d-00144feab7de.html... Reuters, \u0022Nigeria says Liechtenstein making excuses to keep Abacha loot\u0022, October 14, 2013, accessed at: http:\/\/www.reuters.com\/article\/2013\/10\/14\/us-nigeria-liechtenstein-abach... \u0022Okonjo-Iweala laments Liechtenstein\u2019s attitude on \u20ac185m Abacha loot\u0022, accessed at: http:\/\/www.vanguardngr.com\/2013\/10\/okonjo-iweala-laments-liechtensteins-...\n\t\u00a0\n\tLiechtenstein constitutional court decisions accessed at: \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0\u00a0\n\thttp:\/\/www.gerichtsentscheidungen.li\/default.aspx?mode=suche\u0026txt=maryam\u0026...\n\t\u00a0\n\thttp:\/\/www.gerichtsentscheidungen.li\/default.aspx?mode=suche\u0026txt=maryam\u0026...\n\t\u00a0\n\thttp:\/\/www.gerichtsentscheidungen.li\/default.aspx?mode=suche\u0026txt=maryam\u0026...\n"},{"Case ID":"ARW-210","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hosni Mubarak (Spain)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Egypt","Position of Public Official(s) (yrs in office)":"President (1981-2011)","Jurisdiction of Asset Recovery":"Spain","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"","Intl.Cooperation: MLAT\/Letter of Request?":"Letter of Request","Basis for Intl Cooperation":"United Nations Convention against Corruption ","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"","Case Summary":"According to a December 13, 2012 press release by the National Police, EUR 28 million in financial instruments, properties in Madrid and Marbella, and luxury vehicles have been frozen. \u00a0The Spanish investigation into the assets located in Spain belonging to the former President Mubarak, his family, associates and related entities encompassed over 130 individuals. \u00a0(Source: \u00a0Cuerpo Nacional de Policia, Nota de Prensa, \u0022La Polic\u00eda Nacional ejecuta una comisi\u00f3n rogatoria internacional \/ Localizados en Espa\u00f1a 28.000.000\u20ac en productos financieros y propiedades inmobiliarias vinculados a Hosny Mubarak,\u0022 December 13, 2012.)","Disposition of Criminal Case(s)":"According to the New York Times and other sources, in May 2014, Mr. Mubarak was convicted on charge of embezzlement and sentenced to three years\u0027 imprisonment. (Source: \u00a0David Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Central Economic Crime Unit (Unidad Central de Delincuencia Econ\u00f3mica); Fiscal de la Comisar\u00eda General de Polic\u00eda Judicial","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Perez-Llorca Law Firm (Madrid)","Jurisdiction of Asset Recovery: Courts Involved":"Central Economic Crime Unit (Unidad Central de Delincuencia Econ\u00f3mica); Fiscal de la Comisar\u00eda General de Polic\u00eda Judicial","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_Spain_Asset_Freeze_National_Police_Dec_13_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_Embezzlement_Verdict_NYTimes_May_21_2014_1.pdf","Sources ":"Cuerpo Nacional de Policia, Notas de Prensa, \u0022La Polic\u00eda Nacional ejecuta una comisi\u00f3n rogatoria internacional \/ Localizados en Espa\u00f1a 28.000.000\u20ac en productos financieros y propiedades inmobiliarias vinculados a Hosny Mubarak,\u0022 December 13, 2012, at http:\/\/www.policia.es\/prensa\/20121213_1.html; \u00a0David Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014, at http:\/\/www.nytimes.com\/2014\/05\/22\/world\/middleeast\/hosni-mubarak-trial.html\n"},{"Case ID":"ARW-214","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (South Africa)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"South Africa","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"","Legal Basis for Asset Recovery":"United Nations Security Council Resolution","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Ongoing","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Other","Assets Frozen (USD)":"Unspecified","Assets Adjudicated, Not Yet Returned (USD)":"Unspecified Amount","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"","Case Summary":"In June 2013, South Africa\u0027s Minister of Finance announced that his country would return unspecified amount of assets to Libya. In a June 20, 2013 statement, the Minister stated: \u0022The facts of this matter are as follows: \uf0a7 There are Libyan shareholdings in South African entities that were made on a commercial basis. These include the Michelangelo Towers in Sandton, the Centurion Lake Hotel, the Commodore and Portswood Hotels in Cape Town, and the Kruger Park Lodge in Mpumalanga. \uf0a7 Then there have been allegations of Libyan funds and assets that were brought to South Africa under dubious circumstances. None of the people who have made these allegations have produced evidence regarding the transfer of these assets and funds to South Africa. Those who have evidence should hand it over to the relevant Libyan or United Nations authorities.\u0022 (Sources: Republic of South Africa, Ministry of Finance, Media Statement by Minister Gordhan on Repatriation from South Africa of Libyan Funds and Assets, June 13, 2013 and Statement by Minister Gordhan to Clarify the Issue of Libyan Assets and Funds, June 20, 2013.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Qaddafi_South_Africa-Finance_Min_Repatriate_Assets_Jun_13_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Qaddafi_South_Africa_Finance_Min_Clarification_Jun_20_2013.pdf","Sources ":"Republic of South Africa, Ministry of Finance, Media Statement by Minister Gordhan on Repatriation from South Africa of Libyan Funds and Assets, June 13, 2013, at http:\/\/www.treasury.gov.za\/comm_media\/press\/2013\/2013061301.pdf and Statement by Minister Gordhan to Clarify the Issue of Libyan Assets and Funds, June 20, 2013 at http:\/\/www.treasury.gov.za\/comm_media\/press\/2013\/2013062101.pdf\n"},{"Case ID":"ARW-84","Case Title (Name of Public Official or Entity Allegedly Involved)":"Carlos Garcia \/ Clarita Garcia \/ Timothy Mark D. Garcia (New York Bank Accounts)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"Former Comptroller of the Philippine Armed Forces (Carlos Garcia,1990-2004), Wife (Clarita Garcia), Son (Timothy Mark)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"2015","UNCAC Offenses Implicated":"Art.15, Art.17, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"","Case Summary":"Related to the General Carlos Garcia corruption cases in the Philippines, the U.S. filed criminal and civil actions against members of the Garcia family and their US assets.\u00a0 The actions include this 2012 civil asset forfeiture case filed against two bank accounts in New York totalling $245,520.94.\u00a0 According to the complaint filed in the case, the assets were proceeds of General Garcia\u0027s corruption and as part of the plea agreement in his Philippines case, his wife and son forfeited the accounts to the Government of Philippines.\u00a0 The US had alleged that Clarita Garcia had smuggled the cash into the US in 2003-2004 and deposited them into accounts belonging to herself and her son, and over $1.3 million were wire transferred from a Philippines bank to accounts in the U.S. On April 18, 2013, a Default Judgment was ordered in favor of the U.S. (Sources:\u00a0 US v. $201,166.08 in US Currency and [\u00a0 ] $44,354.86 in US currency [ ] in name of ICJ Access Worldwide, Case No. 1:12-cv-9388 (SDNY), Verified Claim filed December 26, 2012 and Default Judgment filed April 18, 2013).\nAccording to a statement by the US Embassy Manila, on June 3, 2015, \u0022U.S. Ambassador Philip S. Goldberg presented Ombudsman Conchita Carpio-Morales with a check in the amount of U.S. $1,384,940.28 payable to the Republic of the Philippines. The check represents \u201cill-gotten\u201d gains acquired by former AFP Comptroller General Carlos F. Garcia.\u00a0 [\u00a0 ]\u00a0 Philippine and U.S. investigators worked closely together to determine that General Garcia laundered a substantial portion of his criminal proceeds through the United States.\u00a0 In particular, investigators with the U.S. Department of Homeland Security traced the criminal proceeds to two Citibank accounts in New York and a condominium in Trump Tower in New York.\u00a0 The U.S. Attorney\u0027s Office for the Southern District of New York then initiated civil forfeiture proceedings against those assets and eventually obtained default judgments of forfeiture.\u00a0 The net proceeds resulting from the sale of the condominium and the funds from the two Citibank accounts were returned to the Philippines by the United States today.\u0022\u00a0 (Source: US Embassy Manila, \u0022U.S. Helps Philippines Recover \u0027Ill-Gotten Gains\u0027\u201d, June 3, 2015, at http:\/\/manila.usembassy.gov\/press-photo-releases-2015\/us-helps-philippines-recover-ill-gotten-gains.html.)\n\u00a0","Disposition of Criminal Case(s)":"According to a June 3, 2015 statement by the Ombudsman of the Philippines, \u0022the Office of the Ombudsman filed criminal cases of perjury, money laundering and plunder against [Carlos] Garcia who eventually was convicted of perjury by the Sandiganbayan.\u00a0 In the last two criminal cases, Garcia pleaded to the lesser offenses of Indirect Bribery and Facilitating Money Laundering, which plea bargaining is the subject of review by the Supreme Court.\u00a0 Meanwhile, forfeiture proceedings are pending with the Sandiganbayan.\u0022\u00a0 (Source:\u00a0 Office of the Ombudsman, \u0022US turns over $1.38M proceeds of Garcia\u2019s forfeited assets,\u0022 June 3,2015.)\nAccording to the April 5, 2005 Information against former Mr. Garcia, his wife Clarita Garcia and their sons Ian Carl, Juan Paulo and Timothy Mark D. Garcia, the Philippines Ombudsman\u0027s Office had charged them with committing the crime of Plunder.\u00a0 (Source:\u00a0 In the Matter of Extradition of Clarita Depakakibo Garcia, Case No. 2:09-mc-50231 (E.D. Mich.), Annex A to Extradition compaint filed on March 4, 2009).\u00a0 In November 2010, Ian Carl and Juan Paulo Depakakibo were sentenced to time served by U.S. District Court for the Northern District of California, subsequent to their guilty plea on bulk cash smuggling charge.\u00a0\u00a0 (Source: U.S. v. Ian Carl Depakakibo and Juan Paulo Depakakibo, Case No. 08-cr-00888-MHP (N.D. Cal.), Judgment in a Criminal Case, filed on December 1, 2010.)\n\u00a0","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Ombudsman, Office of the Special Prosecutor","Jurisdiction of Origin: Courts Involved":"Sandiganbayan Supreme Court (Third Division)","Jurisdiction of Asset Recovery: Investigative Agency":"Department of Homeland Security","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"US Attorney for the Southern District of New York","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Garcia_SDNY_Currency_Forfeit_Complaint_Dec_26_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Garcia_SDNY_Currency_Default_Judgment_Apr_18_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Gacria_US_SDNY_Asset%20Return_USEmbassy%20Manila%20Press_Jun3_2015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Garcia_US%20Asset%20Return_Phil%20Ombudsman_statement_Jun3_2015.pdf","Sources ":"US v. $201,166.08 in US Currency and [\u00a0 ] $44,354.86 in US currency [ ] in name of ICJ Access Worldwide, Case No. 1:12-cv-9388 (SDNY), Verified Claim filed December 26, 2012 and Default Judgment filed April 18, 2013; US Embassy Manila, \u0022U.S. Helps Philippines Recover \u0027Ill-Gotten Gains\u0027\u201d, June 3, 2015, athttp:\/\/manila.usembassy.gov\/press-photo-releases-2015\/us-helps-philippines-recover-ill-gotten-gains.html; Office of the Ombudsman, \u0022US turns over $1.38M proceeds of Garcia\u2019s forfeited assets,\u0022 June 3,2015, at http:\/\/www.ombudsman.gov.ph\/index.php?home=1\u0026pressId=NjU3\n"},{"Case ID":"ARW-207","Case Title (Name of Public Official or Entity Allegedly Involved)":"Zine El Abidine Ben Ali (Lebanon)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Tunisia","Position of Public Official(s) (yrs in office)":"President (1987-2011)","Jurisdiction of Asset Recovery":"Lebanon","Jurisdiction of Asset Description":"Location of Recovery Effort; Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"2013","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Confiscation (Tunisia)","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Efforts by Tunisia, including Tunisian Financial Intelligence Unit, the Committee for the Return of Stolen Assets, and Ministry of Justice; International and Regional Cooperation, including through the Arab Forum on Asset Recovery organized by Qatar and United States Presidency of the G8 (Source: Jean Pierre Brun and Richard Miron, \u0022Tunisia\u0027s cash back: the start of more to come?,\u0022 Public Sector Development Blog, World Bank, April 15, 2013.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"","Case Summary":"According to a December 2012 decision by the Fifth Chamber of the Beirut Court of Appeals, upon examination and consideration of the petition submitted by the Republic of Tunisia by way of the Ministry of Justice, the Court granted the writ of execution for the decision rendered by the Fifth Criminal circuit of the Court of First Instance in Tunisia, ordering the confiscation of the assets of Leila Bent Mohammed Bent Rahouma-al-Trabelsi deposited in her bank account at the Lebanese Canadian Bank S.A.L. in Lebanon. \u00a0The petitioner was ordered to bear fully the fees and expenses in the case. \u00a0(Source: Unpublished decision issued in Case No. 893, December 12, 2012.) \u00a0 According to a blog by the Stolen Asset Recovery Initiative, the funds were \u0022handed over [by Lebanon] in the form of a check to Tunisia\u0027s current President Moncef Marzouki by Ali bin Fetais-al-Marri\u0022 Attorney General of Qatar and UNODC Special Advocate on Stolen Asset Recovery.\u0022 (Source: \u00a0Jean Pierre Brun and Richard Miron, \u0022Tunisia\u0027s cash back: the start of more to come?,\u0022 Public Sector Development Blog, World Bank, April 15, 2013.)","Disposition of Criminal Case(s)":"According to a January 26, 2011 media release by INTERPOL, Mr. Ben Ali\u0027s arrest was sought by Tunisia on charges of alleged property theft and illegal transfer of foreign currency. \u00a0(Source: INTERPOL media release, \u0022Tunisia seeks ousted President and family via INTERPOL,\u0022 January 26, 2011) \u00a0According to secondary sources, Mr. Ben Ali was convicted in absentia in June 2011 on theft and unlawful possesion of cash and jewelry; \u00a0in July 2011, he was convicted of property related charges. (Source: \u00a0BBC News, \u0022Tunisia\u0027s Ben Ali guilty on drugs and gun charges,\u0022 July 4, 2011 and \u0022Tunisia\u0027s Ben Ali guilty of corrupt property deals,\u0022 July 29, 2011) and in June 2012, he was sentenced \u00a0by a Tunisian military court to life imprisonment for his complicity in the murder and attempted murder of demonstrators; Human Rights Watch noted that Mr. Ben Ali has been tried and convicted in absentia and if he returned to Tunisia, he would be entitied to a new trial. (Source: \u00a0Clive Baldwin, \u0022After Ben-Ali\u0027s Conviction: The State of Tunisian Justice,\u0022 Human Rights Watch, June 16, 2012.) \u00a0\n\t\u00a0","Jurisdiction of Origin: Investigative Agency":"Tunisian Financial Intelligence Unit, the Committee for the Return of Stolen Assets, Ministry of Justice","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Ministry of Justice","Jurisdiction of Origin: Courts Involved":"Fifth Criminal Circuit of the Court of First Instance","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Ministry of Justice","Jurisdiction of Asset Recovery: Courts Involved":"Fifth Chamber of the Beirut Court of Appeals","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_Lebanon_StAR_blog_Apr_15_2013.pdf","Sources ":"Fifth Chamber of the Beirut Court of Appeals, Decision issued in Case No. 893, December 12, 2012 (unpublished); Jean Pierre Brun and Richard Miron, \u0022Tunisia\u0027s cash back: the start of more to come?,\u0022 Public Sector Development Blog, World Bank, April 15, 2013, accessed at http:\/\/blogs.worldbank.org\/psd\/tunisias-cash-back-the-start-of-more-to-come.)\n"},{"Case ID":"ARW-123","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hector Javier Villareal Hernandez \/ Bermuda","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mexico","Position of Public Official(s) (yrs in office)":"Former Secretary of Finance, State of Coahuila (2005-2011)","Jurisdiction of Asset Recovery":"Bermuda","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Execution of Foreign Warrant of Arrest in Rem (Bermuda); Non-Conviction Based Confiscation (in United States)","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"($2,275,544.41 frozen in Bermuda; amount included in US entry only to avoid double counting)","Assets Returned (USD)":"","Agreement for Returned Assets":"NA","Agreement for Returned Assets - Description":"","Case Summary":"\n\n\t\t\u00a0\n\n\n\tAccording to the Agreed Final Judgment of Forfeiture filed on January 15, 2015 in the US District Court for the Southern District of Texas, the assets were forfeited to the United States, including after Mr. Villareal Hernandez agreed to the forfeiture. \u00a0(Source: \u00a0US v. All Funds on Deposit At Sun Secured Advantage Account Number 26-2673-031320, Case No. 2:13-cv-00033 (S.D. Tex)). \u00a0\n\n\t\u00a0\n\n\tAccording to the US Department of Justice Press Release dated February 6, 2013, \u0022The United States has seized a bank account located in Bermuda alleged to have been owned by former State of Coahuila, Mexico, Secretary of Finance Hector Javier Villareal Hernandez [ \u00a0]. \u00a0The account, which is held in Bermuda, Sun Secured Advantage account at N.T. Butterfield and Son Limited, contained $2,275,544.41 as of Jan. 4, 2013. The government alleged, as its basis for forfeiture, that the funds in the account were involved in a money laundering transaction, that the property constitutes or was derived from proceeds traceable to offenses including bribery of a public official, or the misappropriation, theft or embezzlement of public funds by or for the benefit of a public official. [ \u00a0]\u00a0\n\n\t\u00a0\n\n\tIn approximately December 2005, Hernandez was appointed by then Governor of Coahuila Humberto Moreira to the position of Under Secretary of Program and Budget for Coahuila. In July 2008, Hernandez was appointed by the same governor to the position of Secretary of Finance for Coahuila. On Aug. 19, 2011, Hernandez resigned that position and became a subject of investigation by the government of Mexico. On Oct. 28, 2011, a local judge from Coahuila charged Hernandez with forging state documents to obtain fraudulent loans for several million pesos between 2008 and 2011. On Oct. 29, 2011, Hernandez was arrested and released on bond. He later fled and remains a fugitive on those charges.\n\n\t\u00a0\n\n\tAccording to the civil complaint, in 2011, Mexican law enforcement officials initiated an investigation involving fraudulent loans obtained from Mexican banks by Hernandez while he held the position of Secretary of Finance. The investigation includes three fraudulent loans from two different Mexican banks from July 2010 to March 2011 totaling more than $3 billion Mexican Pesos ($246 million U.S. dollars based on exchange rates on the dates of the loans). On Feb. 3 and March 8, 2012, Mexican government authorities filed false loan charges and issued arrest warrants for Hernandez\u2019s involvement in the false loans with two Mexican banks. The charges allege Hernandez and other co-conspirators acquired loans by providing false information to Mexican banks. The false information involved the use of false registry stamps or previously approved registry stamps used on the false loan contracts.\u00a0\n\n\t\u00a0\n\n\tThe conspiracy is alleged in the complaint to have begun when Hernandez requested a loan on behalf of the State of Coahuila. He then drafted and submitted a false loan contract for approval by the federal Treasury Department. Hernandez conspired to falsify the approval of the submitted loan contract. His alleged co-conspirators, who worked at the federal Treasury Department, placed a fraudulent federal registry stamp or a previously approved registry stamp on the loan contract to make it appear that the loan contract had been approved. After the loan contract obtained the false registry stamp or previously approved registry stamp and received \u0022approval,\u0022 the contract was submitted to a Mexican federal bank for issuance of a loan to the State of Coahuila. Once the loan proceeds were obtained, they were available for use by the State of Coahuila. [ ]\u00a0\n\n\t\u00a0\n\n\tHernandez opened an offshore investment account in Bermuda during this time period. Since April 2009, it is estimated that Hernandez and his associates received more than $35 million through foreign exchange transactions and cross border wires and subsequently purchased numerous real properties in San Antonio, Brownsville and South Padre Island with the illegal proceeds.\u0022 \u00a0(Source: \u00a0The United States Attorney\u0027s Office - Southern District of Texas, \u0022Bermuda Bank Account Allegedly Owned by Former Mexican Secretary of Finance Seized by US,\u0022 February 6, 2013.) \u00a0\n\n\t\u00a0\n\n\tOn March 3, 2013, a Senator from the Mexican state of Coahuila filed a claim, on behalf of himself and citizens of that state, for the seized funds on the basis that the funds were \u0022embezzled and stolen from and belong to the State of Coahuila, Mexico.\u0022 \u00a0He sought to \u0022recover the Defendant Funds fo return to the treasury of the State of Coahuila, Mexico.\u0022 \u00a0(Source: \u00a0US v. All Funds on Deposit At Sun Secured Advantage Account Number 26-2673-031320, Case No. 13-cv-33 (S.D. Tex), Verified Claim of Senator Luis Fernando Salazar Fernandez Contesting Asset Forfeiture, filed March 13, 2013.) \u00a0 On June 24, 2013, Senator Salazar withdrew his claim, stating \u0022he wil continue to pursue remission of the Defendant funds throught he Department of Justice.\u0022 \u00a0(Source: US v. All Funds on Deposit At Sun Secured Advantage Account Number 26-2673-031320, Case No. 13-cv-33 (S.D. Tex), Notice of Withdrawl of Claim filed June 24, 2013.)\n\n\t\u00a0\n\n\tIn January 2014, the US filed a notice of Mutual Legal Assistance request to Mexico, requesting assistance that notice of the asset forfeiture action be sent directly to anyone, including Mr. Hernandez (account holder) and his wife, who reasonably appears to have interest or claim in the property subject to forfeiture. \u00a0In March, Mr. Hernandez filed an answer to the complaint and a verified claim claiming that he was the lawful owner of the Defendant funds. \u00a0(Sources: \u00a0US v. All Funds on Deposit at Sun Secure Advantaged Account Number 26-2673-031320..., Case No. 2:13-cv-33 (S.D. Tex.), Notice of Mutual Legal Assistance filed on January 8, 2014; Answer to Complaint filed March 11, 2014; and Verified Claim filed March 18, 2014.)\u00a0","Disposition of Criminal Case(s)":"As of May 22, 2016, Mr. Villareal Hernandez\u0027s sentencing in US Federal Court for the Western District of Texas on money laundering conspiracy charge, to which he had plead guilty, was continued to October 5, 2016. \u00a0(Source: US v. Villarreal Hernandez, Case No. 5:14-cr-00100 (W.D. Tex), Agreed and Unopposed, Sealed Motion for Continuance of Sentencing filed February 8, 2016 and Court Docket Report as of May 22, 2016.)","Jurisdiction of Origin: Investigative Agency":"Unspecified investigative agency","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Origin: Courts Involved":"Court - State of Coahuila","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_US_DOJ_Press_Release_Feb_6_2013_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez-US_SDTEX_Complaint_Feb_6_2013_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_US_SDTEX_Claim_Mar_13_2013_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_US_SDTEX_Claim_Withdraw_Jun_24_2013_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Account_Answer_Mar_11_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Account_MLA_19-main_Jan_18_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Account_MLA_Doc_19-1_Jan_8_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Account_Verif_Claim_Mar_18_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Acct_Final_Forfeit_Jan_15_2015.pdf","Sources ":"The United States Attorney\u0027s Office - Southern District of Texas, \u0022Bermuda Bank Account Allegedly Owned by Former Mexican Secretary of Finance Seized by US,\u0022 February 6, 2013, accessed at http:\/\/www.justice.gov\/usao\/txs\/1News\/Releases\/2013%20February\/130206%20... \u00a0US v. All Funds on Deposit At Sun Secured Advantage Account Number 26-2673-031320, Case No. 13-cv-33 (S.D. Tex), Verified Complaint filed February 6, 2013; Verified Claim of Senator Luis Fernando Salazar Fernandez Contesting Asset Forfeiture, filed March 13, 2013 and Notice of Withdrawl of Claim filed June 24, 2013; Notice of Mutual Legal Assistance Request filed January 18, 2014; Answer to Complaint with Jury Demand filed March 11, 2014; and Verified Claim filed March 18, 2014. \u00a0US v. Villarreal Hernandez, Case No. 5:14-cr-00100 (W.D. Tex), Court Docket Report as of May 22, 2016.\n"},{"Case ID":"ARW-209","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hector Javier Villareal Hernandez \/ US Asset Forfeiture of Bermuda account","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mexico","Position of Public Official(s) (yrs in office)":"Former Secretary of Finance, State of Coahuila (2005-2011)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation and related Criminal Prosecution","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty (US-Mexico)","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"$2,275,544.41","Assets Returned (USD)":"","Agreement for Returned Assets":"NA","Agreement for Returned Assets - Description":"","Case Summary":"According to the Agreed Final Judgment of Forfeiture filed on January 15, 2015 in the US District Court for the Southern District of Texas, the assets were forfeited to the United States,including after Mr. Villareal Hernandez agreed to the forfeiture. \u00a0(Source: \u00a0US v. All Funds on Deposit At Sun Secured Advantage Account Number 26-2673-031320, Case No. 2:13-cv-00033 (S.D. Tex)).\u00a0\n\t\t\t\u00a0\n\t\t\tAccording to the US Department of Justice Press Release dated February 6, 2013, \u0022The United States has seized a bank account located in Bermuda alleged to have been owned by former State of Coahuila, Mexico, Secretary of Finance Hector Javier Villareal Hernandez [ \u00a0].\n\t\t\t\u00a0\n\t\t\tThe account, which is held in Bermuda at Sun Secured Advantage account at N.T. Butterfield and Son Limited, contained $2,275,544.41 as of Jan. 4, 2013. The government alleged, as its basis for forfeiture, that the funds in the account were involved in a money laundering transaction, that the property constitutes or was derived from proceeds traceable to offenses including bribery of a public official, or the misappropriation, theft or embezzlement of public funds by or for the benefit of a public official. [ \u00a0]\u00a0\n\t\t\t\u00a0\n\t\t\tIn approximately December 2005, Hernandez was appointed by then Governor of Coahuila Humberto Moreira to the position of Under Secretary of Program and Budget for Coahuila. In July 2008, Hernandez was appointed by the same governor to the position of Secretary of Finance for Coahuila. On Aug. 19, 2011, Hernandez resigned that position and became a subject of investigation by the government of Mexico. On Oct. 28, 2011, a local judge from Coahuila charged Hernandez with forging state documents to obtain fraudulent loans for several million pesos between 2008 and 2011. On Oct. 29, 2011, Hernandez was arrested and released on bond. He later fled and remains a fugitive on those charges.\n\t\t\t\u00a0\n\t\t\tAccording to the civil complaint, in 2011, Mexican law enforcement officials initiated an investigation involving fraudulent loans obtained from Mexican banks by Hernandez while he held the position of Secretary of Finance. The investigation includes three fraudulent loans from two different Mexican banks from July 2010 to March 2011 totaling more than $3 billion Mexican Pesos ($246 million U.S. dollars based on exchange rates on the dates of the loans). On Feb. 3 and March 8, 2012, Mexican government authorities filed false loan charges and issued arrest warrants for Hernandez\u2019s involvement in the false loans with two Mexican banks. The charges allege Hernandez and other co-conspirators acquired loans by providing false information to Mexican banks. The false information involved the use of false registry stamps or previously approved registry stamps used on the false loan contracts.\u00a0\n\t\t\t\u00a0\n\t\t\tThe conspiracy is alleged in the complaint to have begun when Hernandez requested a loan on behalf of the State of Coahuila. He then drafted and submitted a false loan contract for approval by the federal Treasury Department. Hernandez conspired to falsify the approval of the submitted loan contract. His alleged co-conspirators, who worked at the federal Treasury Department, placed a fraudulent federal registry stamp or a previously approved registry stamp on the loan contract to make it appear that the loan contract had been approved. After the loan contract obtained the false registry stamp or previously approved registry stamp and received \u0022approval,\u0022 the contract was submitted to a Mexican federal bank for issuance of a loan to the State of Coahuila. Once the loan proceeds were obtained, they were available for use by the State of Coahuila. [ ]\u00a0\n\t\t\t\u00a0\n\t\t\tHernandez opened an offshore investment account in Bermuda during this time period. Since April 2009, it is estimated that Hernandez and his associates received more than $35 million through foreign exchange transactions and cross border wires and subsequently purchased numerous real properties in San Antonio, Brownsville and South Padre Island with the illegal proceeds.\u0022 \u00a0(Source: \u00a0The United States Attorney\u0027s Office - Southern District of Texas, \u0022Bermuda Bank Account Allegedly Owned by Former Mexican Secretary of Finance Seized by US,\u0022 February 6, 2013.) \u00a0\n\t\t\t\u00a0\n\t\t\tOn March 3, 2013, a Senator from the Mexican state of Coahuila filed a claim, on behalf of himself and citizens of that state, for the seized funds on the basis that the funds were \u0022embezzled and stolen from and belong to the State of Coahuila, Mexico.\u0022 \u00a0He sought to \u0022recover the Defendant Funds fo return to the treasury of the State of Coahuila, Mexico.\u0022 \u00a0(Source: \u00a0US v. All Funds on Deposit At Sun Secured Advantage Account Number 26-2673-031320, Case No. 13-cv-33 (S.D. Tex), Verified Claim of Senator Luis Fernando Salazar Fernandez Contesting Asset Forfeiture, filed March 13, 2013.) \u00a0 On June 24, 2013, Senator Salazar withdrew his claim, stating \u0022he wil continue to pursue remission of the Defendant funds throught he Department of Justice.\u0022 \u00a0(Source: US v. All Funds on Deposit At Sun Secured Advantage Account Number 26-2673-031320, Case No. 13-cv-33 (S.D. Tex), Notice of Withdrawl of Claim filed June 24, 2013.)\n\t\t\t\u00a0\n\t\t\tIn January 2014, the US filed a notice of Mutual Legal Assistance request to Mexico, requesting assistance that notice of the asset forfeiture action be sent directly to anyone, including Mr. Hernandez (account holder) and his wife, who reasonably appears to have interest or claim in the property subject to forfeiture. \u00a0In March, Mr. Hernandez filed an answer to the complaint and a verified claim claiming that he was the lawful owner of the Defendant funds. \u00a0(Sources: \u00a0US v. All Funds on Deposit at Sun Secure Advantaged Account Number 26-2673-031320..., Case No. 2:13-cv-33 (S.D. Tex.), Notice of Mutual Legal Assistance filed on January 8, 2014; Answer to Complaint filed March 11, 2014; and Verified Claim filed March 18, 2014.)\u00a0\n\u00a0","Disposition of Criminal Case(s)":"As of May 22, 2016, Mr. Villareal Hernandez\u0027s sentencing in US Federal Court for the Western District of Texas on money laundering conspiracy charge, to which he had plead guilty, was continued to October 5, 2016. \u00a0(Source: US v. Villarreal Hernandez, Case No. 5:14-cr-00100 (W.D. Tex), Agreed and Unopposed, Sealed Motion for Continuance of Sentencing filed February 8, 2016 and Court Docket Report as of May 22, 2016.)","Jurisdiction of Origin: Investigative Agency":"Unspecified investigative agency","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified court - State of Coahuila","Jurisdiction of Asset Recovery: Investigative Agency":"Organized Crime Drug Enforcement Task Force; Internal Revenue Service - Criminal Investigation; Drug Enforcement Agency; Homeland Security Investigation; Texas Attorney General\u0027s Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney - Southern District of Texas","Jurisdiction of Asset Recovery: Courts Involved":"United States District Court - Southern District of Texas","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_US_DOJ_Press_Release_Feb_6_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez-US_SDTEX_Complaint_Feb_6_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_US_SDTEX_Claim_Mar_13_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_US_SDTEX_Claim_Withdraw_Jun_24_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Account_MLA_19-main_Jan_18_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Account_MLA_Doc_19-1_Jan_8_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Account_Verif_Claim_Mar_18_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Account_Answer_Mar_11_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Hernandez_SDTEX_Bermuda_Acct_Final_Forfeit_Jan_15_2015_0.pdf","Sources ":"The United States Attorney\u0027s Office - Southern District of Texas, \u0022Bermuda Bank Account Allegedly Owned by Former Mexican Secretary of Finance Seized by US,\u0022 February 6, 2013, accessed at http:\/\/www.justice.gov\/usao\/txs\/1News\/Releases\/2013%20February\/130206%20... \u00a0US v. All Funds on Deposit At Sun Secured Advantage Account Number 26-2673-031320, Case No. 2:13-cv-00033 (S.D. Tex), Verified Complaint filed February 6, 2013; Verified Claim of Senator Luis Fernando Salazar Fernandez Contesting Asset Forfeiture, filed March 13, 2013 and Notice of Withdrawl of Claim filed June 24, 2013; Notice of Mutual Legal Assistance Request filed January 18, 2014; Answer to Complaint with Jury Demand filed March 11, 2014; Verified Claim filed March 18, 2014; and Agreed Final Judgment of Forfeiture filed January 27, 2015. US v. Villarreal Hernandez, Case No. 5:14-cr-00100 (W.D. Tex), Court Docket Report as of May 22, 2016.\n"},{"Case ID":"ARW-206","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ferdinand Marcos and Imelda Marcos \/ Vilma Bautista New York Art Case \/ Human Rights Victims\u0027 Settlement","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"President (F. Marcos,1965-1986); First Lady, Governor of Metro Manila and Minister of Human Settlements (I. Marcos. Governor and Minister from 1978-1986); Foreign Service Officer and de facto Personal Secretary to Mrs. Marcos (Bautista, early 1970s through approx. 1986)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Location of Recovery Effort; Asset location \/ Alleged asset location","Asset Recovery Start":"2011","Asset Recovery End":"2013","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Private settlement agreement","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Settlement agreement with the current owners of the artwork","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$10,000,000","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"Private Settlement agreement","Case Summary":"On October 29, 2013, the US District Court in Hawaii approved a settlement agreement in the sum of $10 million between the Marcos-era human rights victims and the current owner of art that is currently the subject of a criminal action in New Yorl. \u00a0(Source: In re: Estate of Ferdinand Marcos Human Rights Litigation, Case No. 03-cv-11111 (D. Hawaii), Order of Settlement filed October 29, 2013).\u00a0\n\t\u00a0\n\tAccording to a statement by the lawyers representing the Marcos era human rights victims, \u0022Filipinos tortured, summarily executed or who disappeared during the Marcos regime may soon receive a second distribution. \u00a0Robert Swift, lead counsel for the 10,000 Filipino victims human rights abuses, announced a $10 million settlement over artwork owned by Imelda Marcos. \u00a0The settlement derives from litigation in New York City by the victims to recover on their judgments against the Marcoses.\n\t\u00a0\n\tImmediately after the Marcoses fled to Hawaii in February 1986, more than 200 pieces of artwork purchased by Imelda Marcos disappeared from the Marcoses townhouse in New York. \u00a0In 2010, the New York District Attorney indicted a former assistant to Imelda Marcos, Vilma Bautista, for the illegal sale of one of the paintings, an impressionist masterpiece by Claude Monet. \u00a0The District Attorney also recovered $15 million from the sale as well as three other valuable artworks. \u00a0Class counsel, who obtained a contempt judgment against Imelda Marcos and Senator Ferdinand R. Marcos for $353.6 million, immediately filed suit in New York to recover the paintings and the proceeds. \u00a0The $10 million settlement was paid by the current owner of the Monet painting, a good faith purchaser of that artwork. \u00a0The victims continue to sue all others involved in the sale of the painting.\n\t\u00a0\n\tRobert Swift commented: \u201cWith this settlement, the Class is just starting to recover on its judgment. \u00a0The Marcoses have hidden many of their assets and prevented the victims from making any significant recovery on their original 1995 judgment of $2 billion. \u00a0It is poetic justice that the victims are benefitting from a valuable painting that Imelda Marcos purchased and revered. \u00a0The Marcoses have thumbed their noses at the United States court and Filipino victims of \u00a0human rights violations ever since the original judgment was entered. \u00a0They were caught trying to dissipate the Marcos Estate\u2019s assets to re-capitalize their political dynasty in the Philippines. \u00a0This New York litigation may be the vehicle to discover the totality of the Marcos artwork trove and to recover still more money for the victims.\u201d\n\t\u00a0\n\tPhilippine co-counsel Rod C. Domingo, Jr. said \u201cthe recovery of $10 million will be welcome news to the victims, most of whom are now aged and poor. \u00a0The first distribution of $1,000 to each victim in 2011 was greeted joyously. \u00a0We anticipate a second distribution in early 2014 when perhaps even more money will have been recovered.\u201d \u00a0The approval of the settlement is pending before Judge Manuel Real of the Federal Court in Hawaii. \u00a0Any distribution must be approved by the Court.\u0022 \u00a0(Source: \u00a0Class Suit Lawyers Statement on Monet Painting Recovery, Press Statement, Re: Marcos Human Rights Litigation, July 18, 2013.)","Disposition of Criminal Case(s)":"\u00a0A trial in the U.S. District Court for the Southern District of New York on criminal racketeering and fraud charges concluded in an acquittal for Mrs. Marcos. \u00a0Mr. Marcos had also been indicted in the case, but the court had deemed him too ill to stand trial. (Sources: US v. Tantoco, et al, Case No. 1-87-cr-598-JFK (S.D.N.Y.), Docket Report accessed on January 2, 2011 and Indictment of October 22, 1988, obtained from US National Archives; Craig Wolff, \u0022The Marcos Verdict; Marcos Is Cleared of All Charges In Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990.) \u00a0On April 21, 2010, the GMA News reported that \u0022According to records of the Philippine anti-graft court Sandiganbayan as of 2005, Mrs. Marcos continues to face 11 criminal charges and 25 civil cases.\u0022 \u00a0(Source: Sophia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....). \u00a0In November 2013, Ms. Bautista was convicted in New York state court \u00a0of Criminal Tax Fraud in the First Degree, Conspiracy in the Fourth Degree, and Offering a False Instrument for Filing in the First Degree. \u00a0In October 2015, the New York State Appellate Court vacated the conspiracy conviction based on err in jury instructions but stated that the Manhattan District Attorney may retry the charge; the Court upheld the tax fraud conviction. \u00a0(Source: \u00a0New York County District Attorney\u0027s Office Press Release, \u0022DA VANCE: FORMER SECRETARY TO IMELDA MARCOS CONVICTED ON ALL COUNTS AT TRIAL INVOLVING DISAPPEARANCE OF MONET AND OTHER ARTWORKS,\u0022 November 18, 2013; James C. McKinley, Jr., \u0022Former Marcos Aide Sentenced in Art Sale,\u0022 New York Times, January 13, 2014, at http:\/\/www.nytimes.com\/2014\/01\/14\/nyregion\/aide-to-imelda-marcos-is-sent... New York State Court Appellate Division, People v. Bautista, 2015 NY Slip Op 07589)","Jurisdiction of Origin: Investigative Agency":"NA","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Robert Swift (Private Attorney)","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for Hawaii","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_HRs_Victims_Statement_Art_Settlement_July_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Hawaii_Art_Settle_Final_Order_Judgment_Oct_29_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Memo_Mtn__Settlement_Hrs_Victims_NY_Art_Jul_10_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Bautista_Conviction_NY_District_Attorney_PR_Nov_18_2013_0.pdf","Sources ":"\n\t\u00a0New York County District Attorney\u0027s Office Press Release, \u0022DA Vance: \u00a0Three Individuals Charged in Conspiracy Involving Monet Artworks that Disappeared with the Collapse of the Marcos Regime in the Philippines,\u0022 November 20, 2012, accessed at\n\n\thttp:\/\/www.manhattanda.org\/press-release\/da-vance-three-individuals-char..., and New York County District Attorney\u0027s Office Press Release, \u0022DA Vance: \u00a0Three Individuals Charged in Conspiracy Involving Monet Artworks that Disappeared with the Collapse of the Marcos Regime in the Philippines,\u0022 November 20, 2012, accessed at\n\n\thttp:\/\/www.manhattanda.org\/press-release\/da-vance-three-individuals-char... and \u0022DA VANCE: FORMER SECRETARY TO IMELDA MARCOS CONVICTED ON ALL COUNTS AT TRIAL INVOLVING DISAPPEARANCE OF MONET AND OTHER ARTWORKS,\u0022 November 18, 2013, at \u00a0http:\/\/manhattanda.org\/press-release\/da-vance-former-secretary-imelda-ma...\n\n\t\u00a0\n\n\tIn re: Estate of Ferdinand Marcos Human Rights Litigation, Case No. 03-cv-11111 (D. Hawaii), Order of Settlement filed October 29, 2013, and Memorandum in Support of Motion to Approve Settlement filed July 10, 2013;\u00a0\n\n\t\u00a0\n\n\tClass Suit Lawyers Statement on Monet Painting Recovery, Press Statement, Re: Marcos Human Rights Litigation, July 18, 2013, at http:\/\/claimants1081.org\/2013\/07\/20\/class-suit-lawyers-statement-on-mone...\n"},{"Case ID":"ARW-205","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ferdinand Marcos and Imelda Marcos \/ Vilma Bautista New York Art Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"President (F. Marcos,1965-1986); First Lady, Governor of Metro Manila and Minister of Human Settlements (I. Marcos. Governor and Minister from 1978-1986); Foreign Service Officer and de facto Personal Secretary to Mrs. Marcos (Bautista, early 1970s through approx. 1986)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking recovery effort; Asset location \/ Alleged asset location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Ongoing Case, but in announcing the indictment against Ms. Bautista and others,  District Attorney Vance \u0022thanked the New York State Department of Taxation and Finance for its contribution to the investigation, and thanked the auction house and fine art storage firm Christie\u2019s for its valuable assistance.\u0022  (Source:  New York County District Attorney\u0027s Office Press Release, \u0022DA Vance:  Three Individuals Charged in Conspiracy Involving Monet Artworks that Disappeared with the Collapse of the Marcos Regime in the Philippines,\u0022 November 20, 2012.)  ","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Other","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$0","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tIn January 2014, Ms. Bautista was sentenced to imprisonment and ordered to pay US$3.8 million in taxes owed from US $28 milion she had received from the sale of a Monet painting. \u00a0(Sources: \u00a0James C. McKinley, Jr., \u0022Former Marcos Aide Sentenced in Art Sale,\u0022 New York Time, January 13, 2014 and New York County District Attorney\u0027s Office Press Release, \u0022DA Vance: Three individuals Charged in Conspiracy Involving Monet Artworks that Disappeared with the Collapse of the Marcos Regime in the Philippines,\u0022 November 20, 2012.). \u00a0In November 2013, the Philippines\u0027 Presidential Commission on Good Government issued a statement welcoming Ms. Bautista\u0027s conviction and stated that the PCGG \u0022will now be working to recover the proceeds and assets which were confiscated from Ms. Bautista and which we assert to be owned by the Republic.\u0022 \u00a0(Source: Philippines Presidential Commission on Good Government, PCGG Statement on the Conviction of Vilma Bautista, November 19, 2013.)\u00a0\n\n\t\u00a0\n\n\tOn November 20, 2012, the District Attorney for New York County, New York, announced the indictment of \u0022VILMA BAUTISTA, 74, CHAIYOT JANSEN NAVALAKSANA (\u201cJANSEN\u201d), 37, and PONGSAK NAVALAKSANA (\u201cPONGSAK\u201d), 40, for illegally conspiring to possess and sell valuable works of art acquired by former First Lady of the Philippines Imelda Marcos during her husband\u2019s presidency, keeping the proceeds for themselves, and hiding those proceeds from New York State tax authorities and others. The art included a Claude Monet \u201cWater-Lily\u201d painting, which the defendants sold in September 2010 for $32 million. The indictment charges all three defendants with Conspiracy in the Fourth Degree, and also charges BAUTISTA with Criminal Tax Fraud in the First Degree and Offering a False Instrument for Filing in the First Degree. JANSEN is charged with Criminal Tax Fraud in the Fourth Degree and Offering a False Instrument for Filing in the First Degree. [ ] \u00a0\u00a0\n\n\tAccording to the indictment, BAUTISTA was employed by the Philippine government as a Foreign Service Officer assigned to the Philippine Mission to the United Nations in New York from the early 1970s through approximately 1986. During that period and for years after, BAUTISTA unofficially acted as the New York-based personal secretary of Imelda Marcos, whose husband, Ferdinand Marcos, now deceased, served as President of the Philippines from 1965 to 1986. During her husband\u2019s presidency, Imelda Marcos used state assets to acquire a vast collection of artwork and other valuables. Much of the art adorned official Philippine government property in the Philippines and Manhattan. Ferdinand and Imelda Marcos fled the Philippines in February 1986 following a popular revolt.\n\n\t\u00a0\n\n\tIn the period of time immediately before and after the fall of the Marcos regime, a significant amount of artwork and other valuables disappeared from Philippine government property, including from the Philippine Consulate townhouse in Manhattan. Since then, the Philippine government has engaged in a public campaign to recover missing and stolen property acquired by the Marcoses. BAUTISTA is accused of having been aware of and monitoring this campaign, even as she possessed some of the valuable works of art.\u0022 \u00a0(Source: \u00a0New York County District Attorney\u0027s Office Press Release, \u0022DA Vance: \u00a0Three Individuals Charged in Conspiracy Involving Monet Artworks that Disappeared with the Collapse of the Marcos Regime in the Philippines,\u0022 November 20, 2012.) \u00a0 \u00a0","Disposition of Criminal Case(s)":"A trial in the U.S. District Court for the Southern District of New York on criminal racketeering and fraud charges concluded in an acquittal for Mrs. Marcos. \u00a0Mr. Marcos had also been indicted in the case, but the court had deemed him too ill to stand trial. (Sources: US v. Tantoco, et al, Case No. 1-87-cr-598-JFK (S.D.N.Y.), Docket Report accessed on January 2, 2011 and Indictment of October 22, 1988, obtained from US National Archives; Craig Wolff, \u0022The Marcos Verdict; Marcos Is Cleared of All Charges In Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990.) \u00a0On April 21, 2010, the GMA News reported that \u0022According to records of the Philippine anti-graft court Sandiganbayan as of 2005, Mrs. Marcos continues to face 11 criminal charges and 25 civil cases.\u0022 \u00a0(Source: Sohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....). \u00a0In October 2015, the New York State Appellate Court overturned her conviction on conspiracy charge and remanded to trial court; it affirmed conviction on charges of Criminal Tax Fraud in the First Degree and Offering a False Instrument for Filing in the First Degree. \u00a0(Source: People v. Baptists, 2015 NY Slip Op 07589, October 20, 2015.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"New York County District Attorney\u0027s Office, Major Economic Crimes Bureau; New York State Department of Taxation and Finance","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"New York County District Attorney\u0027s Office","Jurisdiction of Asset Recovery: Courts Involved":"New York State Supreme Court (trial level); Appellate Division, First Department","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bautista_Statement%20on%20the%20Indictment%20of%20Vilma%20Bautista%20_%20PCGG_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Bautista_Conviction_NY_District_Attorney_PR_Nov_18_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Bautista_US_Sentenced%20in%20Art%20Sale_NYTimes_Jan_13_2014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Bautista_PCGG-statement-on-the-conviction-of-vhb1.pdf","Sources ":"\n\tNew York County District Attorney\u0027s Office Press Release, \u0022DA Vance: \u00a0Three Individuals Charged in Conspiracy Involving Monet Artworks that Disappeared with the Collapse of the Marcos Regime in the Philippines,\u0022 November 20, 2012, accessed at\n\n\thttp:\/\/www.manhattanda.org\/press-release\/da-vance-three-individuals-char... and \u0022DA VANCE: FORMER SECRETARY TO IMELDA MARCOS CONVICTED ON ALL COUNTS AT TRIAL INVOLVING DISAPPEARANCE OF MONET AND OTHER ARTWORKS,\u0022 November 18, 2013, at http:\/\/manhattanda.org\/press-release\/da-vance-former-secretary-imelda-ma...\n\n\t\u00a0\n\n\t\u00a0\n\n\tThe People of the State of New York vs. Vilma Bautista, et al, Indictment No. 4939\/2012), accessed at Russ Buettner, \u0022Imelda Marcos\u0027s Ex-Aide Charged in \u002780s Art Theft,\u0022 New York Times, November 20, 2012, at http:\/\/www.nytimes.com\/2012\/11\/21\/nyregion\/imelda-marcoss-ex-aide-charge...\n\n\tPresidential Commission on Good Government Statement on Bautista Conviction, at http:\/\/thenewcommission.files.wordpress.com\/2013\/11\/pcgg-statement-on-th... \u00a0New York State Court Appellate Division 2015 NY Slip Op 07589 (October 20, 2015);\n\n\t\u00a0\n\n\tUS v. Tantoco, et al, Case No. 1-87-cr-598-JFK (S.D.N.Y.), Docket Report accessed on January 2, 2011 and Indictment of October 22, 1988, obtained from US National Archives;\u00a0\n\n\t\u00a0\n\n\tCraig Wolff, \u0022The Marcos Verdict; Marcos Is Cleared of All Charges In Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990;\n\n\t\u00a0\n\n\tSohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica... \u00a0PCGG Statement on the Indictment of Vilma Bautista, undated, accessed at http:\/\/pcgg.gov.ph\/2012\/12\/04\/pcgg-statement-on-the-indictment-of-vilma-...\n\n\t\u00a0\n\n\tJames C. McKinley, Jr., \u0022Former Marcos Aide Sentenced in Art Sale,\u0022 New York Time, January 13, 2014, at http:\/\/www.nytimes.com\/2014\/01\/14\/nyregion\/aide-to-imelda-marcos-is-sent...\n"},{"Case ID":"ARW-208","Case Title (Name of Public Official or Entity Allegedly Involved)":"Weir Group plc","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United Kingdom","Position of Public Official(s) (yrs in office)":"NA","Jurisdiction of Asset Recovery":"Iraq [Development Fund for Iraq]","Jurisdiction of Asset Description":"","Asset Recovery Start":"2010","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Prosecution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"In announcing the return of some of the confiscated proceeds of crime, Scottish Culture and External Affairs ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"$0","Assets Adjudicated, Not Yet Returned (USD)":"$0","Assets Returned (USD)":"$2,375,790","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"United Nations Development Assistance Framework for Environmental Management initiatives; Scottish NGO for work in Iraq; Iraqi Youth Orchestra","Case Summary":"According to the Crown Office and Procurator Fiscal Service news release dated December 15, 2010, \u0022The Crown Office has secured \u00a313.9 million under Proceeds of Crime legislation after a Scottish engineering company pled guilty to paying \u2018kickbacks\u2019 in return for contracts from Saddam Hussein\u2019s government. The confiscation order, made against Glasgow-based Weir Group Plc, is the biggest ever made by a Scottish court. \u00a0At the High Court in Edinburgh today, the company was also fined \u00a33 million after pleading guilty to paying more than \u00a33m in \u2018kickbacks\u2019, in contravention of UN sanctions against Iraq, through a Swiss bank account. \u00a0The Weir Group also admitted facilitating the payment of kickbacks by paying a fee of more than \u00a31.4 m to their agent, an Iraqi national, to the same Swiss bank account. The agent made the payments to the Iraqi government on behalf of Weir. \u00a0The kickbacks were paid to the Iraqi Government from funds in the UN\u2019s Oil for Food Programme, which should have been used for humanitarian purposes. An Independent Inquiry Committee set up by the UN has estimated that, in total, about US $1.5 billion that could have been used to ease the suffering of the Iraqi people was paid as kickbacks to Saddam Hussein\u0027s government. The Lord Advocate, the Right Honourable Elish Angiolini QC, said: \u0027This case represents the biggest single confiscation order made so far in Scotland using the Proceeds of Crime legislation. It is the result of a highly successful collaboration between National Casework Division of the Crown Office and Procurator Fiscal Service, Strathclyde Police and the Serious Fraud Office. In this year alone we have recovered over \u00a324 million, a record amount under the Proceeds of Crime legislation.\u0027\u0022 \u00a0The news release added that in notes to editors: \u0022Weir Group companies secured 16 contracts for which they were paid \u00a334,340,204 by paying kickbacks of \u00a33,104,527. The confiscation order has been granted for \u00a313,945,962.\u0022 This includes Weir\u2019s gross profit of \u00a39, 414,283 from the contracts - plus the kickback of \u00a33,104,527 and the fee of \u00a31,427,152 paid to Weir\u2019s agent in Iraq.(Source: \u00a0The Crown Office and Procurator Fiscal Service news release, \u0022CROWN SECURES RECORD \u00a313.9M AS WEIR GROUP CONVICTED OF PAYING KICKBACKS FOR IRAQ CONTRACTS,\u0022 December 15, 2010.) \u00a0According to a February 13, 2011 press statement by the Government of Scotland, GBP1.5 million of the GBP 13.9 million seized under the Proceeds of Crime Act will support water development in Iraq and humanitarian programmes in Iraq and Afghanistan. Specifically, GBP1.4 million were to go towards projects in Iraq and GBP 100,000 to a Scottish charity for humanitarian work in Afghanistan. The remainder, GBP 12.4 million \u0022will be used to fund community projects in Scotland.\u0022 \u00a0(Source: The Scottish Government, \u0022Seized cash returned to Iraq,\u0022 February 13, 2011.)According to the Crown Office and Procurator Fiscal Service news release dated December 15, 2010, \u0022The Crown Office has secured \u00a313.9 million under Proceeds of Crime legislation after a Scottish engineering company pled guilty to paying \u2018kickbacks\u2019 in return for contracts from Saddam Hussein\u2019s government. The confiscation order, made against Glasgow-based Weir Group Plc, is the biggest ever made by a Scottish court. \u00a0At the High Court in Edinburgh today, the company was also fined \u00a33 million after pleading guilty to paying more than \u00a33m in \u2018kickbacks\u2019, in contravention of UN sanctions against Iraq, through a Swiss bank account. \u00a0The Weir Group also admitted facilitating the payment of kickbacks by paying a fee of more than \u00a31.4 m to their agent, an Iraqi national, to the same Swiss bank account. The agent made the payments to the Iraqi government on behalf of Weir. \u00a0The kickbacks were paid to the Iraqi Government from funds in the UN\u2019s Oil for Food Programme, which should have been used for humanitarian purposes. An Independent Inquiry Committee set up by the UN has estimated that, in total, about US $1.5 billion that could have been used to ease the suffering of the Iraqi people was paid as kickbacks to Saddam Hussein\u0027s government. The Lord Advocate, the Right Honourable Elish Angiolini QC, said: \u0027This case represents the biggest single confiscation order made so far in Scotland using the Proceeds of Crime legislation. It is the result of a highly successful collaboration between National Casework Division of the Crown Office and Procurator Fiscal Service, Strathclyde Police and the Serious Fraud Office. In this year alone we have recovered over \u00a324 million, a record amount under the Proceeds of Crime legislation.\u0027\u0022 \u00a0The news release added that in notes to editors: \u0022Weir Group companies secured 16 contracts for which they were paid \u00a334,340,204 by paying kickbacks of \u00a33,104,527. The confiscation order has been granted for \u00a313,945,962.\u0022 This includes Weir\u2019s gross profit of \u00a39, 414,283 from the contracts - plus the kickback of \u00a33,104,527 and the fee of \u00a31,427,152 paid to Weir\u2019s agent in Iraq.(Source: \u00a0The Crown Office and Procurator Fiscal Service news release, \u0022CROWN SECURES RECORD \u00a313.9M AS WEIR GROUP CONVICTED OF PAYING KICKBACKS FOR IRAQ CONTRACTS,\u0022 December 15, 2010.) \u00a0According to a February 13, 2011 press statement by the Government of Scotland, GBP1.5 million of the GBP 13.9 million seized under the Proceeds of Crime Act will support water development in Iraq and humanitarian programmes in Iraq and Afghanistan. Specifically, GBP1.4 million were to go towards projects in Iraq and GBP 100,000 to a Scottish charity for humanitarian work in Afghanistan. The remainder, GBP 12.4 million \u0022will be used to fund community projects in Scotland.\u0022 \u00a0(Source: The Scottish Government, \u0022Seized cash returned to Iraq,\u0022 February 13, 2011.)","Disposition of Criminal Case(s)":"According to the \u00a0Crown Prosecution and Procurator Fiscal Service, in 2010 the Weir Group pleaded guilty to charges of paying kick-backs to secure Iraqi contracts. \u00a0(Source: \u00a0Crown Prosecution and Procurator Fiscal Service News Release, \u0022Crown Secures record \u00a313.9 million as Weir Group convicted of paying kick-backs for Iraq contracts,\u0022 December 15, 2010.)","Jurisdiction of Origin: Investigative Agency":"Serious Fraud Office (Scotland)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Crown Office and Procurator Fiscal Service","Jurisdiction of Origin: Courts Involved":"High Court (Edinburgh)","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Weir_Group_COPFS_Settlement_Dec_15_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Scotland_Crown_Office_POCA_Record_News_Release_June_2011.pdf","Sources ":"Crown Office and Procurator Fiscal Service Press Release, \u0022Crown Secures record \u00a313.9 million as Weir Group convicted of paying kickbacks for Iraq contracts,\u0022 December 15, 2010, accessed at http:\/\/www.copfs.gov.uk\/News\/Releases\/2010\/12\/Crown-Secures-record-%C2%A... The Scottish Government, \u0022Seized cash returned to Iraq,\u0022 February 13, 2011, at http:\/\/www.scotland.gov.uk\/News\/Releases\/2011\/02\/14085030.\n"},{"Case ID":"ARW-12","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alstom S.A. (World Bank)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Zambia","Position of Public Official(s) (yrs in office)":"unspecified former government official","Jurisdiction of Asset Recovery":"World Bank","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Administrative Sanctions (Negotiated Resolution Agreement)","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"The World Bank\u0027s Negotiated Resolution Agreement with Alstom included a provision for the payment of restitution by the company. (Source:  World Bank Press Release, \u0022Enforcing Accountability: World Bank Debars Alstom Hydro France, Alstom Network Schweiz AG, and their Affiliates,\u0022 February 22, 2012.)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Other","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"$9,500,000","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"","Case Summary":"According to the February 2012 press release by the World Bank\u0027s Integrity Vice Presidency, \u0022The World Bank Group today announced the debarment of Alstom Hydro France and Alstom Network Schweiz AG (Switzerland) - in addition to their affiliates - for a period of three years following Alstom\u2019s acknowledgment of misconduct in relation to a Bank-financed hydropower project.\n\tThe debarment is part of a Negotiated Resolution Agreement between Alstom and the World Bank which also includes a restitution payment by the two companies totaling approximately $9.5 million. [\u00a0 ]\u00a0\n\tIn 2002, Alstom made an improper payment of \u20ac110,000, to an entity controlled by a former senior government official for consultancy services in relation to the World Bank-financed Zambia Power Rehabilitation Project. During the debarment period of Alstom Hydro France and Alstom Network Schweiz AG, Alstom SA and its other affiliates are conditionally non-debarred.\u0022 (Source:\u00a0 World Bank Press Release, \u0022Enforcing Accountability: World Bank Debars Alstom Hydro France, Alstom Network Schweiz AG, and their Affiliates,\u0022 February 22, 2012.)\n\tIn the World Bank Intrgrity Vice Presidency\u0027s fiscal year 2012 Annual Report, the World Bank President Jim Yong Kim stated, \u0022the World Bank Group will continue to work with patience and perseverance on the thornier parts of fighting corruption: [\u00a0 ] designing an Anti-Corruption Fund that equitably and purposefully distributes recovered assets and restitution payments to those who would benefit the most.\u0022\u00a0 (Source: Integrity Vice Presidency, \u0022Annual Report Fiscal Year 2012: Finding the Right Balance,\u0022 The World Bank (October 2012), at iv.)","Disposition of Criminal Case(s)":"N\/A (Administrative sanctions)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"World Bank Integrity Vice Presidency","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"World Bank Integrity Vice Presidency","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alstom_World%20Bank_Debar_Press_Release_Feb_22_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alstom_World_Bank_Annual_Report_2012.pdf","Sources ":"\n\tWorld Bank Press Release, \u0022Enforcing Accountability: World Bank Debars Alstom Hydro France, Alstom Network Schweiz AG, and their Affiliates,\u0022 February 22, 2012, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,contentMDK:23123315~pagePK:64257043~piPK:437376~theSitePK:4607,00.html;\u00a0World Bank Integrity Vice Presidency Fiscal Year 2012 Annual Report, at http:\/\/www-wds.worldbank.org\/external\/default\/WDSContentServer\/WDSP\/IB\/2...\n\n\t\u00a0\n"},{"Case ID":"ARW-28","Case Title (Name of Public Official or Entity Allegedly Involved)":"C. Lotti and Associati Societa\u2019 di Ingegneria S.p.A. (Lotti)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Italy","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort (World Bank)","Asset Recovery Start":"","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.26","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Administrative Sanctions (Negotiated Resolution Agreement) ","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Unspecified cooperation","Contributing Factors in Asset Recovery":"In announcing the Negotiated Resolution Agreement, the Integrity Vice Presidency stated, \u201cThis moves us closer to answering a longstanding call by victim countries to return illicit gains.\u0022  (Source: World Bank Press Release, \u0022Enforcing Accountability: Italian Company Lotti to pay US$350,000 in restitution to Indonesia after acknowledging fraudulent misconduct in a World Bank-financed project,\u0022 December 22, 2010.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$350,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the World Bank press release of December 22, 2010, \u0022The World Bank Group debarred C. Lotti and Associati Societa\u2019 di Ingegneria S.p.A. (Lotti) in the wake of the company\u2019s acknowledged misconduct in a World Bank investigation relating to a Bank-financed public works project in the water sector in Indonesia.\u00a0\n\tUnder the negotiated resolution agreement, Lotti has committed to pay an estimated US$350,000 in restitution to Indonesia, where the World Bank-financed project was being implemented.\u00a0 This is the first time the World Bank included restitution payment in resolving an investigation into fraud in a Bank-financed project. The restitution amount of US$350,000 represents the unjustified payments received by Lotti as well as its partners as a result of fraudulent invoicing.\u0022\u00a0 (Source: World Bank Press Release, \u0022Enforcing Accountability: Italian Company Lotti to pay US$350,000 in restitution to Indonesia after acknowledging fraudulent misconduct in a World Bank-financed project,\u0022 December 22, 2010.)\u00a0","Disposition of Criminal Case(s)":"N\/A (Administrative Sanctions by the World Bank)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"World Bank Integrity Vice Presidency","Jurisdiction of Asset Recovery: Courts Involved":"N\/A","Documents":"","Sources ":"World Bank Press Release, \u0022Enforcing Accountability: Italian Company Lotti to pay US$350,000 in restitution to Indonesia after acknowledging fraudulent misconduct in a World Bank-financed project,\u0022 December 22, 2010, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/TOPICS\/EXTLAWJUSTICE\/0,,contentMDK:22796379~menuPK:2643814~pagePK:64020865~piPK:149114~theSitePK:445634,00.html;\n\tWorld Bank Integrity Vice Presidency Fiscal Year 2011 Annual Report, accessed at http:\/\/siteresources.worldbank.org\/INTDOII\/Resources\/588889-1316720250792\/INT_AR_FY11_web.pdf\n"},{"Case ID":"ARW-24","Case Title (Name of Public Official or Entity Allegedly Involved)":"James Ibori \/ Bhadresh Gohil (India)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Solicitor to James Ibori, Delta State Governor (1999-2007)","Jurisdiction of Asset Recovery":"India","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture (United Kingdom)","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the 2008 Restraint Order issued by the UK High Court, among the assets ordered restrained were two properties located in India: \u00a0\u0022\u0027 b) Flat X12. Ashoka, A building, Panch Tantra Road, Verova M, Mumbai, India, 401105 registered in the name of Babulal Gahil, c) Divine Sheraton Plaza Wing B, No 33, 3rd floor, Jesal Park, Bhayander East India, 404105 registered in the name of Babulal Gahil.\u0022 \u00a0(Source: UNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012.), Exhibit .B, UK High Court Order of Restraint against Mr. Gohil, November 17, 2008.)\n\t\u00a0\n\tIn July 2013, the US Government filed a response to the Court Order to Show Cause, urging the court not to terminate the action and to retain jurisdiction over the matter until confiscation proceedings in the UK conclude. \u00a0As of June 2016, the US case was ongoing. \u00a0(Source: \u00a0In Re: Enforcement of Restraining Order Issued by the High Court of England and Wales, Case No. 1:12-mc-00289 (D.D.C.), US Government Reponse to Order to Show Cause filed July 16, 2013; Court Docket Report as of June 2016.) \u00a0According to news reports, the UK confiscation hearing that was rescheduled for June 2016 was again postponed. \u00a0(Source: Today (Nigeria), \u0022London court postpones James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016; Vanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015.)","Disposition of Criminal Case(s)":"According to a May 2014 statement by Nigeria\u0027s Economic and Financial Crimes Commission, a lower court decision to strike out \u0022all 170-count charge of money laundering preferred against former governor of Delta State, James Onanefe Ibori by the Economic and Financial Crimes Commission, EFCC, a three-man panel of justices at the Benin Division of the Court of Appeal today, May 15, 2014 ruled that the ex- governor who is currently serving a 13-year jail term in a London prison, has a case to answer.\u0022 \u00a0(Source: EFCC, \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014.) \u00a0 According to the United States\u0027 Ex Parte Application to Enforce and Register Foreign Restraining Orders, Mr. Gohil was convicted in the UK \u0022in November 2010 of money laundering and prejudicing a money laundering investigation, and in December 2010, pleaded guilty to an additional eight offenses related to the V Mobile fraud. Gohil was sentenced to ten years imprisonment.\u0022 \u00a0(Source: UNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012.)","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission (Nigeria)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service (United Kingdom)","Jurisdiction of Origin: Courts Involved":"Southwark Crown Court (United Kingdom)","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Ex_Parte_Restrain_Order_DDC_May_2012_3.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Asset_Restraint_DOJ_PR_Jul_23_2012_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_Nigeria_Appeals_Ct_EFCC_May_15_2014_2.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_UK_London%20judge%20adjourns%20Ibori%27s%20case%20to%20June%206%2C%202016%20-%20Vanguard%20News_Apr_14_2015_2.pdf","Sources ":"\n\n\t\tNigeria Economic and Financial Crimes Commission (EFCC), \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014, at https:\/\/efccnigeria.org\/efcc\/index.php\/news\/870-money-laundering-ibori-h...\n\n\t\t\u00a0\n\n\t\tToday (Nigeria), \u0022London court suspends James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016;\n\n\t\t\u00a0\n\n\t\tVanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015);\n\n\t\t\u00a0\n\n\t\tUNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012), Exhibit B, UK High Court Order of Restraint against Mr. Gohil, November 17, 2008.);\u00a0\n\n\t\t\u00a0\n\n\t\tUS Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012, accessed at \u00a0http:\/\/www.justice.gov\/opa\/pr\/2012\/July\/12-crt-906.html\n\n\u00a0\n"},{"Case ID":"ARW-23","Case Title (Name of Public Official or Entity Allegedly Involved)":"James Ibori \/ Bhadresh Gohil (Hong Kong SAR, China)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Solicitor to James Ibori, Delta State Governor (1999-2007)","Jurisdiction of Asset Recovery":"Hong Kong SAR, China","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20, Art.25","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture (United Kingdom)","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the 2008 Restraint Order issued by the UK High Court, among the assets ordered restrained was \u0022An account held at HSBC Bank, Harcourt Road Branch, Central Hong Kong account number 102-397296-274, held in the name of Zetland Financial Group Ltd.\u0022 \u00a0(Source: UNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012.), Exhibit .B, UK High Court Order of Restraint against Mr. Gohil, November 17, 2008.)\n\t\u00a0\nIn July 2013, the US Government filed a response to the Court Order to Show Cause, urging the court not to terminate the action and to retain jurisdiction over the matter until confiscation proceedings in the UK conclude. \u00a0As of June 2016, the US case was ongoing. \u00a0(Source: \u00a0In Re: Enforcement of Restraining Order Issued by the High Court of England and Wales, Case No. 1:12-mc-00289 (D.D.C.), US Government Reponse to Order to Show Cause filed July 16, 2013; Court Docket Report as of June 17, 2016.) \u00a0According to news reports, the UK confiscation hearing that had been rescheduled for June 2016 was again postponed. \u00a0(Sources: Today (Nigeria), \u0022London court suspends James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016; Vanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015)","Disposition of Criminal Case(s)":"According to a May 2014 statement by Nigeria\u0027s Economic and Financial Crimes Commission, a lower court decision to strike out \u0022all 170-count charge of money laundering preferred against former governor of Delta State, James Onanefe Ibori by the Economic and Financial Crimes Commission, EFCC, a three-man panel of justices at the Benin Division of the Court of Appeal today, May 15, 2014 ruled that the ex- governor who is currently serving a 13-year jail term in a London prison, has a case to answer.\u0022 \u00a0(Source: EFCC, \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014.) \u00a0 According to the United States\u0027 Ex Parte Application to Enforce and Register Foreign Restraining Orders, Mr. Gohil was convicted in the UK \u0022in November 2010 of money laundering and prejudicing a money laundering investigation, and in December 2010, pleaded guilty to an additional eight offenses related to the V Mobile fraud. Gohil was sentenced to ten years imprisonment.\u0022 \u00a0(Source: UNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Economic and Financial Crimes Commission (Nigeria); Crown Prosecution Service (UK)","Jurisdiction of Origin: Courts Involved":"Southwark Crown Court (UK)","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Ex_Parte_Restrain_Order_DDC_May_2012_2.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Asset_Restraint_DOJ_PR_Jul_23_2012_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_Nigeria_Appeals_Ct_EFCC_May_15_2014_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_UK_London%20judge%20adjourns%20Ibori%27s%20case%20to%20June%206%2C%202016%20-%20Vanguard%20News_Apr_14_2015_1.pdf","Sources ":"Nigeria Economic and Financial Crimes Commission (EFCC), \u0022Money Laundering:\u00a0 Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014, at https:\/\/efccnigeria.org\/efcc\/index.php\/news\/870-money-laundering-ibori-has-case-to-answer-appeal-court;\n\tToday (Nigeria), \u0022London court suspends James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016;\n\tVanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015);\n\tUNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012), Exhibit B, UK High Court Order of Restraint against Mr. Gohil, November 17, 2008.);\n\tUS Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012, accessed at\u00a0 http:\/\/www.justice.gov\/opa\/pr\/2012\/July\/12-crt-906.html\n\u00a0\n"},{"Case ID":"ARW-11","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alstom S.A. (Tunisia)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"France","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"Tunisia","Jurisdiction of Asset Description":"","Asset Recovery Start":"2011","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Prosecution and Restitution (in Switzerland)","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Article 53 Swiss Criminal Code payment of reparations","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Funds were transferred to the International Committee of the Red Cross for use in ICRC projects in Tunisia, Latvia and Malaysia. (Source: The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Case Summary":"According to the November 2011 Summary punishment order imposed by the Swiss authorities, Alstom Network Schweiz AG (Swiss subsidiary of the French company Alstom S.A.) was convicted of not having taken all necessary and reasonable organizational precautions to precent bribery of foreign public officials in Latvia, Tunisia and Malaysia.\u00a0 In Tunisia, in connection with the RADES project by the Carthage Power Company (licensed by the state company STEG - Societee Tunisienne de l\u0027Electricite et du Gaz),\u00a0 Alstom concluded consultancy agreements with two offshore companies controlled by the son-in-law of former president of Tunisia and a payment was made to one of the entities which exceeded the internal threshold for consultancy fees.\u00a0 The Summary punishment order stated that as son-in-law of the former president, Slim Chiboub \u0022was obviously in a position to influence not only the contract awards for the RADES project [\u00a0 ] but to avert compensation payments that later threatened ALSTOM due to damages caused by late performance.\u0022 Alstom Schweiz was fined CHF 2.5 million; a compensatory claim of CHF 36.4 million was also imposed. The parent company Alstom S.A. paid the CHF 1 million in reparation, a third of which was to be used for International Committee of the Red Cross projects in Latvia. (Sources:\u00a0 Office of the Swiss Attorney General, Summary punishment order in the invesitgation of defendant Alstom Network Schweiz AG, November 22, 2011 and The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Disposition of Criminal Case(s)":"According to the November 2011 press release by The Federal Authorities of the Swiss Confederation, Alstom Network Schweiz AG was convicted under article 102 of the Swiss Criminal Code of not having taken \u0022all necessary and reasonable organizational precautions to prevent bribery of foreign public officials\u0022; proceedings against the French parent company Alstom S.A. were dismissed based on art. 53 of the Swiss Criminal Code, imposing costs of proceedings and payment of reparations.\u00a0 (Source: The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Office of the Swiss Attorney General, Summary punishment order in the investigation of defendant Alstom Network Schweiz AG, November 22, 2011, accessed at http:\/\/www.scribd.com\/doc\/73503009\/Summary-Punishment-Order;\n\tThe Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011, accessed at http:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=42300.\n"},{"Case ID":"ARW-9","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alstom S.A. (Malaysia)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"France","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"Malaysia","Jurisdiction of Asset Description":"","Asset Recovery Start":"2011","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Prosecution and Restitution (in Switzerland)","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Article 53 Swiss Criminal Code payment of reparations","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Funds were transferred to the International Committee of the Red Cross for use in ICRC projects in Tunisia, Latvia and Malaysia. (Source: The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Case Summary":"According to the November 2011 Summary punishment order imposed by the Swiss authorities, Alstom Network Schweiz AG (Swiss subsidiary of the French company Alstom S.A.) was convicted of not having taken all necessary and reasonable organizational precautions to precent bribery of foreign public officials in Latvia, Tunisia and Malaysia.\u00a0 In Malaysia, two executives of Alstom\u0027s client company, state-licensed TTPC (Teknologi Tenaga Perlis Consortium Sdtn Bhd) were deemed to be beneficiaries of consulting contracts signed by Alstom with offshore companies in connection with the PERLIS gas turbines contract.\u00a0 One of the beneficiaries of the bribe payments was also a local politician in the area where the power station was to be built. \u0022In return for payment, they influenced both the award of contracts as part of the project in previous years (including securing of financing) and ensured that any difficulties encountered by the client in the performance of the contract were resolved in favor of ALSTOM.\u0022 Alstom Schweiz was fined CHF 2.5 million; a compensatory claim of CHF 36.4 million was also imposed. The parent company Alstom S.A. paid the CHF 1 million in reparation, a third of which was to be used for International Committee of the Red Cross projects in Latvia. (Sources:\u00a0 Office of the Swiss Attorney General, Summary punishment order in the invesitgation of defendant Alstom Network Schweiz AG, November 22, 2011 and The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Disposition of Criminal Case(s)":"According to the November 2011 press release by The Federal Authorities of the Swiss Confederation, Alstom Network Schweiz AG was convicted under article 102 of the Swiss Criminal Code of not having taken \u0022all necessary and reasonable organizational precautions to prevent bribery of foreign public officials\u0022; proceedings against the French parent company Alstom S.A. were dismissed based on art. 53 of the Swiss Criminal Code, imposing costs of proceedings and payment of reparations.\u00a0 (Source: The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alstom_SA_Swiss_Attorney_General_Summary_Punishment_Order_PR_Nov_22_2011_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alstom_Company_Statement_Nov_2011.pdf","Sources ":"Office of the Swiss Attorney General, Summary punishment order in the investigation of defendant Alstom Network Schweiz AG, November 22, 2011, accessed at http:\/\/www.scribd.com\/doc\/73503009\/Summary-Punishment-Order;\n\tThe Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011, accessed at http:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=42300.\n"},{"Case ID":"ARW-8","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alstom S.A. (Latvia)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"France","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"Latvia","Jurisdiction of Asset Description":"","Asset Recovery Start":"2011","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution and Restitution (in Switzerland)","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Article 53 Swiss Criminal Code payment of reparations","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Funds were transferred to the International Committee of the Red Cross for use in ICRC projects in Tunisia, Latvia and Malaysia. (Source: The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Case Summary":"According to the November 2011 Summary punishment order imposed by the Swiss authorities, Alstom Network Schweiz AG (Swiss subsidiary of the French company Alstom S.A.) was convicted of not having taken all necessary and reasonable organizational precautions to precent bribery of foreign public officials in Latvia, Tunisia and Malaysia.\u00a0 In Latvia,\u0022from 2006 onwards, the state energy company LATVENERGO AS had contracts to award in various projects in Latvia relating to the modernization of power stations. ALSTOM Power Sweden and ALSTOM Hydro Sweden signed various consultancy agreements with companies of a former ALSTOM employee providing for success fees to be paid for the successful signing of delivery and maintenance contracts for power stations: Plavinas Hydo Power Plant 4, 5 and 7 and Plavinas Hydri Power Paint 1, 3, 6, 9 and 10.\u00a0 After the\u00a0 award of the two Plavinas projects to the Swedish Alstom companies, the companies paid the success fees to Alstom Network, which then transferred them to the former employee\/consultant who in turn transferred the funds to three executives of the state company LATVENERGO who \u0022were decisively involved in the decisions related to awarding projects. Apparently the sole interest was influencing LATVENERGO AS decision-makers with bribes to award the contract to ALSTOM.\u0022\u00a0 Alstom Schweiz was fined CHF 2.5 million; a compensatory claim of CHF 36.4 million was also imposed. The parent company Alstom S.A. paid the CHF 1 million in reparation, a third of which was to be used for International Committee of the Red Cross projects in Latvia. (Sources:\u00a0 Office of the Swiss Attorney General, Summary punishment order in the invesitgation of defendant Alstom Network Schweiz AG, November 22, 2011 and The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Disposition of Criminal Case(s)":"According to the November 2011 press release by The Federal Authorities of the Swiss Confederation, Alstom Network Schweiz AG was convicted under article 102 of the Swiss Criminal Code of not having taken \u0022all necessary and reasonable organizational precautions to prevent bribery of foreign public officials\u0022; proceedings against the French parent company Alstom S.A. were dismissed based on art. 53 of the Swiss Criminal Code, imposing costs of proceedings and payment of reparations.\u00a0 (Source: The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Office of the Swiss Attorney General, Summary punishment order in the investigation of defendant Alstom Network Schweiz AG, November 22, 2011, accessed at http:\/\/www.scribd.com\/doc\/73503009\/Summary-Punishment-Order;\n\tThe Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011, accessed at http:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=42300.\n"},{"Case ID":"ARW-190","Case Title (Name of Public Official or Entity Allegedly Involved)":"Vitol S.A.","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Switzerland, United States","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"Iraq [Development Fund for Iraq]","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort (United States)","Asset Recovery Start":"2007","Asset Recovery End":"2007","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution and Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified ","Contributing Factors in Asset Recovery":"Restitution to the People of Iraq via the Development Fund of Iraq was part of the plea agreement by Vitol SA and the New York County District Attorney\u0027s Office. (Source: New York County District Attorney\u0027s Office News Release on Vitol S.A., November 20, 2007.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$13,000,000","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Restitution to people of Iraq via Development Fund of Iraq","Case Summary":"According to the United States report to the OECD on enforcement of foreign bribery actions, \u0022[i]n 2007, the Manhattan (NY) District Attorney\u2019s Office charged Vitol, S.A. (Vitol), a Swiss oil trading firm, with Grand Larceny in the First Degree for its involvement in a scheme to pay kickbacks to Iraq in connection with oil purchases made under the United Nations Oil-for-Food Program (OFFP). According to court documents, while the OFFP was in effect, Vitol purchased Iraqi crude oil first as direct purchaser and later from third-parties. In June 2001, after an OPEC meeting, an agent of VITOL was told by Iraqi officials that surcharges had to be paid in order for Iraqi crude oil to be lifted. Over the next year, VITOL paid or caused surcharges to be paid on certain oil purchases in two ways. In direct purchases, VITOL had an associated entity called Vitol Bahrain send the surcharge monies to accounts controlled by the Iraqi regime. In indirect purchases, VITOL financed the purchase of oil through third parties who then paid the surcharge to the Iraqi regime. VITOL did not inform the UN about the surcharge payments. During the period from June 2001 through September 2002, approximately $13,000,000 in surcharge monies were paid directly to the Iraqi regime in connection with crude oil purchased directly or indirectly by VITOL. [ ] On November 20, 2007, Vitol pleaded guilty and was sentenced to pay restitution of $13 million to the Iraqi people through the Development Fund for Iraq, in addition to a payment of $4.5 million in lieu of fines, forfeiture and to cover the costs of prosecution.\u0022\u00a0 (Source: United States Department of Justice Report to the OECD, \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 \u2013 February 10, 2012,\u0022 Vitol S.A. matter at 101-102.)","Disposition of Criminal Case(s)":"In 2007, Vitol S.A. pleaded guilty to a charge of Grand Larceny for its misconduct in the UN Oil-for-Food scheme.\u00a0 (Source: New York County District Attorney\u0027s Office News Release on Vitol S.A., November 20, 2007.)","Jurisdiction of Origin: Investigative Agency":"New York County District Attorney\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"New York County District Attorney\u0027s Office","Jurisdiction of Origin: Courts Involved":"New York State Supreme Court","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/2013-02-25-steps-taken-oecd-anti-bribery-convention-us.pdf","Sources ":"New York County District Attorney\u0027s Office News Release on Vitol S.A., November 20, 2007;\n\tUnited States Department of Justice Report to the OECD, \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 \u2013 February 10, 2012,\u0022 Vitol S.A. matter at 101-102, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/2012-02-29-steps-taken-oecd-anti-bribery-convention.pdf.\n"},{"Case ID":"ARW-172","Case Title (Name of Public Official or Entity Allegedly Involved)":"Siemens A.G. \/ Greece Settlement","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Germany","Position of Public Official(s) (yrs in office)":"Various","Jurisdiction of Asset Recovery":"","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Settlement agreement ratified by Greek Parliament","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Civil settlement ratified by Greek Parliament.","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction (in part)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"Up to US$350,263,000; Please see Summary for details.","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Please see Summary for details.","Case Summary":"According to the April 2012 press release by Siemens, the Greek Parliament ratified the company\u0027s settlement agreement with Greek authorities to resolve multiple criminal and civil complaints regarding bribery in public contracts.\u00a0 The press release stated that the company, \u0022waives claims of \u20ac80 million that concern implemented projects and the delivery of equipment to the Greek State. Siemens will dispense up to the amount of 90 million Euro for transparency initiatives and anti-corruption programs, as well as for academic and research programs that aim at enhancing Greece\u2019s competitiveness. Finally, Siemens will spend over \u20ac100 million, in order to enhance its activities in Greece and preserve a significant number of jobs in the local market.\u0022 (Source: Siemens S.A. Press Release, \u0022Siemens and the Hellenic Republic reach a settlement agreement and mark a new beginning,\u0022 April 5, 2012.)\u00a0 Some details of the Greek investigation into Siemens\u0027 activities in that country and filing of lawsuit by the Hellenic Telecommunications Organization S.A. are noted in Siemens\u0027 regulatory filings in the United States.\u00a0 (Source: United States Securities and Exchange Commission, Form F-20, Siemens AG, 2011 and 2010)","Disposition of Criminal Case(s)":"N\/A (Civil Settlement)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Greek Parliamentary Investigation Committee; Greek Public Prosecutor","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Public Prosecutor","Jurisdiction of Asset Recovery: Courts Involved":"N\/A","Documents":"","Sources ":"Siemens S.A. Press Release, \u0022Siemens and the Hellenic Republic reach a settlement agreement and mark a new beginning,\u0022 April 5, 2012, accessed at http:\/\/www.siemens.com\/press\/en\/pressrelease\/?press=\/en\/pressrelease\/2012\/corporate\/axx20120420.htm;\n\tUnited States Securities and Exchange Commission, Form F-20, Siemens AG, 2011 and 2010.\n"},{"Case ID":"ARW-147","Case Title (Name of Public Official or Entity Allegedly Involved)":"Oxford University Press \/ World Bank Settlement","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United Kingdom","Position of Public Official(s) (yrs in office)":"N\/A","Jurisdiction of Asset Recovery":"","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2011","Asset Recovery End":"","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Negotiated Resolution Agreement ","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Cooperation in investigation with the UK Serious Fraud Office","Contributing Factors in Asset Recovery":"The $500,000 payment by the Oxford University Press -- \u0022in order to remedy part of the harm done by the misconduct\u0022 - was part of its Negotiated Resolution.  (Source:  The World Bank Press Release, \u0022World Bank Sanctions Oxford University Press for Corrupt Practices Impacting Education Projects in East Africa,\u0022 July 3, 2012.)\r\n","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$500,000","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"Unspecified","Case Summary":"According to the press release by the World Bank, on July 3, 2012, \u0022The World Bank Group today announced the debarment of two wholly-owned subsidiaries of Oxford University Press (OUP), namely: Oxford University Press East Africa Limited (OUPEA) and Oxford University Press Tanzania Limited (OUPT) - for a period of three years following OUP\u2019s acknowledgment of misconduct by its two subsidiaries in relation to two Bank-financed education projects in East Africa.\n\tThe debarment is part of a Negotiated Resolution Agreement between OUP and the World Bank Group. In May 2011, investigators from the World Bank\u2019s Integrity Vice Presidency (INT) approached OUP about potential misconduct in Africa. Following this, OUP conducted an internal investigation into its operations and reported its findings to INT. [\u00a0 ]\n\tThe two companies made improper payments to government officials for two contracts to supply text books in relation to two World Bank-financed projects. As a result, OUPEA and OUPT will be debarred for three years and OUP will receive a conditional non-debarment. In addition, in order to remedy part of the harm done by the misconduct, OUP has agreed to make a payment of US$500,000 to the World Bank as part of the Negotiated Resolution.\u0022 (Source:\u00a0 The World Bank Press Release, \u0022World Bank Sanctions Oxford University Press for Corrupt Practices Impacting Education Projects in East Africa,\u0022 July 3, 2012.)\n\tIn the World Bank Intrgrity Vice Presidency\u0027s fiscal year 2012 Annual Report, the World Bank President Jim Yong Kim stated, \u0022the World Bank Group will continue to work with patience and perseverance on the thornier parts of fighting corruption: [\u00a0 ] designing an Anti-Corruption Fund that equitably and purposefully distributes recovered assets and restitution payments to those who would benefit the most.\u0022\u00a0 (Source: Integrity Vice Presidency, \u0022Annual Report Fiscal Year 2012: Finding the Right Balance,\u0022 The World Bank (October 2012), at iv.","Disposition of Criminal Case(s)":"N\/A (Administrative sanctions case)","Jurisdiction of Origin: Investigative Agency":"UK Serious Fraud Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"World Bank Integrity Vice Presidency","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"World Bank Integrity Vice Presidency","Jurisdiction of Asset Recovery: Courts Involved":"N\/A","Documents":"","Sources ":"The World Bank Press Release, \u0022World Bank Sanctions Oxford University Press for Corrupt Practices Impacting Education Projects in East Africa,\u0022 July 3, 2012, acessed at http:\/\/www.worldbank.org\/en\/news\/2012\/07\/03\/world-bank-sanctions-oxford-university-press-corrupt-practices-impacting-education-projects-east-africa;\nWorld Bank Integrity Vice Presidency, \u0022Annual Report Fiscal Year 2012: Finding the Right Balance,\u0022 The World Bank (October 2012), accessed at\u00a0 http:\/\/www-wds.worldbank.org\/external\/default\/WDSContentServer\/WDSP\/IB\/2012\/10\/08\/000356161_20121008012319\/Rendered\/PDF\/731010AR0Box370C0disclosed010050120.pdf\n"},{"Case ID":"ARW-146","Case Title (Name of Public Official or Entity Allegedly Involved)":"Oxford University Press \/ UK Serious Fraud Office Settlement","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United Kingdom","Position of Public Official(s) (yrs in office)":"N\/A","Jurisdiction of Asset Recovery":"Various, unnamed jurisdictions","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Unilateral voluntary payment arising out of foreign bribery case","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"\u0022This was a reflection of the seriousness with which OUP [Oxford University Press] views the course of events that were subject to the investigation and a wish to acknowledge that the conduct of [its subsidiaries] OUPEA and OUPT fell short of that expected within its wider organisation.  The contribution would benefit the people within the affected region and be consistent with the overall mission of OUP.  The offer also confirmed that the funds would not be used so as to provide OUP with a commercial advantage.\u0022  (Source:  UK Serious Fraud Office Press Release, \u0022Oxford Publishing Ltd to pay almost \u00a31.9 million as settlement after admitting unlawful conduct in its East African operations,\u0022 July 3, 2012.)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Other","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Oxford University Press \u0022unilaterally offered to contribute \u00a32,000,000 to not-for-profit organisations for teacher training and other educational purposes in sub-Saharan Africa.\u0022 (Source:  UK Serious Fraud Office Press Release, \u0022Oxford Publishing Ltd to pay almost \u00a31.9 million as settlement after admitting unlawful conduct in its East African operations,\u0022 July 3, 2012.)","Case Summary":"According to the press release by the UK Serious Fraud Office, \u0022In 2011, OUP [Oxford University Press] became aware of the possibility of irregular tendering practices involving its education business in East Africa.\u00a0 OUP acted immediately to investigate the matter, instructing independent lawyers and forensic accountants to undertake a detailed investigation.\nAs a result of the investigation, in November 2011 OUP voluntarily reported certain concerns in relation to contracts arising from a number of tenders which its Kenyan and Tanzanian subsidiaries, OUPEA and OUPT, entered into between the years 2007 and 2010.\u0022\u00a0\u00a0\u00a0 As part of the agreed upon Civil Recovery Order, OUP agreed to pay GBP1,895,435 (US$2,971,300) and GBP 12,500 (US$19,595) for SFO\u0027s costs of pursuing the order.\u00a0\n\u0022In addition to the property recovered under the civil recovery order, OUP unilaterally offered to contribute \u00a32,000,000 to not-for-profit organisations for teacher training and other educational purposes in sub-Saharan Africa.\u00a0 This was a reflection of the seriousness with which OUP views the course of events that were subject to the investigation and a wish to acknowledge that the conduct of OUPEA and OUPT fell short of that expected within its wider organisation.\u00a0 The contribution would benefit the people within the affected region and be consistent with the overall mission of OUP.\u00a0 The offer also confirmed that the funds would not be used so as to provide OUP with a commercial advantage\nAlthough the benefits to the people of the affected region are acknowledged by the SFO, the SFO decided that the offer should not be included in the terms of the court order as the SFO considers it is not its function to become involved in voluntary payments of this kind.\u00a0\u00a0 However, the SFO welcomes OUP\u0027s commitment to make this contribution and to work with a range of not-for-profit organisations in sub-Saharan Africa to achieve the above objectives.\u0022\u00a0 (Source:\u00a0 UK Serious Fraud Office Press Release, \u0022Oxford Publishing Ltd to pay almost \u00a31.9 million as settlement after admitting unlawful conduct in its East African operations,\u0022 July 3, 2012.)\n\u00a0","Disposition of Criminal Case(s)":"N\/A (Civil Recovery Order)","Jurisdiction of Origin: Investigative Agency":"UK Serious Fraud Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Justice, Queen\u0027s Bench Division (UK)","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/application_notice_form_n244.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Oxford_Univ_Press_Settlement_SFO_Press_Release_Jul_3_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/part_8_claim_form_n208.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/sealed_consent_order.pdf","Sources ":"UK Serious Fraud Office Press Release, \u0022Oxford Publishing Ltd to pay almost \u00a31.9 million as settlement after admitting unlawful conduct in its East African operations,\u0022 July 3, 2012, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-20...\n\tConsent Order, accessed at http:\/\/www.sfo.gov.uk\/media\/215466\/sealed_consent_order.pdf;\n\t\u00a0\n\tClaim Form to the High Court, accessed at http:\/\/www.sfo.gov.uk\/media\/215458\/part_8_claim_form_n208.pdf;\n\t\u00a0\n\tApplication Notice to the High Court, accessed at http:\/\/www.sfo.gov.uk\/media\/215462\/application_notice_form_n244.pdf.\n\t\u00a0\n\t\u00a0\n\t\u00a0\n"},{"Case ID":"ARW-142","Case Title (Name of Public Official or Entity Allegedly Involved)":"Nicolau Dos Santos Neto","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Brazil","Position of Public Official(s) (yrs in office)":"Judge (inclusive 1991-1994)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Confiscation; Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT; Letter of Request","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Criminal and civil legal mechanisms employed in Switzerland and Brazil; more than a decade of international legal cooperation.  (Sources:  Swiss Federal Court decision 6B_688\/2011 (August 21, 2012) and Swiss Federal Department of Justice and Police, \u0022Strengthening co-operation in the fight against crime \/\r\nBrazilian delegation visits Bern,\u0022 Press Release October 14, 2002.)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction (in part)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"$2,100,000","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tAccording to a July 9, 2013 press release by the Swiss Federal Office of Justice, \u00a0\u0022The sum of USD 4.8 million has now been transferred to the Federative Republic of Brazil. The Federal Supreme Court also ordered that Nicolau Dos Santos Neto should pay a replacement value of USD 2.1 million to Brazil.\u0022 \u00a0(Source: \u00a0Swiss Federal Office of Justice, Press Release, \u0022USD 4.8 m returned to Brazil\u0022, July 9, 2013. )\n\n\tAccording to an August 2012 decision by the Swiss Federal Court, between 1991 and 1994, 18 transactions totalling $6.8 million were transferred into accounts in the names of Mr. Neto and his spouse. \u00a0 The funds were proceeds of fraud and embezzlement by Mr. Neto in connection with the construction of a Regional Labour Court of Sao Paulo, Brazil. \u00a0Preliminary criminal inquiry was opened in Switzerland in 1999 but the complicated nature of the case - which included the intervention of third parties, use of shell corporations and international ramifications requiring the sending of letters rogatory to Brazil - added to the length of the case. \u00a0(Source: \u00a0Swiss Federal Court decision 6B_688\/2011 (August 21, 2012). \u00a0The funds had been frozen and confiscated pursuant to a Swiss investigation launched in 1999; in 2005, following Mr. Neto\u0027s criminal conviction in Brazil, Brazil filed suit in Switzerland to recover the assets. \u00a0(Source: \u00a0Id. and Jamil Chade, \u0022Suica vai devolver ao Brasil parte do dinheiro desviado por \u0027Lalau\u0027,\u0022 Estado.com.br, September 3, 2012, both accessed at http:\/\/www.icc-ccs.org\/home\/news\/90-fraudnet-and-its-members-in-the-news....) \u00a0 According to a 2011 presentation on the case by Brazil\u0027s Swiss attorney Yves Klein, in 2001 Brazil was admitted to the Swiss criminal case as an injured party which provided Brazil with the \u0022Right to consult the file, to participate in the acts of investigation, to make determinations on the cause, and to request investigative acts from the examining magistrate: \u2022 investigate other bank accounts in Switzerland; \u2022 question bank employees so as to assess their criminal liability.\u0022 \u00a0(Source: Attorney Yves Klein, \u0022The TRT Case \u2013 The forfeiture of the assets of Nicolau Dos Santos Neto in Switzerland,\u0022 presentation at the International Fraud \u0026 Asset Recovery and Trans-Border Insolvency Cooperation conference of Escola Superior do Minist\u00e9rio P\u00fablico de S\u00e3o Paulo (November-December 2011).\u00a0","Disposition of Criminal Case(s)":"According to the August 2012 decision by the Swiss Federal Court, Mr. Neto had been convicted in Brazil in 2005 of bribery, embezzlement, fraud and money laundering, and his conviction was upheld on appeal.\u00a0 (Source:\u00a0 Swiss Federal Court decision 6B_688\/2011 (August 21, 2012)).","Jurisdiction of Origin: Investigative Agency":"Ministry of Justice; Federal Police","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Federal Prosecutor","Jurisdiction of Origin: Courts Involved":"Federal Regional Court of the 3rd Region","Jurisdiction of Asset Recovery: Investigative Agency":"Prosecutor General, Geneva canton; Swiss Federal Department of Justice and Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General - Geneva canton; Federal Republic of Brazil - Attorneys Enrico Monfrini and Yves Klein","Jurisdiction of Asset Recovery: Courts Involved":"Court of Justice, Geneva; Swiss Federal Court","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Neto_Switzerland_Fed_Office_Justice_PR_Return_Jul_9_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Neto_Swiss_Ct_Decision_Aug_21_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Neto_Swiss_Fed_Justice_Statement_Oct_13_2002.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Neto_Swiss_Klein_Presentation_Nov_Dec_2011.pdf","Sources ":"\n\tSwiss Federal Office of Justice, Press Release, \u0022USD 4.8 m returned to Brazil\u0022, July 9, 2013, at https:\/\/www.bj.admin.ch\/\/content\/bj\/en\/home\/dokumentation\/medieninformat...\n\n\tSwiss Federal Court decision 6B_688\/2011 (August 21, 2012), accessed at http:\/\/jumpcgi.bger.ch\/cgi-bin\/JumpCGI?id=21.08.2012_6B_688\/2011; Jamil Chade, \u0022Suica vai devolver ao Brasil parte do dinheiro desviado por \u0027Lalau\u0027,\u0022 Estado.com.br, September 3, 2012, accessed via link provided at http:\/\/www.icc-ccs.org\/home\/news\/90-fraudnet-and-its-members-in-the-news... Swiss Federal Department of Justice and Police, \u0022Strengthening co-operation in the fight against crime \/ Brazilian delegation visits Bern,\u0022 Press Release October 14, 2002, accessed at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2002\/2002... See also presentation on the case by Attorney Yves Klein (representing Brazil), at the International Fraud \u0026 Asset Recovery and Trans-Border Insolvency Cooperation conference of Escola Superior do Minist\u00e9rio P\u00fablico de S\u00e3o Paulo (November-December 2011), at: \u00a0http:\/\/www.icc-ccs.org\/jdownloads\/Publications\/111201_klein_presentation...\n\n\t\u00a0\n"},{"Case ID":"ARW-137","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi \/ Saadi Quaddafi \/ London Mansion Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"The case marks the first international asset recovery by Libya; contributing factors included (1) media publicity surrounding the purchase of the mansion by Mr. Qaddafi\u0027s son; (2) wide disparity between Mr. Saadi Qaddafi\u0027s official salary as a member of the armed forces and the purchase price of the mansion, as well as strict bar on ownership of foreign property by members of Libyan armed forces; and (3) failure of Mr. S. Qaddafi and Capitana Seas Limited to appear and challenge the suit.  (Source: Phone interview with Libya\u0027s UK attorney in the suit.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$14,200,000 (approximate value of mansion)","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a Judgment by the United Kingdom\u0027s High Court of Justice, Libya was granted a default judgment against Capitana Seas Limited, the legal owner of a mansion located at 7 Winnington Close, Hampstead Gardens Suburb, London N2 0UA.\u00a0 The Justice in the case wrote, \u0022I am satisfied, on the evidence which has been put before me, that Saadi Quaddafi is the sole ultimate beneficial owner of the Defendant company [Capitana Seas Limited] [and that] the property was wrongfully and unlawfully purchased with funds belonging to [Libya].\u00a0 In those circumstances, the beneficial interest in the property is held by the Defendant, for the Claimant, as constructive trustees.\u0022\u00a0 (Source:\u00a0 Between The State of Libya and Capitana Seas Limited, [2012] EWHC 602 (Com).]\u00a0 The British media had reported on the purchase of the mansion by Capitana Seas Limited, a British Virgin Islands registered entity, and when sanctions were imposed against Mr. Qaddafi\u0027s assets in the UK, the property was included on the sanctions list.\u00a0 (Source:\u00a0 Libya\u0027s UK attorney in the case; see also,\u00a0 Christopher Leake and Daniel Bouffe, \u0022Colonel Gaddafi\u0027s son buys \u00a310m Hampstead mansion,\u0022 MailOnline, August 23, 2009.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Mohamed Shaban (MS- Legal Solicitors)","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Justice, Commercial Cour","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Libya_v_Capitana_Seas_UK_High_Ct_Judgment_Mar_2012.pdf","Sources ":"Between The State of Libya and Capitana Seas Limited, [2012] EWHC 602 (Com);\n\tChristopher Leake and Daniel Bouffe, \u0022Colonel Gaddafi\u0027s son buys \u00a310m Hampstead mansion,\u0022 MailOnline, August 23, 2009, accessed at http:\/\/www.dailymail.co.uk\/news\/article-1208434\/Gaddafi-son-buys-10m-Hampstead-mansion.html;\n\tPhone interview with Libya\u0027s UK attorney (October 2012)\n"},{"Case ID":"ARW-116","Case Title (Name of Public Official or Entity Allegedly Involved)":"Lesotho Highlands Water Project \/ Jacob Michael du Plooy","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"South Africa","Position of Public Official(s) (yrs in office)":"Chief executive of the Lesotho Highlands Development Agency (Masupha Ephraim Sole, 1986-1995) and former delegates of Lesotho on the Highlands Water Commission (Reatile Mochebelele and Letiafuoa Molapo); Acres International Limited (Canada); Lahmeyer International GmbH (Germany); Impregilo SpA (Italy); Jacobus Michiel Du Plooy (Impregilo intermediary); Spie Batignolles (France)","Jurisdiction of Asset Recovery":"Lesotho","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"1999","Asset Recovery End":"2003","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Successful collaboration of OLAF [European Anti-Fraud Office] in prosecuting the European companies involved; mutual legal assistance from Switzerland in the prosecutions (Source:  LL Thetsane and GH Penzhorn SC, \u0022Case Study: The Lesotho bribery prosecutions,\u0022 presented at Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities, Rabat, May 14-16, 2007); World Bank investigation and debarment of involved companies, Acres International and Lahmeyer International GmbH (Source: World Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, which noted \u0022Once the indictments [in the case] were announced in mid-1999, the World Bank provided extensive evidentiary support to the Lesotho prosecutors and made bank staff available for interviews.\u0022)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$67,114","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the decision by the Lesotho High Court, Mr. Du Plooy pleaded guilty to bribery and in September 2003, was sentenced to pay a fine of US$67,114.\u00a0 (Source: R v Du Plooy (CRI\/T\/111\/1999), 2003 LSHC 122).\u00a0 The case arose out of the Lesotho Highlands Water Project, which the Lesotho Court of Appeal as \u0022[0]ne of the biggest and most ambitious dam projects in the world, which entailed inter alia the construction of the Katse Dam in a remote and inaccessible part of the highlands of Lesotho.\u0022\u00a0 (Source: In the matter between: Ephraim Masupha Sole and The Crown, Lesotho Court of Appeals, Case (CRI) 5 OF 2002, Judgment dated April 13, 2003).\u00a0 According to the 2003 Lesotho Court of Appeal judgment, the High Court of Lesotho had found Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, guilty of accepting bribes from various multinational companies that were attempting to secure contracts related to the project.\u00a0 In an earlier dispute involving Mr. Sole, the government hired Ernst and Young, whose audit discovered that Mr. Sole had Swiss bank accounts into which the project contractors and consultants had placed large sums of money.\u00a0 Four multinational companies also were convicted or pleaded guilty in the case. (Please see other Lesotho Highlands Water Project entries.)","Disposition of Criminal Case(s)":"According to the Lesotho Court of Appeal, Mr. Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, was found guilty of accepting bribes from various multinational companies in connection with the Lesotho Highlands Water Project. According to the decision by the Lesotho High Court, Mr. Du Plooy pleaded guilty to bribery and in September 2003, was sentenced to pay a fine of US$67,114.\u00a0 (Source: R v Du Plooy (CRI\/T\/111\/1999), 2003 LSHC 122).","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"European Anti-Fraud Office (OLAF)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions of Lesotho","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Lesotho; Court of Appeal of Lesotho","Documents":"","Sources ":"R v Du Plooy (CRI\/T\/111\/1999), 2003 LSHC 122, accessed at http:\/\/www.lesotholii.org\/ls\/judgment\/high-court\/2003\/122;\u00a0\n\tIn the Matter between Ephraim Masupha Sole and the Crown, in the Appeal Court of Lesotho, C. of A. (CRI) 5 of 2002, CRI\/T\/111\/91, April 2, 3, and 14, 2003;\n\t\u0022Case Study: The Lesotho bribery prosecutions,\u0022 Paper presented by LL Thetsane and GH Penzhorn SC, at the Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities,\u0022 Rabat, May 14-16, 2007.\u00a0\u00a0\n\tWorld Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,contentMDK:21116129~pagePK:64257043~piPK:437376~theSitePK:4607,00.html;\n\tEuropean Anti-Fraud Office Press Release, \u0022Three European Companies Guilty in African Aid Fraud Case,\u0022 October 3, 2006, accessed at http:\/\/ec.europa.eu\/anti_fraud\/cases\/aid_en.html.\u00a0\n\tLesotho Highlands Water Project, at http:\/\/ipocafrica.org which also provides a list and links to relevant documents.\n"},{"Case ID":"ARW-86","Case Title (Name of Public Official or Entity Allegedly Involved)":"James Ibori  (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Delta State Governor (1999-2007)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\n\t\tAccording to media reports, the confiscation hearings in Mr. Ibori\u0027s case which was to take place in June 2016, has been adjourned. (Source: \u00a0Today (Nigeria), \u0022London court suspends James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016.)\n\n\n\t\u00a0\n\n\tOn June 4, 2008, the UK High Court issued a Restraint Order against properties, accounts and other assets owned and\/or controlled by Governor Ibori and legal entities Haleway Properties Limited; Telaton Quays Limited, Stanhope Investments Limited, and \u00a0Erin Aviation Limited located within and outside of the United Kingdom. \u00a0(Source: IN THE MATTER OF James Onanefe IBORI, Restraint Order Prohibiting Disposal of Assets, UK High Court, Queen\u0027s Bench Division, June 4, 2008.). \u00a0In February 2012, in reporting on Mr. Ibori\u0027s guilty plea in the UK, the BBC News reported, \u0022Some $35m of his alleged UK assets were frozen in 2007.\u0022 \u00a0(Source: \u00a0BBC News, \u0022Nigeria ex-Delta state governor James Ibori guilty plea,\u0022 February 27, 2012.)\n\n\t\u00a0\n\n\tOn November 17, 2008, the High Court also issued a Restraint Order against assets related to Bhadresh Gohil, including in India, Hong Kong and the UK. \u00a0(Source: IN THE MATTER OF Bhadresh Babulal Gohil, Restraint Order Prohibiting Disposal of Assets, UK High Court, Queen\u0027s Bench Division, November 17, 2008.)\n\n\t\u00a0","Disposition of Criminal Case(s)":"According to a May 2014 statement by Nigeria\u0027s Economic and Financial Crimes Commission, a lower court decision to strike out \u0022all 170-count charge of money laundering preferred against former governor of Delta State, James Onanefe Ibori by the Economic and Financial Crimes Commission, EFCC, a three-man panel of justices at the Benin Division of the Court of Appeal today, May 15, 2014 ruled that the ex- governor who is currently serving a 13-year jail term in a London prison, has a case to answer.\u0022 \u00a0(Source: EFCC, \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014.) According to the US Department of Justice, \u0022Governor Ibori was convicted in the United Kingdom of money laundering and conspiracy to defraud and was sentenced by a British court on April 18, 2012, to 13 years in prison.\u0022 (Source: US Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012.)","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission ","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"Court of Appeals, Benin Division","Jurisdiction of Asset Recovery: Investigative Agency":"London Metropolitan Police, Proceeds of Corruption Unit","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service","Jurisdiction of Asset Recovery: Courts Involved":"High Court, Queen\u0027s Bench","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_UK_Restart_Confisc_Hearing_Channelstv_Oct_8_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_DDC_US_Response_Show_Cause_Order_Jul_16_2013_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Ex_Parte_Restrain_Order_DDC_May_2012_4.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Asset_Restraint_DOJ_PR_Jul_23_2012_2.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_UK_Restraint_Order_Nov_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_UK_London%20judge%20adjourns%20Ibori%27s%20case%20to%20June%206%2C%202016%20-%20Vanguard%20News_Apr_14_2015.pdf","Sources ":"\n\tNigeria Economic and Financial Crimes Commission (EFCC), \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014, at https:\/\/efccnigeria.org\/efcc\/index.php\/news\/870-money-laundering-ibori-h...\n\n\t\u00a0\n\n\n\t\t\u00a0\n\n\t\tToday (Nigeria), \u0022London court suspends James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016, at https:\/\/www.today.ng\/news\/national\/135296\/london-court-suspends-james-ib...\n\n\t\t\u00a0\n\n\n\tVanguard News, \u0022London judge adjourns Ibori\u0027s case to June 6, 2016,\u0022 April 15, 2015;\u00a0\n\n\t\u00a0\n\n\tIN THE MATTER OF James Onanefe IBORI, Restraint Order Prohibiting Disposal of Assets, UK High Court, Queen\u0027s Bench Division, June 4, 2008; IN THE MATTER OF Bhadresh Babulal Gohil, Restraint Order Prohibiting Disposal of Assets, UK High Court, Queen\u0027s Bench Division, November 17, 2008, attached as Exhibits to \u00a0In Re: Enforcement of Restraining Order Issued by the High Court of England and Wales, Case No. 1:12-mc-00289 (D.D.C.), Ex Parte application by United States filed on May 16, 2012 (both accessed via PACER);\n\n\t\u00a0\n\n\tUS Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012, accessed at http:\/\/www.justice.gov\/opa\/pr\/2012\/July\/12-crt-906.html;\n\n\t\u00a0\n\n\tBBC News, \u0022Nigeria ex-Delta state governor James Ibori guilty plea,\u0022 February 27, 2012. );\u00a0\n\n\t\u00a0\n\n\tChanneltv.com, \u0022UK Court May Restart $145m Ibori Asset-Confiscation Case,\u0022 October 8, 2013, at http:\/\/www.channelstv.com\/home\/2013\/10\/08\/uk-court-may-restart-145m-ibor...\n"},{"Case ID":"ARW-85","Case Title (Name of Public Official or Entity Allegedly Involved)":"James Ibori (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Delta State Governor (1999-2007)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2012","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Forfeiture; Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Instrument as Contemplated by Article 3(2) of the Agreement on Mutual Legal Assistance Between the United States of America and the European Union Signed 25 June 2003, as to the Application of the Treaty Between the United States of America and the Government of the United Kingdom of Great Britain and Northern Ireland on Mutual Legal Assistance in Criminal Matters Signed 6 January 1994, U.S.-U.K., Dec. 16, 2004, S. Treaty Doc. 109-13 (2006); Treaty with the United Kingdom on Mutual Legal Assistance on Criminal Matters, U.S.-U.K., Jan. 6, 1994","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\nAccording to the US Department of Justice Press Release, \u0022Through an application to register and enforce two orders from United Kingdom courts, the Department of Justice has secured a restraining order against more than $3 million in corruption proceeds located in the United States related to James Onanefe Ibori. [ ] The application, which was filed under seal on May 16, 2012, in U.S. District Court in the District of Columbia, seeks to restrain assets belonging to Governor Ibori and Bhadresh Gohil, Ibori\u2019s former English solicitor, that are proceeds of corruption.\u00a0 Specifically, it seeks to restrain a mansion in\u00a0 Houston and two Merrill Lynch brokerage accounts. [ ] The United States is working with the United Kingdom\u2019s Crown Prosecution Service and the Metropolitan Police Service to forfeit these corruption proceeds.\u0022\u00a0 (Source: US Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012.)\u00a0 According to the Ex Parte Application filed by the US Department of Justice, the Houston property is located at 931 Enclave Lake Drive and the Merrill Lynch accounts are: 1CA-07411 and 1CA-07246. (Source: In Re: Enforcement of Restraining Order Issued by the High Court of England and Wales, Case No.\u00a0Case No. 1:12-mc-00289 (D.D.C.), Ex Parte application by United States filed on May 16, 2012.)\nIn July 2013, the US Government filed a response to the Court Order to Show Cause, urging the court not to terminate the action and to retain jurisdiction over the matter until confiscation proceedings in the UK conclude.\u00a0 As of June 2016, the US case was ongoing.\u00a0 (Source:\u00a0 In Re: Enforcement of Restraining Order Issued by the High Court of England and Wales, Case No.\u00a01:12-mc-00289 (D.D.C.), US Government Reponse to Order to Show Cause filed July 16, 2013; Court Docket Report as of June 17, 2016.) \u00a0According to news reports, the UK confiscation hearing that was rescheduled for June 2016 was again postponed.\u00a0 (Source: Vanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015; Today (Nigeria), \u0022London court suspends James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016, at https:\/\/www.today.ng\/news\/national\/135296\/london-court-suspends-james-ib...)\n\n\u00a0","Disposition of Criminal Case(s)":"According to a May 2014 statement by Nigeria\u0027s Economic and Financial Crimes Commission, a lower court decision to strike out \u0022all 170-count charge of money laundering preferred against former governor of Delta State, James Onanefe Ibori by the Economic and Financial Crimes Commission, EFCC, a three-man panel of justices at the Benin Division of the Court of Appeal today, May 15, 2014 ruled that the ex- governor who is currently serving a 13-year jail term in a London prison, has a case to answer.\u0022 \u00a0(Source: EFCC, \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014.) According to the US Department of Justice, \u0022Governor Ibori was convicted in the United Kingdom of money laundering and conspiracy to defraud and was sentenced by a British court on April 18, 2012, to 13 years in prison.\u0022 (Source: US Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Asset Forfeiture and  Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the District of Columbia","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_DDC_US_Response_Show_Cause_Order_Jul_16_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Asset_Restraint_DOJ_PR_Jul_23_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Ex_Parte_Restrain_Order_DDC_May_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_Nigeria_Appeals_Ct_EFCC_May_15_2014_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_UK_London%20judge%20adjourns%20Ibori%27s%20case%20to%20June%206%2C%202016%20-%20Vanguard%20News_Apr_14_2015_0.pdf","Sources ":"\nNigeria Economic and Financial Crimes Commission (EFCC), \u0022Money Laundering:\u00a0 Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014, at https:\/\/efccnigeria.org\/efcc\/index.php\/news\/870-money-laundering-ibori-has-case-to-answer-appeal-court;\nToday (Nigeria), \u0022London court suspends James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016, at https:\/\/www.today.ng\/news\/national\/135296\/london-court-suspends-james-ib...\nVanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015;\nUS Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012, accessed at http:\/\/www.justice.gov\/opa\/pr\/2012\/July\/12-crt-906.html;\u00a0\nIn Re: Enforcement of Restraining Order Issued by the High Court of England and Wales, Case No. 1:12-mc-00289 (D.D.C.), Ex Parte application by United States filed on May 16, 2012; US Government Response to Order to Show Cause filed July 16, 2013; Court Docket Report as of September 14, 2015.\n\n\u00a0\n"},{"Case ID":"ARW-80","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hosni Mubarak (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Egypt","Position of Public Official(s) (yrs in office)":"President (1981-2011)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case ","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to written evidence provided by the Chancellor of the Exchequer to the UK Parliament on Januaty 26, 2012, \u0022The sanctions in respect of Egypt impose an asset freeze against 19 individuals identified as responsible for the misappropriation of Egyptian state funds. A list of these individuals is available from the Treasury website http:\/\/www.hm-treasury.gov.uk\/fin_sanctions_egypt.htm and is reproduced here for convenience.\n\t(1) Ahmed, Abla Mohamed Fawzi Ali\n\t(2) Al Naggar, Shahinaz Abdel Aziz Abdel Wahab\n\t(3) El Gammal, Khadiga Mahmoud\n\t(4) El Gazaerly, Naglaa Abdallah\n\t(5) Eladli, Habib Ibrahim Habib\n\t(6) Eldin, Jaylane Shawkat Hosni Galal\n\t(7) Elmaghraby, Ahmed Alaeldin Amin Abdelmaksoud\n\t(8) Ezz, Ahmed Abdelaziz\n\t(9) Fahmy, Hania Mahmoud Abdel Rahman\n\t(10) Garrana, Amir Mohamed Zohir Mohamed Wahed\n\t(11) Garrana, Mohamed Zohir Mohamed Wahed\n\t(12) Hussein, Rachid Mohamed Rachid\n\t(13) Mubarak, Alaa Mohamed Hosni Elsayed\n\t(14) Mubarak, Gamal Mohamed Hosni Elsayed\n\t(15) Mubarak, Mohamed Hosni Elsayed\n\t(16) Rasekh, Heidy Mahmoud Magdy Hussein\n\t(17) Sharshar, Elham Sayed Salem\n\t(18) Thabet, Suzanne Saleh\n\t(19) Yassin, Khadiga Ahmed Ahmed Kamel\n\tFor reasons of confidentiality, the Treasury is unable to disclose the information requested about individuals and their assets frozen in the UK under the Egypt sanctions regime.\u0022\u00a0 (Source: UK Parliament, Commons Debates, Written Answers January 26, 2012, \u0022Treasury \/ Assets: Egypt.\u0022)\u00a0\nAccording to media reports in late May 2012, UK and Egyptian authorities met to discuss GBP85 million in Mubarak-related assets frozen in the UK.\u00a0 (Source: Amer Sultan, \u0022UK, Egypt resume talks on Mubarak assets recovery,\u0022 Ahramonline, May 27, 2012.)","Disposition of Criminal Case(s)":"According to the New York Times and other sources, in May 2014, Mr. Mubarak was convicted on charge of embezzlement and sentenced to three years\u0027 imprisonment. (Source: \u00a0David Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014.)","Jurisdiction of Origin: Investigative Agency":"Prosecutor-General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor-General\u0027s Office","Jurisdiction of Origin: Courts Involved":"Cairo Appeals Court","Jurisdiction of Asset Recovery: Investigative Agency":"UK Treasury","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Asset Recovery: Courts Involved":"NA","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_Embezzlement_Verdict_NYTimes_May_21_2014_2.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_UK_Asset_Freeze_uksi_20110887_en.pdf","Sources ":"\n\tUK Parliament, Commons Debates, Written Answers January 26, 2012, \u0022Treasury \/ Assets: Egypt,\u0022 accessed at http:\/\/www.publications.parliament.uk\/pa\/cm201212\/cmhansrd\/cm120126\/text...\n\n\t\u00a0\n\n\tSanctions: http:\/\/www.hm-treasury.gov.uk\/fin_sanctions_egypt.htm;\n\n\t\u00a0\n\n\tDavid Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014, at http:\/\/www.nytimes.com\/2014\/05\/22\/world\/middleeast\/hosni-mubarak-trial.html\n\n\t\u00a0\n\n\tAmer Sultan, \u0022UK, Egypt resume talks on Mubarak assets recovery,\u0022 Ahramonline, May 27, 2012, accessed at http:\/\/english.ahram.org.eg\/NewsContent\/3\/12\/43036\/Business\/Economy\/UK,-...\n"},{"Case ID":"ARW-71","Case Title (Name of Public Official or Entity Allegedly Involved)":"Haiti Teleco \/ Patrick Joseph","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Haiti","Position of Public Official(s) (yrs in office)":"Director General, Haiti Teleco (inclusive March 2001 through June 2003)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"Close cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"Mr. Joseph, a former Director General of Haiti Teleco, pleaded guilty to one count of conspiracy to commit money laundering, in connection with the Haiti Teleco bribery case.\u00a0 (Source: U.S. v. Joseph, Case No. 1:09-cr-21010-MGC (S.D. Fla.), Superseding Indictment filed July 12, 2011.)\u00a0\u00a0 As part of his sentence, Mr. Joseph was ordered to forfeit $955,596.69, the sum determined to represent the proceeds of his crime.\u00a0 (Source: U.S. v. Joseph, Case No. 1:09-cr-21010-MGC (S.D. Fla.), Order of Forfeiture filed July 6, 2012.)","Disposition of Criminal Case(s)":"According to the Judgement in his case, Mr. Joseph pleaded guilty to one count of conspiracy to commit money laundering and in July 2012, was sentenced to one year and one day of imprisonment. (Source: US v. Joseph, Case No. 1:09-cr-21010 (S.D. Fla.), Judgment in a Criminal Case, July 9, 2012.)","Jurisdiction of Origin: Investigative Agency":"N\/A","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Internal Revenue Service, Criminal Investigations -  Miami Field Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney\u0027s Office for the Southern District of Florida","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of Florida","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Patrick_Joseph_Order_Forfeiture_Jul_6_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Patrick_Joseph_Judgment_Jul_10_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Haiti_Teleco_Joseph_Superseding_Indictment_July_12_2011.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Haiti_Teleco_Joseph_Indictment_DOJ_PR_Jul-13-2011.pdf","Sources ":"U.S. v. Joseph,\u00a0 Case No. 1:09-cr-21010-MGC (S.D. Fla.), Superseding Indictment filed July 12, 2011; Order of Forfeiture filed July 6, 2012; Judgment in a Criminal Case filed July 9, 2012 (all accessed via PACER);\nUS Department of Justice Press Release, \u0022Florida Telecommunications Company, Two Executives, an Intermediary and Two Former Haitian Government Officials Indicted for Their Alleged Participation in Foreign Bribery Scheme,\u0022 July 13, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/July\/11-crm-910.html.\n"},{"Case ID":"ARW-69","Case Title (Name of Public Official or Entity Allegedly Involved)":"Gautam Sengupta","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"","Position of Public Official(s) (yrs in office)":"Task Manager, World Bank","Jurisdiction of Asset Recovery":"United States, World Bank","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2002","Asset Recovery End":"2002","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution and Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Mr. Sengupta\u0027s plea agreement with the US Department of Justice included provision for restitution to the World Bank, pursuant to 18 U.S.C. \u00a7 3663 (a)(3) [\u0022The court may also order restitution in any criminal case to the extent agreed to by the parties in a plea agreement.\u0022].  (Source: US v. Sengupta, Case No. 1:02-cr-00040 (D.D.C.), Plea Agreement filed January 30, 2002.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$127,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the Statement of Facts agreed to by Mr. Sengupta as part of his plea agreement, between 1997 and 1999 while employed as a task manager at the World Bank, Mr. Sengupta entered into agreements relating to projects in Ethiopia and Kenya resulting in consulting contracts for a Swedish consultant. The consultant then kicked back payments to Mr. Sengupta. He also admitted that \u0022sometime in January 1999, [ ] he received a request for money from a foreign government official in the Kenyan PIU for a $50,000 payment. Sengupta agreed with the foreign official that he would relay the request, and he did so with knowledge that the payment was to corruptly influence an act or decision of the foreign official in his official capacity.\u0022\u00a0 (Source: US v. Sengupta, Case No. 1:02-cr-00040 (D.D.C.), Statement of Facts filed January 30, 2002.)\u00a0 According to Mr. Sengupta\u0027s plea agreement, \u0022Pursuant to 18 U.S.C. \u00a7 3663 (a)(3), the defendant and the government agree that the amount of loss in this case is $127,000 and the defendant agrees to pay full restitution of this amount for all damage that resulted from his violations of the statutes listed in Section I herein. The United States and the Defendant agree that the Defendant has made such restitution, and The World Bank, Mr. Sengupta\u0027s former employer, has represented to the Department of Justice that it has no further claim against the defendant.\u0022\u00a0\u00a0 (Source: US v. Sengupta, Case No. 1:02-cr-00040 (D.D.C.), Plea Agreement filed January 30, 2002.)","Disposition of Criminal Case(s)":"According to the Judgment in his case, in 2006,\u00a0 Mr. Sengupta was sentenced to two months\u0027 imprisonment; in 2002, he had pleaded guilty to one count conspiracy to commit crimes against the United States and one count violation of the US Foreign Corrupt Practices Act.\u00a0 (Source: US v. Sengupta, Case No. 1:02-cr-40 (D.D.C.), Judgment filed on February 15, 2006).","Jurisdiction of Origin: Investigative Agency":"N\/A","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Criminal Division","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the District of Columbia","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Sengupta_Judgment_Feb_15_2006.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Sengupta_Plea_Agreement_Jan_30_2002.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Sengupta_Statement_Facts_Jan_30_2002.pdf","Sources ":"US v. Sengupta, Case No. 1:02-cr-00040 (D.D.C.), Plea Agreement and Statement of Facts filed January 30, 2002; Judgment filed February 15, 2006;\nUS Department of Justice Press Release, \u0022Former World Bank Employee Sentenced for Taking Kickbacks and Assisting in the Bribery of a Foreign Official,\u0022 April 25, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/April\/08-crm-341.html.\n"},{"Case ID":"ARW-59","Case Title (Name of Public Official or Entity Allegedly Involved)":"Bayoil Corporation \/ Oscar J. Wyatt, Jr.","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United States","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"Iraq [Development Fund for Iraq], United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort (United States)","Asset Recovery Start":"2005","Asset Recovery End":"2009","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution and Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"The Government Sentencing Memorandum stated the need to pay restitution to the victims, i.e. people of Iraq. (Source: US v. Wyatt, Case No. 1:05-cr-59 (SDNY), Government Sentencing Memorandum filed November 26, 2007.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$11,023,246","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Restitution to people of Iraq via Development Fund of Iraq","Case Summary":"In 2007, Mr. Wyatt, founder of the US energy company Coastal Corporation, entered into a plea agreement with the United States Attorney for the Southern District of New York in relation to his involvement in the UN Oil-for-Food scheme.\u00a0 As part of his plea agreement, Mr. Wyatt agreed to pay $11,023,245.91 in restitution to the victims of his crime.\u00a0 The Government\u0027s Sentencing Memorandum stated that the people of Iraq were among the victims of the scheme and that the restitution paid be transferred the Development Fund for Iraq for use to benefit the Iraqi people. (Source: US v. Wyatt, Case No. 1:05-cr-59 (D.D.C.), Government Sentencing Memorandum filed November 26, 2007.)","Disposition of Criminal Case(s)":"In 2007, Mr. Wyatt pleaded guilty to one count conspiracy to commit wire fraud, and subsequently sentenced to one year\u0027 imprisonment. (Source: United States Attorney for the Southern District of New York, \u0022Texas Oilman Sentenced to One Year in Prison for Conspiring to Make Illegal Payments to the Former Government of Iraq,\u0022 November 27, 2007.)","Jurisdiction of Origin: Investigative Agency":"N\/A","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, Criminal and Counterintelligence Divisions; Department of the Treasury, Office of Foreign Assets Control; Department of State; United Nations Office of Legal Affairs and the former Independent Inquiry Committee into the United Nations Oil-for-Food Program","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney for the Southern District of New York","Jurisdiction of Asset Recovery: Courts Involved":"United States District Court for the Southern District of New York","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Wyatt_SDNY_Second_Superseding_Indictment.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Wyatt_SDNY_Sentencing_Memorandum.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Wyatt_SDNY_Final_Judgment.pdf","Sources ":"US v. Wyatt, Case No. 1:05-cr-59 (SDNY), Government Sentencing Memorandum filed November 26, 2007; Judgment filed November 28, 2007;\n\tUnited States Attorney for the Southern District of New York Press Release, \u0022Texas Oilman Sentenced to One Year in Prison for Conspiring to Make Illegal Payments to the Former Government of Iraq,\u0022 November 27, 2007, accessed at http:\/\/abcnews.go.com\/images\/Blotter\/wyatt_sentencing071127.pdf\n"},{"Case ID":"ARW-58","Case Title (Name of Public Official or Entity Allegedly Involved)":"El Paso Corporation","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United States","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"Iraq [Development Fund for Iraq], United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort (United States)","Asset Recovery Start":"2005","Asset Recovery End":"2007","UNCAC Offenses Implicated":"","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Prosecution and Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"The United States Attorney for the Southern District of New York and El Paso\u0027s Non-Prosecution Agreement included a provision for forfeiture of funds which were then transferred the Development Fund of Iraq \u0022to be used as restitution to the people of Iraq asthe intended beneficiaries of the proceeds of the sale of all Iraqi oil made pursuant to the United Nations Oil-for-Food Program.\u0022 (Source: El Paso Non-Prosecution Agreement dated February 5, 2007.) ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$5,482,363","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Forfeited funds returned to people of Iraq via Development Fund of Iraq","Case Summary":"In 2007, El Paso entered into a Non-Prosecution Agreement with the United States Attorney for the Southern District of New York to resolve criminal charges filed against it in relation to the UN Oil-for-Food scheme.\u00a0 According to the agreement, El Paso agreed to forfeit to the United States $5,482,363, \u0022representing the benefits provided to the former Government of Iraq as a result of El Paso\u0027s conduct [ ] It is the intent of the United States Attorney\u0027s Office for the Southern District of New York to seek the transfer of these funds to the Development Fund of Iraq [ ] to be used as restitution to the people of Iraq as the intended beneficiaries of the proceeds of the sale of all Iraqi oil made pursuant to the United Nations Oil-for-Food Program.\u0022 (Source: El Paso Corporation Non-Prosecution Agreement, February 5, 2007.)","Disposition of Criminal Case(s)":"In 2007, El Paso Corporation entered into a Non-Prosecution Agreement with the United States Attorney for the Southern District of New York to resolve criminal charges filed against it.\u00a0 (Source: El Paso Corporation Non-Prosecution Agreement, February 5, 2007.)","Jurisdiction of Origin: Investigative Agency":"NA","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, Securities and Exchange Commission, Office of Foreign Assets Control  (Department of the Treasury)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney for the Southern District of New York","Jurisdiction of Asset Recovery: Courts Involved":"N\/A","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/El_Paso_SDNY_Non-Prosecution_Agreement_Feb_2007.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/ElPaso_US_SDNY_Prosecution_PR_Feb_7_2007.pdf","Sources ":"El Paso Non-Prosecution Agreement, Feb. 5, 2007; US Attorney for the Southern District of New York, \u0022U.S. Announces Oil-for-Food Settlement with El Paso Corporation,\u0022 Feb. 7, 2007, at http:\/\/lib.law.virginia.edu\/Garrett\/prosecution_agreements\/press_\u200brelease\/ElPaso.pdf\n"},{"Case ID":"ARW-41","Case Title (Name of Public Official or Entity Allegedly Involved)":"Chevron Corporation","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Iraq","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"Iraq [Development Fund for Iraq], United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2007","Asset Recovery End":"2007","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Prosecution and Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"The United States Attorney for the Southern District of New York and Chevron\u0027s Non-Prosecution Agreement included a provision for forfeiture of funds which were then transferred the Development Fund of Iraq \u0022to be used as restitution to the people of Iraq asthe intended beneficiaries of the proceeds of the sale of all Iraqi oil made pursuant to the United Nations Oil-for-Food Program.\u0022 (Source: Chevron Non-Prosecution Agreement dated November 8, 2007.) ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$20,000,000","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Forfeited funds returned to people of Iraq via Development Fund of Iraq","Case Summary":"In 2007, Chevron entered into a Non-Prosecution Agreement with US authorities, in relation to the UN Oil-for-Food scheme.\u00a0 According to the agreement, Chevron admitted that it had \u0022obtained Iraqi oil under the Program from third parties that paid secret, illegal surcharges to the former government of Iraq, in violation of United States wire fraud statutes and administrative regulations that prohibited transactions with the former Government of Iraq. Pursuant to the Agreement, CHEVRON will make the following payments totaling $27,000,000: (1) forfeiture of $20,000,000 to the U.S. Attorney\u0027s Office for the Southern District of New York (\u0022SDNY\u0022), which will seek to transfer that money to the Development Fund of Iraq (established on May 21, 2003, by United Nations Security Council Resolution 1483) to be paid as restitution for the benefit of the people of Iraq; (2) $5,000,000 to the New York County District Attorney\u0027s Office (\u0022DANY\u0022) to be distributed as DANY shall deem appropriate; and (3) $2,000,000 to OFAC in settlement of civil penalties. In a separate agreement, CHEVRON agreed to pay an additional monetary penalty of $3,000,000 to the Securities and Exchange Commission (\u0022SEC\u0022), and to pay disgorgement of $25,000,000, which will be satisfied by their payments to SDNY and DANY. (Source: United States Attorney Southern District of New York Press Release, \u0022Chevron Corporation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007.)","Disposition of Criminal Case(s)":"In 2007, Chevron entered into a Non-Prosecution Agreement with the US Attorney for the Southern District of New York and the New York County District Attorney\u0027s Office.\u00a0 (Source: United States Attorney Southern District of New York, \u0022Chevron Corporation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007.)","Jurisdiction of Origin: Investigative Agency":"NA","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, Securities and Exchange Commission, Office of Foreign Assets Control, New York Police Department","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney for the Southern District of New York, New York County District Attorney\u0027s Office","Jurisdiction of Asset Recovery: Courts Involved":"NA","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chevron_SDNY_Non-Prosecution_Agreement_2007.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chevron_SDNY_Agreement_PR_Mar_7_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chevron_SEC_Complaint_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chevron_SEC_Litigation_Release_Nov_2007.pdf","Sources ":"United States Attorney for Southern District of New York Press Release, \u0022Chevron Corporation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007 ;\n\tChevron Non-Prosecution Agreement dated November 8, 2007.\n"},{"Case ID":"ARW-40","Case Title (Name of Public Official or Entity Allegedly Involved)":"Chen Shui-Bian","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Taiwan, China","Position of Public Official(s) (yrs in office)":"President (2000-2008)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2010","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unspecified","Contributing Factors in Asset Recovery":"Ongoing Cases, but the U.S. Department of Justice stated in its press release that it was working closely with the Taiwan Supreme Prosecutors Office, Special Investigation Division to gather and exchange evidence (Source: U.S. Department of Justice, \u0022Forfeiture Complaint Seeks to Recover Bribery Proceeds Paid to Former Taiwan President and His Family,\u0022 July 14, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/July\/10-crm-812.html).","Status of Asset Recovery ":"","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tIn August 2012, the US Department of Justice and Avallo Ltd., the legal entity that purported to be the legal owner of the Manhattan condominium and Virginia house which were the subjects of civil forfeiture complaints in New York and Virginia, entered into a settlement agreement to resolve the cases. \u00a0Avallo Ltd. agreed to forfeit its interest in the two properties in exchange for $225,000 and $67,321 from the net proceeds from the sale of the Manhattan and Virginia properties, respectively to Avallo. \u00a0(Sources: \u00a0U.S. v. Real Property Known as Unit 5B Of The Onyx Chelsea Condominium Located at 261 West 28th Street, New York, New York 10001-5933, Case No. 1:10-cv-05390-GBD (S.D.N.Y.), Stipulation and Order of Settlement and Discontinuance filed August 30, 2012; U.S. v. Real Property Known as 2291 Ferndown Lane, Keswick, Virginia 22947-9195, Stipulation and Order of Settlement and Discontinuance filed August 30, 2012.) On July 14, 2010, civil asset forfeiture complaints were filed by U.S. Department of Justice in federal courts in the Southern District of New York and the Western District of Virginia against a Manhattan condominium and a Keswick, Virginia home. \u00a0The U.S. government alleged that the properties were purchased with proceeds of crime for which Mr. Chen and family had been convicted in Taiwan. \u00a0In New York, a post-complaint protective order was filed against the property in August 2010. \u00a0The properties were valued at $2 million total. \u00a0The complaints also noted the ongoing criminal prosecution of Florida attorney Stefan Seuss and that he had told investigators that he established the offshore structure allegedly used to conceal the corrupt proceeds. (Sources: U.S. v. Real Property Known as Unit 5B Of The Onyx Chelsea Condominium Located at 261 West 28th Street, New York, New York 10001-5933, Case No. 1:10-cv-05390-GBD (S.D.N.Y.), Complaint filed July 14, 2010; U.S. v. Real Property Known as 2291 Ferndown Lane, Keswick, Virginia 22947-9195, Case No. 3:10-cv-00037-nkm, (W.D. Va.), Complaint filed July 14, 2010. and U.S. v. Seuss, Case No. 09-cr-683 (E.D. Pa.). \u00a0On September 19, 2011, the US filed a First Amended Verified Complaint in the New York suit against the Manhattan condominium which the US alleged \u0022defendant property is owned by a New York limited liability company, West 28th Street LLC. West 28th Street LLC is owned by a British Virgin Island company, Avallo Ltd. HUANG, Jui-Ching, is the beneficial owner and director of Avallo Ltd. HUANG, Jui-Ching, is the daughter-in-law of the former president of Taiwan, CHEN, Shui-Bian and the spouse of CHEN, Chi-Chung, CHEN, Shui-Bian\u2019s son. Avallo Ltd. is held in trust by the\u00a0Knight Square Irrevocable Trust, an Island of Nevis trust, with\u00a0a British Virgin Islands Company, Global Fiduciaries Limited, as\u00a0trustee. HUANG, Jui-Ching is beneficiary of the Knight Square\u00a0Irrevocable Trust.\u0022 (Source: US v. Real Property Known as Unit 5B Of The Onyx Chelsea Condominium Located at 261 West 28th Street, New York, New York 10001-5933, Case No. 1:10-cv-05390-GBD (S.D.N.Y.), First Amended Verified Complaint filed September 19, 2011.) \u00a0According to a June 12, 2012 Court Scheduling Order, the trial date had not yet been determined but was to take place prior to March 15, 2013. \u00a0(Source: \u00a0US v. Real Property Known as Unit 5B Of The Onyx Chelsea Condominium Located at 261 West 28th Street, New York, New York 10001-5933, Case No. 1:10-cv-05390-GBD (S.D.N.Y.), Scheduling Order filed June 12, 2012.) \u00a0In the Virginia case, the US Government filed an amended complaint on July 12, 2011 and as of November 4, 2011, a Bench Trial is scheduled for October 29, 2012-November 2, 2012. \u00a0(Sources: U.S. v. Real Property Known as 2291 Ferndown Lane, Keswick, Virginia 22947-9195, Case No. 3:10-cv-00037-nkm, (W.D. Va.), First Amended Complaint for Forfeiture filed July 12, 2011; Second Amended Pretrial Order filed October 6, 2011.) \u00a0According to Taiwan News, the US and Taiwanese authorities were reported to be discussing the auctioning of the two properties. (Source: (Source: Taiwan News, \u0022SID seeking recovery of Chen Shui-bian\u2019s Swiss deposits,\u0022 October 6, 2013.)","Disposition of Criminal Case(s)":"According to a July 14, 2010 U.S. Department of Justice press release, \u0022The former president and his wife were convicted in Taiwan on Sept. 11, 2009, for bribery, embezzlement and money laundering. They are currently sentenced to 20 years in prison. Their convictions were upheld on appeal and are now pending before the Supreme Court in Taiwan. Wu Sue-Jen previously pleaded guilty to other money laundering and forgery charges and was also convicted of perjury. The former president and his wife are also currently under indictment in Taiwan for additional alleged acts of graft and money laundering.\u0022\u00a0 (Source: U.S. Department of Justice Press Release, \u0022Forfeiture Complaint Seeks to Recover Bribery Proceeds Paid to Former Taiwan President and His Family,\u0022 July 14, 2010.)\u00a0 According to a December 7, 2010 press release by the Federal Authorities of the Swiss Confederation, since January 7, 2008, the Swiss Attorney General had been conducting criminal proceedings against Chen Shui-Bian\u0027s son and daughter-in-law on suspicion of money laundering. (Source:\u00a0 The Federal Authorities of the Swiss Confederation Press Release, \u0022CHF 20 million returned to Taiwan,\u0022 December 7, 2010.)\u00a0\u00a0","Jurisdiction of Origin: Investigative Agency":"Taiwan Supreme Prosecutors Office, Special Investigation Panel","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Taiwan Supreme Prosecutors Office, Special Investigation Panel","Jurisdiction of Origin: Courts Involved":"Taipei District Court; Supreme Court","Jurisdiction of Asset Recovery: Investigative Agency":"Immigration and Customs Enforcement, Homeland Security Investigations Miami Field Office\u0027s Foreign Corruption Investigations Group and the Asset Identification and Removal Group; Immigration and Customs Enforcement Attache in the Hong Kong.","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York; U.S. District Court for the Western District of Virginia","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_SDNY_Settlement_Aug_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_WVA_Settlement_Aug_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_SDNY_First_Amended_Complaint_Sep_19_2011.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_Taiwan_Court_Decision.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_Switzerland_Recover_Funds_Taiwan_News_Oct_6_2013_0.pdf","Sources ":"\u00a0U.S. v. Real Property Known as Unit 5B Of The Onyx Chelsea Condominium Located at 261 West 28th Street, New York, New York 10001-5933, Case No. 1:10-cv-05390-GBD (S.D.N.Y.), Complaint filed July 14, 2010; Stipulation and Order of Settlement and Discontinuance filed August 30, 2012;\u00a0U.S. v. Real Property Known as 2291 Ferndown Lane, Keswick, Virginia 22947-9195,Complaint filed July 14, 2012; Stipulation and Order of Settlement and Discontinuance filed August 30, 2012;\u00a0U.S. Department of Justice Press Release, \u0022Forfeiture Complaint Seeks to Recover Bribery Proceeds Paid to Former Taiwan President and His Family,\u0022 July 14, 2010;\u00a0The Federal Authorities of the Swiss Confederation Press Release, \u0022CHF 20 million returned to Taiwan,\u0022 December 7, 2010;\u00a0aiwan News, \u0022SID seeking recovery of Chen Shui-bian\u2019s Swiss deposits,\u0022 October 6, 2013, at http:\/\/www.taiwannews.com.tw\/etn\/print.php\n"},{"Case ID":"ARW-39","Case Title (Name of Public Official or Entity Allegedly Involved)":"Chen Shui-Bian (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Taiwan, China","Position of Public Official(s) (yrs in office)":"President (2000-2008)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2007","Asset Recovery End":"2015","UNCAC Offenses Implicated":"Art.15, Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"MLAT","Contributing Factors in Asset Recovery":"\u0022Thanks to close and effective collaboration between the Taiwanese Supreme Prosecutors Office and the OAG [Office of the Attorney General], part of the funds deposited in Switzerland that are presumed to have originated from the criminal activities of former Taiwanese President has been returned to the Taiwanese authorities as an anticipated handover.  No objection was raised by any of the parties to the proceedings to the return of the sum of around CHF 20 million.\u0022 (Source: The Federal Authorities of the Swiss Confederation Press Release, \u0022CHF 29 million returned to Taiwan,\u0022 December 7, 2010.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$25,649,500","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tAccording to the September 4, 2015 news release by the Supreme Prosecutors Office of Taiwan China, the Swiss authorities returned US$6,429,018 in corruption proceeds. (Source: \u00a0Press release of the Supreme Prosecutors Office, issued September 4, 2015, at http:\/\/www.tps.moj.gov.tw\/public\/Data\/51013112053580.pdf) \u00a0In April the prosecutors\u0027 office had issued a statement noting that \u0022The Federal Supreme Court of Switzerland has ruled the decision to return the illegal proceeds to Taiwan at the amount of US$6,746,840 [ ] acquired by the former ROC President Mr. Chen Shui-bian as bribes from the merging case of Yuanta with Fuhua during the Second Financial Reform Case and remitted to Switzerland. \u00a0[ \u00a0] With the assistance of the Swiss judicial authorities, the bank accounts held by Chen Chih-chung and Huang Jui-ching at Bounchon of Merrill Lynch Bank (Suisse) SA and Galahad Management of RBS Coutts Bank AG, and the accounts of Avallo Ltd. and Bravo International Holdings, two companies controlled by Chen Chih-chung and Huang Jui-ching at Wegelin and Co. and Private Bankers, were frozen accordingly. [ \u00a0] \u00a0Among the said accounts, the two accounts of Bouchon and Galahad held the illegal proceeds acquired from the Lungtan Corruption Case, the Nangang Corruption Case, the State Affairs Confidential Funds Case, and their relevant money laundering cases, totaled as approximately US$22,614,850. [ \u00a0] \u00a0On April 1, 2014, Federal Prosecutors Office of Swiss granted its order to remit the assets under Avallo and Bravo accounts at the amount of US$6,746,840 (approximately equivalent to NT$200 million) to the designated account of the SID. But Chen Chih-chung et al. appealed to Swiss Federal Criminal Court, which in January 2015 ruled out the objection appeal. Chen Chih-chung et al, then appealed to the Supreme Court of Switzerland. On April 28, 2015, the SID received the notification from Federal Prosecutors Office stating that the Supreme Court of Switzerland has dismissed the appeal of Chen and the assets of US$6,746,840 will be remitted to the designated account of the SID accordingly. The remaining assets under Avallo and Bravo accounts should be continuously frozen awaiting the further requests from Taiwan.\u0022 (Source: \u00a0News release of the Supreme Prosecutors Office, April 29, 2015 on the Chen Shui Bian case).\u00a0\n\n\t\u00a0\n\n\tAccording to a December 7, 2010 press release by the Federal Authorities of the Swiss Confederation, \u0022The Attorney General of Switzerland has returned some CHF 20 million [$18,899,500 of the $34,964,000 total frozen] to the Supreme Prosecutors Office of Taiwan, part of the money that was deposited in Switzerland by the former Taiwanese President, Chen Shui-bian, who was recently convicted of corruption in his homeland.\u0022 \u00a0The same press release noted that as part of the Swiss criminal proceedings against Chen\u0027s son and daughter-in-law and in response to a request for mutual assistance filed by Taiwan, some CHF 37 million had been seized. \u00a0Swiss investigation on the origin of the remainder of the assets is continuing. \u00a0(Source: \u00a0The Federal Authorities of the Swiss Confederation Press Release, \u0022CHF 20 million returned to Taiwan,\u0022 December 7, 2010.)\u00a0","Disposition of Criminal Case(s)":"According to an April 2015 statement by Taiwan, China\u0027s Supreme Prosecutor\u0027s Office, \u0022In the final judgment [by the Supreme Court], Chen Shui-Bian was sentenced to the imprisonment of ten years, in addition thereto, being fined 100 million New Taiwan dollars. Wu Shu-Jen was sentenced to the imprisonment of eight years, in addition thereto, being fined 80 million New Taiwan dollars. For the proceeds of crime, Chen Shui-Bian and Wu Shu-Jen have the joint liability of restitution and confiscation for 200 million New Taiwan dollars.\u0022 \u00a0(Source: \u00a0News release of the Supreme Prosecutors Office, April 29, 2015 on the Chen Shui Bian case)\n\t\u00a0\n\tAccording to a December 7, 2010 press release by the Federal Authorities of the Swiss Confederation, since January 7, 2008, the Swiss Attorney General had been conducting criminal proceedings against Chen Shui-bian\u0027s son and daughter-in-law on suspicion of money laundering. (Source: \u00a0The Federal Authorities of the Swiss Confederation Press Release, \u0022CHF 20 million returned to Taiwan,\u0022 December 7, 2010.) \u00a0\u00a0","Jurisdiction of Origin: Investigative Agency":"Taiwan Supreme Prosecutors Office, Special Investigation Panel","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Taiwan Supreme Prosecutors Office, Special Investigation Panel","Jurisdiction of Origin: Courts Involved":"Taipei District Court, Supreme Court","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Office of the Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_Switzerland_CHF20M_Returned_PR_Dec_7_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_Switzerland_Return_Taipei_Times_June_3_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_US_Justice_Dept_PR_Jul_14_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_Switzerland_Recover_Funds_Taiwan_News_Oct_6_2013.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_Shui%20Bian_Taiwan%20China_Supreme%20Prosecutors%20Office_PR_Swiss%20Assets_Apr29%202015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_Shui_Bian_Swiss%20Asset%20Return_Taipei%20Times_Sept6%202015.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Chen_Taiwan%20China_Swiss%20Return_PR_Sep%204%202015.pdf","Sources ":"\n\tNews releases of the Supreme Prosecutors Office, September 4, 2015 at http:\/\/www.tps.moj.gov.tw\/public\/Data\/51013112053580.pdf; and April 29, 2015 on Shui Bian case, at http:\/\/www.tps.moj.gov.tw\/public\/Data\/552612157236.pdf\n\n\t\u00a0\n\n\tTaipei Times, \u00a0\u0022Chen Shui-bian\u2019s Swiss illicit gains returned to Taiwan,\u0022 September 6, 2015, at http:\/\/www.taipeitimes.com\/News\/taiwan\/archives\/2015\/09\/06\/2003627068;\n\n\t\u00a0\n\n\tThe Federal Authorities of the Swiss Confederation Press Release, \u0022CHF 29 million returned to Taiwan,\u0022 December 7, 2010 (please note that the press release was obtained from www.news.admin.ch on December 15, 2010; the release notes that the information was \u0022corrected or amended after publication.\u0022), accessed at \u00a0http:\/\/www.news.admin.ch\/message\/?lang=en\u0026msg-id=36627); \u00a0U.S. Department of Justice press release, \u0022Forfeiture Complaint Seeks to Recover Bribery Proceeds Paid to Former Taiwan President and His Family,\u0022 July 14, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/July\/10-crm-812.html; See also Rich Chang, \u0022Swiss banks begin remitting money from Chen accounts,\u0022 Taipei Times, May 23, 2010; Staff Writers, \u0022Swiss bank remits more of Chen Family\u0027s money,\u0022 Taipei Times, June 3, 2010. \u00a0Taipei trial court decision (in Chinese) in the first Chen Shui Bian trial; Government Information Office, Republic of China (Taiwan) \u0022History\u0022 chapter under \u0022About Taiwan,\u0022 accessed at http:\/\/www.gio.gov.tw\/ct.asp?xItem=18690\u0026CtNode=2579\u0026mp=807; Taiwan News, \u0022SID seeking recovery of Chen Shui-bian\u2019s Swiss deposits,\u0022 October 6, 2013, at http:\/\/www.taiwannews.com.tw\/etn\/print.php\n"},{"Case ID":"ARW-26","Case Title (Name of Public Official or Entity Allegedly Involved)":"James Ibori \/ Bhadresh Gohil (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Gohil: Solicitor to James Ibori, Delta State Governor (1999-2007)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2012","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20, Art.25","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Enforcement of Foreign Restraint Order","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Instrument as Contemplated by Article 3(2) of the Agreement on Mutual Legal Assistance Between the United States of America and the European Union Signed 25 June 2003, as to the Application of the Treaty Between the United States of America and the Government of the United Kingdom of Great Britain and Northern Ireland on Mutual Legal Assistance in Criminal Matters Signed 6 January 1994, U.S.-U.K., Dec. 16, 2004, S. Treaty Doc. 109-13 (2006); Treaty with the United Kingdom on Mutual Legal Assistance on Criminal Matters, U.S.-U.K., Jan. 6, 1994","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\n\t\tSee related entry \u0022James Ibori - United Kingdom\u0022\n\n\t\t\u00a0\n\n\t\tAccording to the factual basis for the US ex parte application to enforce the UK restraint order, \u0022Governor Ibori and his associates misappropriated millions of dollars in Delta State funds and laundered those proceeds through a myriad of shell companies, intermediaries, and nominees in the United Kingdom. Governor Ibori, with the active assistance and participation of Gohil, fraudulently diverted and misappropriated millions of dollars in Delta State funds to various businesses he controlled through his relatives and associates.\u0022 (Source: UNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., 16 May 2012.). \u00a0The US federal court granted the restaint order. \u00a0(Source: US Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012.)\n\n\t\t\u00a0\n\n\t\tIn July 2013, the US Government filed a response to the Court Order to Show Cause, urging the court not to terminate the action and to retain jurisdiction over the matter until confiscation proceedings in the UK conclude. \u00a0As of June 2016, the US case was ongoing. \u00a0(Source: \u00a0In Re: Enforcement of Restraining Order Issued by the High Court of England and Wales, Case No. 1:12-mc-00289 (D.D.C.), US Government Reponse to Order to Show Cause filed July 16, 2013; Court Docket Report as of June 17, 2016.) \u00a0According to news reports, the UK confiscation hearing that was rescheduled for June 2016 was again postponed. \u00a0(Source: Vanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015.)\n\n\u00a0","Disposition of Criminal Case(s)":"According to a May 2014 statement by Nigeria\u0027s Economic and Financial Crimes Commission, a lower court decision to strike out \u0022all 170-count charge of money laundering preferred against former governor of Delta State, James Onanefe Ibori by the Economic and Financial Crimes Commission, EFCC, a three-man panel of justices at the Benin Division of the Court of Appeal today, May 15, 2014 ruled that the ex- governor who is currently serving a 13-year jail term in a London prison, has a case to answer.\u0022 \u00a0(Source: EFCC, \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014.) \u00a0 According to the United States\u0027 Ex Parte Application to Enforce and Register Foreign Restraining Orders, Mr. Gohil was convicted in the UK \u0022in November 2010 of money laundering and prejudicing a money laundering investigation, and in December 2010, pleaded guilty to an additional eight offenses related to the V Mobile fraud. Gohil was sentenced to ten years imprisonment.\u0022 \u00a0(Source: UNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012.)","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission (Nigeria)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service (UK)","Jurisdiction of Origin: Courts Involved":"Southwark Crown Court (UK)","Jurisdiction of Asset Recovery: Investigative Agency":"Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Columbia","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Gohil_UK_Restraint_Order_Nov_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Ex_Parte_Restrain_Order_DDC_May_2012_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Restrain_3_Million_Dept_Justice_Press_Release_Jul_23_2012_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_DDC_US_Response_Show_Cause_Order_Jul_16_2013_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_Nigeria_Appeals_Ct_EFCC_May_15_2014_4.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_UK_London%20judge%20adjourns%20Ibori%27s%20case%20to%20June%206%2C%202016%20-%20Vanguard%20News_Apr_14_2015_4.pdf","Sources ":"\n\tNigeria Economic and Financial Crimes Commission (EFCC), \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014, at https:\/\/efccnigeria.org\/efcc\/index.php\/news\/870-money-laundering-ibori-h...\n\n\t\u00a0\n\n\tToday (Nigeria), \u0022London court suspends James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016;\n\n\t\u00a0\n\n\tVanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015;\n\n\t\u00a0\n\n\tUNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012), Exhibit B, UK High Court Order of Restraint against Mr. Gohil, November 17, 2008.);\u00a0\n\n\t\u00a0\n\n\tUS Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012, accessed at \u00a0http:\/\/www.justice.gov\/opa\/pr\/2012\/July\/12-crt-906.html\n"},{"Case ID":"ARW-25","Case Title (Name of Public Official or Entity Allegedly Involved)":"James Ibori \/ Bhadresh Gohil (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Gohil: Solicitor to James Ibori, Delta State Governor (1999-2007)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20, Art.25","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"See related entry \u0022James Ibori - United Kingdom\u0022\n\t\u00a0\n\tAccording to the factual basis for the US ex parte application to enforce the UK restraint order, \u0022Governor Ibori and his associates misappropriated millions of dollars in Delta State funds and laundered those proceeds through a myriad of shell companies, intermediaries, and nominees in the United Kingdom. Governor Ibori, with the active assistance and participation of Gohil, fraudulently diverted and misappropriated millions of dollars in Delta State funds to various businesses he controlled through his relatives and associates.\u0022 \u00a0As of June 2016, the case was ongoing. (Source: UNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C.), filed May 16, 2012; court docket report as of June 17, 2016.)\n\t\u00a0\n\tAccording to news reports, the UK confiscation hearing that was rescheduled for June 2016 was again postponed. \u00a0(Sources: Today (Nigeria), \u0022London court postpones James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016; Vanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015.)","Disposition of Criminal Case(s)":"According to a May 2014 statement by Nigeria\u0027s Economic and Financial Crimes Commission, a lower court decision to strike out \u0022all 170-count charge of money laundering preferred against former governor of Delta State, James Onanefe Ibori by the Economic and Financial Crimes Commission, EFCC, a three-man panel of justices at the Benin Division of the Court of Appeal today, May 15, 2014 ruled that the ex- governor who is currently serving a 13-year jail term in a London prison, has a case to answer.\u0022 \u00a0(Source: EFCC, \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014.) \u00a0 According to the United States\u0027 Ex Parte Application to Enforce and Register Foreign Restraining Orders, Mr. Gohil was convicted in the UK \u0022in November 2010 of money laundering and prejudicing a money laundering investigation, and in December 2010, pleaded guilty to an additional eight offenses related to the V Mobile fraud. Gohil was sentenced to ten years imprisonment.\u0022 \u00a0(Source: UNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012.)","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified ","Jurisdiction of Asset Recovery: Investigative Agency":"Serious Fraud Office, City of London Police Overseas Anti-Corruption Unit","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service","Jurisdiction of Asset Recovery: Courts Involved":"Serious Fraud Office, City of London Police Overseas Anti-Corruption Unit","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Ex_Parte_Restrain_Order_DDC_May_2012_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_US_Restrain_3_Million_Dept_Justice_Press_Release_Jul_23_2012_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_Nigeria_Appeals_Ct_EFCC_May_15_2014_3.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ibori_UK_London%20judge%20adjourns%20Ibori%27s%20case%20to%20June%206%2C%202016%20-%20Vanguard%20News_Apr_14_2015_3.pdf","Sources ":"\n\tNigeria Economic and Financial Crimes Commission (EFCC), \u0022Money Laundering: \u00a0Ibori Has Case to Answer - Appeals Court,\u0022 May 15, 2014, at https:\/\/efccnigeria.org\/efcc\/index.php\/news\/870-money-laundering-ibori-h...\n\n\t\u00a0\n\n\tToday (Nigeria), \u0022London court suspends James Ibori\u0027s confiscation hearing,\u0022 June 10, 2016;\n\n\t\u00a0\n\n\tVanguard, \u0022London judge adjourns Ibori\u2019s case to June 6, 2016,\u0022 April 14, 2015;\n\n\t\u00a0\n\n\tUNITED STATES\u2019 EX PARTE APPLICATION TO ENFORCE AND REGISTER FOREIGN RESTRAINING ORDERS PURSUANT TO 28 U.S.C. \u00a7 2467(d)(3) AND STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT THEREOF. IN RE ENFORCEMENT OF RESTRAINING ORDERS ISSUED BY THE HIGH COURT OF ENGLAND AND WALES, QUEEN\u2019S BENCH DIVISION, UNITED KINGDOM, AND THE CROWN COURT OF ENGLAND WALES, UNITED KINGDOM, Case No. 12-mc-289. (D.D.C., May 16, 2012), Exhibit B, UK High Court Order of Restraint against Mr. Gohil, November 17, 2008.);\u00a0\n\n\t\u00a0\n\n\tUS Department of Justice Press Release, \u0022U.S. Restrains More Than $3 Million in Corruption Proceeds Related to Former Governor of Nigeria,\u0022 July 23, 2012, accessed at \u00a0http:\/\/www.justice.gov\/opa\/pr\/2012\/July\/12-crt-906.html\n"},{"Case ID":"ARW-10","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alstom S.A. (Swiss Settlement)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"France","Position of Public Official(s) (yrs in office)":"Various - Latvia, Malaysia and Tunisia","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort; Location of Recovery Effort","Asset Recovery Start":"2011","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Article 53 Swiss Criminal Code payment of reparations","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Funds were transferred to the International Committee of the Red Cross for use in ICRC projects in Tunisia, Latvia and Malaysia. (Source: The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Case Summary":"According to the November 2011 Summary punishment order imposed by the Swiss authorities, Alstom Network Schweiz AG (Swiss subsidiary of the French company Alstom S.A.) was convicted of not having taken all necessary and reasonable organizational precautions to precent bribery of foreign public officials in Latvia, Tunisia and Malaysia.\u00a0\u00a0 Alstom Schweiz was fined CHF 2.5 million; a compensatory claim of CHF 36.4 million was also imposed. The parent company Alstom S.A. paid the CHF 1 million in reparation, a third of which was to be used for International Committee of the Red Cross projects in Latvia, Malaysia and Tunisia. (Sources:\u00a0 Office of the Swiss Attorney General, Summary punishment order in the invesitgation of defendant Alstom Network Schweiz AG, November 22, 2011 and The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Disposition of Criminal Case(s)":"According to the November 2011 press release by The Federal Authorities of the Swiss Confederation, Alstom Network Schweiz AG was convicted under article 102 of the Swiss Criminal Code of not having taken \u0022all necessary and reasonable organizational precautions to prevent bribery of foreign public officials\u0022; proceedings against the French parent company Alstom S.A. were dismissed based on art. 53 of the Swiss Criminal Code, imposing costs of proceedings and payment of reparations.\u00a0 (Source: The Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)","Jurisdiction of Origin: Investigative Agency":"N\/A","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Office of the Swiss Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"N\/A","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alstom_SA_Swiss_Attorney_General_Summary_Punishment_Order_PR_Nov_22_2011.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alstom_Summary_Punishment_Order_Nov_22_2011.pdf","Sources ":"Office of the Swiss Attorney General, Summary punishment order in the invesitgation of defendant Alstom Network Schweiz AG, November 22, 2011, accessed at http:\/\/www.scribd.com\/doc\/73503009\/Summary-Punishment-Order;\n\tThe Federal Authorities of the Swiss Confederation, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011, accessed at http:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=42300.\n"},{"Case ID":"ARW-181","Case Title (Name of Public Official or Entity Allegedly Involved)":"Taiwan Frigates Case \/ Thales Payment","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Taiwan, China","Position of Public Official(s) (yrs in office)":"Navy Captain (Kuo Li-heng)","Jurisdiction of Asset Recovery":"France","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2001","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Other (Commercial Arbitration)","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"N\/A; international commercial arbitration","Contributing Factors in Asset Recovery":"International arbitration decision upheld by Paris Court of Appeals (Sources: The Thales Group, Half-yearly financial report 2011 (June 2011), \u0022Taiwan Arbitration\u0022, accessed at www.thalesgroup.com; Sebastian Moffett and Adam Mitchell, \u0022Thales Loses Appeal in Case with Taiwan,\u0022 Wall Street Journal, June 9, 2011.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$909,913,000","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the Thales company\u0027s Half-yearly financial report 2011 (June 2011), \u0022Thales has been notified of the decision of the Paris Court of Appeal on 9 June 2011, rejecting the petition filed by the company to set aside the award handed down on 3 May 2010 in the arbitration against Taiwan, in relation to the procurement of six Lafayette-class frigates. The decision of the Court of Appeal is enforceable and led Thales to disburse on 11 July 2011 an amount of \u20ac166 million, i.e. 27.46% of the total, corresponding to its industrial stake in the supply contract. This payment is neutral on the company\u0027s financial results, as this litigation had already been fully provisioned in previous years.\u0022 \u00a0(Source: The Thales Group, Half-yearly financial report 2011 (June 2011), Taiwan Arbitration at 13.) \u00a0\u0022Thales has also been informed by DCNI that the Republic of China Navy (Taiwan) initiated arbitration proceedings against DCNI during the second half of 2010 with respect to a contract related to the contract mentioned above. This arbitration is related to an alleged breach of the terms pertaining to the use of intermediaries contained in the contract. In its 2010 financial statements, Thales has booked a provision of \u20ac 15 million, which corresponds to the company\u2019s industrial share in the related contract.\u0022 (Ibid., at 40.) \u00a0According to a press release from the French Prime Minister\u0027s Office, date June 9, 2011, the French Government agreed to pay the remaining EUR 460 million ordered. (Source: \u0022Communiqu\u00e9 des services du Premier ministre, en date du 9 juin 2011, sur le rejet de l\u0027appel form\u00e9 par la soci\u00e9t\u00e9 Thal\u00e8s contre la sentence de la Cour d\u0027arbitrage de la Chambre de commerce internationale (ICC) \u00e0 la suite du litige concernant la vente de fr\u00e9gates \u00e0 Ta\u00efwan en 1991\u0022, accessed at \u00a0 http:\/\/discours.vie-publique.fr\/notices\/112001441.html , June 9, 2011).\n\t\u00a0","Disposition of Criminal Case(s)":"According to a November 2010 Taipei Times article, Taiwan prosecutors announced that they would not appeal the earlier acquittals against five co-defendants in the Taiwan frigates case but would appeal the acquittal of Mr. Kuo Li-heng, a Navy captain accused of taking bribes.\u00a0 (Source:\u00a0 Taipei Times, \u0022Prosecutors won\u0027t appeal acquittals in frigate case,\u0022 November 11, 2010, accessed at http:\/\/www.taipeitimes.com\/News\/taiwan\/archives\/2010\/11\/11\/2003488256.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Court of Appeals","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taiwan_Frigates_Thales_Press_Release_Arbirtration_Decision_May_3_2010_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taiwan_Frigates_Thales_Arbitration%20_%20Thales%20Group_Jun_9_2011.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taiwan_Frigates_Thales_Govt_France_PR_Jun_15_2011.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taiwan_Frigates_Thales_Payment_Le_Monde_Jun_9_2011.pdf","Sources ":"\n\tThe Thales Group, Half-yearly financial report 2011 (June 2011), \u0022Taiwan Arbitration\u0022, accessed at www.thalesgroup.com; Sebastian Moffett and Adam Mitchell, \u0022Thales Loses Appeal in Case with Taiwan,\u0022 Wall Street Journal, June 9, 2011, accessed at http:\/\/online.wsj.com\/article\/SB1000142405270230425930457637563119431410... Thales Group statement, \u0022Thales: Repubilc of China (Taiwan) Arbitration,\u0022 June 9, 2011 at https:\/\/www.thalesgroup.com\/en\/content\/thales-republic-china-taiwan-arbi... \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0French Prime Minister\u0027s Office, Press release, \u0022Communiqu\u00e9 des services du Premier ministre, en date du 9 juin 2011, sur le rejet de l\u0027appel form\u00e9 par la soci\u00e9t\u00e9 Thal\u00e8s contre la sentence de la Cour d\u0027arbitrage de la Chambre de commerce internationale (ICC) \u00e0 la suite du litige concernant la vente de fr\u00e9gates \u00e0 Ta\u00efwan en 1991\u0022, accessed at \u00a0 http:\/\/discours.vie-publique.fr\/notices\/112001441.html , (June 9, 2011) \u00a0 \u00a0Le Monde, Press article, \u0022Fr\u00e9gates de Ta\u00efwan : Thales et l\u0027Etat condamn\u00e9s \u00e0 rembourser 630 millions d\u0027euros\u0022, \u00a0accessed at: http:\/\/www.lemonde.fr\/economie\/article\/2011\/06\/09\/fregates-de-taiwan-tha... (June, 9, 2011)\u00a0\n\n\t\u00a0\n\n\t\u00a0\n"},{"Case ID":"ARW-180","Case Title (Name of Public Official or Entity Allegedly Involved)":"Taiwan Frigates Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Taiwan, China","Position of Public Official(s) (yrs in office)":"Navy Captain (Kuo Li-heng)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2001","Asset Recovery End":"2007, In part","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction; Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Federal International Mutual Legal Assistance Act","Contributing Factors in Asset Recovery":"2007 Asset Return:  Express consent of two account-holders concerned and Taiwan\u0027s guarantee that they would abide by the Swiss Federal Examining Magistrate\u0027s conditition that the \u0022legal proceedings against the two persons would comply with human rights principles.\u0022 (Source: Federal Office of Justice Press Release, \u0022USD 34 million handed over to Taiwan,\u0022 June 13, 2007.)","Status of Asset Recovery ":"Completed (in part) and Ongoing (in part)","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction (in part)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the Swiss Ministry of Foreign Affairs, as of September 30, 2009, $34 million was returned to Taiwan (in 2007) and $800 million remain frozen.\u00a0 According to the December 8, 2003 press release by the Swiss Federal Office of Justice, Switzerland provided legal assistance to Taiwan, France and Liechtenstein which had been requested in connection with legal proceedings related to the $2.5 billion sale of six frigates to Taiwan in 1991 by the then French company Thomson.\u00a0 According to the press release, \u0022Although a clause in the contract expressly forbids the payment of commission, the Taiwanese authorities concluded from the inflated price that the deal constituted a serious case of international corruption. On 6 November 2001 they submitted a request for legal assistance from Switzerland in connection with criminal proceedings on the grounds of fraud, money laundering and corruption.\u0022 The press release stated that the French authorities requested assistance \u0022in connection with criminal proceedings on the grounds of disloyal business management and handling stolen goods\u0022 and Liechtenstein request was in connection with \u0022criminal proceedings on the grounds of money laundering and participation in a criminal organization.\u0022 (Source: Federal Office of Justice Press Release, \u0022Frigate sale to Taiwan: Switzerland provides legal assistance,\u0022 December 12, 2003.)\u00a0\u00a0 The Swiss Federal Office of Justice announced, on\u00a0 June 13, 2007, that with the \u0022express consent of the two account-holders concerned, the competent Federal Examining Magistrate ordered the return of USD 34 million to Taiwan.\u0022\u00a0 According to the press release, on September 5, 2006, the Taiwanese authorities lodged an application for the handover of assets that had been frozen in Switzerland as part of criminal and international legal assistance proceedings.\u00a0 The Taiwanese application was not based on any court recovery order, but the press release noted that \u0022in exceptional cases - such as where the frozen assets are clearly of criminal origin - the Federal International Mutual Legal Assistance Act permits assets to be returned without a recovery order issued by the applicant state.\u0022\u00a0 The Taiwanese authorities had stated in their application that based on their review of the bank records provided to them by the Swiss authorities, the funds frozen can be proven to orginate from the frigate affair.\u00a0 (Source: Federal Office of Justice Press Release, \u0022USD 34 million handed over to Taiwan,\u0022 June 13, 2007.)\u00a0 On May 3, 2010, the French company Thales S.A. (formerly Thomson-CSF) announced that it had been notified of the award handed down that day in the arbitration case against Taiwan (The Navy of the Republic of China (Taiwan) v. Thales S.A. (formerly Thomson-CSF) (France).\u00a0 According to the company\u0027s release, the total amount of the award was around 630 million euros (plus interest).\u00a0 The company\u0027s share of the litigation was 27.463% of the total award, corresponding to its industrial share in the supply contract.\u00a0 Please see entry on \u0022Taiwan Frigates Case\u0022 Jurisdiction of Recovery Effort - France for an update. (Source:\u00a0 Thales, \u0022Thales: Results of the arbitration with the Republic of China (Taiwan), May 3, 2010.)","Disposition of Criminal Case(s)":"According to a November 2010 Taipei Times article, Taiwan prosecutors announced that they would not appeal the earlier acquittals against five co-defendants in the Taiwan frigates case but would appeal the acquittal of Mr. Kuo Li-heng, a Navy captain accused of taking bribes.\u00a0 (Source:\u00a0 Taipei Times, \u0022Prosecutors won\u0027t appeal acquittals in frigate case,\u0022 November 11, 2010, accessed at http:\/\/www.taipeitimes.com\/News\/taiwan\/archives\/2010\/11\/11\/2003488256.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Examining Magistrate (Geneva)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Swiss Federal Tribunal (Geneva); [ICC Paris]","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taiwan_Frigates_Swiss_EJPD_Press_Release_Assistance_Dec_8_2003.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taiwan_Frigates_Swiss_EJPD_Press_Release_34M_Handed_Over_Jun_13_2007.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taiwan_Frigates_Thales_Press_Release_Arbirtration_Decision_May_3_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taiwan_Frigates_Prosecutors_No_Appeal_Taipei%20Times_Nov_11_2010.pdf","Sources ":"Swiss Ministry of Foreign Affairs, September 30, 2009;\u00a0\n\tSwiss Federal Office of Justice Press Releases, \u0022Frigate sale to Taiwan: Switzerland provides legal assistance,\u0022 December 8, 2003, accessed at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2003\/ref_2003-12-08.html, and \u0022USD 34 million handed over to Taiwan,\u0022 June 13, 2007, accessed at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2007\/ref_2007-06-13.html;\n\tThales Press Release, \u0022Thales: Result of the arbitration with the Republic of China (Taiwan),\u0022 May 3, 2010, posted on company website, at http:\/\/www.thalesgroup.com\/Pages\/PressRelease.aspx?id=12795;\n\tAFP (Taipei), \u0022Prosecutors won\u0027t appeal acquittals in frigate case,\u0022 printed in Taipei Times, November 11, 2010, accessed at http:\/\/www.taipeitimes.com\/News\/taiwan\/archives\/2010\/11\/11\/2003488256.\n"},{"Case ID":"ARW-168","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha \/ United Kingdom Mutual Legal Assistance Treaty Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2000","Asset Recovery End":"2004","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"MLAT","Contributing Factors in Asset Recovery":"A 2001 judgment by the UK Courts backed the decision of The Home Secretary, thereby enabling various governmental bodies concerned, such as the Serious Fraud Office and the National Criminal Investigation Service (NCIS), to proceed officially with their work.  (Source: Tim Daniel and James Maton, \u0022General Sani Abacha - a nation\u0027s thief,\u0022 in Mark Pieth, ed., Recovering Stolen Assets [Peter Lang, 2008].)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to Attorney Enrico Monfrini, in June 2000, a request for mutual assistance was lodged with the United Kingdom\u0027s Home Office, providing evidence of suspect transfers to London banks in excess of $1 billion.  In May 2001, the Home Office decided to execute the Nigerian request, and the Abacha family sought judicial review.  The family\u0027s application was rejected by the High Court on October 18, 2001. (Source: Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets [Peter Lang, 2008] and Abacha \u0026 Ors \u0026 Secretary of State for the Home Department [2001] EWHC Admin 787 (18th October 2001)). As noted by Attorneys Tim Daniel and James Maton, in March 2001, United Kingdom\u0027s Financial Services Authority issued a press release which stated that a total of $1.3 billion was found to have passed through accounts in British banks controlled by the Abacha family.\u0022  In 2004, the Home Office indicated that it was ready to submit evidence to Nigeria, the family again challenged the decision; \u0022The challenge was rejected by the English High Court towards the end of 2004.\u0022 (Source: Tim Daniel and James Maton, \u0022General Sani Abacha - a nation\u0027s thief,\u0022 in Mark Pieth, ed., Recovering Stolen Assets [Peter Lang, 2008] and United Kingdom Financial Services Authority Press Release, \u0022FSA publishes results of money laundering investigation,\u0022 FSA\/PN\/029\/2001, March 8 2001).","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate.  (Source:  Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"Special Panel established to investigate Abacha looting","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Home Department, Financial Services Authority; Serious Fraud Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Edwards Angell Palmer \u0026 Dodge (Attorneys James Maton and Tim Daniel)","Jurisdiction of Asset Recovery: Courts Involved":"High Court","Documents":"","Sources ":"Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008);\nAbacha \u0026 Ors \u0026 Secretary of State for the Home Department [2001] EWHC Admin 787 (18th October 2001), accessed at http:\/\/www.bailii.org\/cgi-bin\/markup.cgi?doc=\/ew\/cases\/EWHC\/Admin\/2001\/7... and ICC FraudNet at http:\/\/www.icc-ccs.org\/home\/resources\/118-leading-cases\/697-abacha-case;\nUnited Kingdom Financial Services Authority press release, \u0022FSA publishes results of money laundering investigation,\u0022 FSA\/PN\/029\/2001, March 8 2001, accessed at http:\/\/www.fsa.gov.uk\/Pages\/Library\/Communication\/PR\/2001\/029.shtml; and \nTim Daniel and James Maton, \u0022General Sani Abacha - a nation\u0027s thief,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008).\n"},{"Case ID":"ARW-169","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha\/Ajaokuta Steel Plant debt buy-back case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"2003","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Private civil action","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$198,484,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to Attorneys Tim Daniel and James Maton, Russian debt had financed the construction of the massive Ajaokuta Steel Plant in Nigeria\u0027s Kogi State:  \u0022Construction, mainly by Russian contractors, took place at substantial cost over a period of fifteen years but, by 1998, few products had been manufactured by the plant...In an effort to cut their losses, the Russians started selling off the debt...through the use of a British Virgin Islands company called Mecosta that was beneficially owned by Mohammed Abacha and Abubakar Bagudu.  Mecosta (indirectly) acquired the debt from the Russians and sold it to the Nigerian government for twice the sum it had paid, taking payment partly in cash and partly in Nigerian par bonds. The Abachas\u0027 profit was approximately DM 500 million (GBP 166 million), and was held by the London branch of a major bank.\u0022  In 1999, Nigeria brought civil proceedings against a number of parties.  In 2001, Mr. Justice Rix  ordered the Abachas to pay DM332,818,786.94 to Nigeria.  This was paid from the frozen proceeds of the sale.  In 2003, Mr. Justice Rix\u0027s judgment was upheld by the Court of Appeals and permission was refused to apply to the House of Lords. (Source: Tim Daniel and James Maton, \u0022General Sani Abacha - a nation\u0027s thief,\u0022 in Mark Pieth, ed., Recovering Stolen Assets [Peter Lang, 2008]) and Compagnie Noga D\u0027importation Et D\u0027exportation SA v Abacha \u0026 Ors [2003] EWCA Civ 1100 (23 July 2003) and related decisions.)","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate.  (Source:  Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"Special Panel established to investigate Abacha looting","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Kendall Freeman solicitors (Mr David Railton QC; Mr Andrew Mitchell) for the Federal Government of Nigeria; Harwood Stephenson solicitors (Mr Steven Gee QC, Miss Vasanti Selvaratnam QC) for Compagnie Noga D\u0027importation S.A.","Jurisdiction of Asset Recovery: Courts Involved":"Court of Appeals (Civil Division); High Court, Queen\u0027s Bench Division (Commercial Court)","Documents":"","Sources ":"Compagnie Noga D\u0027importatation Et D\u0027exportation SA v Abacha \u0026 Ors [2003] EWCA Civ 1100 (23 July 2003) and related decisions accessed at http:\/\/www.bailii.org\/ew\/cases\/EWCA\/Civ\/2003\/1100.html;  \nTim Daniel and James Maton, \u0022General Sani Abacha - a nation\u0027s thief,\u0022 in Mark Pieth, ed., Recovering Stolen Assets [Peter Lang, 2008]) and an earlier version of the article accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.\n"},{"Case ID":"ARW-171","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sheikh Hamad Bin Jassim Bin Jaber Al Thani","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Qatar","Position of Public Official(s) (yrs in office)":"Emir (1972-1995)","Jurisdiction of Asset Recovery":"Jersey","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1998","Asset Recovery End":"2002","UNCAC Offenses Implicated":"Art.16, Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Other (Voluntary Payment)","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"As noted in the Royal Court\u0027s December 2, 2002 decision in Between Jersey Evening Post and His Excellency Sheikh Hamad Bin Jassim Bin Japer Al-Thani and four additional respondents, a \u0022press release issued on behalf of the Attorney General on 28th May 2002 with the agreement of the legal advisers of Sheikh Hamad. That press release indicated that a criminal investigation into the conduct of Sheikh Hamad was at an end and that the Sheikh had voluntarily paid GBP 6 million towards the costs of the investigation into the affairs of his three Jersey trusts.\u0022 (Source: Royal Court (Samedi Division), Case No. 2002-227, at paragraph 7.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$8,740,800","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the May 28, 1999 decision by the Jersey Royal Court, following Mr. Hamad\u0027s ouster as Emir in 1995, Qatar instituted legal proceedings, alleging that Mr. Hamad transferred public funds to private accounts.  The Royal Court wrote, \u0022On November 9th, 1998 the Deputy Bailiff made an Order ex parte at the instance of the State of Qatar restraining the defendant, inter alia, from removing any of his assets from the jurisdiction save to the extent that those assets exceeded GBP 913m. The history of the matter, as it appears from the Order of Justice, is as follows. The defendant was Emir of Qatar from 1972 until 1995. On June 27th, 1995, he was removed from office. The Government of Qatar opened an enquiry into the defendant\u0027s use of public funds entrusted to him whilst he was Emir. It is alleged that substantial amounts of public funds had been transferred during his reign to accounts around the world in violation of Qatari law. A significant part of those funds is said to have come from overdrafts of the defendant in the accounts of the Emiri Diwan at the Qatar National Bank. In June 1996, the plaintiff commenced proceedings against, inter alia, the defendant and obtained a Mareva injunction against his assets with certain third parties in Jersey. Parallel proceedings were commenced against the defendant in a number of other jurisdictions. In October 1996, the action was settled upon terms which were amended by an addendum in February 1997. The plaintiff [Qatar] now claims that the defendant has failed to comply with the terms of the settlement. In November 1998, the plaintiff commenced attachment proceedings against the defendant in Switzerland as well as bringing proceedings before this court and elsewhere.\u0022  The Royal Court dismissed Mr. Hamad\u0027s appeal against the order.  (Source: State of Qatar v. Al Thani, [1999] JLR 118 (May 28, 1999)).   As noted in the Royal Court\u0027s December 2, 2002 decision in Between Jersey Evening Post and His Excellency Sheikh Hamad Bin Jassim Bin Japer Al-Thani and four additional respondents, a \u0022press release issued on behalf of the Attorney General on 28th May 2002 with the agreement of the legal advisers of Sheikh Hamad. That press release indicated that a criminal investigation into the conduct of Sheikh Hamad was at an end and that the Sheikh had voluntarily paid GBP 6 million towards the costs of the investigation into the affairs of his three Jersey trusts.\u0022 (Royal Court (Samedi Division), Case No. 2002-227, at paragraph 7.  See also, Anthony Lewis, \u0022The Qatar Case,\u0022 Jersey Evening Post, March 24, 2003; Jimmy Burns and Michael Peel, \u0022SFO is \u0027actively\u0027 pursuing corruption allegations,\u0022 Financial Times, February 8, 2007.  The actual text of the Jersey Attorney General\u0027s May 28, 2002 press release could not be located.)","Disposition of Criminal Case(s)":"As noted in the Isle of Jersey Royal Court\u0027s December 2, 2002 decision in Between Jersey Evening Post and His Excellency Sheikh Hamad Bin Jassim Bin Japer Al-Thani and others, a \u0022press release issued on behalf of the Attorney General on 28th May 2002 with the agreement of the legal advisers of Sheikh Hamad. That press release indicated that a criminal investigation into the conduct of Sheikh Hamad was at an end.\u0022  (Soource:  Between Jersey Evening Post and His Excellency Sheikh Hamad Bin Jassim Bin Japer Al-Thani, and four additional respondents, Royal Court (Samedi Division), Case No. 2002-227, at paragraph 7.  The actual text of the Jersey Attorney General\u0027s May 28, 2002 press release could not be located.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Jersey Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"Royal Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Al-Thani_Jersey_1999_JLR_118.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Jersey_Evening_Post_Qatar_Case.pdf .pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sheikh_Hamad_Al_Thani_Jersey_Evening_Post_2002_%20JLR%20542.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sheikh_Hamad_Al_Thani_Qatar_Case_Jersey_Evening_Post_Mar_24_2003.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sheikh_Hamad_SFO_Investigation_Financial_Times_Feb_8_2007.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Al-Thani_Jersey_1999_JLR_118.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Al-Thani_Jersey_1999_JLR_118.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Jersey_Evening_Post_Qatar_Case.pdf .pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sheikh_Hamad_Al_Thani_Jersey_Evening_Post_2002_%20JLR%20542.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sheikh_Hamad_Al_Thani_Qatar_Case_Jersey_Evening_Post_Mar_24_2003.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sheikh_Hamad_SFO_Investigation_Financial_Times_Feb_8_2007.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Sheikh_Hamad_SFO_Investigation_Financial_Times_Feb_8_2007.pdf","Sources ":"State of Qatar v. Al Thani, [1999] JLR 118 (May 28, 1999), accessed at http:\/\/www.jerseylaw.je\/Judgments\/JerseyLawReports\/Display.aspx?Cases\/JL... \nAnthony Lewis, \u0022The Qatar Case,\u0022 Jersey Evening Post, March 24, 2003; Jimmy Burns and Michael Peel, \u0022SFO is \u0027actively\u0027 pursuing corruption allegations,\u0022 Financial Times, February 8, 2007, accessed at http:\/\/www.ft.com\/cms\/s\/0\/a752039c-b718-11db-8bc2-0000779e2340.html#axzz... \nJersey Evening Post, \u0022The Qatar Case: Secrecy case, Sheikh backs down,\u0022 and December 2, 2002 Judgment of the Royal Court (Samedi Division) by the Jersey Royal Court in Between Jersey Evening Post Limited (Representor) And His Excellency Sheikh Hamad Bin Jassim Bin Japer Al-Thani (and on behalf of the adult beneficiaries of the Y Trust, the H Trust and the Y No. 2 Trust) (First Respondent) And David Fisher Le Quesne, Advocate (on behalf of the minor and unborn beneficiaries of the said Trusts) (Second Respondent) And Standard Chartered Grindlays Trust Corporation (Jersey) Limited (Third Respondent) And The State of Qatar (Fourth Respondent) And Her Majesty\u0027s Attorney General (Fifth Respondent), accessed at http:\/\/www.thisisjersey.co.uk\/qatar\/index.html.\n"},{"Case ID":"ARW-177","Case Title (Name of Public Official or Entity Allegedly Involved)":"Stanley Mombo Amuti","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kenya","Position of Public Official(s) (yrs in office)":"Financial Controller, National Water Conservation and Pipeline Corporation (Inclusive September 2007); Finance Manager, Water Services Regulatory Board (2004 or 2005-2007)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"On May 13, 2011, the Court of Appeal of Kenya in Nairobi upheld the freezing of Mr. Amuti\u0027s bank accounts and other assets pending the outcome his appeal in a case brought against him on September 18, 2008 by the Kenya Anti-Corruption Commission (KACC).  One of the bank accounts frozen was Account Number 32757182, National Westminster Bank PLC-London Branch, 60-15-49.   (Source: Between Kenya Anti-Corruption Commission and Stanley Mombo Amuti [2011] eKLR, Civil Application No. NAL 30 of 2011 (UR 25\/2011), Court of Appeal at Nairobi, May 13, 2011).  According to the May 13, 2011 ruling, the KACC had filed an originating summons before the superior court, \u0022stating that it had conducted investigations which established that Stanley Mombo Amuti [ ] was in possession of unexplained assets\u0022 that were grossly disportionate to his income.  The KACC affidavit posited that a court authorized search of Mr. Amuti\u0027s office and residence revealed cash and checks in excess of Kshs. 21 million (USD 276,316), which were seized and further searches of his bank accounts established that he had deposited sums in excess of Kshs. 140 million (USD 1,842,110) and withdrawn in exces sof Kshs. 85 million (USD1,118,420) over a period if ten months between September 2007 and June 2008, as well as several immovable properties being traced to him.  Mr. Amuti\u0027s gross salary as financial controller of the National Water Conservation and Pipeline Corporation was Kshs. 306,000 (USD 4,026.32) per month and net salary of Kshs. 180,031 (USD 2,368.83).  Previously as finance manager with the Water Services Regulatory Board, he earned a gross salary of Kshs. 225,4000  (USD 3,965.79) for a period of three years.  Mr. Amuti had been given an opportunity to explain the origin of his assets, but the KACC did not find the explanation satisfactory and filed its case. (Source: Ibid.)","Disposition of Criminal Case(s)":"According to the May 13, 2011 ruling by the Court of Appeal of Kenya in Nairobi, on September 18, 2008 the Kenyan Anti-Corruption Commission filed an originating summon before the superior court invoking section 55 of the Anti-Corruption and Economic Crimes Act.  The case is ongoing, as of May 13, 2011. (Source: Between Kenya Anti-Corruption Commission and Stanley Mombo Amuti [2011] eKLR, Civil Application No. NAL 30 of 2011 (UR 25\/2011), Court of Appeal at Nairobi, May 13, 2011).","Jurisdiction of Origin: Investigative Agency":"Kenya Anti-Corruption Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Kenya Anti-Corruption Commission","Jurisdiction of Origin: Courts Involved":"Court of Appeal at Nairobi, High Court at Nairobi, superior court","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Between Kenya Anti-Corruption Commission and Stanley Mombo Amuti [2011] eKLR, Civil Application No. NAL 30 of 2011 (UR 25\/2011), Court of Appeal at Nairobi, May 13, 2011 (overturning High Court decision of February 4, 2011, acessed at http:\/\/www.kenyalaw.org\/CaseSearch\/view_preview1.php?link=84516167880392...), via link provided in May 20, 2011 newsletter of the Kenya Law Reports at  http:\/\/www.kenyalaw.org\/newsletter; \nFebruary 2011 decision accessed at http:\/\/kenyalaw.org\/Downloads_FreeCases\/81903.pdf; Kenya Anti-Corruption Commission v. Stanley Mombo Amuti, [2008] eKLR, Civil Case 448 of 2008 (OS), High Court at Nairobi, Ruling November 21, 2008, accessed at http:\/\/www.kenyalaw.org\/CaseSearch\/view_preview1.php?link=77620306260192....\n"},{"Case ID":"ARW-178","Case Title (Name of Public Official or Entity Allegedly Involved)":"Steve Ferguson \/ Piarco Airport case  (Bahamas)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Trinidad and Tobago","Position of Public Official(s) (yrs in office)":"Former Chairman of the National Gas Company (1998- unspecified)","Jurisdiction of Asset Recovery":"Bahamas","Jurisdiction of Asset Description":"Location of Recovery Effort\u00a0","Asset Recovery Start":"","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Unspecified","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Unknown","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In June 2009, Assistant Director Janice Ayala of the U.S. Immigration and Customs Enforcement testified before a U.S. Senate Committee that the case involved accounts of shell companies which were held in the Bahamas, and that the restitution ordered by U.S. courts had yet to be paid.  (Source: Statement of Janice Ayala, Deputy Assistant Director, Office of Investigations, U.S. Immigration and Customs Enforcement, Department of Homeland Security, regarding a Hearing on \u0022Examining State Business Incorporation Practices: A Discussion of the Incorporation Transparency and Law Enforcement Assistance Act (S. 569),\u0022 Before the U.S. Senate Committee on Homeland Security and Governmental Affairs, June 18, 2009.)","Disposition of Criminal Case(s)":"According to official documents filed in U.S. District Court for the Southern District of Florida, Mr. Ferguson is under indictment on multiple counts of fraud and money laundering charges.  Mr. Ferguson is challenging his extradition from Trinidad and Tobago to the U.S.  (Sources:  US v. Gutierrez, et al, Case no: 1:05-cr-20859-PCH (S.D. Fla),  Superseding indictment filed on March 29, 2006; Court Docket Report as of August 21, 2014.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Origin: Courts Involved":"High Court, Court of Appeals","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Bahamas_Ayala_Testimony_Jun_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Status_Rept_Extradition_Apr_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Superseding_Indictment_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Appeals_Court_Civil_Appeal_108_2009_Judgment_May_3_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Galbaransingh_SDFLA_Updated_Status_Report_Sep_7_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Trinidad_High_Court_Extradition_Denied_Trinidad_Express_Nov_7_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ferguson_Bahamas_Ayala_Testimony_Jun_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Bahamas_Ayala_Testimony_Jun_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Status_Rept_Extradition_Apr_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Superseding_Indictment_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Appeals_Court_Civil_Appeal_108_2009_Judgment_May_3_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Galbaransingh_SDFLA_Updated_Status_Report_Sep_7_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Trinidad_High_Court_Extradition_Denied_Trinidad_Express_Nov_7_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Steve_Ferguson_US_SDFLA_Status_Rept_Extradition_Apr_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Bahamas_Ayala_Testimony_Jun_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Status_Rept_Extradition_Apr_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Superseding_Indictment_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Appeals_Court_Civil_Appeal_108_2009_Judgment_May_3_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Galbaransingh_SDFLA_Updated_Status_Report_Sep_7_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Trinidad_High_Court_Extradition_Denied_Trinidad_Express_Nov_7_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Steve_Ferguson_Trinidad_Appeals_Court_Civil_Appeal_108_2009_Judgment_May_3_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Bahamas_Ayala_Testimony_Jun_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Status_Rept_Extradition_Apr_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Superseding_Indictment_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Appeals_Court_Civil_Appeal_108_2009_Judgment_May_3_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Galbaransingh_SDFLA_Updated_Status_Report_Sep_7_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Trinidad_High_Court_Extradition_Denied_Trinidad_Express_Nov_7_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Steve_Ferguson_Extradition_Refused_Trinidad_Express_Nov_7_2011.pdf","Sources ":"Statement of Janice Ayala, Deputy Assistant Director, Office of Investigations, U.S. Immigration and Customs Enforcement, Department of Homeland Security, regarding a Hearing on \u0022Examining State Business Incorporation Practices: A Discussion of the Incorporation Transparency and Law Enforcement Assistance Act (S. 569),\u0022 Before the U.S. Senate Committee on Homeland Security and Governmental Affairs, June 18, 2009.  \nUS v. Gutierrez, et al, Case no: 1:05-cr-20859-PCH (S.D. Fla.),  Superseding indictment filed on March 29, 2006; Court Docket Report as of August 21, 2014.\n"},{"Case ID":"ARW-179","Case Title (Name of Public Official or Entity Allegedly Involved)":"Steve Ferguson \/ Piarco Airport case (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Trinidad and Tobago","Position of Public Official(s) (yrs in office)":"Former Chairman of the National Gas Company (1998- ?)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2005","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution; Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Completed (in part) and Ongoing (in part)","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In a criminal case in U.S. District Court for the Southern District of Florida, the following restitution was ordered against Mr. Ferguson\u0027s co-defendants, to be paid to Trinidad and Tobago: Mr. Gutierrez $4 million, Mr. Hillman $2 million, and Mr. Mora $100,000.  (Source: U.S. v. Gutierrez, et al, Case No. 1:05-cr-20859-PCH (S.D. Fla) Superseding indictment filed March 29, 2006, Restitution hearing minutes, filed March 17, 2007, judgments (various)).  As of October 2013, Mr. Ferguson and Mr. Galbaransingh still faced criminal charges in the United States.  (Source: Ferguson and Galbaransingh (Appellants) and The Commissioner of Prisons, Civil Appeal No. 108 of 2009, Republic of Trinidad and Tobago Court of Appeal, judgment of May 3, 2010 and Between Steve Ferguson and Ishwar Galbaransingh (Appellants) and His Worship Mr. Sherman McNicholls, Claim No.: CV2008-03639, Republic of Trinidad and Tobago High Court of Justice, judgment of October 7, 2008 (extradition related hearings).  Trinidad and Tobago also brought civil complaint against them in Florida state courts. (Source: Trinidad and Tobago v. Birk Hillman Consultants, No. 04-11813 CA 30 (11th Fla. Cir. Ct. April 13, 2007.)","Disposition of Criminal Case(s)":"According to official documents filed in U.S. District Court for the Southern District of Florida, Mr. Ferguson is under indictment on multiple counts of fraud and money laundering charges.  Mr. Ferguson is challenging his extradition from Trinidad and Tobago to the U.S. (Sources:  US v. Gutierrez, et al, Case no: 1:05-cr-20859-PCH (S.D. Fla),  Superseding indictment filed on March 29, 2006; Court Docket Report as of August 21, 2014.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Origin: Courts Involved":"High Court, Court of Appeals","Jurisdiction of Asset Recovery: Investigative Agency":"Immigration and Customs Enforcement, Foreign Corruption Investigations Group","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Criminal: United States Attorney for the Southern District of Florida; Civil: Astigarraga David (Edward H. Davis, Jr., representing Trinidad and Tobago)","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of Florida","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_US_SDFLA_Status_Rept_Extradition_Apr_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Appeals_Court_Civil_Appeal_108_2009_Judgment_May_3_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Claim_CV2008_03639_High_Court_Judgment_Oct_7_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part1_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part2_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part3_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part4_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part5_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_ICE_Investigation_Oct_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Gutierrez_Amended_Judgment_Mar_19_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Hillman_Waller_Judgment_Jan_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Restitution_Hearing_Mar_17_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Superseding_Indictment_Mar_26_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Galbaransingh_SDFLA_Updated_Status_Report_Sep_7_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Trinidad_High_Court_Extradition_Denied_Trinidad_Express_Nov_7_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ferguson_Trinidad_High_Court_Extradition_Denied_Trinidad_Express_Nov_7_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_US_SDFLA_Status_Rept_Extradition_Apr_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Appeals_Court_Civil_Appeal_108_2009_Judgment_May_3_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Claim_CV2008_03639_High_Court_Judgment_Oct_7_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part1_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part2_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part3_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part4_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part5_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_ICE_Investigation_Oct_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Gutierrez_Amended_Judgment_Mar_19_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Hillman_Waller_Judgment_Jan_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Restitution_Hearing_Mar_17_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Superseding_Indictment_Mar_26_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Galbaransingh_SDFLA_Updated_Status_Report_Sep_7_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Trinidad_High_Court_Extradition_Denied_Trinidad_Express_Nov_7_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ferguson_US_SDFL_Restitution_sharing_ag_Disclosure_Aug_21_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_US_SDFLA_Status_Rept_Extradition_Apr_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Appeals_Court_Civil_Appeal_108_2009_Judgment_May_3_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_Trinidad_Claim_CV2008_03639_High_Court_Judgment_Oct_7_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part1_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part2_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part3_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part4_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_Florida_Circuit_Court_Civil_Complaint_Apr_13_2007_Part5_of_5.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_ICE_Investigation_Oct_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Gutierrez_Amended_Judgment_Mar_19_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Hillman_Waller_Judgment_Jan_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Restitution_Hearing_Mar_17_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Steve_Ferguson_US_SDFLA_Superseding_Indictment_Mar_26_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Galbaransingh_SDFLA_Updated_Status_Report_Sep_7_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferguson_Trinidad_High_Court_Extradition_Denied_Trinidad_Express_Nov_7_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ferguson_US_SDFL_Transcript_Status_Conf_Feb_22_2013.pdf","Sources ":"U.S. v. Gutierrez, et al, Case No. 1:05-cr-20859-PCH (S.D. Fla) Superseding indictment filed March 29, 2006, Restitution hearing minutes \u00a0filed March 17, 2007, Amended Judgment against Raul Gutierrez filed March 19, 2007, Eduardo Hillman-Waller filed January 29, 2007, Government of Trinidad and Tobago Restutiton Determination Motion against Leonardo Mora-Rodriguz, filed April 16, 2007, Status Report (Ferguson extradition) filed April 27, 2011; Between Steve Ferguson and Ishwar Galbaransingh (Appellants) and The Commissioner of Prisons, Civil Appeal No. 108 of 2009, Republic of Trinidad and Tobago Court of Appeal, judgment of May 3, 2010 and Between Steve Ferguson and Ishwar Galbaransingh (Appellants) and His Worship Mr. Sherman McNicholls, Claim No.: CV2008-03639, Republic of Trinidad and Tobago High Court of Justice, judgment of October 7, 2008 (extradition related hearings); Civil complaint in Trinidad and Tobago v. Birk Hillman Consultants, No. 04-11813 CA 30 (11th Fla. Cir. Ct. Apr. 13, 2007); The Cornerstone Report by the U.S. Immigration and Customs Enforcement, \u0022ICE Investigates Birk Hillman, et al\u0022 (October 2008). US v. Ferguson and Galbaransingh, Case No. 1:05-cr-20859 (S.D. Fla.), Court Docket Report as of August 21, 2014. \u00a0See also, Denyse Renne, \u0022No extradition for Ish and Steve,\u0022 Trinidad Express, November 10, 2011, accessed at http:\/\/www.trinidadexpress.com\/news\/No_extradition_for_Ish_and_Steve-133....\n"},{"Case ID":"ARW-183","Case Title (Name of Public Official or Entity Allegedly Involved)":"Teodoro Nguema Obiang Mbasogo \/ Teodoro Nguema Obiang Mangue (France)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Equatorial Guinea","Position of Public Official(s) (yrs in office)":"President (Teodoro Nguema Obiang Mbasogo: 1979-current); Minister of Agriculture and Forestry and son of President (Teodoro Nguema Obiang Mangue: current)","Jurisdiction of Asset Recovery":"France","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2007","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case, but Transparency International stated that this is the first time French courts allowed such a complaint by nongovernmental organizations to proceed. Source: Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision: The complaint filed by Transparency International France is ruled admissible,\u0022 November 9, 2010.","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to Transparency International France, on May 23, 2016, the French Prosecutor\u0027s Office filed an indictment against Mr. Obiang for a trial in the Criminal Court of Paris. (Source: Transparency International France, \u0022Bien Mal Acquis: le Procurer de la Republiquw demande l\u0027ouverture d\u0027un proces contre Obiang,\u0022 May 26, 2016, at https:\/\/transparency-france.org\/project\/bma-procureur-ouverture-proces-o...) In November 2010, the French Supreme Court overturned a lower court decision and permitted the \u0022Biens Mal Acquis\u0022 (\u201cIll-Gotten Gains\u201d) complaint, originally filed in March 2007 by Transparency International France and  SHERPA to proceed.  The civil society organizations had filed a complaint against assets allegedly belonging to three African public officials: Omar Bongo, Dennis Sassou Nguesso, and Teodoro Obiang, and their relatives.  Transparency International stated that \u0022this decision stands as a considerable legal milestone that goes beyond the \u0027Biens Mal Acquis\u0027 case.  For the first time in France, the collective action of an anti-corruption association is deemed admissible before a criminal court.\u0022 (Source: Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision: The complaint filed by Transparency International France is ruled admissible,\u0022 November 9, 2010.)  According to secondary sources, including GTSpirit.com, on September 29, 2011, the French National Police seized 11 supercars belonging to Mr. Obiang; among the cars seized from the Obiang Paris residence at 42 Avenue Foch were two Bugati Veyrons, a Maserati MC12, a Porsche Carrera GT, a Ferrari Enzo, a Ferrari 599 GTO, Aston Martin V8 V600 LM, Rolls Royce Drophead Coupe, and a Bentley (model not identified) valued at total of $5 million.  (Source: Des, Car News, \u002211 Supercars of Teodoro Obiang Nguema Mbasogo Seized by French Police,\u0022 September 29, 2011). According to the Agence France-Presse (AFP), French authorities have seized and auctioned luxury goods purchased by Mr. Obiang in February and July 2012 (respectively, valuable artwork and antiquities, and a 1,000 square metre property on 40\/ 42 avenue Foch in Paris detained through French and Swiss companies which were alleged to be beneficially owned by Mr. Obiang (two French companies, Foch Services and SCI Avenue du Bois; and five Swiss companies, Ganesha, Re Entreprise, Gep, Nordi And Shipping, Raya Holding) (Source: Decision confirmed by the French Supreme court on March 5, 2014: Cour de cassation,  criminelle, Chambre criminelle, 5 March 2014, N\u00b0 de pourvoi: 13-84977). French authorities issued an Europe-wide arrest warrant against him in July 2012 (Sources: Decision confirmed by the French Supreme court: Cour de cassation, criminelle, Chambre criminelle, 5 mars 2014, N\u00b0 de pourvoi: 13-84.705, Publi\u00e9 au bulletin; Cour de cassation, criminelle, Chambre criminelle,19 f\u00e9vrier 2014, N\u00b0 de pourvoi: 13-84.705). French newspaper Liberation press release, \u0022Biens mal acquis: saisie record chez Teodoro Obiang\u0022, February 2012, available at: http:\/\/www.liberation.fr\/monde\/2012\/02\/24\/biens-mal-acquis-saisie-record... AFP press release, \u0022Biens mal acquis: le fils du pr\u00e9sident de Guin\u00e9e \u00e9quatoriale mis en examen\u0022, March 19, 2014.)  According to a press release from the NGOs Transparency International France and Sherpa, the Paris court (the Tribunal de Grande Instance) issued an indictment against Teodoro Nguema Obiang Mangue on money-laundering charges on March 19, 2014. (Sources: Transparency International press release, \u0022Teodorin Obiang Nguema indicted in Bien Mal Acquis case\u0022,  March 20, 2014;  Human Right Watch news release, \u0022Equatorial Guinea: Indictment of President\u2019s Son in France\u0022, March 20, 2014.) .   According to Sherpa in December 2015, the Court of Cassation rejected Mr. Obiang\u0027s petition to have his case dismissed on grounds of diplomatic immunity, thus paving the way for the trial to proceed.  (Source: Sherpa Press Release, \u0022No immunity for Teodoro Obiang: a trial is imminent,\u0022 December 15, 2015.)\n                                                                                                                                                                               In parallel, the Obiang family brought several defamation cases in France notably against two NGOs, the Catholic Committee Against Hunger (CCFD -Terre Solidaire) and Transparency International France, and a French news magazine L\u0027Express. According to RFI, the Paris court dismissed the defamation case against Transparency International France on June 26, 2014, and dismissed the one brought against l\u2019Express on July 4, 2014. The libel suit against CCFD was also dismissed and this decision upheld on appeal on April 25, 2013. (Sources: UNCAC Coalition, \u201cLandmark French rulings dismiss Teodorin Nguema Obiang defamation cases\u201d,  July 23, 2014; RFI press release, \u201cEquatorial Guinea leader\u0027s son Obiang loses legal case against French magazine\u201d, July 5, 2014;  Leexpres.fr, \u201cTeodorin Obiang perd son proc\u00e8s en diffamation\u201d, June 26, 2014; RFI, \u201cGuinea\u0027s Obiang loses libel case against French NGO\u201d, April 26, 2013.).","Disposition of Criminal Case(s)":"In November 2010, the French Supreme Court held that the criminal complaint filed earlier by Transparency International and other non-governmental organizations against Mr. Obiang may proceed. (Source: Supreme Court of France, Case No. 6092, decision of November 9, 2010, L\u0027association Transparence International France, partie civile, reversing High Court of Paris, section 2, judgment of October 29, 2009.)\u00a0 In July 2012, a French court issued an international arrest warrant when for the second time, Mr. Obiang, Jr. did not appear before the Investigating Magistrates \u0022for preliminary examination - a legal procedural step that precedes a criminal indictment under French Law.\u0022 (Source:\u00a0 Sherpa Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: Teodorin Obiang refuses to appear before judicial authorities,\u0022 July 13, 2012.) According to a press release from the NGOs Transparency International France and Sherpa, the Paris court (Tribunal de Grande Instance) issued an indictment against Teodoro Nguema Obiang Mangue on money-laundering charges on March 19, 2014 (Source: Transparency International press release, \u0022Teodorin Obiang Nguema indicted in Bien Mal Acquis case\u0022,  March 20, 2014.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Investigating Magistrate","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Public Prosecutor; (Transparency International France and SHERPA - filed complaint)","Jurisdiction of Asset Recovery: Courts Involved":"Supreme Court, Court of Appeals","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_France_SCt_Judgment_Nov_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_France_TransparencyIntl_Sherpa_Press_Release_Nov_9_2010.docx, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang-cars-seized-photos-www.gtspirit_Sep_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_France_Biens%20mal%20acquis_%20Vers%20l%27ouverture%20d%27un%20proc%C3%A8s%20contre%20Obiang_May2016.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_France_SCt_Judgment_Nov_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_France_TransparencyIntl_Sherpa_Press_Release_Nov_9_2010.docx, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang-cars-seized-photos-www.gtspirit_Sep_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_Ill-Gotten%20Gains_%20The%20Public%20Prosecutor%20Requests%20the%20Opening%20of%20a%20Trial%20against%20Obiang%20-%20SHERPA_May2016.pdf","Sources ":"Transparency International France, \u0022Bien Mal Acquis: le Procurer de la Republique demande l\u0027ouverture d\u0027un proces contre Obiang,\u0022 May 26, 2016, at https:\/\/transparency-france.org\/project\/bma-procureur-ouverture-proces-o... \u00a0French Supreme Court\u0027s November 9, 2010 ruling, reversing appeals court decision and permitting civil suit by Transparency International France and SHERPA to proceed: \u00a0Cour de cassation sans renvoi, No. 6092; See also Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision: The complaint filed by Transparency International France is ruled admissible,\u0022 November 9, 2010. \u00a0Sherpa Press Releases, \u0022No immunity for Teodoro Obiang: a trial is imminent,\u0022 December 15, 2015, at https:\/\/www.asso-sherpa.org\/no-immunity-teodoro-obiang-trial-imminent and \u0022\u0027Biens Mal Acquis\u0027 Case: Teodorin Obiang refuses to appear before judicial authorities,\u0022 July 13, 2012, accessed at http:\/\/asso-sherpa.org\/sherpa-content\/docs\/newsroom\/Communiques_de_press.... See also, United States Senate, Permanent Subcommittee on Investigations, Committee on Homeland Security and Governmental Affairs, Majority and Minority Staff Report, \u0022Keeping Foreign Corruption Out of the United States: Four Case Histories,\u0022 released in conjunction with the Permanent Subcommittee on Investigations, February 4, 2010 Hearing, posted at http:\/\/hsgac.senate.gov\/public\/index.cfm?FuseAction=Hearings.Hearing\u0026Hea... links to witness testimonies also at same. \u00a0See also, Des, Car News, \u002211 Supercars of Teodoro Obiang Nguema Mbasogo Seized by French Police,\u0022 September 29, 2011, accessed at http:\/\/www.gtspirit.com\/2011\/09\/29\/11-supercars-of-teodoro-obiang-nguema.... \u00a0Cour de cassation, \u00a0criminelle, Chambre criminelle, 5 March 2014, N\u00b0 de pourvoi: 13-84977. Cour de cassation, criminelle, Chambre criminelle, 5 mars 2014, N\u00b0 de pourvoi: 13-84.705, Publi\u00e9 au bulletin; Cour de cassation, criminelle, Chambre criminelle,19 f\u00e9vrier 2014, N\u00b0 de pourvoi: 13-84.705. French newspaper Liberation press release, \u0022Biens mal acquis: saisie record chez Teodoro Obiang\u0022, February 2012, available at: http:\/\/www.liberation.fr\/monde\/2012\/02\/24\/biens-mal-acquis-saisie-record... AFP press release, \u0022Biens mal acquis: le fils du pr\u00e9sident de Guin\u00e9e \u00e9quatoriale mis en examen\u0022, March 19, 2014, available at: https:\/\/fr.news.yahoo.com\/biens-mal-acquis-fils-pr%C3%A9sident-guin%C3%A.... Transparency International press release, \u0022Teodorin Obiang Nguema indicted in Bien Mal Acquis case\u0022, \u00a0March 20, 2014, available at: http:\/\/www.transparency.org\/news\/pressrelease\/teodorin_obiang_nguema_ind... Human Right Watch news release, \u0022Equatorial Guinea: Indictment of President\u2019s Son in France\u0022, March 20, 2014, available at: http:\/\/www.hrw.org\/news\/2014\/03\/20\/equatorial-guinea-indictment-presiden.... See also regarding the defamation cases: UNCAC Coalition, \u201cLandmark French rulings dismiss Teodorin Nguema Obiang defamation cases\u201d, \u00a0July 23, 2014, available at: http:\/\/www.uncaccoalition.org\/en\/learn-more\/blog\/350-landmark-french-rul... RFI press release, \u201cEquatorial Guinea leader\u0027s son Obiang loses legal case against French magazine\u201d, July 5, 2014, available at: http:\/\/www.english.rfi.fr\/africa\/20140705-equatorial-guinea-leaders-son-... \u201cTeodorin Obiang perd son proc\u00e8s en diffamation\u201d, June 26, 2014, available at: http:\/\/www.lexpress.fr\/actualites\/1\/societe\/teodorin-obiang-perd-son-pro... RFI, \u201cGuinea\u0027s Obiang loses libel case against French NGO\u201d, April 26, 2013, available at: http:\/\/www.english.rfi.fr\/africa\/20130426-guineas-obiang-loses-libel-cas...\n"},{"Case ID":"ARW-182","Case Title (Name of Public Official or Entity Allegedly Involved)":"Teodoro Nguema Obiang Mbasogo (Spain)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Equatorial Guinea","Position of Public Official(s) (yrs in office)":"President (1979-current)","Jurisdiction of Asset Recovery":"Spain","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In July 2004, the U.S. Senate Permanent Subcommittee on Investigations issued its report, \u0022Money Laundering and Foreign Corruption: Enforcement and Effectiveness of the PATRIOT Act, Case Study Involving Riggs Bank\u0022 examining the Bank\u0027s extensive relationship with Equatorial Guinea and with Mr. Obiang and his family and associates.  The Senate Report stated, \u0022Over three and one-half years, from June 2000 to December 2003, sixteen wire transfers were sent from the E.G. [Equatorial Guinea] oil account to Kulunga Company SA, an E.G. corporation, totaling over $26.5 million.\u0022  The Senate Report stated that all sixteen wire transfers were made from Riggs Bank to the Kalunga Company accounts held at Bank Santander in Madrid, Spain.  (Source: Senate Report, at 54 and 55)  The Senate Report added that the Subcommittee had reasons to believe that at least one of the accounts opened under the Kalunga Company or another company\u0027s name may be \u0022owned in whole or in part by\u0022 Mr. Obiang. (Source: Senate Report, at 6.)  According to the Open Society Foundations, investigations undertake by the Asociacion Pro Derechos Humanos de Espana (APDHE), a Spanish human rights organization \u0022revealed close correlations in timeing between at least five of these transfers and nine real estate purchases in Madrid, Gijon, and Las Palmas de Gran Canaris in the Canary Islands on behalf of the President, members of his family, and other close associates.\u0022  (Source: Open Society Foundations, APDHE v. Obiang Family,\u0022 last accessed on March 29, 2011.)   On October 22, 2008, APDHE submitted its complaint to Instructing Judge Baltasar Garzon and the next day, Judge Garzon referred the case to the office of the National Criminal Court Prosecutor.  On January 21, 2009, the Office of the Prosecutor (Fiscalia) concluded that there is a case to answer and opened an official investigation in the Pre-Trial Investigative Court and that the investigation should commence in Gran Canaria rather than in Madrid, because the Kalunga account where the money was received was not in Madrid , but at the Banco Santander in Las Palmas, Gran Canaria.  On February 6, 2009, Judge Garzon issued an order ratifying the determination of the Prosecutor requiring transfer of the case to the Pre-Trial Investigative Court in Las Palmas.  The case is pending investigation. (Source: Open Society Foundations, APDHE v. Obiang Family,\u0022 last accessed on November 7, 2013.)   The APDHE complaint named as defendants Marcellino Owono Edu (Minister for Mining, Industry and Energy) and his wife, Constancia Nchama Angue; Miguel Abia Biteco (former Prime Minister) and his wife, Dorotea Anita Roka Elobo; Gabriel Nguema Lima (son of President Obiang, also known as Gabriel M. Obiang Lima; also former Deputy Minister for Mining, Industry and Energy) and his wife, Virginia Esther Maye Mba; Teodoro Biyogo Nsue (Ambassador to Brazil, U.S. and UN and brother in law of President Obiang) and his wife, Elena Mensa; Pastor Micha Ondo Bile (Minister of Foreign Affairs, International Cooperation and Francophony) and his wife Magdalena Ayang; Atanasio Ela Ntugu (former Minister for Mining, Industry and Energy) and any additional persons who may appear to be criminal liable during the course of investigation for money laundering.  (Source: English translation of APDHE\u0027s complaint dated September 22, 2008.)   The complaint stated that Kalunga Company S.A. was a shell entity which did not conduct any business, and that the funds transferred to its Spain account had originated from the \u0022Oil Account\u0022 at Riggs Bank for which President Obiang, his son Gabriel M. Obiang Lima and his nephew Melchor Esono Edjo were signatories.  Two signatories were sufficient to authorize withdrawals from the Oil Account, and one of them always had to be President Obiang.  Total of nine properties alleged to have been purchased in Spain with the Kalunga funds included two properties registered in President Obiang\u0027s name: (1) Housing unit at calle Dolores de la Rocha SN, 4th floor, door C, CP 35001, Las Palmas de Gran Canaria, registered with the Land Registry of Las Palmas de Gran Canaria number one in the name of Teodoro Obiang Nguema Mbasogo, and (2) property located at calle Eufemiano Jurado SN, 2nd floor, CP 35106, Finca Las Labradoras, Las Palmas de Gran Canaria, registered with the Land Registry of Las Palmas de Gran Canaria number one in the name of Teodoro Obiang Nguema Mbasogo.  (Source: English translation of APDHE\u0027s complaint dated September 22, 2008.)","Disposition of Criminal Case(s)":"In November 2010, the French Supreme Court held that the criminal complaint filed earlier by Transparency International and other non-governmental organizations against Mr. Obiang may proceed. (Source: Supreme Court of France, Case No. 6092, decision of November 9, 2010, L\u0027association Transparence International France, partie civile, reversing High Court of Paris, section 2, judgment of October 29, 2009.)\u00a0 In July 2012, a French court issued an international arrest warrant when for the second time, Mr. Obiang, Jr. did not appear before the Investigating Magistrates \u0022for preliminary examination - a legal procedural step that precedes a criminal indictment under French Law.\u0022 (Source:\u00a0 Sherpa Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: Teodorin Obiang refuses to appear before judicial authorities,\u0022 July 13, 2012.) According to a press release from the NGOs Transparency International France and Sherpa, the Paris court (Tribunal de Grande Instance) issued an indictment against Teodoro Nguema Obiang Mangue on money-laundering charges on March 19, 2014 (Source: Transparency International press release, \u0022Teodorin Obiang Nguema indicted in Bien Mal Acquis case\u0022,  March 20, 2014.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Instructing Judge Baltasar Garzon; Fiscalia de la Audiencia Nacional (National Criminal Court Prosecutor); Asocacion Pro Derechos Humanos de Espana (Attorneys Manuel Olle Sese and Almudena Bernabeu)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"[Juzgado de Instruccion, Las Palmas de Gran Canaria?]","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_Spain_APDHE_Complaint_English_Oct_22_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_Spain_APDHEvObiang_Soros_Fdn_March_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Investigation_Riggs_Bank_July_2004.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/APDHE%20v%20Obiang_Open_Society_Fdn_Jan_22_2015.pdf","Sources ":"U.S. Senate Permanant Subcommittee on Investigations Minority Staff Report, \u0022Money Laundering and Foreign Corruption: Enforcement and Effectiveness of the Patriot Act, Case Study Involving Riggs Bank,\u0022 July 15, 2004, accessed at http:\/\/hsgac.senate.gov\/public\/_files\/ACF5F8.pdf;  Open Society Justice Initiative of the Open Society Foundations, \u0022APDHE v. Obiang Family,\u0022 last accessed on January 22, 2015, at http:\/\/www.soros.org\/initiatives\/justice\/litigation\/obiangfamily (which also provides links at bottom to text of APDHE\u0027s complaint in Spanish and English translation). Sherpa Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: Teodorin Obiang refuses to appear before judicial authorities,\u0022 July 13, 2012, accessed at http:\/\/asso-sherpa.org\/sherpa-content\/docs\/newsroom\/Communiques_de_press....\n"},{"Case ID":"ARW-184","Case Title (Name of Public Official or Entity Allegedly Involved)":"Teodoro Nguema Obiang Mbasogo \/ Teodoro Nguema Obiang Mangue (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Equatorial Guinea","Position of Public Official(s) (yrs in office)":"President (Teodoro Nguema Obiang Mbasogo: 1979-current); Second Vice President and son of President (Teodoro Nguema Obiang Mangue: current)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Other \/ Settlement Agreement in Non-Conviction Based Confiscation Case","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"Unspecified amount (includes Malibu mansion, Ferrari, two statues and US$11.3 million)","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"Ongoing but returned funds to be used to establish a charity for benefit of people of Equatorial Guinea","Case Summary":"On October 10, 2014, Mr. Obiang announced that he had reached a settlement with the Department of Justice in which he agreed to forfeit his Malibu mansion, a Ferrari, two statues, US$10.3 million being held in escrow and to make a payment for US$1 million.  The proceeds are to be used to establish a charity that would benefit the people of Equatorial Guinea.  (Source:  US v. One White Crystal-Covered \u0022Bad Tour\u0022 Glove and Other Michael Jackson Memorabilia; Real Property Located on Sweetwater Mesa Road in Malibu, California; One 2011 Ferrari 599 GTO, et al, Case No. 2:11-cv-03582-GW-SS (C.D. Cal), Joint Stipulation and Settlement Agreement filed October 10, 2014; PR Newswire, \u0022Vice President of Equatorial Guinea Settles Case with Justice Department.\u0022)  In October 2011, the US Department of Justice had announced the filing of two civil asset forfeiture suits, in California and in Washington, D.C., against more than $70.8 million in alleged proceeds of corruption by Mr. Teodoro Nguema Obiang Mangue.  The Justice Department stated that the cases originated as part of its Kleptocracy Asset Recovery Initiative. (Source: US Department of Justice Press Release, \u0022Department of Justice Seeks to Recover More Than $70.8 Million in Proceeds of Corruption from Government Minister of Equatorial Guinea,\u0022 October 25, 2011.)  In February 2010, the U.S. Senate Permanent Subcommittee on Investigations had conducted hearings and released an extensive investigative report which concluded that \u0022From 2004 to 2008, Teodoro Nguema Obiang Mangue, son of the President of Equatorial Guinea, has used U.S. lawyers, bankers, real estate agents, and escrow agents to move over $110 million in suspect funds into the United States. Mr. Obiang is the subject of an ongoing U.S. criminal investigation, has been identified in corruption complaints filed in France, and was a focus of a 2004 Subcommittee hearing showing how Riggs Bank facilitated officials from Equatorial Guinea in opening accounts and engaging in suspect transactions.\u0022 (Sources: U.S. Senate Permanent Subcommittee on Investigations Majority and Minority Staff Report, \u0022Keeping Foreign Corruption Out of the United States: Four Case Studies\u0022 and report of the Senate Hearing 111-540 on February 4, 2010.)   The assets involved in the California suit included a Malibu mansion on Sweetwater Mesa Road, a 2011 Ferrari, and Michael Jackson Memorabilia; the Washington, DC suit involves a Gulfstream G-V private jet.  In August 2013, the California court granted a summary judgment, dismissing the case against the assets but declining to rule on the charge of bank fraud.  (Sources: US v. One White Crystal-Covered \u0022Bad Tour\u0022 Glove, et al, Case No. 2:11-cv-03582-GW-SS (C.D. Cal), First Amended Verified Claim for Forfeiture In Rem filed October 13, 2011, US v. One Gulfstream G-V Jet Aircraft Displaying Tail Number VPCES, et al, Case No. 1:11-cv-01874-ABJ (D.D.C.), Complaint for Forfeiture In Rem filed October 25, 2011).  As part of the settlement, the civil forfeiture action filed in Washington DC was to be dropped.","Disposition of Criminal Case(s)":"In November 2010, the French Supreme Court held that the criminal complaint filed earlier by Transparency International and other non-governmental organizations against Mr. Obiang may proceed. (Source: Supreme Court of France, Case No. 6092, decision of November 9, 2010, L\u0027association Transparence International France, partie civile, reversing High Court of Paris, section 2, judgment of October 29, 2009.)\u00a0 In July 2012, a French court issued an international arrest warrant when for the second time, Mr. Obiang, Jr. did not appear before the Investigating Magistrates \u0022for preliminary examination - a legal procedural step that precedes a criminal indictment under French Law.\u0022 (Source:\u00a0 Sherpa Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: Teodorin Obiang refuses to appear before judicial authorities,\u0022 July 13, 2012.) According to a press release from the NGOs Transparency International France and Sherpa, the Paris court (Tribunal de Grande Instance) issued an indictment against Teodoro Nguema Obiang Mangue on money-laundering charges on March 19, 2014 (Source: Transparency International press release, \u0022Teodorin Obiang Nguema indicted in Bien Mal Acquis case\u0022,  March 20, 2014.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Senate Permanent Subcommittee on Investigations; Foreign Corruption Investigations Group (Miami) and HSI Asset identification and Removal Group (Miami) of the Immigration and Customs Enforcement; HSI Office of the Special Agent in Charge (Los Angeles)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the Central District of California; US District Court for the District of Columbia","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Investigation_Riggs_Bank_July_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_Suits_Filed_DOJ_PR_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_CDCA_First_Amended_Verified_Complaint_Oct_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_DDC_Complaint_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Visa_Mansion_NYTimes_Nov_17_2009\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_US_CDCA_Ruling_Mtn_Summary_Judg_Aug_20_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Investigation_Riggs_Bank_July_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_Suits_Filed_DOJ_PR_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_CDCA_First_Amended_Verified_Complaint_Oct_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_DDC_Complaint_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Visa_Mansion_NYTimes_Nov_17_2009\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_US_DDC_Amended_Complaint_Main_Jun_17_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Investigation_Riggs_Bank_July_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_Suits_Filed_DOJ_PR_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_CDCA_First_Amended_Verified_Complaint_Oct_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_DDC_Complaint_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Visa_Mansion_NYTimes_Nov_17_2009\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_US_DDC_Mtn_DIsmiss_Exhibit_5_Oct_4_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Investigation_Riggs_Bank_July_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_Suits_Filed_DOJ_PR_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_CDCA_First_Amended_Verified_Complaint_Oct_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_DDC_Complaint_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Visa_Mansion_NYTimes_Nov_17_2009\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_Statement_Settlement_Oct_10_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Investigation_Riggs_Bank_July_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_Suits_Filed_DOJ_PR_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_CDCA_First_Amended_Verified_Complaint_Oct_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_DDC_Complaint_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Visa_Mansion_NYTimes_Nov_17_2009\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_CDCA_Stip_Settlement_Ag_10102014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Senate_Investigation_Riggs_Bank_July_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_Suits_Filed_DOJ_PR_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_CDCA_First_Amended_Verified_Complaint_Oct_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_DDC_Complaint_Oct_25_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Obiang_US_Visa_Mansion_NYTimes_Nov_17_2009\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Obiang_CDCA_Notice_settlement_10102014.pdf","Sources ":"U.S. Senate Permanent Subcommittee on Investigations Majority and Minority Staff Report, \u0022Keeping Foreign Corruption Out of the United States: Four Case Studies\u0022 and report of the Senate Hearing 111-540 on February 4, 2010, available at the website of the Government Printing Office at http:\/\/www.gpo.gov\/fdsys\/pkg\/CHRG-111shrg56840\/html\/CHRG-111shrg56840.htm; U.S. Senate Permanant Subcommittee on Investigations Minority Staff Report, \u0022Money Laundering and Foreign Corruption: Enforcement and Effectiveness of the Patriot Act, Case Study Involving Riggs Bank,\u0022 July 15, 2004, accessed at http:\/\/hsgac.senate.gov\/public\/_files\/ACF5F8.pdf. \u00a0US Department of Justice Press Release, \u0022Department of Justice Seeks to Recover More Than $70.8 Million in Proceeds of Corruption from Government Minister of Equatorial Guinea,\u0022 October 25, 2011; US v. One White Crystal-Covered \u0022Bad Tour\u0022 Glove and Other Michael Jackson Memorabilia; Real Property Locted on Sweetwater Mesa Road in Malibu, California; One 2011 Ferrari 599 GTO, et al, Case No. 2:11-cv-03582-GW-SS, First Amended Verified Claim for Forfeiture In Rem filed October 13, 2011 and Final Ruling on Defendant\u0027s Motion for Summary Judgment, August 20, 2013, \u00a0Joint Stipulation and Settlement Agreement filed October 10, 2014, 2014; US v. One Gulfstream G-V Jet Aircraft Displaying Tail Number VPCES, et al, Case No. 1:11-cv-01874-ABJ (D.D.C.), Complaint for Forfeiture In Rem filed October 25, 2011 and Amended Complaint filed June 17, 2013, and Defendant\u0027s Motion to Dismiss filed October 4, 2013. See also, Ian Urbina, \u0022Taint of Corruption Is No Barrier to U.S. Visa,\u0022 New York Times, November 16, 2009 (which valued the Malibu mansion at $35 million and showed a photo of it.) and Sherpa Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: Teodorin Obiang refuses to appear before judicial authorities,\u0022 July 13, 2012, accessed at http:\/\/asso-sherpa.org\/sherpa-content\/docs\/newsroom\/Communiques_de_press... PR Newswire, \u0022Vice President of Equatorial Guinea Settles Case with Justice Department,\u0022 October 10, 2014, at http:\/\/www.prnewswire.com\/news-releases\/vice-president-of-equatorial-gui...\n"},{"Case ID":"ARW-186","Case Title (Name of Public Official or Entity Allegedly Involved)":"Tommy Suharto (also known as Hutomo Mandala Putra)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Indonesia","Position of Public Official(s) (yrs in office)":"Son of President (Mohamed Suharto, 1967-1998)","Jurisdiction of Asset Recovery":"Guernsey","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Ongoing Case, but the Guernsey court wrote that \u0022The defendant [BNP Paribas (Suisse) S.A. bank] considered its duties under the provisions of the Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law 1999 and disclosed its position to the Financial Intelligence Service (\u0022FIS\u0022) of the States of Guernsey.\u0022 (Source: Garnet Investments Investments Limited v. BNP Paribas (Suisse) S.A. and Government of Republic of Indonesia, Guernsey Law Reports 2007\u201308 GLR 73 (Royal Court), Judgment of May 23rd, 2007.","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"As noted in the August 22, 2011 Media Release by Guernsey\u0027s Financial Investigative Unit, the Guernsey Court of Appeals ruled in favor of the Chief of Customs and Excise, Immigration and Nationality Service which had appealed a lower court ruling  in favour of Garnet Investments Ltd (Garnet), who had applied for judicial review of the Financial Intelligence Service\u2019s (FIS) decision not to give consent for the bank BNP Paribas (BNP) to make payments, requested by Garnet from its account at the Bank.  (Source: Guernsey Financial Investigation Unit Agency Media Release, \u0022Judicial Review \/ THE CHIEF OFFICER CUSTOMS \u0026 EXCISE, IMMIGRATION \u0026 NATIONALITY SERVICE \u2013 (Now known as the Guernsey Border Agency - GBA) And GARNET INVESTMENTS, August 22, 2011.)  According to a statement by the Government of Guernsey, \u0022On Tuesday 20 November 2012, the Judicial Committee of the Privy Council notified Garnet Investments Limited that it had refused its application to appeal the decision of the Guernsey Court of Appeal which had found in favour of the Chief Officer Customs \u0026 Excise, Immigration \u0026 Nationality.  The Privy Council\u0027s written decision advised Garnet Investments Limited that its \u0022application for permission to appeal had been considered by the Board and permission to appeal had been refused because the application does not raise an arguable point of law and the Board is not persuaded that the decision of the Court of Appeal is arguably wrong.\u0022\u0022  (Source: States of Guernsey, \u0022Judicial Committee of the Privy Council refuses Garnet Investments Ltd application to appeal,\u0022 January 4, 2013.)\nAssets of Garnet Investments Limited, of which Mr. Suharto was identified as the beneficial owner, remain restrained in Guernsey.   In 2002, the BNP Paribas (Suisse) Bank - Guernsey branch disclosed to the Guernsey financial intelligence unit that Tommy Suharto was the beneficial owner of the Garnet Investments Limited account and sought the FIS\u0027s consent to transfer the funds, as requested by Garnet Investments.  The FIU denied consent and the Government of Indonesia was informed and given opportunity to join the proceedings between the Bank and Garnet Investments.  The Guernsey court cited the lack of progress by Indonesia to institute proceedings against Suharto in Indonesia as jusitification for not extending the freeze of the funds but the FIU continued to deny consent to transfer the funds. (Source: Garnet Investments Limited v. BNP Paribas (Suisse) S.A. and Government of Indonesia, Guernsey Law Reports, 2007-08 GLR 73.)  In late 2010, Suharto\u0027s defunct car company found liable to Ministry of Finance for tax evasion; Indonesia may attempt to recover the Guernsey funds again. (Source: Reuters, \u0022Indonesia to keep assets of ex-president Suharto\u0027s son,\u0022 July 16, 2010.)","Disposition of Criminal Case(s)":"According to the January 29, 2007 \u0022Trade and Investment News\u0022 by The Coordinating Ministry for Economic Affairs of the Republic of Indonesia, \u0022Tommy [Suharto], 44, was released from prison last October after serving five years of a 15-year sentence for ordering the murder of an Indonesian judge who had convicted him of corruption in connection with a land-scam case.\u0022  (Source: The Coordinating Ministry for Economic Affairs, Republic of Indonesia, \u0022Trade and Investment News,\u0022 January 29, 2007, accessed on the website of The Indonesian Consulate General Chicago,\u0022 at http:\/\/www.indonesiachicago.org\/economic-N012907.html)","Jurisdiction of Origin: Investigative Agency":"Ministry of Justice and Human Rights","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Financial Investigative Unit, Guernsey Border Agency","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"Royal Court; Court of Appeals","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Conviction_Indonesian_Consulate_Jan_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_2009-10_GLR_1.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_73.pdf Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_442.pdf Suharto_Guernsey_Media Release_Guernsey Court of Appeal_Garnet_Aug_22_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_73.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Conviction_Indonesian_Consulate_Jan_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_2009-10_GLR_1.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_73.pdf Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_442.pdf Suharto_Guernsey_Media Release_Guernsey Court of Appeal_Garnet_Aug_22_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_442.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Conviction_Indonesian_Consulate_Jan_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_2009-10_GLR_1.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_73.pdf Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_442.pdf Suharto_Guernsey_Media Release_Guernsey Court of Appeal_Garnet_Aug_22_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Suharto_Guernsey_Media%20Release_Guernsey%20Court%20of%20Appeal_Garnet_Aug_22_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Conviction_Indonesian_Consulate_Jan_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_2009-10_GLR_1.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_73.pdf Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_442.pdf Suharto_Guernsey_Media Release_Guernsey Court of Appeal_Garnet_Aug_22_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Suharto_Guernsey_Chief%20Officer%20v%20Garnet%20Application%20for%20Leave%20to%20appeal%20to%20the%20PC%20Judgement_19%2012%2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Conviction_Indonesian_Consulate_Jan_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_2009-10_GLR_1.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_73.pdf Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_442.pdf Suharto_Guernsey_Media Release_Guernsey Court of Appeal_Garnet_Aug_22_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Suharto_Guernsey_Customs_v_Garnet_Appeals_Ct_Jul_5_6_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Conviction_Indonesian_Consulate_Jan_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_2009-10_GLR_1.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_73.pdf Tommy_Suharto_Guernsey_Garnet_Investments_Freeze_2007.08_GLR_442.pdf Suharto_Guernsey_Media Release_Guernsey Court of Appeal_Garnet_Aug_22_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Suharto_Guernsey_Privy_Council_Deny_Appeal_Jan_4_2013.pdf","Sources ":"Garnet Invs. Ltd. v. BNP Paribas (Suisse) S.A. and the Government of the Republic of Indonesia (Royal Court) 2007-08 GLR 73; Garnet Invs. Ltd. v. BNP Paribas (Suisse) S.A. and the Government of the Republic of Indonesia (Royal Court) 2007-08 GLR 442; Garnet Invs. Ltd. v. BNP Paribas (Suisse) S.A. and the Government of the Republic of Indonesia (C.A.) 2009-10 GLR 1, all available at Guernsey Legal Resources: http:\/\/www.guernseylegalresources.gg\/ccm\/portal\/; States of Guernsey, \u0022Judicial Committee of the Privy Council refuses Garnet Investments Ltd application to appeal,\u0022 January 4, 2013, at http:\/\/www.gov.gg\/article\/105231\/Judicial-Committee-of-the-Privy-Council...\n The Coordinating Ministry for Economic Affairs, Republic of Indonesia, \u0022Trade and Investment News,\u0022 January 29, 2007, accessed on the website of The Indonesian Consulate General Chicago, at http:\/\/www.indonesiachicago.org\/economic-N012907.html.  See also Reuters, \u0022Indonesia to keep assets of ex-president Suharto\u0027s son,\u0022 July 16, 2010 and The Jakarta Post, \u0022\u0027Tommy\u0027 Soeharto loses appeal in Guernsey,\u0022 August 24, 2011, accessed at http:\/\/www.thejakartapost.com\/news\/2011\/08\/24\/tommy-soeharto-loses-appea....). Guernsey Financial Investigation Unit Agency Media Release, \u0022Judicial Review \/\nTHE CHIEF OFFICER CUSTOMS \u0026 EXCISE, IMMIGRATION \u0026 NATIONALITY SERVICE \u2013 (Now known as the Guernsey Border Agency - GBA) And GARNET INVESTMENTS, August 22, 2011, accessed at http:\/\/www.guernseyfiu.gov.gg\/ccm\/portal\/) and  Court of Appeal decisions (5 and 6 July 2011 and 19 December 2011) in the case;  Frederic Raffray, \u0022The rule of law and \u0027Tommy Suharto\u0027 - son of (former) President Suharto,\u0022 at 29-50, in Emerging Trends in Asset Recovery (Bern: Peter Lang, 2013)\n"},{"Case ID":"ARW-187","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ukrainian Goverment \/ Ukrvaktsina v. Olden Group, LLC and Interfarm, LLC","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Unspecified","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2010","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/","Contributing Factors in Asset Recovery":"Private civil action","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA (private civil action)","Case Summary":"On September 17, 2010, Ukrvaktsina filed a civil suit in Oregon federal court, alleging that \u0022Interfarm and Olden Group conspired to overcharge Ukrvaktsina for millions of dollars in vaccine purchases through acts of fraud, money laundering and other criminal acts.\u0022  Ukrvaktsins is seeking $26 million in damages. (Source: Ukrvaktsina v. Olden Group, LLC, Case No. 6:10-cv-06297-AA (D. Ore.), Complaint filed September 17, 2010).  On June 8, 2011, the US District Court for the District of Oregon issued an Order of Default Judgment for the plaintiff against Olden Group LLC, an Oregon incorporated entity. The Court stated that Olden Group failed to make an appearance or otherwise answer the plaintiff\u0027s amended complaint, and orderd Olden Group to pay a principal of $59,785,291.50 and post-judgment interest until principal was paid. (Source: Ukrvaktsina v. Olden Group, LLC, Case No. 6:10-cv-06297-AA (D. Ore.), Default Judgment Against Defendant Olden Group, LLC filed June 9, 2011).  On October 30, 2011, the Court dismissed the case against co-defendant Interfarm LLC, holding that the court did not have personal or specific jurisdiction over the Ukrainian company.  (Source: Ukrvaktsina v. Olden Group, LLC, Case No. 6:10-cv-06297-AA (D. Ore.), Opinion and Order, and Judgment, both filed on October 30, 2011.)","Disposition of Criminal Case(s)":"Unspecified","Jurisdiction of Origin: Investigative Agency":"Government of Ukraine, Ministry of Finance, Main Control and Revision Office; Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP, Kroll Inc. ","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP, Kroll Inc.","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Trout Cacheris PLLC (Attorney Plato Cacheris); Akin Gump Strauss Hauer \u0026 Feld LLP (Attorney Mark J. MacDougall); Davis Wright Tremaine LLP (Attorney Kevin H. Kono)","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Oregon","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Min_Finance_Investigation_Report_Oct_14_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Ukrvaktsina_Oregon_Default_Judgment_Order_Jun_9_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Ukravaktsina_Interfarm_Oregon_Opinion_Case_Dismissed_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ukraine_Ukrvaktsina_Oregon_Default_Judgment_Order_Jun_9_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Min_Finance_Investigation_Report_Oct_14_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Ukrvaktsina_Oregon_Default_Judgment_Order_Jun_9_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Ukravaktsina_Interfarm_Oregon_Opinion_Case_Dismissed_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Olden_Group_DORE_Opinion_Case_Dismissed_Oct_30_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Min_Finance_Investigation_Report_Oct_14_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Ukrvaktsina_Oregon_Default_Judgment_Order_Jun_9_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Ukravaktsina_Interfarm_Oregon_Opinion_Case_Dismissed_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Olden_Group_US_DOR_Ct_Dkt_July_2011_to_Oct_2013.pdf","Sources ":"Ukravaktsina v. Olden Group, LLC and Interfarm, LLC, Case No. 6:10-cv-06297-AA (D. Ore.), Complaint filed September 17, 2010 and Docket Report as of October 2013; Default Judgment Order filed June 9, 2011;  \nGovernment of Ukraine, Ministry of Finance, Main Control and Revision Office, \u0022Report of Investigative Findings, pursuant to Agreement on Performance of Audit on the Efficiency of Use by the Respective Controllers of the Budget Funds in 2008-2009 and in the First Quarter of 2010,\u0022 October 14, 2010 by Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP and Kroll Inc. posted on the wesbite of the Ministry of Finance at http:\/\/minfin.gov.ua\/document\/274231\/report1.pdf\n"},{"Case ID":"ARW-188","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ukrainian Government \/ Ministry of Emergency Situations","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Unspecified","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2010","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"On October 11, 2010, the Ministry of Emergency Situations of Ukraine (represented by Nabarro LLP) filed a civil claim in the High Court of Justice, Queen\u0027s Bench Division, against Legal Business Consultants Ltd., a UK company that is alleged to be part of an international conspiracy involving the inflated purchase price of depreciated vehicles to the ministry.  The claim seeks damages for conspiracy and deceit.  (Source: Government of Ukraine, Ministry of Finance, Main Control and Revision Office, \u0022Report of Investigative Findings: Pursuant to Agreement on Performance of Audit on the Efficiency of Use by the Respective Controllers of the Budget Funds in 2008-2009 and in the First Quarter of 2010,\u0022 October 14, 2010 Report by Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP, Kroll Inc.)","Disposition of Criminal Case(s)":"Unspecified","Jurisdiction of Origin: Investigative Agency":"Government of Ukraine, Ministry of Finance; Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP, Kroll Inc. ","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP, Kroll Inc.","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP","Jurisdiction of Asset Recovery: Courts Involved":"High Court, Queen\u0027s Bench","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Min_Finance_Investigation_Report_Oct_14_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Ukrvaktsina_Oregon_Complaint_Sep_17_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ukraine_Ukrvaktsina_Oregon_Court_Docket_Report_May_5_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ukraine_UK_Lawsuit_Interfax_Ukraine_Dec_10_2010.pdf","Sources ":"Government of Ukraine, Ministry of Finance, Main Control and Revision Office, \u0022Report of Investigative Findings: Pursuant to Agreement on Performance of Audit on the Efficiency of Use by the Respective Controllers of the Budget Funds in 2008-2009 and in the First Quarter of 2010,\u0022 October 14, 2010 Report by Trout Cacheris PLLC, Akin Gump Strauss Hauer \u0026 Feld LLP, Kroll Inc. posted on the website of the Ministry of Finance at http:\/\/minfin.gov.ua\/document\/274231\/report1.pdf; Interfax-Ukraine (Ukraine News Agency, \u0022Ukrainian government sues in UK, alleges corrupt scheme in purchases of emergency vehicles,\u0022 December 10, 2010, at http:\/\/en.interfax.com.ua\/news\/general\/50622.html.\n"},{"Case ID":"ARW-189","Case Title (Name of Public Official or Entity Allegedly Involved)":"Unnamed Case \/ Burkina Faso","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Burkina Faso","Position of Public Official(s) (yrs in office)":"Unspecified","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"2009","UNCAC Offenses Implicated":"","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Unspecified","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Unknown","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$500,000","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"\u0022Agreement to return the assets through selected NGO projects to the benefit of the population of Burkina Faso\u0022 (Source: Swiss Ministry of Foreign Affairs, September 30, 2009)","Case Summary":"According to the Swiss Ministry of Foreign Affairs, the asset return was completed in 2009.  The name of the case was not disclosed, but there was an \u0022Agreement to return the assets through selected NGO [Non-Governmental Organization] projects to the benefit of the population of Burkina Faso.\u0022  (Source:  Swiss  Ministry of Foreign Affairs, September 30, 2009.)","Disposition of Criminal Case(s)":"Unspecified","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Swiss Ministry of Foreign Affairs, September 30, 2009.\n"},{"Case ID":"ARW-191","Case Title (Name of Public Official or Entity Allegedly Involved)":"Vladimiro Montesinos (Cayman Islands)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Peru","Position of Public Official(s) (yrs in office)":"De facto chief of intelligence and main advisor of former Peruvian President Alberto Fujimori (1990-2000)","Jurisdiction of Asset Recovery":"Cayman Islands","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2001","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Letter of Request","Basis for Intl Cooperation":"Powers Granted to Cayman Grand Court under the Proceeds of Criminal\r\nConduct Law","Contributing Factors in Asset Recovery":"\u0022Effective results were achieved because of the willingness on the part of the Cayman authorities, to take recourse to restrain the money itself in rem out of concern that the local laws were also being violated, instead\r\nof awaiting a judgment in personam which may never have been forthcoming because of the fugitive status of the perpetrator and which would have to be also enforced to recover the proceeds which would have no doubt\r\ntaken flight within the restraint. Thus, what began simply as a letter of request to \u0022lift the bank, financial and stock market secrecy procedures, as well as to execute a preventive attachment in the form of a restraining order\u0022 on all and any bank accounts held in Grand Cayman in the name of Vladimiro Montesinos-Torres or in the name of several other related parties; ended in the repatriation of some $44 million dollars to Peru, without a trial between the parties having to take place. This happened because in urgent response to the Judicial Request from Peru, a restraint order was obtained from the Cayman Court, freezing the bank accounts which could be identified. This afforded the Peruvian Government the time it needed to prepare and present its case for the ultimate declaration of its ownership over those accounts as containing the proceeds of the crime.\u0022   (Source: Cayman Islands Government webpage on Enforcement of Judgments in Practice,\u0022 posted at http:\/\/www.gov.ky\/portal\/page?_pageid=1142,1687439\u0026_dad=portal\u0026_schema=PORTAL).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$44,000,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to Professor Guillermo Jorge, two sets of Montesinos-related funds were involved in the Cayman Islands:  (1) Assets restrained in rem with assistance of newly created Financial Intelligence Unit; Waivers signed by account holders, pursuant to their plea bargaining agreements with Peruvian authorities. [Cayman did not have provisions for adopting provisional measures. Order of restraint could only be made where shown there were already proceedings instituted.  But the Peruvian request for lifting bank secrecy and freezing assets transformed ex officio into a criminal complaint for money laundering, thereby eliminating the need to wait for an in personam judgment from Peru.] (2) Criminal complaint filed in Cayman against Wiese Sudameris International for suspicion of money laundering and freezing order in rem; financial analysis showed funds were never transferred to Cayman, but stayed in Peru; confiscation orders against funds located in Lima resulted in \u0022repatriation\u0022 of $33 milion. (Source: Professor Guillermo Jorge, \u0022The Peruvian efforts to recover the proceeds from Montesinos\u0027 criminal network of corruption,\u0022 presented at Asian Development Bank Regional Seminar, Bali\/Indonesia, September 5-7, 2007).","Disposition of Criminal Case(s)":"According to a case study by Professor Guillermo Jorge, as of September 2007, Mr. Montesinos had been convicted in 13 different trials and more than 70 trials were ongoing.  (Source:  Guillermo Jorge, \u0022The Peruvian Efforts to Recover Proceeds from Montesinos\u0027s Criminal Network of Corruption,\u0022 in  ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational Held in Bali, Indonesia, on 5-7 September 2007 and hosted by the Corruption Eradication Commission, Indonesia, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.)","Jurisdiction of Origin: Investigative Agency":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of theSpecial State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Financial Reporting Authority (CAYFIN) of the Cayman Islands","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"Grand Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Montesinos_Cayman_Islands_Chief_Justice_Speech_May_2006.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Montesinos_Cayman_Islands_Enforcement_Judgments.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Montesinos_Jorge_Case_Study_ADB_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Montesinos_StAR_Case_Study.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Montesinos_Cayman_Islands_Chief_Justice_Speech_May_2006.PDF","Sources ":"StAR Case study at http:\/\/www1.worldbank.org\/publicsector\/star_site\/documents\/Case_Studies_... Professor Guillermo Jorge, \u0022The Peruvian efforts to recover proceeds from Montesinos\u0027 criminal network of corruption,\u0022 Backgrounder paper presented at the Asian Development Bank\u0027s Regional Seminar for Asia-Pacific, \u0022Making international anti-corruption standards operational: Asset Recovery and mutual legal assistance,\u0022 September 5-7, 2007 (Bali, Indonesia), at 1 and 23 and fn 56, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.; Cayman Islands Government webpage on Enforcement of Judgments in Practice,\u0022 posted at http:\/\/www.gov.ky\/portal\/page?_pageid=1142,1687439\u0026_dad=portal\u0026_schema=P...) and a speech by Hon. Anthony Smellie, Chief Justice and Mututal Legal Assistance Authority, The Royal Cayman Islands, \u0022FORFEITING THE PROCEEDS OF CORRUPTION,\u0022 A Seminar on Asset Forfeiture and Money Laundering for Member States of the Organization of American States, May 2-5, 2006 in Miami, Florida.\n"},{"Case ID":"ARW-192","Case Title (Name of Public Official or Entity Allegedly Involved)":"Vladimiro Montesinos (Luxembourg)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Peru","Position of Public Official(s) (yrs in office)":"De facto chief of intelligence and main advisor of former Peruvian President Alberto Fujimori (1990-2000)","Jurisdiction of Asset Recovery":"Luxembourg","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Unspecified","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a Case Study by Professor Guillermo Jorge, citing official figures of the Office of the Special State Attorney for the Montesinos\/Fujimori Case, as of 2007, accounts valued at $ 47 million remain frozen in Switzerland, Mexico, Luxembourg and Panama. (Source: Professor Guillermo Jorge, \u0022The Peruvian efforts to recover the proceeds from Montesinos\u0027 criminal network of corruption,\u0022 presented at Asian Development Bank Regional Seminar, Bali\/Indonesia, September 5-7, 2007.)","Disposition of Criminal Case(s)":"According to a case study by Professor Guillermo Jorge, as of September 2007, Mr. Montesinos had been convicted in 13 different trials and more than 70 trials were ongoing.  (Source:  Guillermo Jorge, \u0022The Peruvian Efforts to Recover Proceeds from Montesinos\u0027s Criminal Network of Corruption,\u0022 in  ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational Held in Bali, Indonesia, on 5-7 September 2007 and hosted by the Corruption Eradication Commission, Indonesia, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.)","Jurisdiction of Origin: Investigative Agency":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of theSpecial State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Professor Guillermo Jorge, \u0022The Peruvian efforts to recover proceeds from Montesinos\u0027 criminal network of corruption,\u0022 Backgrounder paper presented at the Asian Development Bank\u0027s Regional Seminar for Asia-Pacific, \u0022Making international anti-corruption standards operational: Asset Recovery and mutual legal assistance,\u0022 September 5-7, 2007 (Bali, Indonesia), at 1 and 23 and fn 56, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf; Peru, Congreso de la Republica, Comision Investigadora sobre Los Delitos Economicos y Financieros Cometidos entre 1990-2001, Informe Final de Investigacion (June 2002), accessed at http:\/\/www.congreso.gob.pe\/comisiones\/2002\/CIDEF\/oscuga\/informecideffina....\n"},{"Case ID":"ARW-193","Case Title (Name of Public Official or Entity Allegedly Involved)":"Vladimiro Montesinos (Mexico)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Peru","Position of Public Official(s) (yrs in office)":"De facto chief of intelligence and main advisor of former Peruvian President Alberto Fujimori (1990-2000)","Jurisdiction of Asset Recovery":"Mexico","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Unspecified","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a Case Study by Professor Guillermo Jorge, citing official figures of the Office of the Special State Attorney for the Montesinos\/Fujimori Case, as of 2007, accounts valued at $47 million remain frozen in Switzerland, Mexico, Luxembourg and Panama. (Source: Professor Guillermo Jorge, \u0022The Peruvian efforts to recover the proceeds from Montesinos\u0027 criminal network of corruption,\u0022 presented at Asian Development Bank Regional Seminar, Bali\/Indonesia, September 5-7, 2007.)","Disposition of Criminal Case(s)":"According to a case study by Professor Guillermo Jorge, as of September 2007, Mr. Montesinos had been convicted in 13 different trials and more than 70 trials were ongoing.  (Source:  Guillermo Jorge, \u0022The Peruvian Efforts to Recover Proceeds from Montesinos\u0027s Criminal Network of Corruption,\u0022 in  ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational Held in Bali, Indonesia, on 5-7 September 2007 and hosted by the Corruption Eradication Commission, Indonesia, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.)","Jurisdiction of Origin: Investigative Agency":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of theSpecial State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Professor Guillermo Jorge, \u0022The Peruvian efforts to recover proceeds from Montesinos\u0027 criminal network of corruption,\u0022 Backgrounder paper presented at the Asian Development Bank\u0027s Regional Seminar for Asia-Pacific, \u0022Making international anti-corruption standards operational: Asset Recovery and mutual legal assistance,\u0022 September 5-7, 2007 (Bali, Indonesia), at 1 and 23 and fn 56, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf. Peru, Congreso de la Republica, Comision Investigadora sobre Los Delitos Economicos y Financieros Cometidos entre 1990-2001, Informe Final de Investigacion (June 2002), accessed at http:\/\/www.congreso.gob.pe\/comisiones\/2002\/CIDEF\/oscuga\/informecideffina....\n"},{"Case ID":"ARW-194","Case Title (Name of Public Official or Entity Allegedly Involved)":"Vladimiro Montesinos (Panama)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Peru","Position of Public Official(s) (yrs in office)":"De facto chief of intelligence and main advisor of former Peruvian President Alberto Fujimori (1990-2000)","Jurisdiction of Asset Recovery":"Panama","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Unspecified","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a Case Study by Professor Guillermo Jorge, citing official figures of the Office of the Special State Attorney for the Montesinos\/Fujimori Case, as of 2007, accounts valued at $47 million remain frozen in Switzerland, Mexico, Luxembourg and Panama. Professor Jorge wrote that bankers in Panama reported transactions related to Mr. Montesinos while he was a fugitive, and that the Financial Intelligence Unit of Panama initiated a case for suspected money laundering upon receiving several reports from its financial institutions.  Most of the acocunts in Panama, however, had been closed by the time the reports were made.   Professor Jorge\u0027s source for this information was his August 5, 2007 interview with Ms. Maribel Cornejo Batista, then-anticorruption prosecutor in Panama City.  (Source: Professor Guillermo Jorge, \u0022The Peruvian efforts to recover the proceeds from Montesinos\u0027 criminal network of corruption,\u0022 presented at Asian Development Bank Regional Seminar, Bali\/Indonesia, September 5-7, 2007).","Disposition of Criminal Case(s)":"According to a case study by Professor Guillermo Jorge, as of September 2007, Mr. Montesinos had been convicted in 13 different trials and more than 70 trials were ongoing.  (Source:  Guillermo Jorge, \u0022The Peruvian Efforts to Recover Proceeds from Montesinos\u0027s Criminal Network of Corruption,\u0022 in  ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational Held in Bali, Indonesia, on 5-7 September 2007 and hosted by the Corruption Eradication Commission, Indonesia, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.)","Jurisdiction of Origin: Investigative Agency":"Office of the Special State Attorney for the Montesinos \/Fujimori Case, Peru","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Unida de Analisis Financiero (Financial Intelligence Unit of Panama)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Professor Guillermo Jorge, \u0022The Peruvian efforts to recover proceeds from Montesinos\u0027 criminal network of corruption,\u0022 Backgrounder paper presented at the Asian Development Bank\u0027s Regional Seminar for Asia-Pacific, \u0022Making international anti-corruption standards operational: Asset Recovery and mutual legal assistance,\u0022 September 5-7, 2007 (Bali, Indonesia), at 1 and 23 and fn 56, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf. Peru, Congreso de la Republica, Comision Investigadora sobre Los Delitos Economicos y Financieros Cometidos entre 1990-2001, Informe Final de Investigacion (June 2002), accessed at http:\/\/www.congreso.gob.pe\/comisiones\/2002\/CIDEF\/oscuga\/informecideffina....\n"},{"Case ID":"ARW-195","Case Title (Name of Public Official or Entity Allegedly Involved)":"Vladimiro Montesinos (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Peru","Position of Public Official(s) (yrs in office)":"De facto chief of intelligence and main advisor of former Peruvian President Alberto Fujimori (1990\u20132000)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2000","Asset Recovery End":"2002, In part","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"International Mutual Assistance in Criminal Matters\r\n","Contributing Factors in Asset Recovery":"\u0022The return of the assets in the Montesinos case was made possible by efficient\r\ncooperation between the Swiss and Peruvian authorities and in particular by Swiss\r\nlaws against money laundering. On the basis of an obligation arising from the Money\r\nLaundering Act, the banks informed the Money Laundering Reporting Office at the\r\nFederal Office for Police Matters in October 2000 about the assets belonging to\r\nMontesinos and Hermoza Rios. The Money Laundering Reporting Office forwarded this\r\ninformation immediately to the Examining Magistrate\u0027s Office IV Canton of Zurich,\r\nwhich blocked the funds and initiated a criminal investigation. The knowledge gained in\r\nZurich was transferred by the Federal Office for Justice to the Peruvian judicial\r\nauthorities, which in turn made investigations and submitted the corresponding request\r\nfor legal assistance to Switzerland.\u0022\r\n","Status of Asset Recovery ":"Completed (in part) and Ongoing (in part)","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction (in part)","Assets Frozen (USD)":"$17,000,000","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$93,000,000","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Establishment of Special Fund for Management of Illegally Obtained Money against Interests of the State; a board comprised of representatives of Peruvian government agencies involved in the fight against corruption (Source: StAR Case Study, \u0022Vladimiro Montesinos.\u0022)","Case Summary":"According to the Swiss Ministry of Foreign Affairs, as of September 30, 2009, $93 million have been returned to Peru and $17 million remain frozen.  (Source: Swiss Ministry of Foreign Affairs, September 30, 2009.) An August 20, 2002 Swiss Federal Department of Justice press release had stated that, \u0022The account at Banco de la Nacion del Peru at Citibank in New York today received a credit of 77.5 million US dollars from Switzerland. This consisted largely of the blocked assets of Vladimiro Montesinos Torres and the former Peruvian general, Nicolas de Bari Hermoza Rios. The investigations carried out by the Examining Magistrate\u0027s Office IV Canton of Zurich revealed that the funds belonging to Montesinos that were frozen in Switzerland (totalling 49.5 million US dollars) originated from corruption-related crimes. Since 1990 Montesinos received \u0022commissions\u0022 on arms deliveries to Peru and had this bribe money paid to his bank accounts in Luxembourg, the USA and Switzerland. Montesinos received bribes for at least 32 transactions, each worth 18% of the purchase price. Montesinos also collected 10.9 million US dollars in \u0022commissions\u0022 on the purchase of three MIG29 planes, bought by the Peruvian airforce from the state owned Russian arms factory \u0022Rosvoorouzhenie\u0022. In return, Montesinos used his position to ensure that certain arms dealers were given preference when these orders were issued. On the basis of these facts, the Examining Magistrate\u0027s Office IV Canton of Zurich issued a decision on 12 June 2002 ordering the transfer of the assets belonging to Montesinos to Peru. This decision was not appealed and has since come into force. \/ Voluntary return \/ One of the arms dealers who enjoyed preferential treatment is voluntarily repatriating his commission from these transactions (7 million US dollars), hitherto held in Swiss bank accounts. General Nicolas de Bari Hermoza Rios also accepted bribes relating to arms deliveries to Peru. He too misappropriated funds from the military budget. All unlawfully obtained funds were ultimately paid into his bank accounts in Switzerland. Nicolas de Bari Hermoza Rios has agreed to this money (21 million US dollars) being returned to Peru.\u0022  The press release also stated that, \u0022In the Montesinos case, assets totalling 33 million US dollars remain blocked in Switzerland.\u0022 (Source:  Swiss Federal Department of Justice Press Release, \u0022Switzerland transfers 77 million U.S. dollars to Peru,\u0022 August 20, 2002.)","Disposition of Criminal Case(s)":"According to a case study by Professor Guillermo Jorge, as of September 2007, Mr. Montesinos had been convicted in 13 different trials and more than 70 trials were ongoing.  (Source:  Guillermo Jorge, \u0022The Peruvian Efforts to Recover Proceeds from Montesinos\u0027s Criminal Network of Corruption,\u0022 in  ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational Held in Bali, Indonesia, on 5-7 September 2007 and hosted by the Corruption Eradication Commission, Indonesia, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.)","Jurisdiction of Origin: Investigative Agency":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"The Money Laundering Reporting Office at the Federal Office for Police Matters; Examining Magistrate\u0027s Office IV Canton of Zurich; Federal Office for Justice","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Swiss Federal Supreme Court (BGE) decision, 129 II 462, 8 September 2003, posted as part of Montesinos case study at www.assetrecovery.org; Montesinos case: Swiss Federal Department of Justice Press Releases,\u0022Switzerland transfers 77 million U.S. dollars to Peru,\u0022 August 20, 2002, posted at http:\/\/www.bj.admin.ch\/content\/bj\/en\/home\/dokumentation\/medieninformatio... and \u0022Montesinos Torres affair: U.S.D 50 million blocked in Switzerland, November 3, 2000, posted at http:\/\/www.bj.admin.ch\/content\/bj\/en\/home\/dokumentation\/medieninformatio.... Montesinos Case study by Victor A. Dumas, in \u0022Stolen Asset Recovery (StAR) Initiative: Challenges, Opportunities and Tasks Ahead\u0022; Professor Guillermo Jorge, \u0022The Peruvian efforts to recover proceeds from Montesinos\u0027 criminal network of corruption,\u0022 Backgrounder paper presented at the Asian Development Bank\u0027s Regional Seminar for Asia-Pacific, \u0022Making international anti-corruption standards operational: Asset Recovery and mutual legal assistance,\u0022 September 5-7, 2007 (Bali, Indonesia), at 1 and 23 and fn 56, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.\n"},{"Case ID":"ARW-196","Case Title (Name of Public Official or Entity Allegedly Involved)":"Vladimiro Montesinos \/ Victor Alberto Venero Garrido","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Peru","Position of Public Official(s) (yrs in office)":"De facto chief of intelligence and main advisor of former Peruvian President Alberto Fujimori (Montesinos, 1990-2000) \/ Montesinos\u0027 Associate (Venero Garrido)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2000","Asset Recovery End":"2004","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation; Actions Initiated by Foreign Jurisdiction ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"\u0022Venero and his activities were brought to the attention of the FBI [Federal Bureau of Investigation] by the filing of a Suspicious Activity Report by Citibank\u0027s compliance officer in Long Island City, New York... Initially, the account opening did not raise any suspicion because Latin Americans often opened dollar-denominated bank accounts in the U.S. to protect their assets from inflation in their home countries.  However, Citibank and other financial institutions holding bank and brokerage accounts owned or controlled by Venero, Cheryle Mangino Diaz, and others gradually noticed unusual activity in the accounts and filed SARs with the U.S. Government.\u0022 Diaz was a California banker who was married to Venero\u0027s cousin and a former member of the board of directors of Hacienda Bank who had since 1996 helped Venero conceal more than $20 million in the U.S. (Source: Linda M. Samuel, \u0022Repatriation Obligations under the United Nations Convention Against Corruption,\u0022 Resource Material Series No. 65, accessed at the website of the United Nations Asia and Far East Institute for the Prevention of Crime and the Treatment of Offenders (UNAFEI)).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$34,736,372.08","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Agreement between U.S. and Peru that Peru would invest the returned assets in anti-corruption efforts.  Establishment of Special Fund for Management of Illegally Obtained Money against Interests of the State; a board comprised of representatives of Peruvian government agencies involved in the fight against corruption (Source: Acuerdo Entre el Gobierno de la Republica del Peru y El Gobierno de Los Estados Unidos de America Sobre Transferencia de Activos Decomisados, January 21, 2004.)","Case Summary":"According to Linda M. Samuel, then-Deputy Chief, Asset Forfeiture and Money Laundering Section of the U.S. Department of Justice, the U.S. Attorney\u0027s Office for the Central District of California and the Asset Forfeiture and Money Laundering Section of the Department of Justice restrained approximately $17.3 million connected to Mr. Venero-Garrido, ultimately forfeiting $15.9 million plus interest accrued.  During the investigation, U.S. law enforcement agents identified and forfeited approximately $4.3 million, plus interest accrued, in additional assets.  The combined net forfeited amount from these two judgments was $20,277,618.32.  She also notes that the investigation resulted in forfeiture of additional $358,753.76.  In addition, investigation by the FBI and the U.S. Attorney\u0027s Offie for the Southern District of Florida contributed to Montesinos\u0027 arrest and the direct return of additional assets to Peru, including at least $14.1 million repatriated directly by Mr. Venero-Garrido.  Ms. Samuel wrote that, \u0022The United States Department of Justice has approved transferring $20,277,618.32 in forfeited funds to the Government of Peru (GOP) in recognition of its assistance in the Venero case. The forfeited funds represent the proceeds of a broad range of fraud, corruption and money laundering offences committed in Peru and the United States that were connected to former Peruvian intelligence Chief Vladimiro Montesinos, his associate Victor Alberto Venero-Garrido, and other associates of Montesinos and former Peruvian President Alberto Fujimori. The statutory basis for the transfer under U.S. law is Title 18, United States Code, section 981(i)(1) authorizes the Attorney General to transfer money laundering proceeds and instrumentalities forfeited under 18 U.S.C. [Sections] 981 and\/or 982 to a foreign country that participated directly or indirectly in acts leading to the seizure and forfeiture of the property.\u0022 (Source: Linda M. Samuel, \u0022Repatriation Obligations under the United Nations Convention Against Corruption,\u0022 Resource Material Series No. 65 for the United Nations Asia and Far East Institute for the Prevention of Crime and the Treatment of Offenders (UNAFEI).  See also, US v. $17,317,700.38 in US currency, Case No. 1:01-cv-03444 (S.D.Fla.) and US v. $4,362,761.02 in US currency, Case No. 1:02-cv-21779 (S.D.Fla.).","Disposition of Criminal Case(s)":"According to a case study by Professor Guillermo Jorge, as of September 2007, Mr. Montesinos had been convicted in 13 different trials and more than 70 trials were ongoing.  (Source:  Guillermo Jorge, \u0022The Peruvian Efforts to Recover Proceeds from Montesinos\u0027s Criminal Network of Corruption,\u0022 in  ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational Held in Bali, Indonesia, on 5-7 September 2007 and hosted by the Corruption Eradication Commission, Indonesia, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.)","Jurisdiction of Origin: Investigative Agency":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation (Miami)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney\u0027s Office for the Southern District of Florida, with assistance from the United States Attorney\u2019s Office for the Central District of California and Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of Florida; U.S. District Court for the Central District of California","Documents":"","Sources ":"Linda M. Samuel, \u0022Repatriation Obligations under the United Nations Convention Against Corruption,\u0022 Resource Material Series No. 65, accessed at the website of the United Nations Asia and Far East Institute for the Prevention of Crime and the Treatment of Offenders (UNAFEI): http:\/\/www.unafei.or.jp\/english\/pdf\/PDF_rms\/no65\/RESOURCE-DivisionNo06.pdf; US v. $17,317,700.38 in US currency, Case No. 1:01-cv-03444 (S.D.Fla.), Complaint for Forfeiture in Rem filed August 9, 2001; Stipulation and Settlement Agreement filed April 25, 2003 and Final Order of Forfeiture filed April 29, 2002; US v. $4,362,761.02 in US currency, Case No. 1:02-cv-21779 (S.D.Fla.), Complaint for Forfeiture in Rem filed June 14, 2002 and Final Order of Forfeiture filed February 25, 2003. Professor Guillermo Jorge, \u0022The Peruvian efforts to recover proceeds from Montesinos\u0027 criminal network of corruption,\u0022 Backgrounder paper presented at the Asian Development Bank\u0027s Regional Seminar for Asia-Pacific, \u0022Making international anti-corruption standards operational: Asset Recovery and mutual legal assistance,\u0022 September 5-7, 2007 (Bali, Indonesia), at 1 and 23 and fn 56, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf. U.S. Department of Justice Press Release, \u0022Attorney General Eric Holder at the Opening Plenary of the VI Ministerial Global Forum on Fighting Corruption and Safeguarding Integrity\u0022 (Doha, Qatar), November 7, 2009, posted at http:\/\/www.justice.gov\/ag\/speeches\/2009\/ag-speech-091107.html; Acuerdo Entre el Gobierno de la Republica del Peru y El Gobierno de Los Estados Unidos de America Sobre Transferencia de Activos Decomisados, January 21, 2004, accessed at http:\/\/www.rree.gob.pe\/portal\/Tratados.nsf\/22ad71c70685eaa805256ea100718...$FILE\/B-3047%20ACUERDO%20PER%C3%9A%20-%20USA%20SOBRE%20TRANSFERENCIA%20DE%20ACTIVOS%20DECOMISADOS.pdf\n"},{"Case ID":"ARW-197","Case Title (Name of Public Official or Entity Allegedly Involved)":"Vladimiros Montesinos \/ Marco Antonio Rodriguez Huerta","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Peru","Position of Public Official(s) (yrs in office)":"De facto chief of intelligence and main advisor of former Peruvian President Alberto Fujimori (Montesinos, 1990-2000) \/ Brigadier General, Head of the Peruvian military and national Police Pension Fund (Huerta, 1995-1997)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"2009","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation; Actions Initiated by Foreign Jurisdiction ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"In furtherance of the U.S. investigation into the flow of illicit funds to the U.S. by Vladimiro Montesinos, Victor Alberto Venero Garrido, Marco Antonio Rodriguez Huerta and others, the Complaint in this case stated that  the Federal Bureau of Investigation and Immigration and Customs Enforcement worked closely with Peruvian law enforcement and prosecutorial authorities involved in the investigation of the criminal conduct in Peru.  A contingent of U.S. law enforcement agents and analysts travelled to Peru on a number of occasions.  Vast amounts of information and documents, including witness statements were exchanged between the two countries.  FBI and ICE also conducted additional witness interviews, both in Peru and in the U.S.  (Source:  U.S. v. Account No. 7630743391 et al, Case No. 1:04-cv-23073-PCH (S.D. Fla.), Complaint for Forfeiture In Rem filed on December 10, 2004.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$750,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a September 2, 2009 press release by the U.S. Department of Justice, more than $750,000 in forfeited funds from Mr. Rodriguez Huerta\u0027s embezzlement scheme was transferred by the U.S. to the Government of Peru. The press release noted that, \u0022The forfeited funds were taken from the private account of Marco Antonio Rodriguez Huerta, a former Peruvian Army General, who was also on the board of directors of the Peruvian Military and Police Pension Fund in 1996. According to court documents, by abusing those positions, Rodriguez Huerta was able to divert funds intended for use as retirement benefits for retired military and police officers into fraudulent real estate investments. These diverted funds were then transferred into the private accounts of Rodriguez Huerta and other high officials of the Peruvian government. According to court documents, Rodriguez Huerta and his associates utilized banking institutions in the United States to hide their illicit profits from the Peruvian government. For these crimes and other illegal activities, Rodriguez Huerta was arrested and convicted by Peruvian authorities in 2002, and sentenced to 15 years in prison in Peru.\u0022  In 2004, pursuant to a request by the Peruvian government, the U.S. Immigration and Customs Enforcement located assets in bank accounts in Florida.  The U.S. initiated a civil complaint in the District Court for the Southern District of Florida, which issued a Final Order of Forfeiture in 2005.  In May 2008, Peru submitted a petition for remission of forfeited property (under 28 C.F.R. section 9).  In U.S. Department of Justice approved repatriation to the Government of Peru and the Peruvian pension fund.  (Sources: U.S. v. Account No. 7630743391 et al, Case No. 1:04-cv-23073-PCH (S.D. Fla. 2004); DOJ Press Release, \u0022United States Transfers More than $750,000 in Forfeited Funds to Government of Peru,\u0022 September 2, 2009).  The U.S. Government\u0027s December 10, 2004 Complaint for Forfeiture in Rem had alleged that \u0022Rodriguez Huerta was involved in the laundering of in excess of five million dollars.\u0022 (Source: US v. The Contents of Paribas Investment Services, LLC Account, et al, Case No. 04-cv-23073-PCH (S.D. Fla.), Complaint for Forfeiture In Rem filed on December 10, 2004.)","Disposition of Criminal Case(s)":"According to a case study by Professor Guillermo Jorge, as of September 2007, Mr. Montesinos had been convicted in 13 different trials and more than 70 trials were ongoing.  (Source:  Guillermo Jorge, \u0022The Peruvian Efforts to Recover Proceeds from Montesinos\u0027s Criminal Network of Corruption,\u0022 in  ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational Held in Bali, Indonesia, on 5-7 September 2007 and hosted by the Corruption Eradication Commission, Indonesia, accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf.)  According to the U.S. Government\u0027s civil asset forfeiture complaint filed on December 10, 2004, \u0022Rodriguez Huerta was arrested and prosecuted in Peru for public corruption charges and illicit enrichment charges for money belonging to Peru.\u0022 (Source: US v. The Contents of BNP Paribas Investment Services, LLC Account, et al, Case No. 1:04-cv-23073-PCH (S.D. Fla.), Complaint for Forfeiture In Rem filed on December 10, 2004).","Jurisdiction of Origin: Investigative Agency":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Special State Attorney for the Montesinos\/Fujimori Case, Peru","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Immigration and Customs Enforcement, Office of Investigations (Miami); Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section; U.S. Attorney for the Southern District of Florida","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of Florida","Documents":"","Sources ":"US v. The Contents of BNP Paribas Investment Services, LLC Account, et al, Case No. 04-cv-23073-PCH (S.D. Fla.), Complaint for Forfeiture In Rem filed on December 10, 2004 and Final Order of Forfeiture filed on September 22, 2005; U.S. Department of Justice Press Release, \u0022United States Transfers More Than $750,000 in Forfeited Funds to Government of Peru,\u0022 September 2, 2009, accesed at http:\/\/www.justice.gov\/opa\/pr\/2009\/September\/09-crm-909.html.\n"},{"Case ID":"ARW-198","Case Title (Name of Public Official or Entity Allegedly Involved)":"Xu Chaofan (also known as Hui Yat Fai), Xu Guojun (also known as Hui Kit Shun), Yu Zhendong","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"China","Position of Public Official(s) (yrs in office)":"Bank of China, Guangdong Province Sub-Branch, Kaiping County, Executive Managers (successive):  Xu Chaofan (1992-1998);  Yu Zhendong (1998-2000); Xu Guojun (2000-2001)","Jurisdiction of Asset Recovery":"Hong Kong SAR, China","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2001","Asset Recovery End":"2010","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"US Department of Justice press release following the Bank of China Managers\u0027 sentencing cited the \u0022substantial assistance\u0022 by the government of the People\u0027s Republic of China, in particular the Ministries of Justice and Public Security along with the Hong Kong Department of Justice and Hong Kong Police Force, in producing evidence and making witnesses available, both for testimony at trial and videotaped depositions. (Source: U.S. Department of Justice Press Release, \u0022Former Bank of China Managers and Their Wives Sentenced for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 May 6, 2009.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"Bank of China (China) Ltd. brought civil action against its former managers and their corporate vehicles and related  bank accounts, and their co-conspirators. (Source: Hong Kong Appeals Court decision 2841\/2006)  The preliminary court decisions do not mention the amount being recovered, but noted that the scheme involved misappropriation of over 1 billion renminbi.  One of the corporate entities used to funnel the embezzled funds, Yau Hip Trading, held accounts at Bank of China (HK) Limited of more than HK $120 million.  (Source: Hong Kong Appeals Court decision, 5291\/2001)  Bank of China (Hong Kong) Ltd. was also involved in the recovery efforts.  In Hong Kong, civil cases are not public, hence a copy of the final judgment is not publicly available.)","Disposition of Criminal Case(s)":"According to a U.S. Department of Justice press release, Mr. Xu Chaofan and Mr. Xu Guojun were convicted on August 29, 2008, by a federal jury in Las Vegas on charges of racketeering, money laundering, international transportation of stolen property as well as passport and visa fraud. Mr. Yu Zhendong, pleaded guilty to engaging in a racketeering enterprise on Feb. 18, 2004, and voluntarily returned to China, where he was convicted for embezzlement for his role in the bank theft.  (Source: U.S. Department of Justice Press Release, Former Bank of China Managers and Their Wives Convicted for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 September 2, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/September\/08-crm-764.html.)","Jurisdiction of Origin: Investigative Agency":"China Ministry of Justice; Public Security Bureau, Guangdong Province ","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"Intermediate People\u0027s Court of Jiangmen City, Guangdong Province (secondary source)","Jurisdiction of Asset Recovery: Investigative Agency":"Department of Justice; Hong Kong Police Force","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice","Jurisdiction of Asset Recovery: Courts Involved":"Court of Appeal (Civil); District Court (criminal - co-conspirators)","Documents":"","Sources ":"Bank of China Ltd. v. Ever Joint Properties Limited and 18 additional defendants, HCA 2841\/2006 (October 12, 2007 decision), accessed at http:\/\/legalref.judiciary.gov.hk\/lrs\/common\/search\/search_result_detail_... Bank of China v. Kwong Wa Po and Ching Fo Chu, HCA 5291\/2001 (July 18, 2005 decision)\n"},{"Case ID":"ARW-199","Case Title (Name of Public Official or Entity Allegedly Involved)":"Xu Chaofan (also known as Hui Yat Fai), Xu Guojun (also known as Hui Kit Shun), Yu Zhendong","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"China","Position of Public Official(s) (yrs in office)":"Bank of China, Guangdong Province Sub-Branch, Kaiping County, Executive Managers (successive):  Xu Chaofan (1992-1998);  Yu Zhendong (1998-2000); Xu Guojun (2000-2001)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"2009","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Criminal Restitution ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"US Department of Justice press release following the Bank of China Managers\u0027 sentencing cited the \u0022substantial assistance\u0022 by the government of the People\u2019s Republic of China, in particular the Ministries of Justice and Public Security along with the Hong Kong Department of Justice and Hong Kong Police Force, in producing evidence and making witnesses available, both for testimony at trial and videotaped depositions. (Source: U.S. Department of Justice Press Release, \u0022Former Bank of China Managers and Their Wives Sentenced for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 May 6, 2009.)  Bank of China had filed a Petition Pursuant to 18 U.S.C Section 1963 Regarding Property Subject to Forfeiture requesting that the property named in the Forfeiture Allegations be applied to restitution. (Source: U.S. v. Chao Fan Xu, et al, Case No. 2:02-cr-0674-PMP (LRL) (D. Nev.), Final Order of Forfeiture filed on December 15, 2009).  ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"$482,000,000 (Restitution ordered to be paid to Bank of China)","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"As part of their sentence, the U.S. District Court for the District of Nevada ordered that the Mr. Xu and Mr. Xu pay $482 million in restitution to the Bank of China; the defendants were ordered jointly and severally liable for payment of the restitution.  (Source: U.S. v. Xu Guojun, Case No. 2:02-cr-00674-PMP-LRL (D. Nev.), Judgment in a Criminal Case, filed on May 11, 2009; U.S. Department of Justice Press Release, \u0022Former Bank of China Managers and Their Wives Sentenced for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 May 6, 2009.)  In addition, the court ordered the criminal forfeiture of cash, watches and jewelry seized at the time of their arrest.  (U.S. currency and foreign currency totalling $166,000 [note: foreign currency, where amounts were noted was converted using exchange rate as of December 15, 2009, the date of final forfeiture order.  No value was given for the numerous seized watches and jewelry.]  In June 2009, Bank of China had filed a Petition Pursuant to 18 U.S.C Section 1963 Regarding Property Subject to Forfeiture requesting that the property named in the Forfeiture Allegations be applied to restitution.  The court granted a Joint Motion for Various Relief Relating to Assets Subject to Forfeiture, and Bank of China agreed to dimiss, without prejudice, its Petition.  The Bank was granted the forfeited cash and property as described in Attachment A of the final forfeiture order. (Source: U.S. v. Chao Fan Xu, et al, Case No. 2:02-cr-0674-PMP (LRL) (D. Nev.), Final Order of Forfeiture filed on December 15, 2009).","Disposition of Criminal Case(s)":"According to a U.S. Department of Justice press release, Mr. Xu Chaofan and Mr. Xu Guojun were convicted on August 29, 2008, by a federal jury in Las Vegas on charges of racketeering, money laundering, international transportation of stolen property as well as passport and visa fraud. Mr. Yu Zhendong, pleaded guilty to engaging in a racketeering enterprise on Feb. 18, 2004, and voluntarily returned to China, where he was convicted for embezzlement for his role in the bank theft.  (Source: U.S. Department of Justice Press Release, Former Bank of China Managers and Their Wives Convicted for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 September 2, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/September\/08-crm-764.html.)","Jurisdiction of Origin: Investigative Agency":"China Ministry of Justice and Public Security Bureau, Guangdong Province; Hong Kong Department of Justice and Hong Kong Police Force","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"Intermediate People\u0027s Court of Jiangmen City, Guangdong Province (secondary source)","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, Las Vegas Field Office; U.S. Immigration and Customs Enforcement; Support provided by Federal Bureau of Investigation, Beijing and Hong Kong offices","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the District of Nevada; Department of Justice, Cirminal Division, Organized Crime \u0026 Racketeering Section and Public Integrity Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Nevada; Supreme Court of British Columbia","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_Guojun_US_Judgment_May_11_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_DOJ_Press_Release_Conviction_Sep_2_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_DOJ_Press_Release_Sentencing_May_6_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Final_Order_Forfeiture_Dec_15_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Second_Superseding_Indictment_Jan_31_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Yu_Zhendong_Indictment_Dec_17_2002.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Yu_Zhendong_Return_Embassy_Press_Release_Apr_20_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Yu_Zhendong_Sentence_News_Guangdong_Apr_3_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Yu_Zhendong_Stipulation_Jan_22_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Yu_Zhengdong_Extradition_Lewis.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yu_Banker%20in%20Guangdong%20sentenced%2012%20years%20in%20prison_Guangdong_Times_Apr_3_2006_0.pdf","Sources ":"U.S. v. Xu Chaofan, Xu Guojun, et al Case No. 2:02-cr-00674-PMP-LRL (D. Nev.), Second Superseding Indictment filed January 31, 2006 and Judgment in a Criminal Case (Xu Guojun) filed on May 11, 2009, and Final Order of Forfeiture filed on December 15, 2009; U.S. Department of Justice Press Release, \u0022Former Bank of China Managers and Their Wives Sentenced for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 May 6, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/May\/09-crm-446.html and \u0022Former Bank of China Managers and Their Wives Convicted for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 September 2, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/September\/08-crm-764.html.\n"},{"Case ID":"ARW-200","Case Title (Name of Public Official or Entity Allegedly Involved)":"Xu Chaofan (also known as Hui Yat Fai), Xu Guojun (also known as Hui Kit Shun), Yu Zhendong","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"China","Position of Public Official(s) (yrs in office)":"Bank of China, Guangdong Province Sub-Branch, Kaiping County, Executive Managers (successive):  Xu Chaofan (1992-1998);  Yu Zhendong (1998-2000); Xu Guojun (2000-2001)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"2004","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"News Guangdong article noted that Mr. Yu \u0022is the first corrupt Chinese official to be repatriated since China ratified the United Nation\u0027s Convention Against Corruption in October, 2005.\u0022 (Source: News Guangdong, \u0022Banker in Guangdong Sentenced 12 Years in Prison,\u0022 April 3, 2006.); U.S. Department of Justice press release following the Bank of China Managers\u0027 convictions cited the \u0022substantial assistance\u0022 by the government of the People\u2019s Republic of China, in particular the Ministries of Justice and Public Security along with the Hong Kong Department of Justice and Hong Kong Police Force, in producing evidence and making witnesses available, both for testimony at trial and videotaped depositions. (Source: U.S. Department of Justice Press Release, \u0022Former Bank of China Managers and Their Wives Convicted for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 September 2, 2008.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$3,750,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"Yu Zhendong, one of the defendants in the criminal case against the three Bank of China managers, pleaded guilty and agreed to be extradited to China.  The agreement came after extensive negotiations between China and the U.S. which resulted in agreement that Mr. Yu would not face execution upon his return to China.  Mr. Yu also agreed to forfeiture of money embezzled from the Bank of China, including approximately $3,750,000 in U.S. currency that had already been seized and returned to China.  (Sources: U.S. v. Zhen Dong Yu, Case No. 2:02-cr-00673-RLH-RJJ (D.C. Nev.), Indictment filed on December 17, 2002 and Stipulation to Continue Trial Date, filed January 22, 2004; U.S. Embassy Beijing Press Release, \u0022Chinese National Sentenced on Racketeering Charges Returned to China After Embezzling Approximately $485 Million from the Bank of China,\u0022 April, 20, 2004). According to the News Guangdong, upon his return to China, Mr. Yu was tried by the Intermediate People\u0027s Court of Jiangmen City, Guangdong Province and sentenced to 12 years\u0027 imprisonment and confiscation of 1 million yuan ($125,000) on graft and embezzlement of public funds. The article noted that Mr. Yu \u0022is the first corrupt Chinese official to be repatriated since China ratified the United Nation\u0027s Convention Against Corruption in October, 2005.\u0022 (Source: News Guangdong, \u0022Banker in Guangdong Sentenced 12 Years in Prison,\u0022 April 3, 2006.)","Disposition of Criminal Case(s)":"According to a U.S. Department of Justice press release, Mr. Xu Chaofan and Mr. Xu Guojun were convicted on August 29, 2008, by a federal jury in Las Vegas on charges of racketeering, money laundering, international transportation of stolen property as well as passport and visa fraud. Mr. Yu Zhendong, pleaded guilty to engaging in a racketeering enterprise on Feb. 18, 2004, and voluntarily returned to China, where he was convicted for embezzlement for his role in the bank theft.  (Source: U.S. Department of Justice Press Release, Former Bank of China Managers and Their Wives Convicted for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 September 2, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/September\/08-crm-764.html.)","Jurisdiction of Origin: Investigative Agency":"China Ministry of Justice; Public Security Bureau, Guangdong Province; Hong Kong Department of Justice and Hong Kong Police Force","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"Intermediate People\u0027s Court of Jiangmen City, Guangdong Province (secondary source)","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, Las Vegas Field Office; U.S. Immigration and Customs Enforcement; Support provided by Federal Bureau of Investigation, Beijing and Hong Kong offices","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the District of Nevada; Department of Justice, Cirminal Division, Organized Crime \u0026 Racketeering Section and Public Integrity Section; Criminal Division, Office of International Affairs; U.S. Attorney for the Central District of California","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Nevada; Supreme Court of British Columbia","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_DOJ_Press_Release_Sentencing_May_6_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Yu_Zhendong_Indictment_Dec_17_2002.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Yu_Zhendong_Return_Embassy_Press_Release_Apr_20_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Yu_Zhendong_Sentence_News_Guangdong_Apr_3_2006.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Xu_US_Yu_Zhendong_Stipulation_Jan_22_2004.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yu_Banker%20in%20Guangdong%20sentenced%2012%20years%20in%20prison_Guangdong_Times_Apr_3_2006.pdf","Sources ":"U.S. v. Zhen Dong Yu, Case No. 2:02-cr-00673-RLH-RJJ (D.C. Nev.), Indictment filed on December 17, 2002 and Stipulation to Continue Trial Date, filed January 22, 2004; U.S. Department of Justice Press Release, \u0022Former Bank of China Managers and Their Wives Convicted for Stealing More Than $485 Million, Laundering Money Through Las Vegas Casinos,\u0022 September 2, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/September\/08-crm-764.html. U.S. Embassy Beijing Press Release, \u0022Chinese National Sentenced on Racketeering Charges Returned to China After Embezzling Approximately $485 Million from the Bank of China,\u0022 April, 20, 2004; News Guangdong, \u0022Banker in Guangdong Sentenced 12 Years in Prison,\u0022 April 3, 2006, accessed at http:\/\/www.newsgd.com\/citiesandtowns\/jiangmen\/news\/200604030074.htm.) Margaret K. Lewis, \u0022Mutual Legal Assistance and Extradition: Human Rights Implications,\u0022 accessed at http:\/\/papers.ssrn.com\/sol3\/papers.cfm?abstract_id=1432469.\n"},{"Case ID":"ARW-201","Case Title (Name of Public Official or Entity Allegedly Involved)":"Zine El Abidine Ben Ali \/ Belhassen Trabelsi (Canada)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Tunisia","Position of Public Official(s) (yrs in office)":"President (Ben Ali, 1987-2011); Son-in-law of President (Trabelsi)","Jurisdiction of Asset Recovery":"Canada","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tFor detailed background on the freeze of assets related to Mr. Ben Ali and associated individuals, see \u0022Freezing Assets of Corrupt Foreign Officials (Tunisia and Egypt) Regulations, SOR\/2011-78, at http:\/\/laws-lois.justice.gc.ca\/eng\/regulations\/sor-2011-78\/fulltext.html).\n\n\t\u00a0\n\n\tOn March 3, 2011, Foreign Affairs Minister Lawrence Cannon and Minister of Justice Rob Nicholson \u0022introduced legislation that would make it easier for the country to unilaterally freeze the assets of corrupt foreign leaders. The Freezing Assets of Corrupt Regimes Act comes amid pressure on the government to freeze assets belonging to ousted Tunisian leader Zine El Abidine Ben Ali and his family, some of whom have taken refuge in Canada.\u0022 (Source: \u00a0Joe Palazzolo, \u0022Canadian Gov\u2019t Introduces Asset Freeze Bill,\u0022 Wall Street Journal Corruption Currents blog, March 3, 2011. \u00a0Official text of the Bill C-61 can be accessed at website of the Parliament of Canada. \u00a0Please see source column for link.) \u00a0\u00a0\n\n\t\u00a0\n\n\tAccording to the June 27, 2014 decision by the Canadian Federal Court in Montreal, \u0022Zohra Djilani and Belhassen Trabelsi, and their four minor children, are subject to the Freezing Assets of Corrupt Foreign Officials (Tunisia and Egypt) Regulations, SOR\/2011 (Regulations), which were adopted by the Minister of Foreign Affairs and International Trade (Minister) following the events of the Arab Spring. This is an application for judicial review of the Minister\u2019s decision dated June 26, 2013, rejecting their application for a certificate filed pursuant to section 15 of the Freezing Assets of Corrupt Foreign Officials Act, SC 2001, c 10 (Act). By that application, the applicants were seeking to exclude the amount of $109,680 from the application of the Regulations to then transfer it into their lawyers\u2019 trust accounts.\u0022 \u00a0(Source: Trabelsi Et al v. MSPPC, Et al, 2014 FC 631, full text available at http:\/\/decisions.fct-cf.gc.ca\/fc-cf\/decisions\/en\/item\/72380\/index.do?r=A...) \u00a0 According to the Judgment, \u0022In that new application, the applicants explained that the amount must be used to pay for certain living expenses (including counsel fees), but also luxury products and services such as a chauffeur for the family, a non-subsidized private English school for the couple\u2019s children and their apartment, the monthly rent of which is $5,000.\u0022 \u00a0for period of six months beginning January 2013. The Court held that the Minister\u0027s decision was reasonable and rejected the application. \u00a0Mr. Trabelsi, wife and two children are seeking asylum in Canada. (Source: Belhassen Trabelsi Et al v. MSPPC, Et al, Case number IMM\u00ad3644\u00ad12, Docket as of February 5, 2015)\n\n\t\u00a0\n\n\tAccording to media reports, a Canadian Civil Society Organization has alleged that former president Ben Ali\u0027s son-in-law Sakhr El Makeri (married to daughter Nesrine) purchased, in 2008, a CAD 2.8 million mansion in Westmount section of Montreal. \u00a0Abdelijelil Ouanes, president of the Canadian Tunisian Chamber of Commerce in Montreal was quoted as saying that Ben Ali family members also held bank accounts in Canada. \u00a0(Source: Andrew Chung, \u0022Montreal lawyer launches effort to freeze Ben Ali Assets,\u0022 Thestar.com (Montreal), January 24, 2011). \u00a0According to a May 25, 2012 article in Foreign Policy, a $2.5 million mansion and $100,000 bank account belonging to the Ben Ali family have been \u0022seized\u0022 in Canada. \u00a0(Source: Fadil Aliriza, \u0022The godfathers of Tunis,\u0022 Foreign Policy, May 25, 2012.)","Disposition of Criminal Case(s)":"According to a January 26, 2011 media release by INTERPOL, Mr. Ben Ali\u0027s arrest was sought by Tunisia on charges of alleged property theft and illegal transfer of foreign currency. (Source: INTERPOL media release, \u0022Tunisia seeks ousted President and family via INTERPOL,\u0022 January 26, 2011, accessed at http:\/\/www.interpol.int\/public\/ICPO\/PressReleases\/PR2011\/PR007.asp.) According to secondary sources, Mr. Ben Ali was convicted in absentia in June 2011 on theft and unlawful possesion of cash and jewelry; in July 2011, he was convicted of property related charges. (Source: BBC News, \u0022Tunisia\u0027s Ben Ali guilty on drugs and gun charges,\u0022 July 4, 2011 and \u0022Tunisia\u0027s Ben Ali guilty of corrupt property deals,\u0022 July 29, 2011) and in June 2012, he was sentenced by a Tunisian military court to life imprisonment for his complicity in the murder and attempted murder of demonstrators; Human Rights Watch noted that Mr. Ben Ali has been tried and convicted in absentia and if he returned to Tunisia, he would be entitied to a new trial. (Source: Clive Baldwin, \u0022After Ben-Ali\u0027s Conviction: The State of Tunisian Justice,\u0022 Human Rights Watch, June 16, 2012.)","Jurisdiction of Origin: Investigative Agency":"Commission for the Investigation of Corruption and Embezzlement; Attorney Enrico Monfrini (civil asset recovery)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Asset Recovery: Courts Involved":"Federal Court (Montreal)","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Montreal_Assets_Thestar_Jan_24_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Summary_Law_Freeze_Assets_Corrupt_Regimes_Mar_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Text_Bill_C-61_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_INTERPOL_Alert_Jan_26_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Trabelsi_Asylum_CBC_News_Jan_31_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_Canada_Freeze_Assets_Corrupt_Foreign_Officals_Act.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Montreal_Assets_Thestar_Jan_24_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Summary_Law_Freeze_Assets_Corrupt_Regimes_Mar_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Text_Bill_C-61_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_INTERPOL_Alert_Jan_26_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Trabelsi_Asylum_CBC_News_Jan_31_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_Canada_Trabelsi_Fed_Ct_Judgment_Jun_27_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Montreal_Assets_Thestar_Jan_24_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Summary_Law_Freeze_Assets_Corrupt_Regimes_Mar_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Text_Bill_C-61_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_INTERPOL_Alert_Jan_26_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Canada_Trabelsi_Asylum_CBC_News_Jan_31_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_Trabelsi_Canada_Fed_Ct_immigration-docket_Feb_5_2015.pdf","Sources ":"\n\t\u0022Freezing Assets of Corrupt Foreign Officials (Tunisia and Egypt) Regulations, SOR\/2011-78, at http:\/\/laws-lois.justice.gc.ca\/eng\/regulations\/sor-2011-78\/fulltext.html;\u00a0\n\n\t\u00a0\n\n\tCanada News Centre, \u0022Harper Government Introduces Freezing Assets of Corrupt Regimes Act,\u0022 March 3, 2011, accessed at http:\/\/news.gc.ca\/web\/article-eng.do?m=\/index\u0026nid=593199; Text of Bill C-61, \u0022An Act to provide for the taking of restrictive measures in respect of the property of officials and former officials of foreign states and of their family members\u0022 and related documents can be accessed at the official website of the Parliament of Canada, LEGISinfo, at http:\/\/www2.parl.gc.ca\/Sites\/LOP\/LEGISINFO\/index.asp?Language=E\u0026Chamber=...\n\n\t\u00a0\n\n\tTrabelsi Et al v. MSPPC, Et al, 2014 FC 631, full text available at http:\/\/decisions.fct-cf.gc.ca\/fc-cf\/decisions\/en\/item\/72380\/index.do?r=A...); Belhassen Trabelsi Et al v. MSPPC, Et al, Case number IMM\u00ad3644\u00ad12, Docket as of February 5, 2015, accessible at http:\/\/cas-ncr-nter03.cas-satj.gc.ca\/portal\/page\/portal\/fc_cf_en\/Court_I...\n\n\t\u00a0\n\n\tCBC News, \u0022Canada keen to extradite Tunisian billionaire,\u0022 January 28, 2011; Montreal Gazette, \u0022Trabelsi loses bid to stay in Canada,\u0022 May 8, 2012;\u00a0\n\n\t\u00a0\n\n\tFadil Aliriza, \u0022The godfathers of Tunis,\u0022 Foreign Policy, May 25, 2012 "},{"Case ID":"ARW-202","Case Title (Name of Public Official or Entity Allegedly Involved)":"Zine El Abidine Ben Ali (European Union)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Tunisia","Position of Public Official(s) (yrs in office)":"President (1987-2011)","Jurisdiction of Asset Recovery":"European Union","Jurisdiction of Asset Description":"Undertaking Recovery Effort","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tThe Council Regulation and Implementing Regulations were subsequently amended, including in early 2015. See Council Implementing Regulation (EU) No. 2015\/147 (OJL 26, January 31, 2015, at http:\/\/eur-lex.europa.eu\/legal-content\/EN\/TXT\/?uri=OJ:JOL_2015_026_R_0002.\n\n\t\u00a0\n\n\tAs summarized in an article by Edwards Wildman Palmer attorneys, \u0022On 28 May 2013, the EU General Court (\u201cthe Court\u201d), attached to the European Court of Justice, gave three judgments in Cases T-187\/11 Trabelsi, T-188\/11 Chiboub and T-200\/11 Al Matri, in which it annulled the sanctions listing of three relatives of former President Ben Ali of Tunisia.\n\n\t\u00a0\n\n\tMr Al Matri and Mr Chiboub are the sons-in-law of former President Ben Ali and Mr Mohamed Trabelsi is the nephew of his wife. The three individuals and other persons connected to Mr Trabelsi brought proceedings contesting the freezing of their assets pursuant to Council Decisions 2011\/72\/CFSP and 2011\/79\/CFSP.\n\n\t\u00a0\n\n\tThe Court reached similar conclusions in each of the three cases annulling the sanctions. In reaching a decision, the Court noted that Article 1(1) of 2011\/72\/CFSP required that only persons \u201cresponsible for misappropriation of Tunisian State funds\u201d and those associated with them may be subject to an asset freeze, while Decision 2011\/79\/CFSP froze the assets of the applicants on the basis that they were subject to \u201cjudicial investigation by the Tunisian authorities in respect of the acquisition of movable and immovable property, the opening of bank accounts and the holding of financial assets in several countries as part of money laundering operations.\u201d\n\n\t\u00a0\n\n\tThe Court held that the Council had not established that under Tunisian law, \u201cmisappropriation of public funds\u201d encompassed \u201cmoney laundering\u201d (offences for which the Tunisian authorities were stated to be investigating the applicants). The Court held that the Council had not established that the investigations had been launched in relation to the laundering of public rather than private funds. The Court further held that the fact that the applicants were related to Ben Ali was not sufficient to imply that the money laundering investigations related to the misappropriation of state funds, since there was no such presumption in any of the legislation.\n\n\t\u00a0\n\n\tIn all three cases, the Court annulled Decision 2011\/79\/CFSP insofar as it related to them. The funds will not be immediately released because the European Council has two months to challenge the decision. If this does not happen, the freeze will end.\u0022 (Source: \u00a0Antonio Suarez-Martinez and Nicole Grow, Edwards Wildman Palmer LLP, \u0022Tunisian asset recovery efforts: one step forward and two steps back?,\u0022 June 11, 2013.) \u00a0The applications, judgments and orders in these and other related cases are listed in the source field and may be accessed at European Union Case-Law website at http:\/\/europa.eu\/eu-law\/case-law\/index_en.htm.\n\n\t\u00a0\n\n\tAccording to the statement issued by the Tunisian-European Union Task Force at the conclusion of its first meetings on September 28-29, 2011 in Tunis, the group stressed the importance of recovering stolen assets, including overcoming barriers and challenges related to it, as part of their joint work. \u00a0(Source: Meeting of the Tunisia - European Union Task Force, September 28-29, 2011 in Tunis, Co-chairs Conclusions.) \u00a0On February 7, 2011, the Council of the European Union had announced that they had \u0022adopted a decision and a regulation imposing the freezing of assets owned or controlled by persons deemed to be responsible for the misappropriation of state funds in Tunisia and persons associated with them.\u0022 The decision and regulation, \u0022which target a list of 48 persons, including former president Zine El Abidine Ben Ali and his wife, were published on 5 February 2011 in the EU Official Journal. The decision amends and updates decision 2011\/72\/CFSP, adopted on 31 January.\u0022 (Source: Council of The European Union Press Release, \u0022Tunisia: Council imposes assets freeze,\u0022 February 7, 2011. Council Regulation (EU) No 101\/2011- concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Tunisia.) \u00a0The Council Regulation and Implementing Regulations were subsequently amended, including in early 2015. See Council Implementing Regulation (EU) No. 2015\/147 (OJL 26, January 31, 2015, at http:\/\/eur-lex.europa.eu\/legal-content\/EN\/TXT\/?uri=OJ:JOL_2015_026_R_0002.","Disposition of Criminal Case(s)":"According to a January 26, 2011 media release by INTERPOL, Mr. Ben Ali\u0027s arrest was sought by Tunisia on charges of alleged property theft and illegal transfer of foreign currency. (Source: INTERPOL media release, \u0022Tunisia seeks ousted President and family via INTERPOL,\u0022 January 26, 2011, accessed at http:\/\/www.interpol.int\/public\/ICPO\/PressReleases\/PR2011\/PR007.asp.) According to secondary sources, Mr. Ben Ali was convicted in absentia in June 2011 on theft and unlawful possesion of cash and jewelry; in July 2011, he was convicted of property related charges. (Source: BBC News, \u0022Tunisia\u0027s Ben Ali guilty on drugs and gun charges,\u0022 July 4, 2011 and \u0022Tunisia\u0027s Ben Ali guilty of corrupt property deals,\u0022 July 29, 2011) and in June 2012, he was sentenced by a Tunisian military court to life imprisonment for his complicity in the murder and attempted murder of demonstrators; Human Rights Watch noted that Mr. Ben Ali has been tried and convicted in absentia and if he returned to Tunisia, he would be entitied to a new trial. (Source: Clive Baldwin, \u0022After Ben-Ali\u0027s Conviction: The State of Tunisian Justice,\u0022 Human Rights Watch, June 16, 2012.)","Jurisdiction of Origin: Investigative Agency":"Commission for the Investigation of Corruption and Embezzlement; Attorney Enrico Monfrini (asset recovery)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_European_Union_Council_Decision_Feb_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_European_Union_Council_PR_Feb_7_2011.pdf Ben_Ali_Tunisia_EU_Taskforce_Meeting_Statement_Sep_29_2011 Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_EU_Edwards_Wildman_Article_EU_General_Court_Judgments_Jun_11_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_European_Union_Council_Decision_Feb_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_European_Union_Council_PR_Feb_7_2011.pdf Ben_Ali_Tunisia_EU_Taskforce_Meeting_Statement_Sep_29_2011 Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_EU_General_Court_Judgment_Cases_Trabelsi_Choboub_Al_Matri_May_28_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_European_Union_Council_Decision_Feb_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_European_Union_Council_PR_Feb_7_2011.pdf Ben_Ali_Tunisia_EU_Taskforce_Meeting_Statement_Sep_29_2011 Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_EU_Council_Impl_Reg_2015_147_Jan_30_2015.pdf","Sources ":"\n\tCouncil Implementing Regulation (EU) No. 2015\/147 (OJL 26, January 31, 2015, at http:\/\/eur-lex.europa.eu\/legal-content\/EN\/TXT\/?uri=OJ:JOL_2015_026_R_0002;\n\n\t\u00a0\n\n\tJudgments, EU General Court, Case T-187\/11 Trabelsi, Case T-188\/11 Chiboub and T-200\/11 Al Matri at http:\/\/eur-lex.europa.eu\/LexUriServ\/LexUriServ.do?uri=OJ:C:2013:225:0068... \u00a0\n\n\t\u00a0\n\n\tTrabelsi and Others v. Council (Case T-187\/11); Chiboub v. Council (Case T-188\/11); El-Matri v. Council (Case T-200\/11); Ben Ali v. Council (Case T-301-11); Ben Ali v. Council (Case T-133\/12); CW v. Council (Case T-162\/12); Al Matri v. Council (Case T-545\/13); Ben Ali v. Council (Case T-200\/14); Mabrouk v. Council (Case T-218\/14) - Orders, Judgments and Applications accessible at European Union Case-Law, http:\/\/europa.eu\/eu-law\/case-law\/index_en.htm;\n\n\t\u00a0\n\n\tAntonio Suarez-Martinez and Nicole Grow, Edwards Wildman Palmer LLP, \u0022Tunisian asset recovery efforts: one step forward and two steps back?,\u0022 June 11, 2013, accessed at http:\/\/www.lexology.com\/library\/detail.aspx?g=796ed555-372b-4c78-ac1a-0b...\n\n\t\u00a0\n\n\tMeeting of the Tunisia - European Union Task Force, September 28-29, 2011 in Tunis, Co-chairs Conclusions, accessed at http:\/\/www.eeas.europa.eu\/tunisia\/docs\/20110929_taskforce_en.pdf; Council of The European Union Press Release, \u0022Tunisia: Council imposes assets freeze,\u0022 February 7, 2011, at http:\/\/www.consilium.europa.eu\/uedocs\/cms_data\/docs\/pressdata\/EN\/foraff\/... \u00a0Text of Decision at http:\/\/eur-lex.europa.eu\/LexUriServ\/LexUriServ.do?uri=OJ:L:2011:031:0040... Text of Regulation at http:\/\/eur-lex.europa.eu\/LexUriServ\/LexUriServ.do?uri=OJ:L:2011:031:0001... INTERPOL Alert, \u0022Tunisia seeks ousted President and family via INTERPOL,\u0022 January 26, 2011, accessed at http:\/\/www.interpol.int\/public\/ICPO\/PressReleases\/PR2011\/PR007.asp; BBC News, \u0022Tunisia\u0027s Ben Ali guilty on drugs and gun charges,\u0022 July 4, 2011, accessed at http:\/\/www.bbc.co.uk\/news\/world-africa-14014757 and \u0022Tunisia\u0027s Ben Ali guilty of corrupt property deals,\u0022 July 29, 2011, accessed at http:\/\/www.bbc.co.uk\/news\/world-africa-14340863.\n"},{"Case ID":"ARW-203","Case Title (Name of Public Official or Entity Allegedly Involved)":"Zine El Abidine Ben Ali (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Tunisia","Position of Public Official(s) (yrs in office)":"President (1987-2011)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual legal assistance","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"$66,149,000","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tAccording to Swissinfo.ch. in April 2014, the Swiss Federal Prosecutor\u0027s Office announced that it would unfreeze US $40 million being held in Swiss banks: \u00a0\u201cThe decision is the result of good collaboration with the Tunisian authorities,\u201d Federal Prosecutor Michael Lauber told Swiss public radio, SRF, on Friday.\n\n\t\u00a0\n\n\tThe Tunisian authorities were able to provide enough evidence to allow the monies, which were linked to Tunisia\u2019s former autocrat Zine el-Abidine Ben Ali, to be returned prematurely.\n\n\t\u00a0\n\n\tHowever, the decision is still not definitive, as an appeal could be lodged at the Federal Criminal Court.\n\n\t\u00a0\n\n\tThe cabinet blocked around CHF60 million ($68.5 million) in assets from Tunisia after the fall of Ben Ali in January 2011.\n\n\t\u00a0\n\n\tThe Federal Prosecutor\u2019s Office hopes that the rest of the funds can also be returned soon. \u201cThere are other millions that are blocked in Switzerland. We are trying to go forward there as well,\u201d Lauber stated.\u0022 (Source: Swissinfo.ch, \u0022Swiss unfreeze $40 million of Tunisian assets,\u0022 April 11, 2014.)\n\n\t\u00a0\n\n\tAccording to a media release by the Swiss Federal Department of Foreign Affairs of January 19, 2011, the Swiss government announced that it had frozen assets connected to Mr. Ben Ali. \u00a0The ordinances which originally applied for three years was further extended in 2014 for three additional years. \u00a0(Source: Swiss Federal Department of Foreign Affairs Media Release, \u0022Federal Council orders freeze of any assets held by former Tunisian President Ben Ali in Switzerland,\u0022 January 19, 2011; Swiss Federal Department of Foreign Affairs, \u0022Freezing of Assets: Tunisia\u0022, last updated April 28, 2016.) \u00a0 The Swiss government subsequently announced that it had received a request for assistance from Tunisian authorities, and the January 19th Special Ordinance was amended on January 28th and February 4 with an updated list of individuals whose assets are to be frozen. \u00a0(Source: \u00a0Swiss Ordinance, Verordnung uber Massnahmen gegen gewisse Personen aus Tunesien, Anderung, February 4, 2011 (amending ordinances of January 28, 2011 and January 19, 2011.) \u00a0 According to a September 27, 2011 statement by the Swiss Federal Department of Foreign Affairs, \u0022Soon after the overthrow of Ben Ali, Switzerland became the first country in the world to freeze the assets of persons associated with the regime. \u00a0These total some 60 million Swiss francs. \u0027Returning illicit funds is our first priority, and is a core element in the support that Switzerland would like to provide for Tunisia\u0027s transformation process,\u0027 said Federal President Calmy-Rey before the conference [of the EU-Tunisia Task Force].\u0022 (Source: Swiss Federal Department of Foreign Affairs, \u0022Federal President Calmy-Rey at EU-Tunisia Task Force meeting in Tunis,\u0022 September 27, 2011.)\n\n\t\u00a0","Disposition of Criminal Case(s)":"According to a January 26, 2011 media release by INTERPOL, Mr. Ben Ali\u0027s arrest was sought by Tunisia on charges of alleged property theft and illegal transfer of foreign currency. (Source: INTERPOL media release, \u0022Tunisia seeks ousted President and family via INTERPOL,\u0022 January 26, 2011, accessed at http:\/\/www.interpol.int\/public\/ICPO\/PressReleases\/PR2011\/PR007.asp.) According to secondary sources, Mr. Ben Ali was convicted in absentia in June 2011 on theft and unlawful possesion of cash and jewelry; in July 2011, he was convicted of property related charges. (Source: BBC News, \u0022Tunisia\u0027s Ben Ali guilty on drugs and gun charges,\u0022 July 4, 2011 and \u0022Tunisia\u0027s Ben Ali guilty of corrupt property deals,\u0022 July 29, 2011) and in June 2012, he was sentenced by a Tunisian military court to life imprisonment for his complicity in the murder and attempted murder of demonstrators; Human Rights Watch noted that Mr. Ben Ali has been tried and convicted in absentia and if he returned to Tunisia, he would be entitied to a new trial. (Source: Clive Baldwin, \u0022After Ben-Ali\u0027s Conviction: The State of Tunisian Justice,\u0022 Human Rights Watch, June 16, 2012.)","Jurisdiction of Origin: Investigative Agency":"Commission for the Investigation of Corruption and Embezzlement; Attorney Enrico Monfrini (asset recovery)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Prosecutors Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Federal Prosecutor\u0027s Office","Jurisdiction of Asset Recovery: Courts Involved":"Geneva","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_INTERPOL_Alert_Jan_26_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Asset_Freeze_Swissinfo_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Fed_Council_Press_Release_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Change_Feb_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Change_Jan_28_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/EU_Tunisia_Task_Force_Meeting_Swiss_Statement_Sep_27_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Assets_Frozen_Swissinfo_May_2_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_Switzerland_Time_Needed_Swissinfo_May_2_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_INTERPOL_Alert_Jan_26_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Asset_Freeze_Swissinfo_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Fed_Council_Press_Release_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Change_Feb_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Change_Jan_28_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/EU_Tunisia_Task_Force_Meeting_Swiss_Statement_Sep_27_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Assets_Frozen_Swissinfo_May_2_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_Switzerland_Asset_Freeze_Extended_Swiss_Admin_News_Dec_18_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_INTERPOL_Alert_Jan_26_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Asset_Freeze_Swissinfo_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Fed_Council_Press_Release_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Change_Feb_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Change_Jan_28_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/EU_Tunisia_Task_Force_Meeting_Swiss_Statement_Sep_27_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Assets_Frozen_Swissinfo_May_2_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_Switzerland_Funds%20freed_Swiss%20unfreeze%20%2440%20million%20of%20Tunisian%20assets_Swissinfo_April_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_INTERPOL_Alert_Jan_26_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Asset_Freeze_Swissinfo_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Fed_Council_Press_Release_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Change_Feb_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Change_Jan_28_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Ordinance_Jan_19_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/EU_Tunisia_Task_Force_Meeting_Swiss_Statement_Sep_27_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Conviction_Property_BBC_Jul_29_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali-Conviction_Drugs_Weapon_BBC_Jul_4_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ben_Ali_Switzerland_Assets_Frozen_Swissinfo_May_2_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Tunisia_Swiss%20OAG_Statement_Oct12%202015.pdf","Sources ":"\n\tSwiss Federal Department of Foreign Affairs, \u0022Freezing of Assets: Tunisia,\u0022 last updated April 28, 2016, at https:\/\/www.fdfa.admin.ch\/eda\/en\/fdfa\/foreign-policy\/financial-centre-ec... \u00a0Media Release, \u0022Federal Council orders freeze of any assets held by former Tunisian President Ben Ali in Switzerland,\u0022 January 19, 2011, accessed at http:\/\/www.eda.admin.ch\/eda\/en\/home\/recent\/media\/single.html?id=37285;\n\n\tSwiss Ordinance, Verordnung uber Massnahmen gegen gewisse Personen aus Tunesien, Anderung, February 4, 2011 (amending ordinances of January 28, 2011 and January 19, 2011 which are also included here, all accessed at http:\/\/www.admin.ch\/dokumentation\/gesetz\/00068\/index.html?lang=de\u0026unters.... See also Luca Beti, \u0022Freezing of presidential accounts welcomed,\u0022 Swissinfo.ch, January, 19, 2011 and Eveline Kobler, \u0022Time needed before Ben-Ali assets returned,\u0022\n\n\tSwissinfo.ch, May 2, 2011, accessed at http:\/\/www.swissinfo.ch\/eng\/specials\/the_arab_spring\/Time_needed_before_... INTERPOL Alert, \u0022Tunisia seeks ousted President and family via INTERPOL,\u0022 January 26, 2011, accessed at http:\/\/www.interpol.int\/public\/ICPO\/PressReleases\/PR2011\/PR007.asp; Swiss Federal Department of Foreign Affairs, \u0022Federal President Calmy-Rey at EU-Tunisia Task Force meeting in Tunis,\u0022 September 27, 2011, accessed at http:\/\/www.eda.admin.ch\/eda\/en\/home\/recent\/media\/single.html?id=41409; SwissInfo.ch, \u0022Tunisia launches new bid for Ben Ali assets,\u0022 October 5, 2011, accessed at http:\/\/www.swissinfo.ch\/eng\/politics\/Tunisia_launches_new_bid_for_Ben_Al... BBC News, \u0022Tunisia\u0027s Ben Ali guilty on drugs and gun charges,\u0022 July 4, 2011, accessed at http:\/\/www.bbc.co.uk\/news\/world-africa-14014757 and \u0022Tunisia\u0027s Ben Ali guilty of corrupt property deals,\u0022 July 29, 2011, accessed at http:\/\/www.bbc.co.uk\/news\/world-africa-14340863; Swiss Federal Administration, \u0022The Federal Council extends the freezing of assets of several individuals from Tunisia and Egypt,\u0022 December 18, 2013, at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=51477;\n\n\tSwissinfo.ch, \u0022Swiss unfreeze $40 million of Tunisian assets,\u0022 April 11, 2014 at http:\/\/www.swissinfo.ch\/eng\/politics\/Swiss_unfreeze_$40_million_of_Tunisian_assets.html?cid=38369152;\n\n\t\u00a0\n\n\tSee also, Swiss Office of the Attorney General press statement, \u0022St\u00e4rkung der Geldw\u00e4schereiverfahren,\u0022 October 12, 2015, at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=59054\n"},{"Case ID":"ARW-204","Case Title (Name of Public Official or Entity Allegedly Involved)":"Zine El Abidine Ben Ali (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Tunisia","Position of Public Official(s) (yrs in office)":"President (1987-2011)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"European Union sanctions ","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the United Kingdom\u0027s Parliamentary website (http:\/\/services.parliament.uk\/hansard\/Lords\/bydate\/20111003\/writtenanswe...), On October 3, 2011, the following written response was given to \u0022Question Asked by Lord Hylton: To ask Her Majesty\u2019s Government whether they, or international institutions of which they are a member, are holding frozen Tunisian funds; if so, whether they are taking action to release them in order to aid the Tunisian economy.[HL11926] The Minister of State, Foreign and Commonwealth Office (Lord Howell of Guildford): An EU-wide asset freeze was imposed against 48 Tunisian individuals on 4 February. The Treasury subsequently introduced criminal penalties for breaches of the asset freeze and notified the financial sector of the measures. The Treasury also added the list of Tunisia targets to its consolidated list of financial sanctions which is checked by the sector against client and customer databases. A small amount of assets have been frozen within the UK. We cannot disclose further details at this stage but are working with the Tunisian Government to ensure they understand the legal processes involved in releasing and repatriating these assets. Assets have been frozen in other jurisdictions across Europe.\u0022","Disposition of Criminal Case(s)":"According to a January 26, 2011 media release by INTERPOL, Mr. Ben Ali\u0027s arrest was sought by Tunisia on charges of alleged property theft and illegal transfer of foreign currency. (Source: INTERPOL media release, \u0022Tunisia seeks ousted President and family via INTERPOL,\u0022 January 26, 2011, accessed at http:\/\/www.interpol.int\/public\/ICPO\/PressReleases\/PR2011\/PR007.asp.) According to secondary sources, Mr. Ben Ali was convicted in absentia in June 2011 on theft and unlawful possesion of cash and jewelry; in July 2011, he was convicted of property related charges. (Source: BBC News, \u0022Tunisia\u0027s Ben Ali guilty on drugs and gun charges,\u0022 July 4, 2011 and \u0022Tunisia\u0027s Ben Ali guilty of corrupt property deals,\u0022 July 29, 2011) and in June 2012, he was sentenced by a Tunisian military court to life imprisonment for his complicity in the murder and attempted murder of demonstrators; Human Rights Watch noted that Mr. Ben Ali has been tried and convicted in absentia and if he returned to Tunisia, he would be entitied to a new trial. (Source: Clive Baldwin, \u0022After Ben-Ali\u0027s Conviction: The State of Tunisian Justice,\u0022 Human Rights Watch, June 16, 2012.)","Jurisdiction of Origin: Investigative Agency":"Commission for the Investigation of Corruption and Embezzlement; Attorney Enrico Monfrini (civil asset recovery)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Treasury","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"http:\/\/Ben_Ali_UK_Parliament_Written_Answer_Tunisia_Oct_3_2011 Ben_Ali_Sentence_BBC_News_Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ben_Ali_UK_Parliament_Written_Answers_Oct_3_2011.pdf","Sources ":"UK Parliament, Written Answer 3 October 2011 on Tunisia, submitted by The Minister of State, Foreign and Commonwealth Office, accessed at http:\/\/www.publications.parliament.uk\/pa\/ld201011\/ldhansrd\/text\/111003w0...\n"},{"Case ID":"ARW-99","Case Title (Name of Public Official or Entity Allegedly Involved)":"Juthamas Siriwan (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Thailand","Position of Public Official(s) (yrs in office)":"Governor of Tourism (2002-2006)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"\n\tAs of May 22, 2016, the US criminal case was ongoing. \u00a0( U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Court Docket Report as of May 22, 2016.)\n\n\t\u00a0\n\n\tIn January 2009, United States authorities filed a criminal indictment against Ms. Siriwan and her daughter on charges of money laundering and transporting funds to support unlawful activity. The indictment included criminal forfeiture allegations against bank accounts located in Isle of Jersey (HSBC Bank International Limited, Acct #11108670 in amount of $411,434.80; Singapore (Citibank Bank, Acct #0259766-001 in the amount of $543,456.79 and Standard Chartered Bank, Acct #25-0-852573-6); United Kingdom (HSBC Bank PLC, Acct #22751518). \u00a0The indictment also noted that under Section 152 of Thailand\u0027s Penal Code, it is unlawful for any government official, having the duty of managing or looking after any activity, to take the interest for the benefit of herself or another person concerning such activity. (Source: U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Indictment filed January 28, 2009.) \u00a0Ms. Siriwan has filed a Motion to Dismiss the Indictment in January 2012. (Source: \u00a0U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Court Docket Report, entry for January 30, 2012.) \u00a0 See also \u0022Disposition of criminal case\u0022 for update on the case in Thailand.","Disposition of Criminal Case(s)":"According to the Joint Status Report and Indictment filed by Thai Special Prosecutor (Exh A in Thai and Exh B in English translation), Ms. Siriwan has been charged with violations of Thai laws pertaining to conduct of Thai officials and the Criminal Code pertaining to acceptance of bribery. The US criminal case against Ms. Siriwan is ongoing as of May 22, 2016. (Source: US v. Siriwan, Case No. 2:09-cr-81 (C.D. Cal), Joint Status Report of the Parties filed on October 13, 2015 and Exhibits A and B; Court Docket Report as of May 22, 2016.","Jurisdiction of Origin: Investigative Agency":"National Anti-Corruption Commission of Thailand; Attorney General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney for the Central District of California, Criminal Division, Major Frauds Section; Department of Justice, Frauds Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Central District of California","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_UK_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_UK_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_USG_Supplemental_Resp_Jan_11_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_UK_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_USG_Supplemental_Resp_Thai_Govt_Exhibit_A_Jan_11_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_UK_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_Siriwan_Response_Feb_01_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_UK_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_Status_Rept_Mar_10_2014_3.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_UK_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_CDCA_Joint_Stip_Exhibit_Nov_19_2014_3.pdf","Sources ":"U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.),  Indictment filed January 28, 2009;  Joint Stipulation to Continue Hearing Date; and Order filed October 17, 2011; Government\u0027s Third Supplemental Brief in Opposition to Defendant\u0027s Motion to Dismiss and Exhibit A, filed January 11, 2013; Status Report by US and Exhibit A (Letter by Thailand\u0027s Office of the National Anti-Corruption Commission) filed March 10, 2014; Joint Status Report of the Parties and Exhibits A and B,filed October 13, 2015 and Court Docket Report as of May 22, 2016.)\nThe indictment can also be downloaded at the U.S. Department of Justice website: http:\/\/www.justice.gov\/criminal\/fraudsiriwan.html.\/fcpa\/cases\/.\nSee also Bangkok Post, \u0022US wants Juthamas extradited,\u0022 August 4, 2012 .\n"},{"Case ID":"ARW-100","Case Title (Name of Public Official or Entity Allegedly Involved)":"Juthamas Siriwan \/ Gerald and Patricia Green Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Thailand","Position of Public Official(s) (yrs in office)":"Governor of Tourism (Siriwan, 2002-2006) \/ Bribe givers (Greens)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2007","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Criminal Fine; Criminal Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Unknown if Thailand was recipient of restitution ordered in the Greens\u0027 case, but US Sentencing Memorandum submitted to the court in January 2010 stated that \u0022Restitution to Thailand of bribe amounts is discretionary under federal statute, but is necessary to comply with U.S. treaty obligations and to serve the ends of justice.\u0022  (Source: U.S. v. Green, Case No. 2:08-cr-00059-GW (C.D. Cal), Government\u0027s Combined Sentencing Position for Defendants Gerald Green and Patricia Green filed January 14, 2010.)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"Judgment under appeal; restitution ($250,000 - joint and several liability; $1,049, 465 plus shares in Artist Design Corp Defined Benefit Plan; Unspecified in judgment how much, if any, restitution may be given to Thailand]\u00a0","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"Gerald and Patricia Green, convicted in the U.S. District Court for the Central District of California, of paying bribes to Juthamas Siriwan were ordered to pay $250,000 in restitution as part of their September 10, 2010 Amended Judgment. The Judgment does not indicate the recipients of the restitution, but the Government\u0027s sentencing memorandum requested that the court \u0022inpose restitution to Thailand of $1,822,494 on defendants jointly and severally.\u0022  (Source: U.S. v. Green, Case No. 2:08-cr-00059-GW (C.D. Cal.), Government\u0027s Supplemental Sentencing Memorandum for Defendants Gerald Green and Patricia Green and Exhibit E (Letter by the National Anti-Corruption Commission of Thailand regarding their investigation of the Juthamas Siriwan bribery case), both filed on March 12, 2010; Government\u0027s Combined Sentencing Position for Defendants Gerald Green and Patricia Green filed January 14, 2010.)  The Greens were also ordered to pay a money judgment of $1,049,465 and their share in their company Artist Design Corp\u0027s Defined Benefit Plan.","Disposition of Criminal Case(s)":"According to the Joint Status Report and Indictment filed by Thai Special Prosecutor (Exh A in Thai and Exh B in English translation), Ms. Siriwan has been charged with violations of Thai laws pertaining to conduct of Thai officials and the Criminal Code pertaining to acceptance of bribery. The US criminal case against Ms. Siriwan is ongoing as of May 22, 2016. (Source: US v. Siriwan, Case No. 2:09-cr-81 (C.D. Cal), Joint Status Report of the Parties filed on October 13, 2015 and Exhibits A and B; Court Docket Report as of May 22, 2016.)","Jurisdiction of Origin: Investigative Agency":"National Anti-Corruption Commission of Thailand","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Central District of California; Department of Justice","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Central District of California","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Amended_Judgment_Sep_10_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Exhibit_E_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Forfeiture_Order_Aug_13_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Mtn_Amend_Forfeiture_Order_Nov_11_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_Status_Rept_Mar_10_2014_4.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Amended_Judgment_Sep_10_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Exhibit_E_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Forfeiture_Order_Aug_13_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Mtn_Amend_Forfeiture_Order_Nov_11_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_Status_Exhibit_A_Filed_Mar_10_2014_4.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Amended_Judgment_Sep_10_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Exhibit_E_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Forfeiture_Order_Aug_13_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Mtn_Amend_Forfeiture_Order_Nov_11_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_CDCA_Joint_Stip_Exhibit_Nov_19_2014_4.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Amended_Judgment_Sep_10_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Exhibit_E_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Forfeiture_Order_Aug_13_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Mtn_Amend_Forfeiture_Order_Nov_11_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_CDCA_Joint%20Stipulation_Sept14_2015_4.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Amended_Judgment_Sep_10_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Exhibit_E_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Forfeiture_Order_Aug_13_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Govt_Sentencing_Memo_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Greens_Mtn_Amend_Forfeiture_Order_Nov_11_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_CDCA_Joint%20Stipulation_Exhibit%20A_Sept14_2015_4.pdf","Sources ":"U.S. v. Green, Case No. 2:08-cr-00059-GW (C.D. Cal), Amended Judgment filed September 10, 2010 and General Order of Forfeiture as to Defendants Gerald Green and Patricia Green filed on August 13, 2010, and Government\u0027s Motion to Amend Forfeiture Order and Substitute Property filed on November 11, 2010 and for which a hearing was scheduled for January 24, 2011; Government\u0027s Supplemental Sentencing Memorandum for Defendants Gerald Green and Patricia Green and Exhibit E (Letter by the National Anti-Corruption Commission of Thailand regarding their investigation of the Juthamas Siriwan bribery case), both filed on March 12, 2010; Government\u0027s Combined Sentencing Position for Defendants Gerald Green and Patricia Green filed January 14, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/greeng\/01-14-10green-se... U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Indictment filed January 28, 2009; Joint Stipulation to Continue Hearing Date; and Order filed October 17, 2011; Government\u0027s Third Supplemental Brief in Opposition to Defendant\u0027s Motion to Dismiss and Exhibit A, filed January 11, 2013; Status Report by US and Exhibit A (Letter by Thailand\u0027s Office of the National Anti-Corruption Commission) filed March 10, 2014; Joint Status Report of the Parties and Exhibits A and B,filed October 13, 2015 and Court Docket Report as of May 22, 2016.)\n"},{"Case ID":"ARW-101","Case Title (Name of Public Official or Entity Allegedly Involved)":"Kazakhstan Oil Mining \/ James Giffen - Mercator Corporation (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kazakhstan","Position of Public Official(s) (yrs in office)":"Unnamed senior officials (\u0022KO-1,\u0022 \u0022KO-2,\u0022 and \u0022KO-3\u0022)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2003","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Other (Memorandum of Understanding)","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"Memorandum of Understanding","Contributing Factors in Asset Recovery":"Memorandum of Understanding by Kazakhstan, Switzerland and the United States; World Bank signed a Service Agreement to assist in the establishment of the BOTA Foundation and implement the BOTA Program.  The Government of the Republic of Kazakhstan pays a fixed annual fee to the World Bank for the contracted Services; these payments are posted to government accounts and are not disclosed in the Foundation\u0027s special purpose financial statements. (Source:  BOTA Foundation, Independent Auditor\u0027s Report and special financial statements for the year ended 31 December 2010.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"The 2008 Amended Memorandum of Understanding among the Governments of Kazakhstan, Switzerland and the United States provided that the recovered assets would be used to establish a social welfare foundation in Kazakhstan, the Bota Foundation.  The Foundation is being overseen by the World Bank.","Case Summary":"See also US entry. \u00a0Pursuant to an Amended Memorandum of Understanding signed in May 2008 by the Governments of Kazakhstan, Switzerland and the United States, $84 million were to be returned to Kazakhstan. The funds were to be used to establish the BOTA Foundation, with its operations overseen by the World Bank. \u00a0(Source: Amended Memorandum of Understanding by the Swiss Confederation, United States and the Republic of Kazakhstan (May 2008). \u00a0According to the BOTA Foundation Independent Auditor\u0027s Report and special financial statements for the year ended 31 December 2013, the BOTA Program is funded with US$ 115 million (principal and interest) held on account No. T-94025 with Pictet and Cie in Switzerland in the name of the Treasury of the Ministry of Finance of the Republic of Kazakhstan. \u00a0The Foundation subsequently announced that it had completed its mission and ceased operations. \u00a0(Source: \u00a0BOTA Foundation Final Summative Report, February 12, 2015, at https:\/\/www.irex.org\/sites\/default\/files\/BOTA%20Summative%20Report%20FIN....) \u00a0","Disposition of Criminal Case(s)":"Unknown as to Unnamed Senior Officials 1-3.  According to the Judgment in a Criminal Case filed in the U.S. District Court for the Southern District of New York, Mercator Corporation pleaded guilty to one count violation of Foreign Corrupt Practices Act and was fined $32,000, which it satisfied on November 30, 2010.  (Sources: US v. Mercator Corporation, Case No. 1:03-cr-00404-WHP (S.D.N.Y.), Judgment in a Criminal Case filed on November 23, 2010 and Satisfaction of Judgment filed on December 9, 2010.)  According to the Judgment in a Criminal Case filed in US v. James Giffen in the U.S. District Court for the Southern District of New York, Mr. Giffen pleaded guilty to one count of willful failure to supply information regarding foreign bank accounts and sentenced to time served. (Source: US v. Giffen, Case No. 1:03-cr-00404-WHP (S.D.N.Y.), Judgment in a Criminal Case, filed on November 23, 2010.)","Jurisdiction of Origin: Investigative Agency":"N\/A","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"N\/A","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Asset Recovery: Courts Involved":"N\/A","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Switzerland_MOU.CH.US.KZ_BOTA_FDN_2008.pdf Bota_Foundation_Indepent_Auditor_Report_FY_End_Dec_31_2010\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bota_Fdn_Annual_Report_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Switzerland_MOU.CH.US.KZ_BOTA_FDN_2008.pdf Bota_Foundation_Indepent_Auditor_Report_FY_End_Dec_31_2010\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bota_Fdn_Indep_Audit_Dec_31_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Switzerland_MOU.CH.US.KZ_BOTA_FDN_2008.pdf Bota_Foundation_Indepent_Auditor_Report_FY_End_Dec_31_2010\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Kazakh_Oil_Bota_Audit_Report_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Switzerland_MOU.CH.US.KZ_BOTA_FDN_2008.pdf Bota_Foundation_Indepent_Auditor_Report_FY_End_Dec_31_2010\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Kazakh_Oil_BOTA%20Fdn_End_Announcement_Dec_2014.pdf","Sources ":"\n\tSwiss Ministry of Foreign Affairs, September 30, 2009; Amended Memorandum of Understanding by the Swiss Confederation, United States and the Republic of Kazakhstan (May 2008). \u00a0\n\n\t\u00a0\n\n\tBOTA Foundation Final Summative Report, February 12, 2015, at https:\/\/www.irex.org\/sites\/default\/files\/BOTA%20Summative%20Report%20FIN... Independent Auditor\u0027s Report and special financial statements for the year ended December 31, 2013 at http:\/\/www.bota.kz\/uploads\/538478d53d7ca.pdf. \u00a0For additional information on the BOTA Foundation\u0027s charter and copies of financial statements, please see the Foundation\u0027s website at \u00a0 http:\/\/www.bota.kz\/en\/index.php\/main\/index\/0 (Resources); \u00a0BOTA Foundation 2012 Annual Report, \u0022Summary Details from BDO Kazakhstan\u0027s Audit of BOTA\u0027s,\u0022 at http:\/\/www.bota.kz\/uploads\/51911a859a66c.pdf; BOTA Foundation Independent Auditor\u0027s Report and Special Purpose Financial Statements for the Year Ended 31 December 2012, at http:\/\/www.bota.kz\/uploads\/51b9fa19cffaf.pdf;\u00a0\n\n\t\u00a0\n\n\tBOTA Foundation Announcement, \u0022BOTA Foundation completed its mission.\u0022 \u00a0December 31, 2014, at http:\/\/www.bota.kz\/en\/index.php\/announcements\/index\/51.\n"},{"Case ID":"ARW-102","Case Title (Name of Public Official or Entity Allegedly Involved)":"Kazakhstan Oil Mining \/ James Giffen - Mercator Corporation (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kazakhstan","Position of Public Official(s) (yrs in office)":"Unnamed senior officials (\u0022KO-1,\u0022 \u0022KO-2,\u0022 and \u0022KO-3\u0022)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2003","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Settlement agreements; Non-conviction based confiscation ","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"Memorandum of Understanding","Contributing Factors in Asset Recovery":"Memorandum of Understanding by Kazakhstan, Switzerland and the United States; World Bank administration of project","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$115,000,000","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Memorandum of Understanding","Case Summary":"\n\tSee also Swtizerland entry. \u00a0Pursuant to an Amended Memorandum of Understanding signed in May 2008 by the Governments of Kazakhstan, Switzerland and the United States, $84 million were to be returned to Kazakhstan. The funds were to be used to establish the BOTA Foundation, with its operations overseen by the World Bank. \u00a0(Source: Amended Memorandum of Understanding by the Swiss Confederation, United States and the Republic of Kazakhstan (May 2008). \u00a0According to the BOTA Foundation Independent Auditor\u0027s Report and special financial statements for the year ended 31 December 2013, the BOTA Program is funded with US$ 115 million (principal and interest) held on account No. T-94025 with Pictet and Cie in Switzerland in the name of the Treasury of the Ministry of Finance of the Republic of Kazakhstan. \u00a0The Foundation subsequently announced that it had completed its mission and ceased operations. \u00a0(Source: \u00a0BOTA Foundation Final Summative Report, February 12, 2015, at https:\/\/www.irex.org\/sites\/default\/files\/BOTA%20Summative%20Report%20FIN....) \u00a0\n\n\t\u00a0\n\n\tIn addition, as part of their August 6, 2010 plea agreements, U.S. citizen \u00a0James Giffen and The Mercator Corporation relinquished any right or title they may have to additional Swiss accounts. (Sources: U.S. v. Approximately $84 million on deposit in account no. T-94025 in the name of the Treasury of the Ministry of Finance of the Republic of Kazakhstan, Case No. 2:07-cv-03559-LAP (S.D.N.Y.); August 6, 2010 plea agreements and information in U.S. v James H. Giffen, Case No. S4 03 Cr. 404 (WHP) and U.S. v The Mercator Corporation, Case No. S3 03 Cr. 404 (WHP) (S.D.N.Y.)).","Disposition of Criminal Case(s)":"Unknown as to Unnamed Senior Officials 1-3.  According to the Judgment in a Criminal Case filed in the U.S. District Court for the Southern District of New York, Mercator Corporation pleaded guilty to one count violation of Foreign Corrupt Practices Act and was fined $32,000, which it satisfied on November 30, 2010.  (Sources: US v. Mercator Corporation, Case No. 1:03-cr-00404-WHP (S.D.N.Y.), Judgment in a Criminal Case filed on November 23, 2010 and Satisfaction of Judgment filed on December 9, 2010.)  According to the Judgment in a Criminal Case filed in US v. James Giffen in the U.S. District Court for the Southern District of New York, Mr. Giffen pleaded guilty to one count of willful failure to supply information regarding foreign bank accounts and sentenced to time served. (Source: US v. Giffen, Case No. 1:03-cr-00404-WHP (S.D.N.Y.), Judgment in a Criminal Case, filed on November 23, 2010.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Southern District of New York; Department of Justice, Fraud Section; Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_$84m_Verified_Complaint_May_3_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Final_Order_Jun_1_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Giffen_Judgment_Nov_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Mercator_Judgment_Nov_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Mercator_Judgment_Satified_Dec_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Status_Rept_Dec_10_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_US_Giffen_Plea_Ag_Aug_6_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_US_Mercator_Information_Aug_6_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bota_Fdn_Annual_Report_2012_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_$84m_Verified_Complaint_May_3_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Final_Order_Jun_1_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Giffen_Judgment_Nov_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Mercator_Judgment_Nov_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Mercator_Judgment_Satified_Dec_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Status_Rept_Dec_10_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_US_Giffen_Plea_Ag_Aug_6_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_US_Mercator_Information_Aug_6_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bota_Fdn_Indep_Audit_Dec_31_2012_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_$84m_Verified_Complaint_May_3_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Final_Order_Jun_1_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Giffen_Judgment_Nov_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Mercator_Judgment_Nov_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Mercator_Judgment_Satified_Dec_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Status_Rept_Dec_10_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_US_Giffen_Plea_Ag_Aug_6_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_US_Mercator_Information_Aug_6_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Kazakh_Oil_Bota_Audit_Report_2013_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_$84m_Verified_Complaint_May_3_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Final_Order_Jun_1_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Giffen_Judgment_Nov_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Mercator_Judgment_Nov_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Mercator_Judgment_Satified_Dec_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_Status_Rept_Dec_10_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_US_Giffen_Plea_Ag_Aug_6_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kazakhstan_Oil_US_Mercator_Information_Aug_6_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Kazakh_Oil_BOTA%20Fdn_End_Announcement_Dec_2014_0.pdf","Sources ":"\n\tU.S. v. Approximately $84 million on deposit in account no. T-94025 in the name of the Treasury of the Ministry of Finance of the Republic of Kazakhstan, Case No. 2:07-cv-03559-LAP (S.D.N.Y.), Verified Complaint filed on May 3, 2007, Final Order filed on June 1, 2009 and Status Report filed on December 10, 2009; August 6, 2010 plea agreements and information in U.S. v. James H. Giffen, Case No. S4 03 Cr. 404 (WHP) and U.S. v. The Mercator Corporation, Case No. S3 03 Cr. 404 (WHP) (S.D.N.Y.); and Satisfaction of Judgement on December 9, 2010 in U.S. v. The Mercator Corporation, Case No. S3 03 Cr. 404 (WHP) (S.D.N.Y.); BOTA Foundation 2012 Annual Report, \u0022Summary Details from BDO Kazakhstan\u0027s Audit of BOTA\u0027s,\u0022 at http:\/\/www.bota.kz\/uploads\/51911a859a66c.pdf; BOTA Foundation, Independent Auditor\u0027s Report and special financial statements for the year ended December 31, 2013 at http:\/\/www.bota.kz\/uploads\/538478d53d7ca.pdf;\n\n\t\u00a0\n\n\tBOTA Foundation, Final Summative Report, February 12, 2016; Announcement, \u0022BOTA Foundation completed its mission.\u0022 \u00a0December 31, 2014, at http:\/\/www.bota.kz\/en\/index.php\/announcements\/index\/51.\n"},{"Case ID":"ARW-103","Case Title (Name of Public Official or Entity Allegedly Involved)":"Kuwaiti Investment Organization","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kuwait","Position of Public Official(s) (yrs in office)":"Kuwaiti Investment Organization Management (inclusive 1989-1992)","Jurisdiction of Asset Recovery":"Bahamas","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"\u0022The following items were critical to the success of asset recovery in the Kuwaiti case. -The establishment of a dedicated and competent National Team was critical to the success of the initiative. - Political will was secured to ensure the success of asset recovery. - The elimination of pressures helped to achieve breakthrough successes for stolen assets recovery efforts. - Processes were initiated against individuals, rather than institutions, resulting in less resistance and fewer legal battles. - Private law actions, for several reasons, were a well-established route for asset recovery.\u0022  (Source: Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unspecified","Case Summary":"The United Kingdom\u0027s Privy Council wrote that Sheikh Fahad Mohammed Al Sabah, as the former head of the Kuwait Investment Authority in London, had \u0022embarked on a huge programme of investment in Spain through a Spanish company named  Grupo Torras  SA (\u0022GT\u0022).  With the help of co-conspirators the debtor defrauded GT on a very large scale. The misappropriations were effected by four separate fraudulent schemes between 1988 and 1990. After a long civil trial in London the debtor [the Sheikh] was found liable for very large damages (see  Grupo Torras  SA v Al Sabah [1999] CLC 1, 469). There have subsequently been various proceedings in different parts of the world by which GT, and more recently the [Sheikh\u0027s] Bahamian trustee in bankruptcy, have sought to recover funds in order to satisfy the judgment. The Sheikh was a resident of Bahamas, and on 29 June 2001 he was adjudicated bankrupt under the Bahamian Bankruptcy Act 1870. The bankruptcy was deemed to have commenced on 6 February 2001. GT\u0027s proof of debt was for a sum of the order of U.S.$800m. On 30 July 2001 the first meeting of creditors was held and Mr Clifford Culmer, a partner in BDO Mann Judge of Nassau, was appointed as trustee in bankruptcy.  The Sheikh was the settlor of two trusts governed by the law of the Cayman Islands. On 14 February 2002 the trustee in bankruptcy made an ex parte application to the Bahamian Grand Court for an order under section 122 of the Bankruptcy Act 1914 of the United Kingdom (or alternatively under the inherent jurisdiction) requesting aid from the Grand Court of the Cayman Islands\u0022 which was subsequently granted.  (Source: Al Sabah \u0026 Anor v. Grupo Torras SA \u0026 Anor (Cayman Islands) [2005] UKPC 1 (11 January 2005), at http:\/\/www.bailii.org\/uk\/cases\/UKPC\/2005\/1.html)","Disposition of Criminal Case(s)":"Unspecified","Jurisdiction of Origin: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization; Kuwaiti Public Prosecutor","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Courts Involved":"Grand Court, Court of Appeals, Supreme Court","Documents":"","Sources ":"Al Sabah \u0026 Anor v. Grupo Torras SA \u0026 Anor (Cayman Islands) [2005] UKPC 1 (11 January 2005), accessed at http:\/\/www.bailii.org\/uk\/cases\/UKPC\/2005\/1.html); \nSheikh Fahad Mohammed Al-Sabah v. George Clifford Culmer (Trustee in Bankruptcy of the Property of Sheikh Fahad Mohammed Al-Sabah), Court of Appeal of the Commonwealth of the Bahamas, Civil Appeal No. 22 of 2003 (Judgment dated April 1, 2004), accessed at http:\/\/www.courtofappeal.org.bs\/download\/22of2003sheikhfahad.pdf; \nGrupo Torras SA v Meespierson (Bahamas) Limited et al, Supreme Court of Commonwealth of Bahamas (March 1998) Sawyer CJ Court of Appeal of Commonwealth of Bahamas (April 1999).  \nDr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery Initiative\u0027s Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009.)\n"},{"Case ID":"ARW-104","Case Title (Name of Public Official or Entity Allegedly Involved)":"Kuwaiti Investment Organization","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kuwait","Position of Public Official(s) (yrs in office)":"Kuwaiti Investment Organization Management  (inclusive 1989-1992)","Jurisdiction of Asset Recovery":"Cayman Islands","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"\u0022The following items were critical to the success of asset recovery in the Kuwaiti case. -The establishment of a dedicated and competent National Team was critical to the success of the initiative. - Political will was secured to ensure the success of asset recovery. - The elimination of pressures helped to achieve breakthrough successes for stolen assets recovery efforts. - Processes were initiated against individuals, rather than institutions, resulting in less resistance and fewer legal battles. - Private law actions, for several reasons, were a well-established route for asset recovery.\u0022  (Source: Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unspecified","Case Summary":"The Kuwaiti Investment Organization sought enforcement of the English judgment in the Cayman Islands.  Early restraint orders were obtained by the Kuwaiti Investment Organization, enabling them to freeze trust assets belonging to Sheikh Fahad. Trusts maintained in Cayman by Sheikh Fahad were made to surrender their more than $30 million in assets, in partial satisfaction of the English judgment. (Source:  Cayman Islands Government, \u0022Enforcement of Judgments in Practice,\u0022 posted at Cayman Islands Government website, at http:\/\/www.gov.ky\/portal\/page?_pageid=1142,1687439\u0026_dad=portal\u0026_schema=P....)","Disposition of Criminal Case(s)":"Unspecified","Jurisdiction of Origin: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization; Kuwaiti Public Prosecutor","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Courts Involved":"Grand Court","Documents":"","Sources ":"In the Matter of Al-Sabah, 2002 CILR 148; Grupo Torras S.A. v. Bank of Butterfied International (Cayman) Limited and Five Others, 2000 CILR 452;  \nGrupo Torras S.A. v. Bank of Butterfield International (Cayman) Limited and Nine Others, Al-Sabah v. Grupo Torras S.A., Pictet Bank and Trust (Cayman) Limited and Pictet Trustee Company S.A. 2002 CILR 550; \nGrupo Torras S.A. v. Bank of Butterfied International (Cayman) Limited and Nine Others; Al-Sabah v. Grupo Torras S.A., Pictet Bank and Trust (Cayman) Limited and Pictet Trustee Company S.A. 2003 CILR 413; \nIn the matter of Al Sabah, B.A. Al Sabah and M.R. Al Sabah v. Grupo Torras S.A. and Culmer (as Trustee of the Property of Sheikh Fahad Mohammed Al Sabah, Bankrupt), 2004\u201305 CILR 373.  \nAll Cayman Islands court decisions accessed via World Bank Law Library and http:\/\/www.caymanjudicial-legalinfo.ky\/Judgments\/Cayman-Islands-Law-Reports. \nDr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009), accessed at http:\/\/www1.worldbank.org\/publicsector\/star_site\/publications\/non_convic... \nCayman Islands Government, \u0022Enforcement of Judgments in Practice,\u0022 posted at Cayman Islands Government website, at http:\/\/www.gov.ky\/portal\/page?_pageid=1142,1687439\u0026_dad=portal\u0026_schema=P....\n"},{"Case ID":"ARW-105","Case Title (Name of Public Official or Entity Allegedly Involved)":"Kuwaiti Investment Organization","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kuwait","Position of Public Official(s) (yrs in office)":"Kuwaiti Investment Organization Management (inclusive 1989-1992)","Jurisdiction of Asset Recovery":"Jersey","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"\u0022The following items were critical to the success of asset recovery in the Kuwaiti case. -The establishment of a dedicated and competent National Team was critical to the success of the initiative. - Political will was secured to ensure the success of asset recovery. - The elimination of pressures helped to achieve breakthrough successes for stolen assets recovery efforts. - Processes were initiated against individuals, rather than institutions, resulting in less resistance and fewer legal battles. - Private law actions, for several reasons, were a well-established route for asset recovery.\u0022  (Source: Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"The National Team established by the Kuwaiti Investment Organization sought to enforce the United Kingdom judgment in the Isle of Jersey where its former Sheikh Fahad held assets. The Jersey courts stated in the cases of In the Matter of the Esteem Settlement and the No. 52 Trust (Abacus (C.I.) Limited as Trustee) and Grupo Torras S.A. v. Al Sabah and six others [2002] JLR 53 that between May 1988 and October 1990, Sheikh Fahad conspired with others to defraud Grupo Torras of a total sum of approximately $430 million, of which $120 million was paid to Sheikh Fahad.  The court held that (a) Grupo Torras has a proprietary interest of 4.75% of 97 Dulwich Village and 4.27% of 242 Turney Road. Grupo Torras is entitled to an order which enables these interests to be realized. (b) The gift of Ceyla to the Esteem Settlement is to be set aside. Ceyla is entitled to recover the amount owed to it by the Esteem Settlement. (c) The gift of GBP 4 million to the No. 52 Trust is to be set aside. Grupo Torras is entitled to recover the net assets of the No. 52 Trust. (d) The gifts of GBP 1,693,500 and GBP 3,514,339 to the Esteem Settlement are to be set aside to the extent of 9.975% of the current value of 97 Dulwich Village.","Disposition of Criminal Case(s)":"Unspecified","Jurisdiction of Origin: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization; Kuwaiti Public Prosecutor","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"In the Matter of the Esteem Settlement and the No. 52 Trust (Abacus (C.I.) Limited as Trustee), Grupo Torras S.A. v. Al Sabah and Six Others, 2002 JLR 53; In the Matter of the Esteem Settlement (Abacus (C.I.) Limited as Trustees), Grupo Torras S.A. and Culmer v. Al Sabah and Four Others, 2003 JLR 188; Al-Sabah and Another v. Grupo Torras S.A. and Others (Jersey) [2000] UKPC 38 (10th October, 2000) (denial of interlocutory appeal).  Jersey court decisions accessed at, http:\/\/www.jerseylaw.je\/Judgments\/JerseyLawReports.  See also, Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009), accessed at http:\/\/www1.worldbank.org\/publicsector\/star_site\/publications\/non_convic....\n"},{"Case ID":"ARW-106","Case Title (Name of Public Official or Entity Allegedly Involved)":"Kuwaiti Investment Organization","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kuwait","Position of Public Official(s) (yrs in office)":"Kuwaiti Investment Organization Management (inclusive 1989-1992)","Jurisdiction of Asset Recovery":"Kuwait","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"1991","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"\u0022The following items were critical to the success of asset recovery in the Kuwaiti case. -The establishment of a dedicated and competent National Team was critical to the success of the initiative. - Political will was secured to ensure the success of asset recovery. - The elimination of pressures helped to achieve breakthrough successes for stolen assets recovery efforts. - Processes were initiated against individuals, rather than institutions, resulting in less resistance and fewer legal battles. - Private law actions, for several reasons, were a well-established route for asset recovery.\u0022  (Source: Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009).","Status of Asset Recovery ":"Unknown","Stage in Asset Recovery Chain":"Unknown [UK judgment noted criminal proceedings in Kuwait]","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unspecified","Case Summary":"The UK High Court - Queen\u0027s Bench, Commercial Court wrote in its June 24, 1999 decision that \u0022According to Sheikh Fahad, [criminal] proceedings have been on foot in Kuwait since 26th October 1992 against him and others for misappropriation of public funds.\u0022 (Source: Grupo Torras SA \u0026 Ors v Sheikh Fahad \u0026 Ors [1999] EWHC 300 (Comm) (24 June 1999), at 109.)   The same decision notes that the Kuwaiti Public Prosecutor in Kuwait brought criminal proceedings against Sheikh Fahad and others who are \u0022wanted for having embezzled large sums from these companies... that is from GT and THL [Grupo Torras and Torras Hostench London Limited].\u0022   (Source: Grupo Torras SA \u0026 Ors v Sheikh Fahad \u0026 Ors [1999] EWHC 300 (Comm) (24 June 1999), at 108.)","Disposition of Criminal Case(s)":"Unspecified","Jurisdiction of Origin: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization; Kuwaiti Public Prosecutor","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Grupo Torras SA \u0026 Ors v Sheikh Fahad \u0026 Ors [1999] EWHC 300 (Comm) (24 June 1999), accessed at www.bailii.org. See also, Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009), accessed at http:\/\/www1.worldbank.org\/publicsector\/star_site\/publications\/non_convic....\n"},{"Case ID":"ARW-107","Case Title (Name of Public Official or Entity Allegedly Involved)":"Kuwaiti Investment Organization","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kuwait","Position of Public Official(s) (yrs in office)":"Kuwaiti Investment Organization Management (inclusive 1989-1992)","Jurisdiction of Asset Recovery":"Spain","Jurisdiction of Asset Description":"Undertaking Asset Recovery, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1993","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"\u0022The following items were critical to the success of asset recovery in the Kuwaiti case. -The establishment of a dedicated and competent National Team was critical to the success of the initiative. - Political will was secured to ensure the success of asset recovery. - The elimination of pressures helped to achieve breakthrough successes for stolen assets recovery efforts. - Processes were initiated against individuals, rather than institutions, resulting in less resistance and fewer legal battles. - Private law actions, for several reasons, were a well-established route for asset recovery.\u0022  (Source: Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009).","Status of Asset Recovery ":"Unknown","Stage in Asset Recovery Chain":"Unknown","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a press report, in January 1993, the Kuwaiti Investment Organization (KIO) issued writs in the Spanish high court against Sheikh Fahad, Fouad Jaffar, Mr. de la Rosa and four other Spaniards who worked for the KIO. It accuses them of falsifying mercantile and public documents, fraud, manipulating prices and tax evasion, producing losses of well over 100 billion pesetas ($870 million).  The KIO also sought a freeze on their assets to cover the alleged financial responsibilities. (Source: Justin Webster, \u0022Kio\u0027s Spanish inquisition: The growing scandal of Kuwait\u0027s massive losses in Spain is exposing the dirty linen of one of the world\u0027s most secretive investment agencies and ringing government alarm bells. As the feud spills into the courts, Justin Webster looks at what lies behind the Grupo Torras disaster,\u0022 The Independent (UK), January 10, 1993. Grupo Torras SA \u0026 Ors v Sheikh Fahad \u0026 Ors [1999] EWHC 300 (Comm) (24 June 1999) mentions a case in Spain, at 108.)","Disposition of Criminal Case(s)":"Unspecified","Jurisdiction of Origin: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization; Kuwaiti Public Prosecutor","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Grupo Torras SA \u0026 Ors v Sheikh Fahad \u0026 Ors [1999] EWHC 300 (Comm) (24 June 1999) mentions a case in Spain. See also, Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009), accessed at http:\/\/www1.worldbank.org\/publicsector\/star_site\/publications\/non_convic... Justin Webster, \u0022Kio\u0027s Spanish inquisition: The growing scandal of Kuwait\u0027s massive losses in Spain is exposing the dirty linen of one of the world\u0027s most secretive investment agencies and ringing government alarm bells. As the feud spills into the courts, Justin Webster looks at what lies behind the Grupo Torras disaster,\u0022 The Independent (UK), January 10, 1993.\n"},{"Case ID":"ARW-108","Case Title (Name of Public Official or Entity Allegedly Involved)":"Kuwaiti Investment Organization","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kuwait","Position of Public Official(s) (yrs in office)":"Kuwaiti Investment Organization Management (inclusive 1989-1992)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"\u0022The following items were critical to the success of asset recovery in the Kuwaiti case. -The establishment of a dedicated and competent National Team was critical to the success of the initiative. - Political will was secured to ensure the success of asset recovery. - The elimination of pressures helped to achieve breakthrough successes for stolen assets recovery efforts. - Processes were initiated against individuals, rather than institutions, resulting in less resistance and fewer legal battles. - Private law actions, for several reasons, were a well-established route for asset recovery.\u0022  (Source: Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009).","Status of Asset Recovery ":"Unknown","Stage in Asset Recovery Chain":"Unknown [UK judgment noted criminal and civil proceedings in Switzerland]","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"Unknown","Assets Returned (USD)":"","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unspecified","Case Summary":"Grupo Torras SA \u0026 Ors v Sheikh Fahad \u0026 Ors [1999] EWHC 300 (Comm) (24 June 1999)\nmakes mention of criminal case in Switzerland.  The court noted that the State of Kuwait requested judicial cooperation in June 1997 to the Swiss Police.  The court notes, on several instances, that Swiss Investigating Magistrate Juge Tappolet obtained numerous bank account documents in connection with his criminal investigation of the case. (Source: Grupo Torras SA \u0026 Ors v Sheikh Fahad \u0026 Ors [1999] EWHC 300 (Comm) (24 June 1999), at 108 and throughout).","Disposition of Criminal Case(s)":"Unspecified","Jurisdiction of Origin: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization; Kuwaiti Public Prosecutor","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Grupo Torras SA \u0026 Ors v Sheikh Fahad \u0026 Ors [1999] EWHC 300 (Comm) (24 June 1999) makes mention of criminal case in Switzerland. See also, Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009), accessed at http:\/\/www1.worldbank.org\/publicsector\/star_site\/publications\/non_convic....\n"},{"Case ID":"ARW-109","Case Title (Name of Public Official or Entity Allegedly Involved)":"Kuwaiti Investment Organization","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kuwait","Position of Public Official(s) (yrs in office)":"Kuwaiti Investment Organization Management (inclusive 1989-1992)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1993","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"\u0022The following items were critical to the success of asset recovery in the Kuwaiti case. -The establishment of a dedicated and competent National Team was critical to the success of the initiative. - Political will was secured to ensure the success of asset recovery. - The elimination of pressures helped to achieve breakthrough successes for stolen assets recovery efforts. - Processes were initiated against individuals, rather than institutions, resulting in less resistance and fewer legal battles. - Private law actions, for several reasons, were a well-established route for asset recovery.\u0022  (Source: Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$548,000,000 (worldwide total for which ARW has official documentation; please see Summary field)","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009) provides an overview of Kuwaiti Investment Organization\u0027s worldwide recovery efforts.  The Case Study noted that legal actions took place in a total of nineteen jurisdictions, including the Bahamas, Cayman Islands, Jersey, Kuwait, Spain, Switzerland the United Kingdom. (Please see separate entries.)  In 1993, the Kuwaiti Investment Organization initiated civil proceedings which resulted in a 1999 judgment in the UK commercial court in its favor of $687 million in damages. [1999 EWHC 300 (Comm) - Grupo Torras SA and Torras Hostench London Limited (in liquidation), Plaintiffs, -and- Sheikh Fahad Mohammed Al-Sabah, and others (total 56 defendants, comprised of natural persons and associated corporate vehicles).  The United Kingdom judgment was the basis for proceedings in the Bahamas, Cayman Islands, and Jersey where trusts and other assets belonging to the main defendant Sheikh Fahad were located.","Disposition of Criminal Case(s)":"Unknown","Jurisdiction of Origin: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization; Kuwaiti Public Prosecutor","Jurisdiction of Origin: Courts Involved":"Unknown","Jurisdiction of Asset Recovery: Investigative Agency":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"National Team established by the Kuwaiti Investment Organization","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Justice, Queen\u0027s Bench Division, Commercial Court","Documents":"","Sources ":"Grupo Torras SA \u0026 Ors v Sheikh Fahad \u0026 Ors [1999] EWHC 300 (Comm) (24 June 1999), accessed at http:\/\/www.bailii.org\/ew\/cases\/EWHC\/Comm\/1999\/300.html#VI2. See also, Dr. Mohammad A.A. Al Moqatei, \u0022Stolen Asset Recovery: A Case from Kuwait,\u0022 in Stolen Asset Recovery: A Good Practices Guide for Non-Conviction Based Asset Forfeiture (Stolen Asset Recovery Initiative, 2009), accessed at http:\/\/www1.worldbank.org\/publicsector\/star_site\/publications\/non_convic... The Independent, \u0022Kuwaiti Sheikh to fight ruling,\u0022 June 27, 1999, accessed at http:\/\/www.independent.co.uk\/news\/business\/kuwaiti-sheikh-to-fight-rulin....\n"},{"Case ID":"ARW-110","Case Title (Name of Public Official or Entity Allegedly Involved)":"Leonid Reiman \/ Jeffrey Galmond \/ IPOC International Growth Fund Ltd. (Bermuda)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Russian Federation","Position of Public Official(s) (yrs in office)":"Telecommunications Minister and Advisor to President (Reiman, to 2010); Attorney to Mr. Reiman (Galmond)","Jurisdiction of Asset Recovery":"Bermuda","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2004","Asset Recovery End":"2008","UNCAC Offenses Implicated":"Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Other","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Investigative cooperation between British Virgin Islands and Bermuda - exact mechanism unknown","Contributing Factors in Asset Recovery":"Joint investigation by the British Virgin Islands and Bermuda into the corporate vehicles domiciled in their respective jurisdictions.  The British Virgin Islands High Court noted in its judgment against IPOC International Growth Fund Limited and co-defendants that \u0022In his concluding remarks, Mr Hodge QC [Queen\u0027s Counsel] commended the work done by the Bermuda Police and the Royal Virgin Islands Police Force as well as the Attorney General\u0027s Chambers in both jurisdictions saying that well over one-half million pages of documents were produced during the 17 month investigation signifying the complexity and density of this case.\u0022  (Source: In the Matter of the Proceeds of Criminal Conduct Act (No. 5 of 1997) of the Laws of the Virgin Islands between The Queen v. (1) IPOC International Growth Fund Limited, (2) Lapal Limited, (3) Albany Invest Limited, (4) Mercury Import Limited, The Eastern Caribbean Supreme Court in the High Court of Justice (Criminal Jurisdiction), Criminal Case. No. 12 of 2008.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"Please see entry case entry for British Virgin Islands.  In a Ministerial address of May 18, 2008, Bermuda\u0027s then-Minister of Finance Paula Cox stated that on May 7, 2008, in the Supreme Court of Bermuda, Justice Kwaley ordered that a group of companies collectively referred to as IPOC be wound up under the provisions of sections 1232(10)(a) and 161 (g) of the Companies Act 1981.  Minister Cox, acting as Finance Minister under authority of section 132 of the Companies Act to initiate investigation of companies, hired the consulting firm, KPMG to investigate the IPOC International Growth Fund.  Based on KPMG\u0027s findings, the wind-up petition was presented to the Supreme Court in 2007. Bermuda cooperated with British Virgin Islands in that jurisdiction\u0027s investigation of IPOC and she stated that \u0022As a result of the criminal conviction in the BVI, some $45 million of assets belonging to IPOC has been confiscated and will be shared equally between the British Virgin Islands and Bermuda.  Bermuda\u0027s share of these proceeds will be placed in the Confiscated Assets Fund.\u0022  (Source: Ministerial Statement by Minister Paula Cox, May 18, 2008 at http:\/\/www.plp.bm\/node\/1273, posted at http:\/\/www.plp.bm\/node\/1273.)","Disposition of Criminal Case(s)":"According to a judgment by the British Virgin Islands High Court of Justice, in 2008, the IPOC International Growth Fund and three associated international business companies formed in BVI (Lapal Limited, Albany Invest Limited, and Mercury Import Limited) pleaded guilty and were each convicted of two counts of perverting the course of justice and furnishing false information, in violation of the BVI Criminal Code. (Source: Judgement in AG v. IPOC International Growth Fund Limited, Jeffrey Galmond, and others, Claim No. BVIHCV2007\/0088, British Virgin Islands High Court of Justice (civil) and In the Matter of the Proceeds of Criminal Conduct Act (No. 5 of 1997) of the Laws of the Virgin Islands, between The Queen v. IPOC International Growth Fund Limited and others, Crim Case No. 12 of 2008, British Virgin Islands, High Court of Justice (criminal jurisdiction).","Jurisdiction of Origin: Investigative Agency":"N\/A","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Bermuda Police Service; Attorney General\u0027s Chambers; Ministry of Finance; Bermuda Monetary Service","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Registrar of Companies","Jurisdiction of Asset Recovery: Courts Involved":"Supreme Court (Commercial Court) of Bermuda; Court of Appeal for Bermuda; [International Court of Arbitration, Zurich and Geneva]","Documents":"","Sources ":"Ministerial Statement by Minister Paula Cox on IPOC, May 18, 2008, as posted on the website of the Bermuda Progressive Labour Party, at http:\/\/www.plp.bm\/node\/1273; \nGovernment of Bermuda, The Cabinet Office, Department of Communication and Information, \u0022Press Statement by the Minister of Finance, the Hon. Paula A. Cox, JP, MP, \u0022IPOC Group of Companies,\u0022 May 1, 2008;  \nIn the matter of (12) IPOC International Growth Fund Limited, and others, Supreme Court of Bermuda (Commercial Court), Companies (winding-up), case 2007: Nos. 12, 12A-12H (December 6, 2007 judgment) and Between IPOC International Growth Fund Ltd. and OAO \u0022CT-Mobile\u0022, LV Finance Group, In the Court of Appeal for Bermuda, Civil Appeal No. 22 \u0026 23 of 2006 (23 March 2007 judgment), obtained September 2010 from the website of the Bermuda Judiciary, Government of Bermuda at http:\/\/www.gov.bm\/portal\/server.pt?open=512\u0026objID=204\u0026\u0026PageID=226633\u0026mod....  \nGovernment press release and related court decisions can also be downloaded from the Government of Bermuda, The Cabinet Office webpage at http:\/\/www.oagbermuda.gov.bm\/portal\/server.pt?in_hi_space=SearchResult\u0026i... \nJonathan Kent, \u0022Bermuda, BVI to share IPOC confiscation,\u0022 The Royal Gazette (Bermuda), May 2, 2008, accessed at accessed at http:\/\/www.royalgazette.com\/siftology.royalgazette\/Article\/article.jsp?a....\n"},{"Case ID":"ARW-111","Case Title (Name of Public Official or Entity Allegedly Involved)":"Leonid Reiman \/ Jeffrey Galmond \/ IPOC International Growth Fund Ltd. (BVI)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Russian Federation","Position of Public Official(s) (yrs in office)":"Telecommunications Minister and Advisor to President (Reiman, to 2010); Attorney to Mr. Reiman (Galmond)","Jurisdiction of Asset Recovery":"British Virgin Islands","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2006","Asset Recovery End":"2008","UNCAC Offenses Implicated":"Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Investigative cooperation between British Virgin Islands and Bermuda - exact mechanism unknown","Contributing Factors in Asset Recovery":"Joint investigation by the British Virgin Islands and Bermuda into the corporate vehicles domiciled in their respective jurisdictions.  The British Virgin Islands High Court noted in its judgment against IPOC International Growth Fund Limited and co-defendants that \u0022In his concluding remarks, Mr Hodge QC [Queen\u0027s Counsel] commended the work done by the Bermuda Police and the Royal Virgin Islands Police Force as well as the Attorney General\u0027s Chambers in both jurisdictions saying that well over one-half million pages of documents were produced during the 17 month investigation signifying the complexity and density of this case.\u0022  (Source: In the Matter of the Proceeds of Criminal Conduct Act (No. 5 of 1997) of the Laws of the Virgin Islands between The Queen v. (1) IPOC International Growth Fund Limited, (2) Lapal Limited, (3) Albany Invest Limited, (4) Mercury Import Limited, The Eastern Caribbean Supreme Court in the High Court of Justice (Criminal Jurisdiction), Criminal Case. No. 12 of 2008.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"As part of their 2008 conviction in the British Virgin Islands,  IPOC International Growth Fund Limited (Bermuda) and three associated companies were In May 2006, an international arbitration tribunal in Zurich \u0022found that Minister Reiman of the Russian Government was the beneficial owner of IPOC [International Growth Fund Limited (Bermuda)] and that he committed criminal acts under Russian law.\u0022 (Source: as cited by the British Virgin Islands Court of Appeal, 18 June 2008, Civil Appeal No. 30 of 2006, in IPOC International Growth Fund Limited (Bermuda) v. LV Finance Group Limited (British Virgin Islands)).  IPOC and its associated corporate vehicles formed in Bermuda and BVI were the subject of a lengthy joint investigation by those jurisdictions for alleged money laundering activities.  In 2008, IPOC and three associated international business companies formed in BVI (Lapal Limited, Albany Invest Limited, and Mercury Import Limited) pleaded guilty and were each convicted of two counts of perverting the course of justice and furnishing false information, in violation of the BVI Criminal Code. (Source: Judgement in AG v. IPOC International Growth Fund Limited, Jeffrey Galmond, and others, Claim No. BVIHCV2007\/0088, British Virgin Islands High Court of Justice (civil) and In the Matter of the Proceeds of Criminal Conduct Act (No. 5 of 1997) of the Laws of the Virgin Islands, between The Queen v. IPOC International Growth Fund Limited and others, Crim Case No. 12 of 2008, British Virgin Islands, High Court of Justice (criminal jurisdiction).","Disposition of Criminal Case(s)":"According to a 2008 judgment by the British Virgin Islands High Court of Justice, the IPOC International Growth Fund and three associated international business companies formed in BVI (Lapal Limited, Albany Invest Limited, and Mercury Import Limited) pleaded guilty and were each convicted of two counts of perverting the course of justice and furnishing false information, in violation of the BVI Criminal Code. (Source: Judgement in AG v. IPOC International Growth Fund Limited, Jeffrey Galmond, and others, Claim No. BVIHCV2007\/0088, British Virgin Islands High Court of Justice (civil) and In the Matter of the Proceeds of Criminal Conduct Act (No. 5 of 1997) of the Laws of the Virgin Islands, between The Queen v. IPOC International Growth Fund Limited and others, Crim Case No. 12 of 2008, British Virgin Islands, High Court of Justice (criminal jurisdiction).","Jurisdiction of Origin: Investigative Agency":"N\/A","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Royal Virgin Islands Police Force; Attorney General\u0027s Chambers; Financial Investigations Agency","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General\u0027s Chambers, Director of Public Prosecutions","Jurisdiction of Asset Recovery: Courts Involved":"The Eastern Caribbean Supreme Court, High Court of Justice (Criminal Jurisdiction); High Court of Justice (Civil); [International Court of Arbitration, Zurich and Geneva]","Documents":"","Sources ":"In the Matter of the Proceeds of Criminal Conduct Act (No. 5 of 1997) of the Laws of the Virgin Islands between The Queen v. (1) IPOC International Growth Fund Limited, (2) Lapal Limited, (3) Albany Invest Limited, (4) Mercury Import Limited, The Eastern Caribbean Supreme Court in the High Court of Justice (Criminal Jurisdiction), Criminal Case. No. 12 of 2008; \nIPOC International Growth Fund Limited (Bermuda) v. LV Finance group Limited (BVI), BVI No. 1 Court of Appeal, 18 June 2008, Civil Appeal No. 30 of 2006;  \nIn the matter of (12) IPOC International Growth Fund Limited,,, and in the Matter of the Companies Act 1981, In the Supreme Court of Bermuda, Commercial Court, Companies (Winding-up), 2007: Nox. 12, 12A-12H (Decision dated December 6, 2007); \nIn her Ministerial address of May 18, 2008, Bermuda\u0027s then-Minister of Finance Paula Cox stated that \u0022As a result of the criminal conviction in the BVI, some $45 million of assets belonging to IPOC has been confiscated and will be shared equally between the British Virgin Islands and Bermuda.  \nBermuda\u0027s share of these proceeds will be placed in the Confiscated Assets Fund.\u0022 Ministerial Statement by Minister Paula Cox, May 18, 2008 at http:\/\/www.plp.bm\/node\/1273, posted at http:\/\/www.plp.bm\/node\/1273.  \nJonathan Kent, \u0022Bermuda, BVI to share IPOC confiscation,\u0022 The Royal Gazette (Bermuda), May 2, 2008, accessed at http:\/\/www.royalgazette.com\/siftology.royalgazette\/Article\/article.jsp?a....\n"},{"Case ID":"ARW-112","Case Title (Name of Public Official or Entity Allegedly Involved)":"Lesotho Highlands Water Project (Canada)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Canada","Position of Public Official(s) (yrs in office)":"Chief executive of the Lesotho Highlands Development Agency (Masupha Ephraim Sole, 1986-1995) and former delegates of Lesotho on the Highlands Water Commission (Reatile Mochebelele and Letiafuoa Molapo); Acres International Limited (Canada); Lahmeyer International GmbH (Germany); Impregilo SpA (Italy); Jacobus Michiel Du Plooy (Impregilo intermediary); Spie Batignolles (France)","Jurisdiction of Asset Recovery":"Lesotho","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"1999","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Successful collaboration of OLAF [European Anti-Fraud Office] in prosecuting the European companies involved; mutual legal assistance from Switzerland in the prosecutions (Source:  LL Thetsane and GH Penzhorn SC, \u0022Case Study: The Lesotho bribery prosecutions,\u0022 presented at Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities, Rabat, May 14-16, 2007); World Bank investigation and debarment of involved companies, Acres International and Lahmeyer International GmbH (Source: World Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, which noted \u0022Once the indictments [in the case] were announced in mid-1999, the World Bank provided extensive evidentiary support to the Lesotho prosecutors and made bank staff available for interviews.\u0022)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$2,042,710","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"On August 15, 2003, the Lesotho Court of Appeal upheld the bribery conviction of Acres International Limited (Canada) and increased the company\u0027s fine to R15 million.  (Source: Acres International Limited v The Crown, Lesotho Court of Appeal, case number C of A (CRI) 8 of 2002, Judgment of August 15, 2003.)  The case arose out of the Lesotho Highlands Water Project, which the Lesotho Court of Appeal as \u0022[0]ne of the biggest and most ambitious dam projects in the world, which entailed inter alia the construction of the Katse Dam in a remote and inaccessible part of the highlands of Lesotho.\u0022  (Source: In the matter between: Ephraim Masupha Sole and The Crown, Lesotho Court of Appeals, Case (CRI) 5 OF 2002, Judgment dated April 13, 2003).  According to the 2003 Lesotho Court of Appeal judgment, the High Court of Lesotho had found Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, guilty of accepting bribes from various multinational companies that were attempting to secure contracts related to the project.  In an earlier dispute involving Mr. Sole, the government hired Ernst and Young, whose audit discovered that Mr. Sole had Swiss bank accounts into which the project contractors and consultants had placed large sums of money.  Four multinational companies were convicted or pleaded guilty in the case, including Acres International Limited.  (Please see Lesotho Highlands Water Project entries.)","Disposition of Criminal Case(s)":"According to the Lesotho Court of Appeal, Mr. Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, was found guilty of accepting bribes from various multinational companies in connection with the Lesotho Highlands Water Project.  (Source: In the matter between: Ephraim Masupha Sole and The Crown, Lesotho Court of Appeals, Case (CRI) 5 OF 2002, Judgment dated April 13, 2003).  According to the Lesotho Court of Appeal, two other Lesotho officials, Reatile Mochebelele and Letiafuoa Molano, were also found guilty of accepting bribes. (Source: R v Mochebelele and Another (C of A (CRI) 02\/08) [2008] LSCA 30 (17 October 2008)).  Four foreign companies were convicted or pleaded guilty in Lesotho to corruption related charges:  Acres International Limited (Canada);  Lahmeyer International GmbH (Germany); Spie Batignolles (now Schneider Electric SA, France), and Impregilo SpA (Italy) (and Jacobus Michiel Du Plooy (Impregilo intermediary).  (Sources: In the matter between: Schneider Electric S.A. (formally Spie Batignolles) (Applicant) and Director of Public Prosecutions (Respondent), High Court of Lesotho, CRI\/APN\/751\/2003; In the Matter between Lahmeyer International GmbH (Appellant) and The Crown (Respondent), C of A (CRI) 6 OF 2002 (April 7, 2004); Crown v Impregilo Spa (Registration Number 104217) Tribunal of Milan (CRI\/T\/174\/2004 CIV\/APN\/437\/05) [2006] LSHC 48 (3 February 2006); and Acres International Limited v The Crown, Lesotho Court of Appeal, case number C of A (CRI) 8 of 2002. Judgment of August 15, 2003.)","Jurisdiction of Origin: Investigative Agency":"European Anti-Fraud Office (OLAF)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions (Lesotho)","Jurisdiction of Origin: Courts Involved":"High Court of Lesotho; Court of Appeal of Lesotho ","Jurisdiction of Asset Recovery: Investigative Agency":"European Anti-Fraud Office (OLAF)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions (Lesotho)","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Lesotho; Court of Appeal of Lesotho","Documents":"","Sources ":"Acres International Limited v The Crown, Lesotho Court of Appeal, case number C of A (CRI) 8 of 2002 delivered on 15 August 2003, accessed at http:\/\/www.saflii.org\/ls\/cases\/LSHC\/2003\/88.pdf; In the Matter between Ephraim Masupha Sole and the Crown, in the Appeal Court of Lesotho, C. of A. (CRI) 5 of 2002, CRI\/T\/111\/91, Judgment dated April 13, 2003; \u0022Case Study: The Lesotho bribery prosecutions,\u0022 Paper presented by LL Thetsane and GH Penzhorn SC, at the Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities,\u0022 Rabat, May 14-16, 2007. World Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,contentMDK:21116129~pag... European Anti-Fraud Office Press Release, \u0022Three European Companies Guilty in African Aid Fraud Case,\u0022 October 3, 2006, accessed at http:\/\/ec.europa.eu\/anti_fraud\/cases\/aid_en.html. Lesotho Highlands Water Project, at http:\/\/ipocafrica.org which also provides a list and links to relevant documents. United Nations Office on Drugs and Crime, United Nations Handbook on Practical Anti-Corruption Measures for Prosecutors and Investigators (Vienna, 2004), Annex: Lesotho Case Study, at 137ff.\n"},{"Case ID":"ARW-113","Case Title (Name of Public Official or Entity Allegedly Involved)":"Lesotho Highlands Water Project (France)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"France","Position of Public Official(s) (yrs in office)":"Chief executive of the Lesotho Highlands Development Agency (Masupha Ephraim Sole, 1986-1995) and former delegates of Lesotho on the Highlands Water Commission (Reatile Mochebelele and Letiafuoa Molapo); Acres International Limited (Canada); Lahmeyer International GmbH (Germany); Impregilo SpA (Italy); Jacobus Michiel Du Plooy (Impregilo intermediary); Spie Batignolles (France)","Jurisdiction of Asset Recovery":"Lesotho","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"1999","Asset Recovery End":"2004","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Successful collaboration of OLAF [European Anti-Fraud Office] in prosecuting the European companies involved; mutual legal assistance from Switzerland in the prosecutions (Source:  LL Thetsane and GH Penzhorn SC, \u0022Case Study: The Lesotho bribery prosecutions,\u0022 presented at Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities, Rabat, May 14-16, 2007); World Bank investigation and debarment of involved companies, Acres International and Lahmeyer International GmbH (Source: World Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, which noted \u0022Once the indictments [in the case] were announced in mid-1999, the World Bank provided extensive evidentiary support to the Lesotho prosecutors and made bank staff available for interviews.\u0022)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$1,417,490","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In February 2004, Spie Batignolles (now Schneider Electric SA, France) pleaded guilty and paid R10 million in fines.  (Source: In the matter between: Schneider Electric S.A. (formally Spie Batignolles) (Applicant) and Director of Public Prosecutions (Respondent), High Court of Lesotho, CRI\/APN\/751\/2003 (11 December 2003)).  The case arose out of the Lesotho Highlands Water Project, which the Lesotho Court of Appeal as \u0022[0]ne of the biggest and most ambitious dam projects in the world, which entailed inter alia the construction of the Katse Dam in a remote and inaccessible part of the highlands of Lesotho.\u0022  (Source: In the matter between: Ephraim Masupha Sole and The Crown, Lesotho Court of Appeals, Case (CRI) 5 OF 2002, Judgment dated April 13, 2003).  According to the 2003 Lesotho Court of Appeal judgment, the High Court of Lesotho had found Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, guilty of accepting bribes from various multinational companies that were attempting to secure contracts related to the project.  In an earlier dispute involving Mr. Sole, the government hired Ernst and Young, whose audit discovered that Mr. Sole had Swiss bank accounts into which the project contractors and consultants had placed large sums of money.  Four multinational companies were convicted or pleaded guilty in the case, including Acres International Limited. (Please see Lesotho Highlands Water Project entries.)","Disposition of Criminal Case(s)":"According to the Lesotho Court of Appeal, Mr. Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, was found guilty of accepting bribes from various multinational companies in connection with the Lesotho Highlands Water Project.  (Source: In the matter between: Ephraim Masupha Sole and The Crown, Lesotho Court of Appeals, Case (CRI) 5 OF 2002, Judgment dated April 13, 2003).  According to the Lesotho Court of Appeal, two other Lesotho officials, Reatile Mochebelele and Letiafuoa Molano, were also found guilty of accepting bribes. (Source: R v Mochebelele and Another (C of A (CRI) 02\/08) [2008] LSCA 30 (17 October 2008)).  Four foreign companies were convicted or pleaded guilty in Lesotho to corruption related charges:  Acres International Limited (Canada);  Lahmeyer International GmbH (Germany); Spie Batignolles (now Schneider Electric SA, France), and Impregilo SpA (Italy) (and Jacobus Michiel Du Plooy (Impregilo intermediary).  (Sources: In the matter between: Schneider Electric S.A. (formally Spie Batignolles) (Applicant) and Director of Public Prosecutions (Respondent), High Court of Lesotho, CRI\/APN\/751\/2003; In the Matter between Lahmeyer International GmbH (Appellant) and The Crown (Respondent), C of A (CRI) 6 OF 2002 (April 7, 2004); Crown v Impregilo Spa (Registration Number 104217) Tribunal of Milan (CRI\/T\/174\/2004 CIV\/APN\/437\/05) [2006] LSHC 48 (3 February 2006); and Acres International Limited v The Crown, Lesotho Court of Appeal, case number C of A (CRI) 8 of 2002. Judgment of August 15, 2003.)","Jurisdiction of Origin: Investigative Agency":"European Anti-Fraud Office (OLAF) ","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions (Lesotho)","Jurisdiction of Origin: Courts Involved":"High Court of Lesotho; Court of Appeal of Lesotho ","Jurisdiction of Asset Recovery: Investigative Agency":"European Anti-Fraud Office (OLAF)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions (Lesotho)","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Lesotho; Court of Appeal of Lesotho","Documents":"","Sources ":"In the matter between: Schneider Electric S.A. (formally Spie Batignolles) (Applicant) and Director of Public Prosecutions (Respondent), High Court of Lesotho, CRI\/APN\/751\/2003 (11 December 2003), accessed at http:\/\/www.saflii.org\/ls\/cases\/LSHC\/2003\/150.pdf; In the matter between Ephraim Masupha Sole and the Crown, in the Appeal Court of Lesotho, C. of A. (CRI) 5 of 2002, CRI\/T\/111\/91, Judgment dated April 13, 2003 and R v Mochebelele and Another (C of A (CRI) 02\/08) [2008] LSCA 30 (17 October 2008), both accessed at www.saflii.org; \u0022Case Study: The Lesotho bribery prosecutions,\u0022 Paper presented by LL Thetsane and GH Penzhorn SC, at the Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities,\u0022 Rabat, May 14-16, 2007. World Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,contentMDK:21116129~pag... European Anti-Fraud Office Press Release, \u0022Three European Companies Guilty in African Aid Fraud Case,\u0022 October 3, 2006, accessed at http:\/\/ec.europa.eu\/anti_fraud\/cases\/aid_en.html. Lesotho Highlands Water Project, at http:\/\/ipocafrica.org which also provides a list and links to relevant documents.\n"},{"Case ID":"ARW-114","Case Title (Name of Public Official or Entity Allegedly Involved)":"Lesotho Highlands Water Project (Germany)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Germany","Position of Public Official(s) (yrs in office)":"Chief executive of the Lesotho Highlands Development Agency (Masupha Ephraim Sole, 1986-1995) and former delegates of Lesotho on the Highlands Water Commission (Reatile Mochebelele and Letiafuoa Molapo); Acres International Limited (Canada); Lahmeyer International GmbH (Germany); Impregilo SpA (Italy); Jacobus Michiel Du Plooy (Impregilo intermediary); Spie Batignolles (France)","Jurisdiction of Asset Recovery":"Lesotho","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"1999","Asset Recovery End":"2004","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Successful collaboration of OLAF [European Anti-Fraud Office] in prosecuting the European companies involved; mutual legal assistance from Switzerland in the prosecutions (Source:  LL Thetsane and GH Penzhorn SC, \u0022Case Study: The Lesotho bribery prosecutions,\u0022 presented at Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities, Rabat, May 14-16, 2007); World Bank investigation and debarment of involved companies, Acres International and Lahmeyer International GmbH (Source: World Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, which noted \u0022Once the indictments [in the case] were announced in mid-1999, the World Bank provided extensive evidentiary support to the Lesotho prosecutors and made bank staff available for interviews.\u0022)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$1,894,750","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"On April 7, 2004, Lahmeyer International GmbH (Germany)\u0027s conviction was upheld by the Lesotho Court of Appeal and fined R12 million. (Source: In the Matter between Lahmeyer International GmbH (Appellant) and The Crown (Respondent), C of A (CRI) 6 OF 2002 (April 7, 2004)).  The case arose out of the Lesotho Highlands Water Project, which the Lesotho Court of Appeal as \u0022[0]ne of the biggest and most ambitious dam projects in the world, which entailed inter alia the construction of the Katse Dam in a remote and inaccessible part of the highlands of Lesotho.\u0022  (Source: In the matter between: Ephraim Masupha Sole and The Crown, Lesotho Court of Appeals, Case (CRI) 5 OF 2002, Judgment dated April 13, 2003).  According to the 2003 Lesotho Court of Appeal judgment, the High Court of Lesotho had found Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, guilty of accepting bribes from various multinational companies that were attempting to secure contracts related to the project.  In an earlier dispute involving Mr. Sole, the government hired Ernst and Young, whose audit discovered that Mr. Sole had Swiss bank accounts into which the project contractors and consultants had placed large sums of money.  Four multinational companies were convicted or pleaded guilty in the case, including Acres International Limited. (Please see Lesotho Highlands Water Project entries.)","Disposition of Criminal Case(s)":"According to the Lesotho Court of Appeal, Mr. Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, was found guilty of accepting bribes from various multinational companies in connection with the Lesotho Highlands Water Project.  (Source: In the matter between: Ephraim Masupha Sole and The Crown, Lesotho Court of Appeals, Case (CRI) 5 OF 2002, Judgment dated April 13, 2003).  According to the Lesotho Court of Appeal, two other Lesotho officials, Reatile Mochebelele and Letiafuoa Molano, were also found guilty of accepting bribes. (Source: R v Mochebelele and Another (C of A (CRI) 02\/08) [2008] LSCA 30 (17 October 2008)).  Four foreign companies were convicted or pleaded guilty in Lesotho to corruption related charges:  Acres International Limited (Canada);  Lahmeyer International GmbH (Germany); Spie Batignolles (now Schneider Electric SA, France), and Impregilo SpA (Italy) (and Jacobus Michiel Du Plooy (Impregilo intermediary).  (Sources: In the matter between: Schneider Electric S.A. (formally Spie Batignolles) (Applicant) and Director of Public Prosecutions (Respondent), High Court of Lesotho, CRI\/APN\/751\/2003; In the Matter between Lahmeyer International GmbH (Appellant) and The Crown (Respondent), C of A (CRI) 6 OF 2002 (April 7, 2004); Crown v Impregilo Spa (Registration Number 104217) Tribunal of Milan (CRI\/T\/174\/2004 CIV\/APN\/437\/05) [2006] LSHC 48 (3 February 2006); and Acres International Limited v The Crown, Lesotho Court of Appeal, case number C of A (CRI) 8 of 2002. Judgment of August 15, 2003.)","Jurisdiction of Origin: Investigative Agency":"European Anti-Fraud Office (OLAF) ","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions of Lesotho","Jurisdiction of Origin: Courts Involved":"High Court of Lesotho; Court of Appeal of Lesotho ","Jurisdiction of Asset Recovery: Investigative Agency":"European Anti-Fraud Office (OLAF)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions of Lesotho","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Lesotho; Court of Appeal of Lesotho","Documents":"","Sources ":"In the Matter between Lahmeyer International GmbH (Appellant) and The Crown (Respondent), C of A (CRI) 6 OF 2002 (April 7, 2004), accessed at http:\/\/www.saflii.org\/ls\/cases\/LSHC\/2004\/60.pdf; In the Matter between Ephraim Masupha Sole and the Crown, in the Appeal Court of Lesotho, C. of A. (CRI) 5 of 2002, CRI\/T\/111\/91, Judgment dated April 13, 2003; \u0022Case Study: The Lesotho bribery prosecutions,\u0022 Paper presented by LL Thetsane and GH Penzhorn SC, at the Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities,\u0022 Rabat, May 14-16, 2007. World Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,contentMDK:21116129~pag... European Anti-Fraud Office Press Release, \u0022Three European Companies Guilty in African Aid Fraud Case,\u0022 October 3, 2006, accessed at http:\/\/ec.europa.eu\/anti_fraud\/cases\/aid_en.html. Lesotho Highlands Water Project, at http:\/\/ipocafrica.org which also provides a list and links to relevant documents.\n"},{"Case ID":"ARW-115","Case Title (Name of Public Official or Entity Allegedly Involved)":"Lesotho Highlands Water Project (Italy)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Italy","Position of Public Official(s) (yrs in office)":"Chief executive of the Lesotho Highlands Development Agency (Masupha Ephraim Sole, 1986-1995) and former delegates of Lesotho on the Highlands Water Commission (Reatile Mochebelele and Letiafuoa Molapo); Acres International Limited (Canada); Lahmeyer International GmbH (Germany); Impregilo SpA (Italy); Jacobus Michiel Du Plooy (Impregilo intermediary); Spie Batignolles (France)","Jurisdiction of Asset Recovery":"Lesotho","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"1999","Asset Recovery End":"2006","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Successful collaboration of OLAF [European Anti-Fraud Office] in prosecuting the European companies involved; mutual legal assistance from Switzerland in the prosecutions (Source:  LL Thetsane and GH Penzhorn SC, \u0022Case Study: The Lesotho bribery prosecutions,\u0022 presented at Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities, Rabat, May 14-16, 2007); World Bank investigation and debarment of involved companies, Acres International and Lahmeyer International GmbH (Source: World Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, which noted \u0022Once the indictments [in the case] were announced in mid-1999, the World Bank provided extensive evidentiary support to the Lesotho prosecutors and made bank staff available for interviews.\u0022)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$2,367,450","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In 2006, Impregilo SpA (Italy) pleaded guilty and was fined R15 million. (Jacobus Michiel Du Plooy, an intermediary for Impregilo also pleaded guilty and was fined.) (Sources: Routledges Incorporated t\/a Routledge Modise Moss Morris v Crown; Crown v Impregilo Spa (Registration Number 104217) Tribunal of Milan (CRI\/T\/174\/2004 CIV\/APN\/437\/05) [2006] LSHC 48 (3 February 2006).  The case arose out of the Lesotho Highlands Water Project, which the Lesotho Court of Appeal as \u0022[0]ne of the biggest and most ambitious dam projects in the world, which entailed inter alia the construction of the Katse Dam in a remote and inaccessible part of the highlands of Lesotho.\u0022  (Source: In the matter between: Ephraim Masupha Sole and The Crown, Lesotho Court of Appeals, Case (CRI) 5 OF 2002, Judgment dated April 13, 2003).  According to the 2003 Lesotho Court of Appeal judgment, the High Court of Lesotho had found Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, guilty of accepting bribes from various multinational companies that were attempting to secure contracts related to the project.  In an earlier dispute involving Mr. Sole, the government hired Ernst and Young, whose audit discovered that Mr. Sole had Swiss bank accounts into which the project contractors and consultants had placed large sums of money.  Four multinational companies were convicted or pleaded guilty in the case, including Acres International Limited.  (Please see Lesotho Highlands Water Project entries.)","Disposition of Criminal Case(s)":"According to the Lesotho Court of Appeal, Mr. Masupha Ephraim Sole, chief executive of the Lesotho Highlands Development Agency, was found guilty of accepting bribes from various multinational companies in connection with the Lesotho Highlands Water Project.  (Source: In the matter between: Ephraim Masupha Sole and The Crown, Lesotho Court of Appeals, Case (CRI) 5 OF 2002, Judgment dated April 13, 2003).  According to the Lesotho Court of Appeal, two other Lesotho officials, Reatile Mochebelele and Letiafuoa Molano, were also found guilty of accepting bribes. (Source: R v Mochebelele and Another (C of A (CRI) 02\/08) [2008] LSCA 30 (17 October 2008)).  Four foreign companies were convicted or pleaded guilty in Lesotho to corruption related charges:  Acres International Limited (Canada);  Lahmeyer International GmbH (Germany); Spie Batignolles (now Schneider Electric SA, France), and Impregilo SpA (Italy) (and Jacobus Michiel Du Plooy (Impregilo intermediary).  (Sources: In the matter between: Schneider Electric S.A. (formally Spie Batignolles) (Applicant) and Director of Public Prosecutions (Respondent), High Court of Lesotho, CRI\/APN\/751\/2003; In the Matter between Lahmeyer International GmbH (Appellant) and The Crown (Respondent), C of A (CRI) 6 OF 2002 (April 7, 2004); Crown v Impregilo Spa (Registration Number 104217) Tribunal of Milan (CRI\/T\/174\/2004 CIV\/APN\/437\/05) [2006] LSHC 48 (3 February 2006); and Acres International Limited v The Crown, Lesotho Court of Appeal, case number C of A (CRI) 8 of 2002. Judgment of August 15, 2003.)","Jurisdiction of Origin: Investigative Agency":"European Anti-Fraud Office (OLAF)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions of Lesotho","Jurisdiction of Origin: Courts Involved":"High Court of Lesotho; Court of Appeal of Lesotho ","Jurisdiction of Asset Recovery: Investigative Agency":"European Anti-Fraud Office (OLAF)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions of Lesotho","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Lesotho; Court of Appeal of Lesotho","Documents":"","Sources ":"Routledges Incorporated t\/a Routledge Modise Moss Morris v Crown; Crown v Impregilo Spa (Registration Number 104217) Tribunal of Milan (CRI\/T\/174\/2004 CIV\/APN\/437\/05) [2006] LSHC 48 (3 February 2006), accessed at http:\/\/www.saflii.org\/ls\/cases\/LSHC\/2006\/48.pdf; In the Matter between Ephraim Masupha Sole and the Crown, in the Appeal Court of Lesotho, C. of A. (CRI) 5 of 2002, CRI\/T\/111\/91, April 2, 3, and 14, 2003; \u0022Case Study: The Lesotho bribery prosecutions,\u0022 Paper presented by LL Thetsane and GH Penzhorn SC, at the Conference on the Protection and Optimization of Public Funds - the Cooperation between National and International Authorities,\u0022 Rabat, May 14-16, 2007. World Bank, \u0022World Bank Sanctions Lahmeyer International for Corrupt Activities in Bank-Financed Projects,\u0022 Press Release No: 129\/2007\/INT, November 6, 2006, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,contentMDK:21116129~pag... European Anti-Fraud Office Press Release, \u0022Three European Companies Guilty in African Aid Fraud Case,\u0022 October 3, 2006, accessed at http:\/\/ec.europa.eu\/anti_fraud\/cases\/aid_en.html. Lesotho Highlands Water Project, at http:\/\/ipocafrica.org which also provides a list and links to relevant documents.\n"},{"Case ID":"ARW-117","Case Title (Name of Public Official or Entity Allegedly Involved)":"Luis Roldan","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Spain","Position of Public Official(s) (yrs in office)":"Head of Guardia Civil (1986-1994)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1986","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Unknown, but Mr. Roldan\u0027s case received international attention when he was captured in Laos after ten months as a fugitive.  (Source: New York Times, \u0022Fugitive returned to Spain,\u0022 March 1, 1995.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$15,000,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"The Swiss Ministry of Foreign Affairs noted that $15 million had been returned to Spain in Mr. Roldan\u0027s case.  (Source: Swiss Ministry of Foreign Affairs, September 30, 2009.)","Disposition of Criminal Case(s)":"According to a Spanish tribunal, Mr. Roldan was sentenced in February 1998 by the Madrid Provincial Court to 28 years in prison on charges of embezzling public funds, bribery, embezzlement and tax fraud. (Source: http:\/\/www.tribunalconstitucional.es\/en\/jurisprudencia\/Pages\/Auto.aspx?c...).","Jurisdiction of Origin: Investigative Agency":"The Committee of Inquiry, House of Representatives","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Origin: Courts Involved":"Madrid Provincial Court","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"","Sources ":"Swiss Ministry of Foreign Affairs, September 30, 2009; Recurso e amparo interpuesto por don Luis Roldan Ibanez, Tribunal Constitucional de Espana, Seccion Cuarta, Auto 39\/2003, de 10 de Febrero de 2003, accessed at http:\/\/www.tribunalconstitucional.es\/en\/jurisprudencia\/Pages\/Auto.aspx?c.... BBC News, \u0022Spanish police chief\u0027s $14m costs him 28 years,\u0022 February 26, 1998; New York Times, \u0022Fugitive returned to Spain,\u0022 March 1, 1995; Constitucion Espanola, Art. 76 synopsis on Legislative Development, accessed at http:\/\/www.congreso.es\/consti\/constitucion\/indice\/sinopsis\/sinopsis.jsp?...\n"},{"Case ID":"ARW-118","Case Title (Name of Public Official or Entity Allegedly Involved)":"Mabey \u0026 Johnson (Iraq)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United Kingdom","Position of Public Official(s) (yrs in office)":"Saddam Hussein (President, 1979-2003)","Jurisdiction of Asset Recovery":"Iraq [Development Fund for Iraq]","Jurisdiction of Asset Description":"","Asset Recovery Start":"2007","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Restitution was paid to the Development Fund for Iraq.","Contributing Factors in Asset Recovery":"The Serious Fraud Office cited Mabey and Johnson\u0027s guilty plea and cooperation.  (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd sentencing,\u0022 September 25, 2009.)   The SFO also noted that \u0022A Development Fund for Iraq was set up internationally and payments in Oil for Food cases are made to that fund.  There is therefore an international mechanism for compensation.\u0022 (Source: UK House of Commons International Development, Financial Crime and Development, Eleventh Report of Session 2010-12 (15 November 2011), Volume 1, at Ev38.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$1,002,790","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Restitution was paid to the Development Fund for Iraq, which was established for payments in Oil for Food cases.","Case Summary":"According to information presented by the Serious Fraud Office to the UK Parliamentary Committee on International Development, the sums ordered against Mabey and Johnson were returned to Iraq through the Development Fund for Iraq. (Source:  UK House of Commons International Development, Financial Crime and Development, Eleventh Report of Session 2010-12, Volume 1, at Ev38.)  On September 25, 2009, Mabey and Johnson was ordered to pay in reparations of GBP 618,000 to Iraq, for its activities in contravention of United Nations sanctions against Iraq.  (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd sentencing,\u0022 September 25, 2009, and Prosecution Opening Notes.)  In February 2011, the Serious Fraud Office announced the conviction of two former directors of Mabey \u0026 Johnson, and included mention that the company had paid GBP 618,000 to the Iraq Reconstruction Fund [also known as the Development Fund for Iraq.].  (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson directors made illegal payments to Sadam Hussein\u0027s Iraq to gain contract,\u0022 February 10, 2011.)   On February 23, 2011, Richard Charles Edward Forsyth, former managing director, was ordered to pay prosecution costs of GBP75,000 (US$121,241) and David Mabey, former sales director, was ordered to pay prosecution costs of GBP125,000 (US$202,069).  No monetary penalty was assessed against a third executive, Richard Gledhill, former sales manager. (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd: Former executives jailed for helping finance Saddam Hussein\u0027s government,\u0022 February 23, 2011.)","Disposition of Criminal Case(s)":"Unknown as to Iraqi Public Officials.  According to a September 25, 2009 press release by the UK\u0027s Serious Fraud Office, Mabey \u0026 Johnson appeared before the Southwark Crown Court that day to be sentenced for admitted offences of overseas corruption offences and breaching UN sanctions. (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd sentencing,\u0022 September 25, 2009.)  The Serious Fraud Office also issued a press release on February 11, 2011, accouncing the conviction of two former Mabey \u0026 Johnson directors in the case.  (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson directors made illegal payments to Sadam Hussein\u0027s Iraq to gain contract,\u0022 February 10, 2011.)","Jurisdiction of Origin: Investigative Agency":"UK Serious Fraud Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service","Jurisdiction of Origin: Courts Involved":"Southwark Crown Court","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd sentencing,\u0022 September 25, 2009, and Prosecution Opening Notes, posted at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-20... UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson directors made illegal payments to Sadam Hussein\u0027s Iraq to gain contract,\u0022 February 10, 2011 and UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd: Former executives jailed for helping finance Saddam Hussein\u0027s government,\u0022 February 23, 2011; UK House of Commons International Development, Financial Crime and Development, Eleventh Report of Session 2010-12 (15 November 2011), Volume 1, at Ev38, accessed at http:\/\/www.publications.parliament.uk\/pa\/cm201012\/cmselect\/cmintdev\/847\/...\n"},{"Case ID":"ARW-119","Case Title (Name of Public Official or Entity Allegedly Involved)":"Mabey \u0026 Johnson (Jamaica)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United Kingdom","Position of Public Official(s) (yrs in office)":"Unspecified","Jurisdiction of Asset Recovery":"Jamaica","Jurisdiction of Asset Description":"","Asset Recovery Start":"2007","Asset Recovery End":"","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified but cooperation in the investigation","Contributing Factors in Asset Recovery":"The Serious Fraud Office cited Mabey and Johnson\u0027s guilty plea and cooperation.  (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd sentencing,\u0022 September 25, 2009.) ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$225,546","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to to a UK Parliamentary committee report, the Serious Fraud Office informed the committee that it was the agency\u0027s understanding that Mabey and Johnson had made reparation payments to \u0022the Jamaican customer.\u0022  (Source: UK House of Commons International Development, Financial Crime and Development, Eleventh Report of Session 2010-12, Volume 1, at Ev38.)  On September 25, 2009, Mabey and Johnson was ordered to pay in reparations of GBP 139,000 to Jamaica, for bribes paid to a Jamaican official.  (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd sentencing,\u0022 September 25, 2009, and Prosecution Opening Notes).","Disposition of Criminal Case(s)":"Unknown as to Jamaican Public Officials.  Unknown as to Ghanian public officials.  According to a September 25, 2009 press release by the UK\u0027s Serious Fraud Office, Mabey \u0026 Johnson appeared before the Southwark Crown Court that day to be sentenced for admitted offences of overseas corruption offences and breaching UN sanctions. (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd sentencing,\u0022 September 25, 2009.)","Jurisdiction of Origin: Investigative Agency":"UK Serious Fraud Office ","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service","Jurisdiction of Origin: Courts Involved":"Southwark Crown Court","Jurisdiction of Asset Recovery: Investigative Agency":"Director of Public Prosecutions, Office of the Contractor General","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd sentencing,\u0022 September 25, 2009, and Prosecution Opening Notes, posted at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-20... UK House of Commons International Development, Financial Crime and Development, Eleventh Report of Session 2010-12 (15 November 2011), Volume 1, at Ev38, accessed at http:\/\/www.publications.parliament.uk\/pa\/cm201012\/cmselect\/cmintdev\/847\/...\n"},{"Case ID":"ARW-121","Case Title (Name of Public Official or Entity Allegedly Involved)":"Mansoor ul-Haq [also spelled Mansur ul Haq]","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Pakistan","Position of Public Official(s) (yrs in office)":"Chief of Naval Staff (Unspecified - 1997)","Jurisdiction of Asset Recovery":"Pakistan [mention of illegal foreign assets]","Jurisdiction of Asset Description":"Undertaking Recovery Effort","Asset Recovery Start":"1999","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Letter of Request","Basis for Intl Cooperation":"28 U.S.C. Section 1782 [Letter of Request from Pakistan to U.S.]","Contributing Factors in Asset Recovery":"\u0022legal assistance from foreign expert organizations which led to a major breakthrough towards collection of concrete evidence and discovery of his illegal foreign assets.\u0022   (Source: Case study #16 \u0022Mansoor ul-Haq\u0022 by the National Accountability Bureau of Pakistan, accessed at http:\/\/www.nab.gov.pk\/Downloads\/Case_studies\/mansoorulhaq.pdf.)","Status of Asset Recovery ":"Completed (in part) and Ongoing (in part)","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$6,279,200","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a case study by Pakistan\u0027s National Accountability Bureau (NAB), \u0022After NAB\u0027s inception in 1999, fresh investigations into the alleged kickbacks of the accused in collaboration with legal assistance from foreign expert organizations which led to a major breakthrough towards collection of concrete evidence and discovery of his illegal foreign assets. The former admiral was arrested by U.S. authorities on 17 April 2001 and a reference back in his home country was filed against him in Accountability Court, Rawalpindi on 12 May 2001.  2. The accused was indicted by court on 22 October.\u0022  The case study also notes that Mr. Mansoor ul-Haq \u0022paid U.S. $6.2792 million as first installment of his Plea-Bargained money through safe deposits of Fatima Trust, which is owned members of his family through an off shore company, Messer. Moylegrove, registered in the Isle of Jersey.\u0022  Mr. Mansoor ul-Haq had been charged with receiving illegal commissions and kick-backs. The total plea amount was $7.5 million. Remaining sum was to be paid within 15 months.  (Source: Case study #16, accessed at http:\/\/www.nab.gov.pk\/Downloads\/Case_studies\/mansoorulhaq.pdf; on U.S. assistance, see In re: Letter of Request from the Government of Pakistan for Assistance in the Investigation of Adm. (R) Mansur ul Haq, Case No. 1:01-cv-00164-SS (W.D. Tex.), Motion by United States for order pursuant to Title 28, U.S.C. 1782 filed on March 9, 2001 and Order granting motion for order pursuant to Title 28, U.S.C. 1782, filed on March 19, 2001.)","Disposition of Criminal Case(s)":"According to a case study posted on the website of Pakistan\u0027s National Accountability Bureau, Mr. Mansoor ul-Haq had been charged with corruption related offenses and entered into a settlement agreement with authorities.  (Source: Case study #16, accessed at http:\/\/www.nab.gov.pk\/Downloads\/Case_studies\/mansoorulhaq.pdf, last accessed on May 9, 2011.)","Jurisdiction of Origin: Investigative Agency":"National Accountability Bureau","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"National Accountability Bureau","Jurisdiction of Origin: Courts Involved":"Accountability Court, Riwalpindi","Jurisdiction of Asset Recovery: Investigative Agency":"National Accountability Bureau","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"National Accountability Bureau (Pakistan); U.S. Attorney for the Western District of Texas [Letter of Request from Pakistan]","Jurisdiction of Asset Recovery: Courts Involved":"Accountability Court, Riwalpindi (Pakistan); U.S. District Court for the Western District of Texas [Letter of Request from Pakistan]","Documents":"","Sources ":"Case study #16, \u0022Mansoor ul-Haq\u0022 by the National Accountability Bureau of Pakistan and posted at its website: http:\/\/www.nab.gov.pk\/Downloads\/Case_studies\/mansoorulhaq.pdf; \nIn re:  Letter of Request from the Government of Pakistan for Assistance in the Investigation of Adm. (R) Mansur ul Haq, Case No. 1:01-cv-00164-SS (W.D. Tex. 2001), Motion by United States for Order pursuant to Title 28, U.S.C. 1782 filed on March 9, 2001 and Order granting motion for order pursuant to Title 28, U.S.C. 1782, filed on March 19, 2001; \nBBC News, \u0022Former head of Pakistan navy disciplined,\u0022 January 31, 2002, posted at http:\/\/news.bbc.co.uk\/2\/hi\/south_asia\/1792779.stm.\n"},{"Case ID":"ARW-122","Case Title (Name of Public Official or Entity Allegedly Involved)":"Manuel Antonio Noriega","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Panama","Position of Public Official(s) (yrs in office)":"Commander, Panama Defense Forces (1983-1989)","Jurisdiction of Asset Recovery":"France","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.18, Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture  ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified, but Panama was Partie Civile in the French prosecution","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"N\/A","Case Summary":"On July 7, 2010, Mr. Noriega was convicted in Paris of money laundering of criminal drug proceeds received while he was commander of the Panama Defense Forces.  He was ordered to forfeit 2.2 million Euros (U.S.$2.8 million) that had been frozen in his French bank accounts.  Reuters reported that the court also ordered EUR 1 million (approx. U.S. $1,026,000) to be paid in damages to Panama.  Mr. Noriega had originally been convicted in absentia in 1999 in France, but retried after completion of his sentence in U.S. and extradition to France.  Mr. Noriega had unsuccessfully contested his extradition from the United States.  Panama had been a \u0022partie civile\u0022 (civil party) in the criminal case. (Source: Administration des Douanes et Droits Indirects c\/ NORIEGA, Republique francaise, Au nom du Peuple francais, Tribunal de Grande Instance de Paris, 11eme chambre\/1, No d\u0027affaire : 8935669013 Jugement du : 7 juillet 2010 no : 14.)","Disposition of Criminal Case(s)":"According to the July 7, 2010 decision by a Paris trial court, Mr. Noriega was convicted money laundering of criminal drug proceeds received while he was commander of the Panama Defense Forces. (Source: Administration des Douanes et Droits Indirects c\/ NORIEGA, Republique francaise, Au nom du Peuple francais, Tribunal de Grande Instance de Paris, 11eme chambre\/1, No d\u0027affaire : 8935669013 Jugement du : 7 juillet 2010 no : 14.)   According to the U.S. 11th Circuit Court of Appeals, Mr. Noriega was also convicted in the U.S. on eight drug-related counts.  (Source: US v. Noriega, Nos. 92-4687, 96-4471 (11th Cir.), Judgment dated July 7, 1997.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Public Prosecutor","Jurisdiction of Asset Recovery: Courts Involved":"Tribunal de Grande Instance de Paris, 11th Chamber","Documents":"","Sources ":"Administration des Douanes et Droits Indirects c\/ NORIEGA, Republique francaise, Au nom du Peuple francais, Tribunal de Grande Instance de Paris, 11eme chambre\/1, No d\u0027affaire : 8935669013 Jugement du : 7 juillet 2010 no : 14; David Jolly, \u0022French court sentences Noriega to 7 years,\u0022 New York Times, July 7, 2010. See also, U.S. v. Noriega, et al, Case No. 1:88-cr-00079-WMH (S.D. Fla), please note that many documents are missing from docket; U.S. v. Noriega, 746 F. Supp. 1511 (11th Circuit Court, affirming conviction and denying new trial, decision dated July 7, 1997.)\n"},{"Case ID":"ARW-125","Case Title (Name of Public Official or Entity Allegedly Involved)":"Maria Carolina Nolasco (also referred to as Carolina Nolasco) \/ Brazil - New York Money Transmitters Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Brazil","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"2007","UNCAC Offenses Implicated":"Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Non-Conviction Based Confiscation ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Close cooperation between U.S. and Brazilian authorities; underlying case triggered by New York County District Attorney\u0027s Office investigation into black market money transmitters. (Source: Decennial Report of the District Attorney, County of New York, 2000-2009, \u0022Merchant\u0027s Bank\/Valley National Bank, at 131.)   ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"As described in a report highlighting its work from 2000-2009, \u0022The District Attorney\u0027s Office, as part of a 2002 investigation into unlicensed money transmissions through New York, discovered that more than 60 people, all Brazilian citizens and all foreign-based money transmitters, were operating unlicensed money transmission businesses in New York County. The 60 Brazilians accomplished their crimes using accounts at Merchant\u0027s Bank \/ Valley National Bank in Manhattan, and then transmitted the funds to other accounts which were designated by their customers. In order to facilitate this criminal activity, the individuals \u0022employed\u0022 Carolina Nolasco, a corrupt employee of Valley National Bank, via bribery payments to manage their accounts and attend to their business interests in New York. The corporate defendants were chiefly offshore shell corporations that were used by the individual defendants.\u0022 (Source: Decennial Report of the District Attorney, County of New York, 2000-2009, \u0022Merchant\u0027s Bank\/Valley National Bank, at 131.)   Maria Carolina Nolasco was arrested in 2002 and, in U.S. District Court for the District of New Jersey, pleaded guilty to money laundering.  She also agreed to forfeit over $21 million held in 39 bank accounts held at Merchants Bank, where she had worked.  The funds were then turned over to the New York County District Attorney\u0027s office (which had initiated the investigation) for civil asset forfeiture.  The NY County District Attorney\u0027s office, in turn, transferred the funds to the custody of the Department of Justice, which filed a civil asset forfeiture action in the U.S. District Court for the District of Columbia for the funds which Brazil was seeking return.  (Sources: U.S. v. Nolasco, Case No. 04-cr-617 (D.N.J.); Morgenthau v. Avion Resources Ltd., et al, 898 N.E.2d 929 (NY 2008); Brief for the United States in Opposition, in Harber Corporation, et al v. U.S., U.S. SCt, 09-1389.  Unable to locate the name and documents of the District of Columbia civil forfeiture case.","Disposition of Criminal Case(s)":"According to a letter by the United States Attorney for the District of New Jersey that was filed in U.S. District Court for the District of New Jersey on October 4, 2004, Ms. Nolasco pleaded guilty to charges of operating a money transmitting business without a license.  (Source:  US v. Nolasco, Case No.  2:04-cr-617-JAG (D.N.J.), Letter by United States Attorney for the District of New Jersey filed on October 4, 2004.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Immigration and Customs Enforcement; Internal Revenue Service, Criminal Division; Drug Enforcement Administration","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"New York County District Attorney\u0027s Office; US Attorney for the District of New Jersey; US Department of Justice","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of New Jersey","Documents":"","Sources ":"U.S. v. Nolasco, Case No. 04-cr-617 (D.N.J.), Plea agreement filed on October 4, 2004, Consent Order for Preliminary Forfeiture, filed on December 17, 2004, Amended Order Amending Preliminary Order of Forfeiture, filed on June 8, 2006; \nMorgenthau v. Avion Resources Ltd., et al, 898 N.E.2d 929 (NY 2008); \nBrief for the United States in Opposition, in Harber Corporation, et al v. U.S., SCt, 09-1389.  (District of Columbia Civil Asset Forfeiture Case -- Case name and information - unable to obtain.); \nDecennial Report of the District Attorney, County of New York, 2000-2009, \u0022Merchant\u0027s Bank\/Valley National Bank, at 131, accessed at http:\/\/manhattanda.org\/whatsnew\/inthenews\/2009-12-30.pdf.\n"},{"Case ID":"ARW-126","Case Title (Name of Public Official or Entity Allegedly Involved)":"Michael Misick","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Turks and Caicos","Position of Public Official(s) (yrs in office)":"Prime Minister (2006-2009); Chief Minister (2003-2006); Legislative Council (1991-?)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\n\n\t\t\tBeginning in 2010, along with the criminal investigation, civil recovery efforts by law firm of Edwards Angell Palmer \u0026 Dodge were taking place in the Turks and Caicos. \u00a0(Sources: Quarterly Statement and Annual Review from the Governor [Gordon Wetherell], dated September 9, 2010; Attorney General v. Salt Cay Devco Limited, Salt Cay Estates Limited, Salt Cay Golf Club Limited, No. CL-5\/2010, Supreme Court of the Turks and Caicos Islands, filed April 23, 2010. \u00a0See also, The Turks and Caicos Islands, Government Information Service Press Release, \u0022Special Prosecutor Helen Garlick Introduced to TCI,\u0022 posted at http:\/\/www.tcgov.tc\/info--ID--500.html.) \u00a0According to the Turks and Caicos Sun, the publication had obtained documents which stated: \u0022on June 23rd, 2011, Chief Justice His Lordship Gordon Ward made the order to freeze all of Misick\u2019s assets, including bank accounts here and overseas, his personal residence in Providenciales, parcels of land throughout the Turks and Caicos Islands, two condominiums, a cinema in Providenciales [ \u00a0] and several credit cards.\u0022 \u00a0 (Source: Hayden Boyce, Sun Publisher and Editor-in- Chief, \u0022Michael Misick\u0027s Assets Frozen World-wide,\u0022 Turks and Caicos Sun, posted July 4, 2011.)\n\n\t\t\t\u00a0\n\n\t\t\tAccording to secondary sources, Mr. MIsick\u0027s trial is ongoing as of June 2016, when he was also granted permission to travel to the Dominican Republic for medical services. (Source: Caribbean News Now, \u0022\u0022Corruption-accused former Turks and Caicos premier to travel for medical attention,\u0022 June 6, 2016.)\n\n\t\t\t\u00a0\n\n\t\t\tIn a related case, according to a press release issued jointly by the Turks and Caicos Attorney General, Director of Public Prosecutions and the Special Investigation and Prosecution Team, Richard Padgett pleaded guilty on May 31, 2013 to bribery and conspiracy. \u00a0The TCI Government also announced that it had settled all civil claims and proceedings against Mr. Padgett and his companies, including \u201ccivil claims arising from the Third Turtle Development referred to in the Report of the Commission of Inquiry, and a separate civil claim arising in relation to Crown Land on East Caicos acquired by a company controlled by Richard Padgett. \u00a0Under the settlement, Mr Padgett has transferred to TCIG land which has been valued at approximately US$7m, and has made a cash contribution of $75,000 to the costs of investigating the claims. The land transferred to TCIG includes about 540 acres of former Crown Land on East Caicos (although some of this land is charged to a bank for about US$1.5m), and two parcels at North West Point and Richmond Commons on Providenciales totalling about 10 acres.\u201d \u00a0(Source: \u0022TCI criminal and civil case update,, issued jointly by the Turks and Caicos Attorney General, Director of Public Prosecutions and the Special Investigation and Prosecution Team, gov.uk, May 31, 2013, accessed at https:\/\/www.gov.uk\/government\/world-location-news\/tci-criminal-and-civil...).\u00a0\n\n\t\t\t\u00a0\n\n\n\u00a0","Disposition of Criminal Case(s)":"According to a January 2014 statement by the Governor\u0027s Office of Turks and Caicos, \u0022Mr Misick faces charges of conspiracy to receive bribes, conspiracy to defraud government, and money laundering related to his time in office.report by the Governor of Turks and Caicos.\u0022  (Source: Governor\u0027s Office Waterloo Grand Turk, \u0022Former Premier of the TCI, Michael Misick, was released on conditional bail by the TCI Supreme Court today, Monday, 13 January 2014.); As of June 2016, his trial was ongoing. (Source: Caribbean News Now, \u0022Corruption-accused former Turks and Caicos premier to travel for medical attention,\u0022 June 16, 2016.)","Jurisdiction of Origin: Investigative Agency":"Special Investigation and Prosecution Team, Special Prosecutor; Edwards Angell Palmer \u0026 Dodge law firm (civil asset recovery)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Special Investigation and Prosecution Team, Special Prosecutor; Edwards Angell Palmer \u0026 Dodge law firm (civil asset recovery)","Jurisdiction of Origin: Courts Involved":"Supreme Court of the Turks and Caicos Islands (against the Salt Cay developers)","Jurisdiction of Asset Recovery: Investigative Agency":"Special Investigation and Prosecution Team, Special Prosecutor; Edwards Angell Palmer \u0026 Dodge law firm (civil asset recovery)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Special Investigation and Prosecution Team, Special Prosecutor ; Edwards Angell Palmer \u0026 Dodge law firm (civil asset recovery)","Jurisdiction of Asset Recovery: Courts Involved":"Supreme Court of the Turks and Caicos Islands (against the Salt Cay developers)","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_AG_v_Salt_Cay_Apr_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Governor_Wetherell_4th_Quarterly_Statement_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Special_Prosecutor_Introduced_Aug_27_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_The Sun_worldwide-freeze-order-posted-Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Misick_UK_SIPT_Update_Oct_4_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_AG_v_Salt_Cay_Apr_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Governor_Wetherell_4th_Quarterly_Statement_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Special_Prosecutor_Introduced_Aug_27_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_The Sun_worldwide-freeze-order-posted-Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Misick_The%20Sun_worldwide-freeze-order-posted-Jul_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_AG_v_Salt_Cay_Apr_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Governor_Wetherell_4th_Quarterly_Statement_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Special_Prosecutor_Introduced_Aug_27_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_The Sun_worldwide-freeze-order-posted-Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Misick_Padgett_UKGOV_PR_May_23_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_AG_v_Salt_Cay_Apr_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Governor_Wetherell_4th_Quarterly_Statement_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Special_Prosecutor_Introduced_Aug_27_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_The Sun_worldwide-freeze-order-posted-Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Misick_Padgett_UKGOV_PR_May_31_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_AG_v_Salt_Cay_Apr_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Governor_Wetherell_4th_Quarterly_Statement_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Special_Prosecutor_Introduced_Aug_27_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_The Sun_worldwide-freeze-order-posted-Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Misick_Charges_Bail_TCI_Gov_Statement_Jan_14_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_AG_v_Salt_Cay_Apr_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Governor_Wetherell_4th_Quarterly_Statement_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_Special_Prosecutor_Introduced_Aug_27_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Misick_The Sun_worldwide-freeze-order-posted-Jul_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Misick_TCI_Govt_Statement_Extradition_Jan_7_2014.pdf","Sources ":"\n\tGovernor\u0027s Office Waterloo Grand Turk, \u0022Former Premier of the TCI, Michael Misick, was released on conditional bail by the TCI Supreme Court today, Monday, 13 January 2014, at https:\/\/www.gov.uk\/government\/world-location-news\/former-turks-and-caico...\n\n\t\u00a0\n\n\tGovernment of the Turks and Caicos Islands, \u0022Premier Ewing Welcomes the Return of Michael Misick,\u0022 January 7, 2014, at http:\/\/www.gov.tc\/pressoffice\/?q=latest-news\/premier-ewing-welcomes-retu...\n\n\t\u00a0\n\n\tQuarterly Statement and Annual Review from the Governor [Gordon Wetherell], dated September 9, 2010; Attorney General v. Salt Cay Devco Limited, Salt Cay Estates Limited, Salt Cay Golf Club Limited, No. CL-5\/2010, Supreme Court of the Turks and Caicos Islands, filed April 23, 2010. \u00a0See also, The Turks and Caicos Islands, Government Information Service Press Release, \u0022Special Prosecutor Helen Garlick Introduced to TCI,\u0022 posted at http:\/\/www.tcgov.tc\/info--ID--500.html; Hayden Boyce, Sun Publisher and Editor-in- Chief, \u0022Michael Misick\u0027s Assets Frozen World-wide,\u0022 Turks and Caicos Sun, posted July 4, 2011, accessed at http:\/\/www.suntci.com\/index.php?p=story\u0026id=1793.\n\n\t\u00a0\n\n\tGov.UK, \u0022TCI criminal and civil case update: Issued jointly by the Turks and Caicos Attorney General, Director of Public Prosecutions and the Special Investigation and Prosecution Team,\u0022 May 31, 2013, accessed at https:\/\/www.gov.uk\/government\/world-location-news\/tci-criminal-and-civil...\n\n\t\u00a0\n\n\tGov.UK, \u0022Civil recovery retrieves $19.5m and 2,500 acres with more to come.\u0022 May 23, 2013 accessed at https:\/\/www.gov.uk\/government\/world-location-news\/civil-recovery-retriev...\n"},{"Case ID":"ARW-127","Case Title (Name of Public Official or Entity Allegedly Involved)":"Mohamed Suharto","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Indonesia","Position of Public Official(s) (yrs in office)":"President (1967-1998)","Jurisdiction of Asset Recovery":"Indonesia","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"1998","Asset Recovery End":"2010","UNCAC Offenses Implicated":"Art.17, Art.19","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Civil suit","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"On Appeal","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$307,000,000","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unspecified","Case Summary":"The Government of Indonesia had brought a civil suit against the Suharto family, charging that they misused the Supersemar Foundations\u0027 funds.  Instead of using the funds for its intended purpose of providing scholarships for poor children, the Soehartos were found to have funnelled foundation\u0027s funds to businesses and banks owned by associates of the former president.  According to the Jakarta Post, the Supreme Court announced in a press conference on December 31, 2010 that the Supersemar suit had retrieved Rp. 2.8 trillion (US$307,440,000) for the government.  (Source:  The Jakarta Post, \u0022Supreme Court retrieves Rp 9.43t in 2010,\u0022 December 31, 2010, accessed at http:\/\/www.thejakartapost.com\/news\/2010\/12\/31\/supreme-court-retrieves-rp....)","Disposition of Criminal Case(s)":"According to his January 28, 2008 obituary, Mr. Suharto \u0022managed to escape criminal prosecution for embezzling millions of dollars, possibly billions, by having himself declared mentally incapable to stand trial.\u0022 (Source: Marilyn Berger, \u0022Suharto Dies at 86; Indonesian Dictator Brought Order and Bloodshed,\u0022 New York Times, January 28, 2008.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Origin: Courts Involved":"South Jakarta District Court; High Court; Supreme Court","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"South Jakarta District Court; High Court; Supreme Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Suharto_Obituary_NYTimes_Jan_28_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Suharto_Supersemar_Atty_Genl_Dec_25_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Suharto_Supersemar_Atty_Genl_Oct_16_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Suharto_Supersemar_SCt_Jakarta_Post_Dec_31_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Suharto_Supersemar_Fdn_Jakarta_Post_May_16_2013.pdf","Sources ":"The Jakarta Post, \u0022Supreme Court retrieves Rp 9.43t in 2010,\u0022 December 31, 2010, accessed at http:\/\/www.thejakartapost.com\/news\/2010\/12\/31\/supreme-court-retrieves-rp... Official Website of the Attorney General of the Republic of Indonesia, \u0022Perkara Perdata Yayasan Supersemar\u0022 [Civil fraud case of Supersemar Foundation], October 16, 2009 and \u0022Perkara Gugatan Perdata Pemerintah RITerhadap Mantan Presiden RI HM.Soeharto\/ Yayasan Supersemar\u0022 [Government Civil Suit against former President Soeharto and Supersemar Foundation], December 25, 2007, accessed respectively at http:\/\/www.kejaksaan.go.id\/unit_kejaksaan.php?idu=25\u0026idsu=19\u0026id=1487 and http:\/\/www.kejaksaan.go.id\/unit_kejaksaan.php?idu=25\u0026idsu=19\u0026id=32. [Court decision numbers: The South Jakarta District Court (904\/Pdt.G\/2007\/PN.Jak.Sel) and the Jakarta High Court (465\/PDT\/2008\/PT.DKI)]; Marilyn Berger, \u0022Suharto Dies at 86; Indonesian Dictator Brought Order and Bloodshed,\u0022 New York Times, January 28, 2008, accessed at http:\/\/www.nytimes.com\/2008\/01\/28\/world\/asia\/28suharto.html?scp=2\u0026sq=suh... Jakarta Post, \u0022Soeharto\u0027s foundation told to pay damages,\u0022 May 16, 2013, at http:\/\/www.thejakartapost.com\/news\/2013\/05\/16\/soeharto-s-foundation-told...\n"},{"Case ID":"ARW-128","Case Title (Name of Public Official or Entity Allegedly Involved)":"Moussa Traore","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mali","Position of Public Official(s) (yrs in office)":"President (1979-1991)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1991","Asset Recovery End":"1997","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Unspecified","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"According to Anne Lugon-Moulin, Mali \u0022asked Switzerland if it was willing to pay for the fees of a Swiss lawyer who could represent the interests of the Malian State.  This request was accepted and funded by the [Swiss Agency for Development and Co-operation], which had been operating in Mali for many years....  It was the first time that Switzerland had repatriated assets to an African State, and was also an example of an innovative collaboration between the Federal Department of Justice and the Foreign Affairs Department.\u0022 (Source: Anne Lugon-Moulin, \u0022Asset recovery: concrete challenges for development assistance,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008)).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$2,400,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"Switzerland noted that the Government of Mali spent the funds on rural development programs.","Case Summary":"According to the Swiss Ministry of Foreign Affairs, $2.4 million in assets were returned to Mali.  Switzerland also paid the fees of the Mali lawyer. (Source: Swiss Ministry of Foreign Affairs, September 30, 2009.)  The 1991 Mutual Legal Assistance Treaty request by the Malian government had asked if Switzerland would be willing to pay for a Swiss lawyer who could represent the interests of the Malian State. The request was accepted and funded by the Swiss Agency for Development and Co-operation (SDC).  The Konare government spent the money on rural development programs.  (Source: Anne Lugon-Moulin, \u0022Asset recovery: concrete challenges for development assistance,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (2008)).","Disposition of Criminal Case(s)":"According to the BBC timeline of Mali\u0027s history, Mr. Traore was pardoned in 2002. (Source:  BBC, Timeline: Mali, accessed at http:\/\/news.bbc.co.uk\/2\/hi\/africa\/country_profiles\/1022844.stm, on May 10, 2011.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"","Sources ":"Swiss Ministry of Foreign Affairs, September 30, 2009; \nAnne Lugon-Moulin, \u0022Asset recovery: concrete challenges for development assistance,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008); \nBBC, Timeline: Mali, accessed at http:\/\/news.bbc.co.uk\/2\/hi\/africa\/country_profiles\/1022844.stm, on May 10, 2011.\n"},{"Case ID":"ARW-141","Case Title (Name of Public Official or Entity Allegedly Involved)":"Munari and Rovelli Settlements \/ Vittorio Metta (Judge) \/ IMI Bank Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Italy","Position of Public Official(s) (yrs in office)":"Court of Appeals Judge (Metta, inclusive 1990)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2007","Asset Recovery End":"2007","UNCAC Offenses Implicated":"Art.15, Art.17, Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Cooperation by the U.S. and Italian authorities and sharing of information which enabled the U.S. to link successfully the assets to the defendants although the underlying criminal offenses had taken place over a decade prior to the filing of the complaint for civil asset forfeiture. (Source: Researcher interview, U.S. Immigration and Customs and Enforcement, December 2010.) ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$122,000,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In November 2007, the United States District Court for the Southern District of Florida issued a Final Judgment of Forfeiture against a number of bank and securities accounts, as proceeds, property traceable to proceeds and property involved in foreign public corruption offenses, fraud against a foreign bank, U.S. money laundering offenses, and violations of 18 U.S.C. section 2314 (transportation of stolen goods, moneys, etc.)  The judgment followed settlement agreements by the U.S. and (1) Pier Francesco Munari and Concejo de Capital Hanne, CCH, S.A. and (2) Oscar Rovelli, Angela Rovelli and Primarosa Battistella in which the individuals agreed to forfeit their interests in the properties to the United States in order that the United States could return the properties to Italy for the resolution of pending Italian legal proceedings against them.  According to the U.S. Government complaint, the money laundering scheme involved shell entities or their financial accounts being \u0022set-up in numerous foreign countries, including, but not limited to, the United States, British Virgin Islands, the Cayman Islands, Guernsey, Jersey, Switzerland, Luxembourg, Liechtenstein, Singapore, the Cook Islands, and Costa Rica. Eventually, portions of the fraudulently obtained IMI monies held by these MUNARI controlled entities found their way into financial accounts located in the United States.\u0022  The U.S. returned $122 million to Italy to an escrow account established by an Italian court which had ordered restitution for the victim bank.   (Sources: U.S. v. Proceeds of Crime Transferred to Certain Domestic Financial Accounts, Case No. 07-21791-civ-UU (S.D. Fla.), Verified Complaint for Forfeiture In Rem filed on July 17, 2007 and Final Judgment of Forfeiture filed November 21, 2007); U.S. Department of Justice Press Release, \u0022Money Laundering Forfeiture Complaint Filed against $110 million in Proceeds from Italian Public Corruption Offenses,\u0022 July 16, 2007; Researcher phone interview with investigator, U.S. Immigration and Customs and Enforcement, December 2010.)","Disposition of Criminal Case(s)":"According to the U.S. civil forfeiture complaint, in May 2006, the Italian Supreme Court affirmed Mr. Metta\u0027s conviction for \u0022bribery in judicial acts.\u0022  (Source: U.S. v. Proceeds of Crime Transferred to Certain Domestic Financial Accounts, Case No. 07-21791-civ-UU (S.D. Fla.), Verified Complaint for Forfeiture in Rem (filed July 17, 2007).","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"Supreme Court; Court of Appeal (Rome); Italian Tribunal (Rome)","Jurisdiction of Asset Recovery: Investigative Agency":"Immigration and Customs Enforcement, Office of Investigations in Miami; Department of Justice Criminal Division\u2019s Office of International Affairs and the Justice Department\u2019s Attach\u00e9 in Rome;  Immigration and Customs Enforcement Attach\u00e9 in Rome.","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section;  U.S. Attorney\u2019s Offices for the Southern District of Florida, Asset Forfeiture Division; U.S. Attorney\u0027s Offices for Southern District of California, District of New Jersey and Southern District of New York (ex-parte restraint orders)","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of Florida","Documents":"","Sources ":"U.S. v. Proceeds of Crime Transferred to Certain Domestic Financial Accounts, Case No. 07-21791-civ-UU (S.D. Fla.), Verified Complaint for Forfeiture in Rem (filed July 17, 2007) and Final Judgment of Forfeiture (filed November 21, 2007); \nU.S. Department of Justice Press Release, \u0022Money Laundering Forfeiture Complaint Filed against $110 million in Proceeds from Italian Public Corruption Offenses,\u0022 July 16, 2007; Researcher interview, U.S. Immigration and Customs and Enforcement, December 2010.\n"},{"Case ID":"ARW-144","Case Title (Name of Public Official or Entity Allegedly Involved)":"Omar Bongo","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Gabon","Position of Public Official(s) (yrs in office)":"President (1967-2009)","Jurisdiction of Asset Recovery":"France","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2007","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Ongoing Case, but Transparency International stated that this is the first time French courts allowed such a complaint by nongovernmental organizations to proceed. Source: Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision: The complaint filed by Transparency International France is ruled admissible,\u0022 November 9, 2010.","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"Three non-governmental organizations had filed their \u0022Biens Mal Acquis\u0022 (Improperly acquired property) complaint against Omar Bongo, Denis Sassou Nguesso and Teodoro Obiang and their relatives.  (Source: Supreme Court of France, Case No. 6092, decision of November 9, 2010, L\u0027association Transparence Intenrational France, partie civile, reversing High Court of Paris, section 2, judgment of October 29, 2009.)  With regard to Mr. Bongo and his relatives, the complaint alleged that they had acquired real estate, including thirty-nine properties, seventeen of which are registered in his name.  According to Transparency International, most of the properties are located in Paris\u0027 upscale 16th district; seventy identified bank accounts, eleven of which are registered in name of Omar Bongo, and a fleet of automobiles comprising at least nine vehicles for a total estimated value of EUR 1,493,443.   (Source: Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision, The complaint by Transparence International France is ruled admissible,\u0022 November 9, 2010.)\nAccording to the August 18, 2015 message by President Bongo, on the occasion of the 55th anniversary of the independence of Gabon, he had decided to offer the Gabonese people all income from part of his inheritance to assist in the education and training of the Gabonese youth, the residence of Omar Bongo Ondimba in the capital will be sold to the state to build a university and two Paris properties will be sold to the state and earmarked for the promotion of culture and diplomatic influences of the country. (Source:  Republique Gabonaise, Direction de la communication Presidentielle, August 18, 2015)","Disposition of Criminal Case(s)":"In November 2010, the French Supreme Court held that the criminal complaint filed earlier by Transparency International and other non-governmental organizations against Mr. Bongo may proceed. (Source: Supreme Court of France, Case No. 6092, decision of November 9, 2010, L\u0027association Transparence Intenrational France, partie civile, reversing High Court of Paris, section 2, judgment of October 29, 2009.)","Jurisdiction of Origin: Investigative Agency":"NA","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Investigating Magistrate","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Public Prosecutor","Jurisdiction of Asset Recovery: Courts Involved":"Supreme Court, High Court (Paris)","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bongo_France_SCt_Judgment_Nov_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bongo_France_TransparencyIntl_Sherpa_Press_Release.docx\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bongo_Statement_Aug2015.pdf","Sources ":"\n\tSupreme Court of France, Case No. 6092, decision of November 9, 2010, L\u0027association Transparence International France, partie civile, reversing High Court of Paris, section 2, judgment of October 29, 2009. See also Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision, The complaint by Transparence International France is ruled admissible,\u0022 November 9, 2010, posted at http:\/\/www.transparency.org\/news_room\/latest_news\/press_releases_nc\/2010...\n\n\t\u00a0\n\n\tRepublique Gabonaise, Direction de la communication Presidentielle, August 18, 2015, at www.preidence-gabon.ga\/presse)\n"},{"Case ID":"ARW-145","Case Title (Name of Public Official or Entity Allegedly Involved)":"Omar Bongo \/ Lobbyist Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Gabon","Position of Public Official(s) (yrs in office)":"President (1967-2009)","Jurisdiction of Asset Recovery":"Malta","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2010","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In the aftermath of the February 4, 2010 U.S. Senate Permanent Subcommittee on Investigations hearing and investigation report on Mr. Bongo, Malta press reported that Maltese authorities were investigating alleged transfer of funds by Mr. Bongo\u0027s Washington lobbyist Jeffrey Birrell to that country.  (Source: Malta Today, \u0022Late Gabon President Omar Bongo had [EUR] 7 million Malta bank account,\u0022 May 2, 2010.)  The U.S. Senate Permanent Subcommittee on Investigations Press Release stated that in 2006, $18 million in funds from Gabon were wired to the U.S. corporate bank accounts of a U.S. lobbyist who then distributed the funds within the United States and across the globe as directed by President Bongo in connection with two projects to support his regime, buying U.S.-made armored cars and C-130 military cargo planes.  Among the funds the lobbyist distributed was $9.2 million which he wire transferred to an account for President Omar Bongo - not in Gabon - but in the country of Malta.  (Source: United States Senate, Permanent Subcommittee on Investigations, Committee on Homeland Security and Governmental Affairs, Majority and Minority Staff Report, \u0022Keeping Foreign Corruption Out of the United States: Four Case Histories,\u0022 released in conjunction with the Permanent Subcommittee on Investigations February 4, 2010 Hearing.)","Disposition of Criminal Case(s)":"In November 2010, the French Supreme Court held that the criminal complaint filed earlier by Transparency International and other non-governmental organizations against Mr. Bongo may proceed. (Source: Supreme Court of France, Case No. 6092, decision of November 9, 2010, L\u0027association Transparence Intenrational France, partie civile, reversing High Court of Paris, section 2, judgment of October 29, 2009.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"United States Senate, Permanent Subcommittee on Investigations, Committee on Homeland Security and Governmental Affairs, Majority and Minority Staff Report, \u0022Keeping Foreign Corruption Out of the United States: Four Case Histories,\u0022 released in conjunction with the Permanent Subcommittee on Investigations February 4, 2010 Hearing, posted at http:\/\/hsgac.senate.gov\/public\/index.cfm?FuseAction=Hearings.Hearing\u0026Hea... links to witness testimonies also at same; \nMalta Today, \u0022Late Gabon President Omar Bongo had [EUR] 7 million Malta bank account,\u0022 May 2, 2010.\n"},{"Case ID":"ARW-148","Case Title (Name of Public Official or Entity Allegedly Involved)":"Paulo Maluf (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Brazil","Position of Public Official(s) (yrs in office)":"Governor and Mayor of Sao Paulo (Governor,1979-1983; Mayor, 1993-1996); Legislator (as of 2007)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In April 2014, a New York Supreme Court Appellate Division panel unanimously refused to overturn a lower court decision not to grant Mr. Maluf\u0027s request to have the indictment filed against him dismissed.  (Sources:  Matter of Maluf v Vance 2014 NY Slip Op 02546 Decided on April 15, 2014 Appellate Division, First Department and Mark Thompson, \u0022Brazilian Pol Can\u0027t Shake Indictment in New York,\u0022 Courthouse News Service, April 22, 2014.)  The appellate court held that: \u0022The extraordinary remedy of prohibition is not available to petitioners, who assert that the underlying criminal action violates their statutory and constitutional rights to a speedy trial and their right to due process, or, in the alternative, that the indictment should be dismissed either in furtherance of justice pursuant to CPL 210.40(1) or under principles of international comity. These claims allege errors of law for which petitioners have adequate alternative remedies, including filing pretrial motions in the underlying criminal action and challenging any conviction on appeal [citation omitted]. That petitioners would have to voluntarily leave their home country to appear for arraignment since Brazil will not extradite its own citizens before availing themselves of such remedies does not render them inadequate [citation omitted] Moreover, petitioners have failed to meet their burden of demonstrating a \u0022clear legal right\u0022 to any of the relief sought [ ].\u0022  (Source: Matter of Maluf v Vance 2014 NY Slip Op 02546 Decided on April 15, 2014 Appellate Division, First Department, published at http:\/\/law.justia.com\/cases\/new-york\/appellate-division-first-department....)\nIn April 2012, the New York County Supreme Court had declined to grant Mr. Maluf\u0027s request to have the indictment filed against him dismissed and to have an Interpol arrest warrant lifted. (Source: Matter of Maluf v. Vance, 2012 NY Slip Op 50743(U), April 24, 2012.)  In March 2007, Mr. Maluf, his family members and his associates were indicted by the New York County District Attorney\u0027s Office, which charged them with conspiracy, grand larceny and criminal possession of stolen property.  The indictment alleged that, \u0022The object of the conspiracy was to steal money from the City of Sao Paulo, Brazil, to possess the money in Brazil, New York and elsewhere, and to conceal the existence of the conspiracy and the location of the stolen money. To do this, the conspirators perpetrated an over-invoicing and kick-back scheme involving the municipal construction of an arterial highway in Sao Paulo known as the Avenida Agua Espraiada project. In the course of the conspiracy, stolen proceeds were transferred to a bank account in New York County and, from New York County, to a bank account located in the Bailiwick of Jersey in the Channel Islands. The conspirators also used the bank account in New York County to return stolen proceeds to Brazil, to buy personal items, and to pay for expenses related to Brazilian political campaigns.  During the period from on or about January 1993 to on or about December 1996, PAULO MALUF was Mayor of Sao Paulo. During this period and thereafter, PAULO MALUF directed the over-invoicing scheme, received kick-backs from the scheme amounting to millions of dollars, used secret bank accounts in New York County and the Bailiwick of Jersey to hide and utilize the stolen funds, and was the conspiracy\u2019s principal beneficiary. (Source: The People of the State of New York v. Paulo Maluf, Flavio Maluf, Simeao Damasceno de Oliveira, Joel Guedes Fernandes and Vivaldo Alves, Indictment filed on March 8, 2007, New York State Supreme Court, County of New York.)   Then-District Attorney for New York County, Mr. Robert Morgenthau, wrote that Mr. Maluf\u0027s indictment was among the spin-offs of his office\u0027s investigation into the unlicensed money transmitter, Beacon Hill Service Corporation.  Mr. Morgenthau wrote that $140 million had passed through Mr. Maluf\u0027s principal account at Safra National Bank in Manhattan.  (Source: Robert Morgenthau, \u0022Tax Evasion Nation,\u0022 American Interest, September-October 2008, last accessed on October 1, 2010 at http:\/\/www.the-american-interest.com\/article-bd.cfm?piece=465.)","Disposition of Criminal Case(s)":"According to the March 8, 2007 press release by the New York County District Attorney\u0027s Office, Mr. Maluf was indicted in New York for his alleged conspiracy in embezzlement of public funds and concealment of such funds, and that charges were also pending against him in Brazil. \u00a0(Source: The People of the State of New York v. Paulo Maluf, Flavio Maluf, Simeao Damasceno de Oliveira, Joel Guedes Fernandes and Vivaldo Alves, Indictment filed on March 8, 2007 in New York state Supreme Court, County of New York and New York County District Attorney\u0027s Office, News Release on the Paulo Maluf case, March 8, 2007.) \u00a0According to Agence France Presse, on November 4, 2013, Mr. Maluf\u0027s conviction on \u0022administrative corruption\u0022 was upheld by a Brazilian court. (Source: Agence France Presse, \u0022Graft sentence upheld for ex-Sao Paulo ex-mayor,\u0022 November 4, 2013.)","Jurisdiction of Origin: Investigative Agency":"Ministry of Justice; Federal Police","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General of the State of Sao Paulo, Prosecutor General of the Republic of Brazil","Jurisdiction of Origin: Courts Involved":"Superior Tribunal of Justice","Jurisdiction of Asset Recovery: Investigative Agency":"New York County District Attorney\u0027s Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"New York County District Attorney\u0027s Office","Jurisdiction of Asset Recovery: Courts Involved":"Supreme Court of the State of New York, County of New York, Criminal Term; New York Supreme Court, Appellate Division, First Department","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_New_York_Indictment_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_NY_Indictment_Press_Release_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Swiss_Dept_Justice_Oct_14_2002.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_US_Morgenthau_Tax_Evasion_American_Interest_SepOct_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_Graft_sentence_upheld_Agence_France_Presse_Nov_4_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_New_York_Indictment_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_NY_Indictment_Press_Release_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Swiss_Dept_Justice_Oct_14_2002.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_US_Morgenthau_Tax_Evasion_American_Interest_SepOct_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_US_NY_Appeal_Court_Decision_Apr_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_New_York_Indictment_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_NY_Indictment_Press_Release_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Swiss_Dept_Justice_Oct_14_2002.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_US_Morgenthau_Tax_Evasion_American_Interest_SepOct_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_US_NY_Appeal_Courthouse%20News%20Service_Apr_22_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_New_York_Indictment_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_NY_Indictment_Press_Release_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Swiss_Dept_Justice_Oct_14_2002.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_US_Morgenthau_Tax_Evasion_American_Interest_SepOct_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_Interpol_wanted_Feb_6_2015_1.pdf","Sources ":"\n\tMatter of Maluf v Vance 2014 NY Slip Op 02546 Decided on April 15, 2014 Appellate Division, First Department (also at 2014 WL 1419459); Mark Thompson, \u0022Brazilian Pol Can\u0027t Shake Indictment in New York,\u0022 Courthouse News Service, April 22, 2014, at http:\/\/www.courthousenews.com\/2014\/04\/22\/67222.htm\n\n\t\u00a0\n\n\tMatter of Maluf v. Vance, 2012 NY Slip Op 50743(U), April 24, 2012, accessed at http:\/\/law.justia.com\/cases\/new-york\/other-courts\/2012\/2012-ny-slip-op-5...\n\n\t\u00a0\n\n\tThe People of the State of New York v. Paulo Maluf, Flavio Maluf, Simeao Damasceno de Oliveira, Joel Guedes Fernandes and Vivaldo Alves, Indictment filed on March 8, 2007 in New York State Supreme Court, County of New York, accessed at http:\/\/manhattanda.org\/whatsnew\/press\/2007-03-08%20Maluf%20Indictment%20...\n\n\t\u00a0\n\n\tNew York County District Attorney\u0027s Office, News Release on the Paulo Maluf Case, March 8, 2007, accessed at http:\/\/www.manhattanda.org\/whatsnew\/press\/2007-03-08.shtml 1\/;\u00a0\n\n\t\u00a0\n\n\tRobert Morgenthau, \u0022Tax Evasion Nation,\u0022 American Interest, September-October 2008, accessed at http:\/\/www.the-american-interest.com\/article-bd.cfm?piece=465;\n\n\t\u00a0\n\n\tSee also, Swiss Federal Department of Police and Justice Press Release, \u0022Strengthening co-operation in the fight against crime \/ Brazilian delegation visits Bern,\u0022 October 14, 2002, accessed at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2002\/2002....\n\n\t\u00a0\n\n\tAgence France Presse, \u0022Graft sentence upheld for ex-Sao Paulo ex-mayor,\u0022 November 4, 2013, at http:\/\/www.globalpost.com\/dispatch\/news\/afp\/131104\/graft-sentence-upheld...\n"},{"Case ID":"ARW-149","Case Title (Name of Public Official or Entity Allegedly Involved)":"Paulo Maluf (Jersey)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Brazil","Position of Public Official(s) (yrs in office)":"Governor and Mayor of Sao Paulo (Governor,1979-1983; Mayor, 1993-1996); Legislator (as of 2007)","Jurisdiction of Asset Recovery":"Jersey","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"Letter of Request","Basis for Intl Cooperation":"Criminal Justice (International Co-operation) (Jersey) Law 2001","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"plus unspecified amount in accrued interest","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tIn April 2013, in upholding the lower court\u0027s judgment in a private civil action brought by Brazilian authorities, the Jersey Appeals Court summarised the decision as follows: \u0022After trial the Royal Court (H.W.B. Page, Q.C. and Jurats) concluded that the claim succeeded and, in November 2012, found and held:-\n\n\t(i) \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 \u00a0That the second respondent had been the victim of a fraud substantially as alleged;\n\n\t(ii) \u00a0 \u00a0 \u00a0 \u00a0 \u00a0That Paulo Maluf was to some extent a party to that fraud, receiving some fifteen secret payments;\n\n\t(iii) \u00a0 \u00a0 \u00a0 \u00a0 That Flavio Maluf, knowing of the nature of such payments arranged for a large proportion of those funds to be transferred out of Brazil and into the bank account known as Chanani with Safra International Bank of New York, an account controlled by Paulo Maluf and beneficially owned by either or both of him and his son;\n\n\t(iv) \u00a0 \u00a0 \u00a0 \u00a0 That those latter payments were traceable into the bank accounts of the first and second appellants with Deutsche Bank in Jersey;\n\n\t(v) \u00a0 \u00a0 \u00a0 \u00a0 \u00a0 That the knowledge of the Malufs that such payments were the proceeds of a fraud on the present respondents was attributable to each of the defendants;\n\n\t(vi) \u00a0 \u00a0 \u00a0 \u00a0 That each of the present appellants was, accordingly, liable to the present respondents as constructive trustee;\n\n\t(vii) \u00a0 \u00a0 \u00a0 \u00a0That the knowledge of the Malufs that the present appellants had no entitlement to such payments was attributable to each of the present appellants, giving rise to liability on the basis of unjust enrichment; and\n\n\t(viii) \u00a0 \u00a0 \u00a0That the present respondents had a proprietary claim to specified monies from funds currently held by Deutsche Bank in accounts in the name of \u00a0the present appellants.\u0022 \u00a0(Source: Brazil v. Durant. [2013] JCA 071, at para 4.) \u00a0The Federal Republic of Brazil and the State of Sao Paolo had brought a civil suit in the Isle of Jersey against frozen assets held in the names of two companies that are alleged to be beneficially owned by Mr. Maluf and\/or his son. \u00a0(Source: Republic of Brazil v. Durant, 2012 JRC 094.) \u00a0 As the Jersey Royal Court noted, the action is a claim by Brazil \u0022to certain funds, of the order of US$10.5 million plus interet, held in bank accounts in Jersey in the name of the defendants, Durant International Corporation (\u0022Durant\u0022) and\/or Kildare Finance Limited (\u0022Kildare\u0022) and subject of a freezing order granted by the Royal Court on 13th March, 2009.\u0022 \u00a0The funds were alleged to have flowed through the \u0022Chanani\u0022 account at Safra Bank of New York. (Source: Republic of Brazil v Durant, 2011 JRC 091.) \u00a0The Jersey courts hade granted Norwich Pharmacal disclosure orders in the Durant Intl, et al and Citibank et al cases. \u00a0(Sources: Durant Intl. Corp. v. Att. Gen., 2006 JLR 31 (19 Jan 2006) and 2006 JLR 112 (17 Mar 2006); Brazil v. Citibank, 2006 JLR 478 (1 Nov 2006); Macdoel Invs v. Brazil, 2007 JLR 201 (19 Mar 2007)).\u00a0\n\n\t\u00a0\n\n\tIn 2015, in an important judgment upholding the concept of backwards tracing of assets, the UK Privy Council rejected an appeal by Durant International that of the US$10.5 million determined to be proceeds of bribes, the total amount that should be traced to the bribery should be limited to US$7.7 million. (Source: The Federal Republic of Brazil and another v. Durant International Corporation and another, [2015] UKPC 35.)\n\n\t\u00a0\n\n\tAccording to the New York County District Attorney\u0027s Office\u0027s March 2007 indictment against Mr. Maluf and his family members and associates, $26 million have been frozen in Jersey; U.S. and Brazillian authorities are seeking to forfeit these funds. (Sources: The People of the State of New York v. Paulo Maluf, Flavio Maluf, Simeao Damasceno de Oliveira, Joel Guedes Fernandes and Vivaldo Alves, Indictment filed on March 8, 2007 in New York state Supreme Court, County of New York and New York County District Attorney\u0027s Office, News Release on the Paulo Maluf case, March 8, 2007; \u00a0\u0022Promotoria quer repatriar R $303 milhoes de empresa de Maluf,\u0022 Estadao.com.br, August 3, 2009; Swiss Federal Department of Police and Justice Press Release, \u0022Strengthening co-operation in the fight against crime \/ Brazilian delegation visits Bern,\u0022 October 14, 2002, accessed at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2002\/2002....) \u00a0 \u00a0According to a secondary source, the return of MacDoel funds are said to have been under negotiation. (Source: \u00a0Marcelo Godoy and Fausto Macedo, \u0022Acordo de Maluf traria US$13 mi a cofres da Prefeturia de Sao Paulo,\u0022 Estado.com.br, August 25, 2011.)","Disposition of Criminal Case(s)":"According to the March 8, 2007 press release by the New York County District Attorney\u0027s Office, Mr. Maluf was indicted in New York for his alleged conspiracy in embezzlement of public funds and concealment of such funds, and that charges were also pending against him in Brazil. (Source: The People of the State of New York v. Paulo Maluf, Flavio Maluf, Simeao Damasceno de Oliveira, Joel Guedes Fernandes and Vivaldo Alves, Indictment filed on March 8, 2007 in New York state Supreme Court, County of New York and New York County District Attorney\u0027s Office, News Release on the Paulo Maluf case, March 8, 2007.) According to Agence France Presse, on November 4, 2013, Mr. Maluf\u0027s conviction on \u0022administrative corruption\u0022 was upheld by a Brazilian court. (Source: Agence France Presse, \u0022Graft sentence upheld for ex-Sao Paulo ex-mayor,\u0022 November 4, 2013.)","Jurisdiction of Origin: Investigative Agency":"Brazilian Financial Intelligence Unit; Ministry of Justice; Federal Police","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General of the State of Sao Paulo, Prosecutor General of the Republic of Brazil","Jurisdiction of Origin: Courts Involved":"Superior Tribunal of Justice","Jurisdiction of Asset Recovery: Investigative Agency":"Jersey Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"BakerPlatt (Attorney Stephen Baker, for the Jersey Attorney General); Advocate P.D. James for the Federal Republic of Brazil;","Jurisdiction of Asset Recovery: Courts Involved":"Court of Appeal; Royal Court (Samedi Division)","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Interpol_Wanted_May_6_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Citibank_2006_JLR_478.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Civil_Actions_Estadao.com_Aug_3_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Durant_Intl_2006_JLR_31.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Durant_Intl_2006_JLR_112.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Macdoel_2007_JLR_201.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_New_York_Indictment_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_NY_Indictment_Press_Release_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Swiss_Dept_Justice_Oct_14_2002.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Republic_of_Brazil-v-Durant_2011_JLR_091, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_MacDoel_Negotiations_Estadao.com.br_Aug_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_Brazil%20v%20Durant_2013_JCA_71_Apr_11_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Interpol_Wanted_May_6_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Citibank_2006_JLR_478.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Civil_Actions_Estadao.com_Aug_3_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Durant_Intl_2006_JLR_31.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Durant_Intl_2006_JLR_112.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Macdoel_2007_JLR_201.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_New_York_Indictment_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_NY_Indictment_Press_Release_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Swiss_Dept_Justice_Oct_14_2002.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Republic_of_Brazil-v-Durant_2011_JLR_091, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_MacDoel_Negotiations_Estadao.com.br_Aug_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_Brazil-v-Durant_2013_JRC_019A_24-Jan-2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Interpol_Wanted_May_6_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Citibank_2006_JLR_478.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Civil_Actions_Estadao.com_Aug_3_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Durant_Intl_2006_JLR_31.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Durant_Intl_2006_JLR_112.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Macdoel_2007_JLR_201.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_New_York_Indictment_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_NY_Indictment_Press_Release_Mar_8_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Swiss_Dept_Justice_Oct_14_2002.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_Republic_of_Brazil-v-Durant_2011_JLR_091, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Maluf_Jersey_MacDoel_Negotiations_Estadao.com.br_Aug_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Maluf_Interpol_wanted_Feb_6_2015_0.pdf","Sources ":"\n\tRepublic of Brazil v. Durant, [2015] UKPC 35 (August 3, 2015), at https:\/\/www.jcpc.uk\/cases\/docs\/jcpc-2013-0069-judgment.pdf; [2013] JCA 071 (April 11, 2013), at http:\/\/www.jerseylaw.je\/Judgments\/UnreportedJudgments\/Documents\/Display.... \u00a0[2013] JRC 019A (January 24, 2013), at http:\/\/www.jerseylaw.je\/Judgments\/UnreportedJudgments\/Documents\/Display.... and \u00a0[2012] JRC 211 (November 16, 2012), at http:\/\/www.jerseylaw.je\/Judgments\/UnreportedJudgments\/Documents\/Display.... \u00a0\n\n\t\u00a0\n\n\tSee also, Brazil v. Durant, [2012] JCA 151 (August 22, 2012) and \u00a0[2012] JCA 094 (May 11, 2012);\u00a0\n\n\tDurant Intl. Corp. v. Att. Gen., 2006 JLR 31 (19 Jan 2006); 2006 JLR 112 (17 Mar 2006) and 2011 JLR 091 (April 27, 2011);\u00a0\n\n\tBrazil v. Citibank, 2006 JLR 478 (1 Nov 2006);\u00a0\n\n\tMacdoel Invs v. Brazil, 2007 JLR 201 (19 Mar 2007). \u00a0\n\n\t\u00a0\n\n\tSee also, The People of the State of New York v. Paulo Maluf, Flavio Maluf, Simeao Damasceno de Oliveira, Joel Guedes Fernandes and Vivaldo Alves, Indictment filed on March 8, 2007 in New York state Supreme Court, County of New York, accessed at http:\/\/manhattanda.org\/whatsnew\/press\/2007-03-08%20Maluf%20Indictment%20... \u00a0New York County District Attorney\u0027s Office, News Release on the Paulo Maluf case, March 8, 2007, accessed at http:\/\/www.manhattanda.org\/whatsnew\/press\/2007-03-08.shtml 1\/;\u00a0\n\n\t\u00a0\n\n\t\u0022Promotoria quer repatriar R $303 milhoes de empresa de Maluf,\u0022 Estadao.com.br, August 3, 2009. \u00a0Swiss Federal Department of Police and Justice Press Release, \u0022Strengthening co-operation in the fight against crime \/ Brazilian delegation visits Bern,\u0022 October 14, 2002, accessed at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2002\/2002... \u00a0Paulo Maluf, Interpol Wanted List, at Interpol website: \u00a0http:\/\/www.interpol.int\/public\/data\/wanted\/notices\/data\/2009\/08\/2009_136... (last accessed on February 6, 2015); \u00a0Marcelo Godoy and Fausto Macedo, \u0022Acordo de Maluf traria US$13 mi a cofres da Prefeturia de Sao Paulo,\u0022 Estado.com.br, August 25, 2011, accessed at http:\/\/www.estadao.com.br\/noticias\/impresso,acordo-de-maluf-traria-us-13... Agence France Presse, \u0022Graft sentence upheld for ex-Sao Paulo ex-mayor,\u0022 November 4, 2013, at http:\/\/www.globalpost.com\/dispatch\/news\/afp\/131104\/graft-sentence-upheld...\n"},{"Case ID":"ARW-150","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pavel Borodin","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Russian Federation","Position of Public Official(s) (yrs in office)":"State Secretary of the Union of Russia and Belarus (inclusive 2000-2001);  Chief of the Administrative Directorate of the Russian Federation (?-2000)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2000","Asset Recovery End":"2002","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"European Convention on Mutual Legal Assistance in Criminal Matters (Switzerland - Requesting State; Russia - Requested State)","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"[fine ordered but unknown if paid]","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a December 19, 2000 Press Release by the Swiss Federal Department of Justice and Police, the Swiss authorities requested and received from the Russian Federation, mutual legal assistance in the investigation of Mr. Borodin\u0027s case. (Source: Swiss Federal Department of Justice and Police Press Release, Bundesanwaltschaft stellt Rechtshilfe der Schweiz an Russland im Strafverfahren  ein,\u0022 December 19, 2000, accessed at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/de\/home\/dokumentation\/mi\/2000\/2000....) According to a Swiss Federal Office of Justice Press Release of February 5, 2001, Switzerland sought Mr. Borodin\u0027s extradition from the U.S., stating that \u0022The request is based on two arrest warrants issued on 10 January 2000 and on 24 January 2001, respectively, by the Geneva Examining Magistrates, who are conducting a criminal proceeding against Borodin on account of money laundering and participation in a criminal organisation.\u0022 (Source: Swiss Federal Department of Justice and Police Press Release, \u0022Switzerland asks the US to extradite Borodin,\u0022 February 5, 2001.) According to the St. Petersburg Times, in March 2002, a judgment was entered in Switzerland against Mr. Borodin on a money laundering charge and he was fined $177,000. The article reported Mr. Borodin\u0027s attorneys as stating that he would not appeal the decision because he did not \u0022recognize the court\u0027s jurisdiction.\u0022 (Source: Robin Munro, \u0022Convicted Borodin Will Defy Swiss Courts,\u0022 St. Petersburg Times, March 19, 2002). According to the article, Mr. Borodin\u0027s case dates back to 2000, when Swiss authorities accused him of receiving $30 million in kickbacks from two Swiss companies (Mabetex and Mercata) involved in the renovation of the Kremlin, and funneling the proceeds through entities owned by him or his family members. The Swiss issued an international arrest warrant, and in 2001, he was arrested as he sought to enter the U.S. and subsequently extradited to Switzerland. (Source: Pavel Borodin (petitioner) v. Ashcroft (respondent), Case No. 01-civ-1433 (E.D.NY), Memorandum and Order March 21, 2001 (denying Mr. Borodin petition seeking release pending extradition hearing; also details allegations of Mr. Borodin\u0027s misuse of corporate vehicles made by the Swiss authorities as part of their formal extradition request.) According to the BBC, Mr. Borodin was briefly detained in Switzerland but returned to Russia after posting bail of $3 million. The BBC stated that the Russian news agency, Interfax, quoted the deputy chief of the special investigations department of the Russian Prosecutor-General\u0027s Office, Ruslan Tamayev, as saying there was \u0022no case\u0022 against Mr. Borodin. (Source: BBC News, \u0022Moscow aide flies home on bail,\u0022 April 13, 2001, accessed at http:\/\/news.bbc.co.uk\/2\/hi\/europe\/1275813.stm.) ","Disposition of Criminal Case(s)":"According to the St. Petersburg Times, on March 19, 2002, a judgment was entered in Switzerland against Mr. Borodin on a money laundering charge and he was fined $177,000.  The article reported Mr. Borodin\u0027s attorneys as stating that he would not appeal the decision because he did not \u0022recognize the court\u0027s jurisdiction.\u0022  (Source: Robin Munro, \u0022Convicted Borodin Will Defy Swiss Courts,\u0022 St. Petersburg Times, March 19, 2002).","Jurisdiction of Origin: Investigative Agency":"Prosecutor General\u0027s Office, Moscow","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Geneva Canton Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"[Public Prosecutor, Geneva, Switzerland, criminal prosecution] U.S. Attorney for the Southern District of New York (extradition)","Jurisdiction of Asset Recovery: Courts Involved":"Switzerland: Unspecified; U.S. District Court for the Southern District of New York (extradition)","Documents":"","Sources ":"Swiss Federal Department of Justice and Police Press Release, Bundesanwaltschaft stellt Rechtshilfe der Schweiz an Russland im Strafverfahren  ein,\u0022 December 19, 2000, accessed at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/de\/home\/dokumentation\/mi\/2000\/2000... Swiss Federal Department of Justice and Police Press Release, \u0022Switzerland asks the US to extradite Borodin,\u0022 February 5, 2001, accessed at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2001\/ref_.... The St. Petersburg Times, \u0022Convicted Borodin Will Defy Swiss Court,\u0022 March 19, 2002; BBC News, \u0022Moscow aide flies home on bail,\u0022 April 12, 2001; BBC News, \u0022Yeltsin aide held in U.S. jail,\u0022 January 19, 2001. See also, Pavel Borodin (petitioner) v. Ashcroft (respondent), Case No. 01-civ-1433 (E.D.N.Y.), Memorandum and Order filed on March 21, 2001 (denying Borodin petition seeking release pending extradition hearing). \n"},{"Case ID":"ARW-151","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pavel I. Lazarenko (Antigua and Barbuda)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Member of Parliament (1998); Prime Minister (1996-1997); First Vice Prime Minister (1995-1996); various government and political positions, Dnepropetrovsk region (1992-1995)","Jurisdiction of Asset Recovery":"Antigua and Barbuda","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.18, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdictions","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tSee related entry - Pavel Lazarenko (US Civil Asset Forfeiture Case). \u00a0According to the November 2010 judgment by the High Court of Justice of Antigua and Barbuda in Claim No: ANUHCV 2010\/0298 Between: \u00a0The Liquidators of Eurofed Bank Limited (in Liquidation) and The Supervisory Authority, \u0022On 21 st September 2010 Harris,J. ordered that a Restraining Order of the United States District Court for the District of Columbia be registered in the High Court of Justice of Antigua and Barbuda and given effect with respect to all funds or property restrained thereby which are held or controlled by Scotia Bank, High Street, S1. John\u0027s, Antigua and the Joint Liquidators of Eurofed Bank (In Liquidation). On 12th October 2010 the Learned Judge gave his reasons for decision in a written judgment delivered on that day by the Registrar of the High Court. [ ] By Notice of Application filed on 20th October 2010 the Liquidators of Eurofed Bank Limited (In Liquidation) made application to the Court for leave to appeal against the aforesaid judgment of Harris, J. and for stay of execution, enforcement and all further proceedings on the decision and orders of Harris, J. dated 12th October 2010 and on the registered United States District Court Restraining Order dated 8th July 2005 pending the hearing of the appeal. the Court takes the view that the Intended Appellants may well have a very difficult task to convince the Court of Appeal to overrule the decision of Harris, J. in this matter but they do have a realistic prospect of doing so.\u0022 \u00a0The Court granted leave to the liquidators of Eurofed Bank to appeal. \u00a0(Source: \u00a0 CLAIM NO: ANUHCV 2010\/0298 Between: The Liquidators of Eurofed Bank LImited (in \u00a0liquidation), Intended Appellants and and The Supervisory Authority, High Court of Antigua and Barbuda, Judgment of November 12, 2010, accessed at the website of the Eastern Caribbean Supreme Court at http:\/\/www.eccourts.org\/judgments\/decisions\/2010\/LiquidatorsofEurofedBan....). \u00a0In 2011, the Restraining Order was upheld by the Court of Appeal. (Source: The Liquidators of Eurofed Bank Limited and The Supervisory Authority, HCVAP 2010\/051, November 21, 2011.)\n\n\t\u00a0","Disposition of Criminal Case(s)":"According to the U.S. Department of Justice Press Release dated November 19, 2009, Mr. Lazarenko was sentenced to 97 months in prison, subsequent to his conviction on eight counts of money laundering.  (Source: U.S. Department of Justice, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison,\u0022 November 19, 2009.) According to  BBC News, Mr. Lazarenko was convicted in Switzerland, in June 2000, on money laundering charges. (Sources:  BBC News, \u0022The case against Lazarenko,\u0022  August 25, 2006.  See also, Swiss court decisions: BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court).","Jurisdiction of Origin: Investigative Agency":"Prosecutor General","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Antigua and Barbuda","Documents":"","Sources ":"\n\tCLAIM NO: ANUHCV 2010\/0298 Between: The Liquidators of Eurofed Bank LImited (in \u00a0liquidation), Intended Appellants and and The Supervisory Authority, High Court of Antigua and Barbuda, Judgment of November 12, 2010, accessed at the website of the Eastern Caribbean Supreme Court at http:\/\/www.eccourts.org\/judgments\/decisions\/2010\/LiquidatorsofEurofedBan... The Liquidators of Eurofed Bank Limited and The Supervisory Authority, HCVAP 2010\/051, November 21, 2011, at https:\/\/www.eccourts.org\/the-liquidators-of-eurofed-bank-ltd-v-the-super...\n\n\t\u00a0\n"},{"Case ID":"ARW-152","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pavel I. Lazarenko \/ Northern California Criminal Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Member of Parliament (1998); Prime Minister (1996-1997); First Vice Prime Minister (1995-1996); various government and political positions, Dnepropetrovsk region (1992-1995)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.18, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Criminal Fine  ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Investigatory cooperation but exact mechanism unknown","Contributing Factors in Asset Recovery":"Close cooperation among investigators and prosecutors of Ukraine, Switzerland, United States and Antigua","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"criminal fine ($9 million), criminal forfeiture ($20 million)","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In November 2009, Mr. Lazarenko was sentenced to 97 months in prison and ordered to pay a $9 million fine and forfeit $22,851,000 and various specified assets resulting from his money laundering convictions.  (Source: Department of Justice Press Release, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison \/ Fined $9 Million for Role in Laundering $30 Million of Extortion Proceeds,\u0022 November 19, 2009.)  The Amended Judgment of February 4, 2010 had ordered Mr. Lazarenko to also pay restitution of $19,473,309 to his co-conspirator\/victim Peter Kiritchenko; this was later reversed by the Ninth Circuit which held that as a general rule, a participant in a crime cannot recover restitution. (Sources: U.S. v. Lazarenko, Case No. 3:00-cr-00284-CRB (N.D. Cal.), Amended Judgment of February 4, 2010, reversed appeal, U.S. (Plaintiff-Appellee), Kiritchenko (Intervenor) v. Lazarenko (Defendant-Appellant), Case No. 08-10185, (9th Cir.). The U.S. Government had opposed the payment of restitution to Mr. Kiritchenko.)  Some of the forfeited assets included Mr. Lazarenko\u0027s assets held in the European Federal Credit Bank in Antigua.  As the Ninth Circuit Court of Appeals noted, Mr. Lazarenko\u0027s \u0022activities raised prosecutorial eyebrows in both the United States and Antigua.  Antiguan officials ordered the liquidation of Eurofed\u0027, and the High Court of Antigua appointed several persons as \u0027Liquidators\u0027 of Eurofed to assist in the collection and distribution of Eurofed\u0027s assets to its rightful, law-abiding owners.\u0022  The Liquidators asserted ownership specifically to the approproximately $2.5 million in funds and Ukrainian bonds on deposit with Bank of America, in a correspondent account of Eurofed.  In January 2011, the Ninth Circuit Court reversed the lower court\u0027s ruling on grounds of ers judicata, and remanded with instructions that the district court vacate the forfeiture order with regard to the funds and Ukrainian bonds held in Bank of America and to return those assets to the Liquidators.  (Source: U.S. v. Liquidators of European Federal Credit Bank, U.S. and Liquidators of European Federal Credit Bank v. Lazarenko, and U.S. v. Lazarenko, Case Nos. 09-10116, 09-10161, 09-10183 (9th Cir.), January 4, 2011.)  On April 4, 2011, the US District Court for the Northern District of California issued the order for return of those assets to the liquidators of EuroFed Bank. (Source: US v. Lazrenko, Case No. 3:00-cr-00284 (N.D. Cal.), Amended Final Order of Forfeiture on Remand filed April 4, 2011.)","Disposition of Criminal Case(s)":"According to the U.S. Department of Justice Press Release dated November 19, 2009, Mr. Lazarenko was sentenced to 97 months in prison, following his conviction on eight counts of money laundering.  (Source: U.S. Department of Justice, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison,\u0022 November 19, 2009.) According to  BBC News, Mr. Lazarenko was convicted in Switzerland, in June 2000, on money laundering charges. (Sources:  BBC News, \u0022The case against Lazarenko,\u0022  August 25, 2006.  See also, Swiss court decisions: BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court).","Jurisdiction of Origin: Investigative Agency":"Prosecutor General","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, Federal Bureau of Investigation, Eurasian Organized Crime Squad (San Francisco); Internal Revenue Service, Criminal Investigations","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney\u0027s Office for the Northern District of California; U.S. Department of Justice, Criminal Division, Organized Crime \u0026 Racketeering Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Northern District of California, Ninth Circuit Court of Appeals, U.S. Supreme Court, U.S. District Court for the District of Columbia","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Lazarenko_US_NDCAL_Indictment_May_18_2000.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Lazarenko_US_NDCAL_Amended_Judgment_Feb_4_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Lazarenko_US_NDCAL_Catch_Oligarch_Oct_4_2004.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Lazarenko_US_NDCAL_Eurofed_Liquidators_Courthouse_News_Jan_5_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Lazarenko_US_NDCAL_Eurofed_Liquidators_Jan_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Lazarenko_US_NDCAL_Kiritchenko_Restitution_Order_Vacate_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Lazarenko_US_NDCAL_Sentence_DOJ_PR_Nov_19_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Lazarenko_NDCAL_Amended_Judgment_Forfeiture_Apr_4_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Lazarenko_NDCAL_Amended_Judgment_Forfeiture_Apr_4_2011.pdf","Sources ":"U.S. v. Lazarenko, Case No. 3:00-cr-00284-CRB (N.D. Cal.), Indictment filed on May 18, 2000; Amended Judgment filed on February 4, 2010; and Amended Final Order of Forfeiture Filed on April 4, 2011. U.S. v. Lazarenko, 564 F. 3d 1026 (9th Cir. 2009); U.S. (Plaintiff-Appellee), Kiritchenko (Intervenor) v. Lazarenko (Defendant-Appellant), Case No. 08-10185, (9th Cir. 2010); Department of Justice Press Release, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison \/ Fined $9 Million for Role in Laundering $30 Million of Extortion Proceeds,\u0022 November 19, 2009. Jason Felch, San Francisco Magazine, \u0022To Catch an Oligarch\u0022 posted at website of the Center for Investigative Reporting at http:\/\/www.centerforinvestigativereporting.org\/articles\/tocatchanoligarch. Eurofed Liquidators: U.S. v. Liquidators of European Federal Credit Bank, U.S. and Liquidators of European Federal Credit Bank v. Lazarenko, and U.S. v. Lazarenko, Case Nos. 09-10116, 09-10161, 09-10183 (9th Cir.), January 4, 2011; Jonny Bonner, \u0022Feds Lose Claim to Assets of Ex-Ukrainian Minister,\u0022 Courthouse News Service, January 5, 2011, accessed at http:\/\/www.courthousenews.com\/2011\/01\/05\/33090.htm.\n"},{"Case ID":"ARW-153","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pavel Lazarenko (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Member of Parliament (1998); Prime Minister (1996-1997); First Vice Prime Minister (1995-1996); various government and political positions, Dnepropetrovsk region (1992-1995)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"2001","UNCAC Offenses Implicated":"Art.15, Art.17, Art.18, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Investigatory cooperation but exact mechanism unknown","Contributing Factors in Asset Recovery":"Close cooperation among investigators of Ukraine, Switzerland, U.S. and Antigua","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In 2000, Mr. Lazarenko was convicted in absentia on money laundering charges.  (Sources:  BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court; see also BBC News, \u0022The case against Pavlo Lazarenko,\u0022 August 25, 2006, accessed at http:\/\/news.bbc.co.uk\/2\/hi\/europe\/4780743.stm.)","Disposition of Criminal Case(s)":"According to the U.S. Department of Justice Press Release dated November 19, 2009, Mr. Lazarenko was sentenced to 97 months in prison, subsequent to his conviction on eight counts of money laundering.  (Source: U.S. Department of Justice, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison,\u0022 November 19, 2009.) According to  BBC News, Mr. Lazarenko was convicted in Switzerland, in June 2000, on money laundering charges. (Sources:  BBC News, \u0022The case against Lazarenko,\u0022  August 25, 2006.  See also, Swiss court decisions: BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court).","Jurisdiction of Origin: Investigative Agency":"Prosecutor General","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Investigating Magistrate","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Asset Recovery: Courts Involved":"Administrative Law Court, Geneva","Documents":"","Sources ":"BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court (decisions can be downloaded from www.bger.ch). Jason Felch, \u0022To Catch an Oligarch,\u0022 San Francisco Magazine, October 4, 2004, posted on http:\/\/www.centerforinvestigativereporting.org\/articles\/tocatchanoligarch; BBC News, \u0022The case against Pavlo Lazarenko,\u0022 August 25, 2006, accessed at http:\/\/news.bbc.co.uk\/2\/hi\/europe\/4780743.stm.\n"},{"Case ID":"ARW-154","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pavel Lazarenko (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Member of Parliament (1998); Prime Minister (1996-1997); First Vice Prime Minister (1995-1996); various government and political positions, Dnepropetrovsk region (1992-1995)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.18, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Unspecified","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the Swiss Ministry of Foreign Affairs, $5.4 million remain frozen.  (Source: Swiss Ministry of Foreign Affairs, September 30, 2009).","Disposition of Criminal Case(s)":"According to the U.S. Department of Justice Press Release dated November 19, 2009, Mr. Lazarenko was sentenced to 97 months in prison, subsequent to his conviction on eight counts of money laundering.  (Source: U.S. Department of Justice, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison,\u0022 November 19, 2009.) According to  BBC News, Mr. Lazarenko was convicted in Switzerland, in June 2000, on money laundering charges. (Sources:  BBC News, \u0022The case against Lazarenko,\u0022  August 25, 2006.  See also, Swiss court decisions: BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court).","Jurisdiction of Origin: Investigative Agency":"Prosecutor General","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Origin: Courts Involved":"Unknown","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"","Sources ":"Swiss Ministry of Foreign Affairs, September 30, 2009.\n"},{"Case ID":"ARW-155","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pavel Lazarenko (United States Civil Asset Forfeiture Case)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Ukraine","Position of Public Official(s) (yrs in office)":"Member of Parliament (1998); Prime Minister (1996-1997); First Vice Prime Minister (1995-1996); various government and political positions, Dnepropetrovsk region (1992-1995)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2005","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17, Art.18, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Investigatory cooperation but exact mechanism unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"As of June 2016, the case was ongoing against approximately $271 million and additional unspecified amounts held in accounts in financial institutions in Guernsey, Antigua and Barbuda, Switzerland, Liechtenstein and Lithuania. (Source: U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Court Docket Report as of June 20, 2016.)\nOn May 14, 2004, the U.S. filed a civil asset forfeiture suit, seeking to forfeit more than $250 million which the government alleged were illegal proceeds of criminal activities by Mr. Lazarenko and his associates.  The U.S. government also alleged that the assets were obtained through the abuse of public office and illegally transported and\/or laundered through the abuse of financial institutions in the United States, and were located in in foreign bank accounts in Guernsey, Antigua \u0026 Barbuda, Switzerland, Lithuania and Liechtenstein.(Source: U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Verified Claim for Forfeiture In Rem filed on May 14, 2004 and First Amended Verified Claim for Forfeiture In Rem filed on June 30, 2005.)   On May 20, 2004, a Restraining Order was issued against the defendant accounts.  (Source: U.S. v. All Assets Held in Julis Baer, et al, Case No. 1:04-cv-00798-PLF (D.D.C.), which stipulated that \u0022terms of Order shall remain in full force and effect until the judgment rendered in the case or further Order of the court.\u0022)  Actions against some of the assets were terminated in June 2005.","Disposition of Criminal Case(s)":"According to the U.S. Department of Justice Press Release dated November 19, 2009, Mr. Lazarenko was sentenced to 97 months in prison, subsequent to his conviction on eight counts of money laundering.  (Source: U.S. Department of Justice, \u0022Former Ukrainian Prime Minister Sentenced to 97 Months in Prison,\u0022 November 19, 2009.) According to  BBC News, Mr. Lazarenko was convicted in Switzerland, in June 2000, on money laundering charges. (Sources:  BBC News, \u0022The case against Lazarenko,\u0022  August 25, 2006.  See also, Swiss court decisions: BGer 125 II 356 (excerpt, judgment of 25 June 1999) and BGer 125 II 238 (excerpt, judgment of 8 April 1999), both of Canton of Geneva, administrative law court).","Jurisdiction of Origin: Investigative Agency":"Prosecutor General","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation; Internal Revenue Service, Criminal Investigations","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Columbia","Documents":"","Sources ":"U.S. v. All Assets Held in Julius Baer, et al, Case. No. 1:04-cv-00798-PLF (D.D.C.), Verified Claim for Forfeiture In Rem filed on May 14, 2004;  First Amended Verified Claim for Forfeiture In Rem filed on June 30, 2005 and Notice of Errata for First Amended Verified Claim for Forfeiture In Rem filed on January 21, 2011; Restraining Order filed on May 20, 2004; Court Docket Report as of June 20, 2016.\n"},{"Case ID":"ARW-156","Case Title (Name of Public Official or Entity Allegedly Involved)":"Pertamina (PT Pertambangan Minyak dan Gas Bumi Negara) \/ Haji Achmad Thahir Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Indonesia","Position of Public Official(s) (yrs in office)":"General Assistant to the President Director of Pertamina (Haji Achmad Thahir, 1968-1976)","Jurisdiction of Asset Recovery":"Singapore","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1977","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"The private civil action was triggered subsequent to Mr. Thahir\u0027s death, by competing claims to the deposited funds between his wife and children from his first marriage.","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$81,757,260.74","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"As described in the Stolen Asset Recovery (StAR) Initiative\u0027s Asset Recovery Handbook (December 2010), \u0022Pertamina - an Indonesian state-owned enterprise whose principal business was the exploration, processing, and marketing of oil and natural gas - sought to recover bribes paid to Pertamina executive Haji Achmad Thahir by contractors hoping for better contractual terms and preferential treatment.  The bribes were deposited by the executive into [the Sumitomo Bank branch] in Singapore.  Pertamina learned about the bank accounts (owned jointly by Thahir and his wife Kertika Ratna thahir) in Singapore after the death of the executive and brought an action in Singapore claiming to be entitied to the funds.  The court of first instance ruled that the bribes and all earned interest were held by the executive as a constructive trustee.\u0022 (Source:  Asset Recovery Handbook, at 160-62, citing Singapore High Court decision in Kartika Ratna Thahir v. PT Pertambangan Minyak dan Gas Bumi Negara (Pertamina) [1994] 3 SLR 257, hereinafter cited as \u0022Pertamina decision.\u0022)  The Court of Appeal of Singapore wrote in its 1994 Pertamina decision that, \u0022This appeal arises from the decision of Lai Kew Chai J on an originating summons taken out by the Sumitomo Bank Ltd for interpleader reliefs in the face of competing claims to 19 separate and discrete deposits with the Asian Currency Unit (ACU) of the Singapore branch of the bank.\u0022  The Court wrote, \u0022Gen Haji Achmad Thahir (Gen Thahir) was employed by Pertamina and at the material time was the general assistant to the then president director of Pertamina, Gen Ibnu Sutowo (Gen Sutowo). Gen Thahir was appointed to the office with effect from 14 October 1968 and at all material times his total salary was about US$9,000 a year. He held that position until 23 July 1976 when he died.\u0022  The Singapore High Court stated that \u0022as of 27 March 1992 the total of the said ACU deposits including the interest, which had accrued during the intervening period, was US$81,757,260.74.\u0022  (Source: Sumitomo Bank Ltd v Kartika Ratna Thahir and others and another matter [1992] SGHC 301.)","Disposition of Criminal Case(s)":"None (The private civil action was triggered subsequent to Mr. Thahir\u0027s death, by competing claims to the deposited funds between his wife and children from his first marriage.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Pertamina (PT Pertambangan Minyak dan Gas Bumi Negara)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Wong Meng Meng \u0026 Pnrs (David\r\nHunt QC, Wong Meng Meng and Alvin Yeo) for Pertamina","Jurisdiction of Asset Recovery: Courts Involved":"High Court, Court of Appeal","Documents":"","Sources ":"Sumitomo Bank Ltd v Kartika Ratna Thahir and others and another matter [1992] SGHC 301, High Court, Suit No. OS 308\/1976, Decision dated December 3, 1992, accessed at http:\/\/lwb.lawnet.com.sg\/legal\/lgl\/rss\/landmark\/%5B1992%5D_SGHC_301.html; Kartika Ratna Thahir v PT Pertambangan Minyak dan Gas Bumi Negara (Pertamina) [1994] 3 SLR 257; [1994] SGCA 105, Court of Appeal, Suit No: CA 204\/1992, Decision dated August 25, 1994, accessed at http:\/\/www.singaporelaw.sg\/rss\/judg\/10401.html; Jean-Pierre Brun, Larissa Gray, Clive Scott, and Kevin M. Stephenson, \u0022Asset Recovery Handbook: A Guide for Practitioners,\u0022 Stolen Asset Recovery (StAR) Initiative (Washington, D.C., December 2010).\n"},{"Case ID":"ARW-157","Case Title (Name of Public Official or Entity Allegedly Involved)":"Propinoduto (Principal - Agent) \/ Rodrigo Silveirinha Correa Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Brazil","Position of Public Official(s) (yrs in office)":"Deputy Head of Tax Collection Office, Tax Officials (1990s, exact years unspecified)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.19","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"On Appeal","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$0","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unspecified","Case Summary":"According to the 2011 U.S. Department of State, Bureau for International Narcotics and Law Enforcement Affairs\u0027 International Narcotics Control Strategy Report, $30 million was repatriated from Switzerland to Brazil in the Propinoduto case. (Source: U.S. Department of State, Bureau for International Narcotics and Law Enforcement Affairs\u0027 International Narcotics Control Strategy Report, Vol. I (March 2011), at 154.) According to a Brazillian Justice Ministry statement, on November 26, 2009, the Brazilian Justice Minister announced that Switzerland had agreed to return $30 million to Brazil, and the only remaining issue was what tools of repatriation (bilateral convention or Merida treaty) but hoped to have money in Brazilian treasury by 2010. (Source: Noticias, Lavagem de Dinheiro, Ministerio da Justica, Brasil, \u0022Brasil consegue repatriacao de cerca de U.S. $30 milhoes na Suica,\u0022 November 26, 2009.) According to the press announcement, the investigation of the \u0022Propinoduto\u0022 case began about 2003 and culminated in the conviction of several people who allegedly received kickbacks from companies in exchange for tax benefits. The Brazilian government opened investigations after detecting suspicious deposits in Swiss banks belonging to tax officials assigned to the Tax Administration of Rio de Janeiro. The money will be returned to the coffers of the Union, with the possibility of it being passed on to the government of Rio de Janeiro, according to the Ministry announcement.","Disposition of Criminal Case(s)":"According to the International Centre for Asset Recovery\u0027s Case Study on Mr. Correa\u0027s case, he was convicted in Brazil of criminal charges related to the Propinoduto case. (Source: \u0022Rodrigo Silveirinha Correa\u0022 Case Study, at http:\/\/www.assetrecovery.org\/kc\/node\/bb4181b0-f78b-11dd-aec1-9dfae7b42ba1.1.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"State Prosecutor, State of Rio de Janeiro","Jurisdiction of Origin: Courts Involved":"Superior Court of Justice, 6th Chamber","Jurisdiction of Asset Recovery: Investigative Agency":"Ministry of Justice, Department of Asset Recovery and International Legal Cooperation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Noticias, Lavagem de Dinheiro, Ministerio da Justica, Brasil, \u0022Brasil consegue repatriacao de cerca de U.S. $30 milhoes na Suica,\u0022 last accessed October 1, 2010 at http:\/\/portal.mj.gov.br\/data\/Pages\/MJ7FABCBFCITEMID8A1481F26CDD463488D2B... U.S. Department of State, Bureau for International Narcotics and Law Enforcement Affairs\u0027 International Narcotics Control Strategy Report, Vol. I (March 2011), at 154, accessed at http:\/\/www.state.gov\/documents\/organization\/156575.pdf. Gabriella Broggi, \u00225 Swiss bankers convicted in Brazil money case,\u0022 Associated Press, Sept. 18, 2008, in \u0022Rodrigo Silveirinha Correa\u0022 Case Study by International Centre for Asset Recovery\u0027, at http:\/\/www.assetrecovery.org\/kc\/node\/bb4181b0-f78b-11dd-aec1-9dfae7b42ba1.1.\n"},{"Case ID":"ARW-158","Case Title (Name of Public Official or Entity Allegedly Involved)":"Raul Salinas (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mexico","Position of Public Official(s) (yrs in office)":"Brother of President Carlos Salinas (1988-1994)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1995","Asset Recovery End":"2008","UNCAC Offenses Implicated":"Art.15, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"According to the Swiss Federal Office of Justice Press Release, \u0022The Mexican authorities demonstrated, with the support of bank documents and other papers, how public funds amounting at the time to around USD 66 million had been misappropriated and moved to domestic banks. The Swiss authorities had already reconstructed the trail of the funds outside Mexico. On the basis of the Swiss and Mexican proceedings, the clearly criminal origin of these assets was thus demonstrated, thereby fulfilling the requirements for their early handover. The parties concerned have not opposed the handover of these assets, totalling USD 74 million (including interest), to Mexico.\u0022 (Source: Swiss Federal Department of Justice and Police Press Release, \u0022Salinas assets handed over to Mexico, Federal Examining Magistrate concludes 12-year proceedings,\u0022 June 18, 2008.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$74,000,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"On June 18, 2008, the Swiss Federal Department of Justice and Police announced that Switzerland would return $74 million to Mexico in assets related to Mr. Salinas\u0027 case.  According to the Swiss government press release, in 1995, Switzerland had initiated criminal proceedings for money laundering, and in 2002 turned over their investigative files to Mexico.  As of 2002, some $110 million were frozen in Switzerland.  Some $74 million (including accrued interest) were deemed to be of criminal origin and returned.   The press release noted that \u0022Other assets, which are not of criminal origin, have been unfrozen.\u0022  The Federal Examining Magistrate has also ordered the CHF 2.2 million ($2,110,010) be transferred to the federal treasury and CHF 1.1 million ( $1,055,000) to the treasury of the Canton of Geneva, both to cover costs of the Swiss authorities\u0027 \u0022wide ranging activities since 1995.\u0022  (Source: Swiss Federal Department of Justice and Police Press Release, \u0022Salinas assets handed over to Mexico, Federal Examining Magistrate concludes 12-year proceedings,\u0022 June 18, 2008.)  On June 18, 2008, the Mexican Prosecutor General\u0027s office also announced the return of assets from Switzerland and indicated that the funds would be returned to the Mexican Treasury to be used for the benefit of the people of Mexico.  (Source:  Procuraduria General de la Republica, Sala de Prensa 501\/08, \u0022PGR Achieves the Repayment of more than 74 million dollars,\u0022 June 18, 2008.)","Disposition of Criminal Case(s)":"According to the New York Times, Mr. Salinas was convicted in January 1999 in Mexico of murder. (Source: Julia Preston, \u0022Raul Salinas Guilty in Killing And Is Sentenced to Fifty Years,\u0022 New York Times, January 22, 1999.) \u00a0According to a December 16, 2014 media release by the Mexican Prosecutor General\u0027s Office, Mr. Salinas was acquitted of unjust enrichment by the Third Criminal Court of the Federal District. (Source: \u00a0Procuraduria General de la Republica, Resumen de Medios Electronicos, December 16, 2014.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Chief Public Prosecutor\u0027s Office","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Examining Magistrate","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Federal Office of Justice; [name of Mexico\u0027s civil attorney not known]","Jurisdiction of Asset Recovery: Courts Involved":"Federal Supreme Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Salinas_GAO_Testimony_1999.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Salinas_Mexico_Murder_Conviction_NYT_Jan_22_1999.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Salinas_Switzerland_Assets_Handover_Dept_Justice_PR_Jun_18_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Salinas_Mexico_PGR_resumenmat16dic2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Salinas_GAO_Testimony_1999.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Salinas_Mexico_Murder_Conviction_NYT_Jan_22_1999.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Salinas_Switzerland_Assets_Handover_Dept_Justice_PR_Jun_18_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Salinas_Swiss_Return_Mexico_Procuradur%C3%ADa%20General%20de%20la%20Rep%C3%BAblica_PR_2007.pdf","Sources ":"\n\tSwiss Federal Department of Justice and Police Press Release, \u0022Salinas assets handed over to Mexico, Federal Examining Magistrate concludes 12-year proceedings,\u0022 June 18, 2008, last accessed on October 4, 2010 at http:\/\/www.ejpd.admin.ch\/ejpd\/en\/home\/dokumentation\/mi\/2008\/ref_2008-06-...\n\n\t\u00a0\n\n\tProcuraduria General de la Republica, Sala de Prensa 501\/08, \u0022PGR Achieves the Repayment of more than 74 million dollars,\u0022 June 18, 2008, at http:\/\/www.pgr.gob.mx\/prensa\/2007\/press08\/Jun\/pr50108.shtm;\n\n\t\u00a0\n\n\tProcuraduria General de la Republica, Resumen de Medios Electronicos, December 16, 2014, at http:\/\/www.pgr.gob.mx\/prensa\/sintesis\/resumenmat16dic2014.pdf;\n\n\t\u00a0\n\n\tJulia Preston, \u0022Raul Salinas Guilty in Killing And Is Sentenced to Fifty Years,\u0022 New York Times, January 22, 1999, accessed at http:\/\/www.nytimes.com\/1999\/01\/22\/world\/raul-salinas-guilty-in-killing-a... \u0022Private Banking: Raul Salinas, Citibank, and Alleged Money Laundering,\u0022 Statement for the Record of Robert H. Hast, Acting Assistant Comptroller General for Investigations, Office of Special InvestigationsTestimony, Before the Permanent Subcommittee on Investigations, Committee on Governmental Affairs, U.S. Senate, November 9, 1999, accessed at http:\/\/www.gao.gov\/archive\/2000\/os00003t.pdf.\n\n\t\u00a0\n"},{"Case ID":"ARW-161","Case Title (Name of Public Official or Entity Allegedly Involved)":"Raul Salinas (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Mexico","Position of Public Official(s) (yrs in office)":"Brother of President Carlos Salinas (1988-1994)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"2009","UNCAC Offenses Implicated":"Art.15, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified ","Contributing Factors in Asset Recovery":"Global settlement agreement","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"Unspecified amount","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a 1998 Report by the U.S. General Accounting Office (currently known as Government Accountability Office), Mr. Salinas\u0027 shell company Trocca held investment accounts in Citibank UK.  (Source:  U.S. General Accounting Office, Report to the Ranking Minority Member, Permanent Subcommittee on Investigations, Committee on Governmental Affairs, U.S. Senate, \u0022Private Banking: Raul Salinas, Citibank and Alleged Money Laundering,\u0022 GAO\/OSI-99-1 (October 1998).  According to a UK official knowledgeable about the case, $20 million in London accounts had been restrained.  After a worldwide settlement was reached, United Kingdom discharged the restraint orders and in early 2009, the funds were forwarded to Switzerland.  Civil lawyers acting on behalf of the Mexican government had a role in the funds transfer. (Source: Researcher interview with United Kingdom official, November 2010.)","Disposition of Criminal Case(s)":"According to the New York Times, Mr. Salinas was convicted in January 1999 in Mexico of murder. (Source: Julia Preston, \u0022Raul Salinas Guilty in Killing And Is Sentenced to Fifty Years,\u0022 New York Times, January 22, 1999.)  According to a December 16, 2014 media release by the Mexican Prosecutor General\u0027s Office, Mr. Salinas was acquitted of unjust enrichment by the Third Criminal Court of the Federal District. (Source:  Procuraduria General de la Republica, Resumen de Medios Electronicos, December 16, 2014.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Chief Public Prosecutor\u0027s Office","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Scotland Yard","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Raul_Salinas_UK_GAO_Rept_Oct_1998.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Salinas_GAO_Testimony_1999.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Salinas_Mexico_Murder_Conviction_NYT_Jan_22_1999.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Salinas_US_Senate_Report_Scotland_Yard.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Salinas_Mexico_PGR_resumenmat16dic2014_0.pdf","Sources ":"\n\tU.S. General Accounting Office [currently known as Government Accountability Office], Report to the Ranking Minority Member, Permanent Subcommittee on Investigations, Committee on Governmental Affairs, U.S. Senate, \u0022Private Banking: Raul Salinas, Citibank and Alleged Money Laundering,\u0022 GAO\/OSI-99-1 (October 1998) and \u0022Private Banking: Raul Salinas, Citibank, and Alleged Money Laundering,\u0022 Statement for the Record of Robert H. Hast, Acting Assistant Comptroller General for Investigations, Office of Special Investigations, Testimony Before the Permanent Subcommittee on Investigations, Committee on Governmental Affairs, U.S. Senate, November 9, 1999, accessed at http:\/\/www.gao.gov\/archive\/2000\/os00003t.pdf; Researcher interview with United Kingdom official, November 2010. \u00a0See also \u00222\/2\/96 document prepared by Scotland Yard on transactions in Salinas\u0027 accounts,\u0022 in Hearings before the Permanent Subcommittee on Investigations of the Committeee on Governmental Affairs, United States Senate, on \u0022Private Banking and Money Laundering: A Case Study of Opportunities and Vulnerabilities,\u0022 S. Hrg. 106-428, November 9 and 10, 1999 at 352-53; Julia Preston, \u0022Raul Salinas Guilty in Killing And Is Sentenced to Fifty Years,\u0022 New York Times, January 22, 1999, accessed at http:\/\/www.nytimes.com\/1999\/01\/22\/world\/raul-salinas-guilty-in-killing-a...\n\n\t\u00a0\n\n\tProcuraduria General de la Republica, Resumen de Medios Electronicos, December 16, 2014, at http:\/\/www.pgr.gob.mx\/prensa\/sintesis\/resumenmat16dic2014.pdf;\n"},{"Case ID":"ARW-163","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha (Bahamas)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"Bahamas","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Letter of Request","Basis for Intl Cooperation":"Criminal Justice (International Co-operation) Act","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In March 2012, the Supreme Court of the Bahamas rejected an application by Ibrahim Ali Amin to remove the restraint on funds held in a numbered account of March Finance SA at the Private Investment Bank in Nassau, Bahamas.  The Court referenced an affidavit by the Swiss Attorney General\u0027s Office which stated that the Swiss Investigating Judge\u0027s Conviction Order of the Republic and Canton of Geneva, dated November 19, 2009, in criminal case P\/12983\/199 versus Mr. Abba Abacha determined that the name Ibrahim Ali Amin was a fake name used to open the account.   The Bahamas Supreme Court stated that this is not refuted, and held that the account should remain frozen until the proceedings against Abacha have been concluded and application for confiscation is made. (Source: The Attorney General vs. General Sani Abacha and others, Bahamas Supreme Court, March 19, 2012.)\n According to the UK\u0027s Anti-Corruption Forum, \u0022Yves Aeschlimann, a magistrate in Geneva, found Abba Abacha, son of General Sani Abacha, the late Nigerian dictator, guilty of corruption, sentenced him to a suspended prison term and ordered confiscation of $350m (EUR 235m, GBP 210m) in funds held in Luxembourg and the Bahamas. The funds had already been frozen by the investigation.\u0022 (Source: UK Anti-Corruption Forum, November 2009 Newsletter).","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate.  (Source:  Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C... According to BBC News, in September 2011, the Swiss supreme court ordered the retrial of Mr. Abba Abacha, son of former President Abacha, on the basis that he had been unable to obtain a visa to attend his trial.  (Source:  BBC News, \u0022Swiss court orders retrial of Nigeria\u0027s Abba Abacha,\u0022 September 20, 2011.)","Jurisdiction of Origin: Investigative Agency":"Special Panel established to investigate Abacha looting","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"Supreme Court, Common Law \u0026 Equity Division","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bahamas_Anti-Corruption_Newsletter_Nov_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Switzerland_Retrial_Son_BBC_News_Sep_20_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Switzerland_Retrial_Son_BBC_News_Sep_20_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bahamas_Anti-Corruption_Newsletter_Nov_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Switzerland_Retrial_Son_BBC_News_Sep_20_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Bahamas_Acct_Freeze_SCt_Judgment_2012.pdf","Sources ":"The Attorney General vs. General Sani Abacha and others, Bahamas Supreme Court Judgment, March 19, 2012, at http:\/\/www.supremecourt.org.bs\/download\/073533800.pdf;\nUK Anti-corruption Forum, November 2009 newsletter, at http:\/\/www.anticorruptionforum.org.uk\/acf\/forum_newsletters\/nov09\/nov09.... BBC News, \u0022Swiss court orders retrial of Nigeria\u0027s Abba Abacha,\u0022 September 20, 2011, accessed at http:\/\/www.bbc.co.uk\/news\/world-africa-14992084\n"},{"Case ID":"ARW-164","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha (Luxembourg)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President","Jurisdiction of Asset Recovery":"Luxembourg","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2000","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Letter of Request","Basis for Intl Cooperation":"Letter of Request","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"On Appeal","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to Attorney Enrico Monfrini, on February 20, 2000, a Letter Rogatory was sent to Luxembourg and within one month, Luxembourg froze $630 million in eight accounts at the M.M. Warburg \u0026 Co Luxembourg S.A.  (Source: Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets [Peter Lang, 2008]).  According to the Swiss Ministry of Foreign Affairs, as of September 30, 2009, $400 million was frozen in Luxembourg and asset recovery effort was ongoing.  According to the UK Anti-Corruption Forum November 2009 newsletter. Yves Aeschlimann, the Investigating Magistrate overseeing the Swiss criminal case, found Abba Abacha (son of late President Sani Abacha) guilty of corruption, sentenced him to a suspended prison term and ordered confiscation of $350m (EUR 235m, GBP 210m) in funds held in Luxembourg and the Bahamas. The funds had already been frozen by the investigation. As of October 2013, the case is ongoing.","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate.  (Source:  Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....  According to BBC News, in September 2011, the Swiss supreme court ordered the retrial of Mr. Abba Abacha, son of former President Abacha, on the basis that he had been unable to obtain a visa to attend his trial.  (Source:  BBC News, \u0022Swiss court orders retrial of Nigeria\u0027s Abba Abacha,\u0022 September 20, 2011.)","Jurisdiction of Origin: Investigative Agency":"Special Panel established to investigate Abacha looting","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Monfrini Crettol \u0026 Partners (Attorneys Enrico Monfrini and Yves Klein)","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Luxembourg_UK_Anticorruption_Newsletter_Nov_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Monfrini_Article_2008.pdf Abacha_Switzerland_Retrial_Son_BBC_News_Sep_20_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Switzerland_Retrial_Son_BBC_News_Sep_20_2011_0.pdf","Sources ":"Swiss Ministry of Foreign Affairs, September 30, 2009; \nEnrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), and also available at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C... \nUK Anti-corruption Forum, November 2009 newsletter, at http:\/\/www.anticorruptionforum.org.uk\/acf\/forum_newsletters\/nov09\/nov09.... \nBBC News, \u0022Swiss court orders retrial of Nigeria\u0027s Abba Abacha,\u0022 September 20, 2011, accessed at http:\/\/www.bbc.co.uk\/news\/world-africa-14992084\n"},{"Case ID":"ARW-165","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha \/ Abubakar Bagudu","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (Abacha,1993-1998) \/ Associate (Bagudu)","Jurisdiction of Asset Recovery":"Jersey","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"2003","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"\u0022The Abacha case is a clear example of the benefit of international cooperation to which the Island is committed. Given the nature of business in Jersey, the investigation of serious financial crime inevitably involves liaison with other jurisdictions, both to provide assistance to other countries, and to obtain assistance from them. The Serious Crime Group continues to assist other countries in fighting crime and uses its close links with other nations to obtain evidence to combat crime in the Island.\u0022 (Source: Attorney General\u0027s Annual Review 2003). ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Part of worldwide settlement, with recovered funds to be used to fund projects in the health, education, water, electricity and road sectors; monitoring responsbility held by the World Bank.  (Source:  \u0022Utilization of Repatriated Abacha Loot, Results of the Field Monitoring Exercise,\u0022 Report Prepared by the World Bank with Cooperation from the Federal Ministry of Finance (December 2006)).","Case Summary":"Jersey Attorney General\u0027s Annual Review for 2003, the report noted that \u00222003 saw Jersey\u2019s long running investigation into Nigerian corruption approach its climax. Working closely with the present Nigerian authorities, the U.S. authorities and countries across Western Europe, Serious Crime Group lawyers played a direct and crucial role in the repatriation of some U.S.$160 million of money embezzled from the people of Nigeria and channelled through Jersey by the late Nigerian dictator Sani Abacha, and his henchmen. Further repatriations of stolen funds are expected to follow in the months ahead.\u0022 (Source: Attorney General\u0027s Annual Review 2003, at 6-7, accessed at http:\/\/www.gov.je\/SiteCollectionDocuments\/Government%20and%20administrat....) According to Attorney Enrico Monfrini, the Jersey authorities had informally frozen the $160 million. In 2003, Abubakar Bagudu, an associate of Mr. Abacha, was arrested and extradited from Houston, Texas at the request of Jersey. Mr. Bagudu settled with the Nigerian government, agreeing to return the $160 million in exchange for deportation to Nigeria. (Source: Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008)).","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate.  (Source:  Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"Special Panel established to investigate Abacha looting","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Attorney General\u0027s Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Jersey: Attorney General\u0027s Office, Serious Crime Group; United States: United States Attorney for the Southern District of Texas; Civil: Edwards Angell Palmer \u0026 Dodge (Attorneys James Maton and Tim Daniel); Monfrini Crettol \u0026 Partners (Attorneys Enrico Monfrini and Yves Klein)","Jurisdiction of Asset Recovery: Courts Involved":"Jersey Royal Court; United States: U.S. District Court for the Southern District of Texas","Documents":"","Sources ":"Government of Jersey, Attorney General\u0027s Annual Review 2003, accessed at http:\/\/www.gov.je\/SiteCollectionDocuments\/Government%20and%20administrat... and at ICC FraudNet, notable cases: http:\/\/www.icc-ccs.org\/home\/resources\/118-leading-cases\/697-abacha-case; Jersey Financial Services Commission Press Release, \u0022Abacha Investigation,\u0022 March 1, 2004 posted at http:\/\/www.jerseyfsc.org\/the_commission\/general_information\/press_releas... (notes investigation and return of assets, although not the amount returned); Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), and also available at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C... Tim Daniel, \u0022General Abacha - A Nation\u0027s Thief,\u0022 Case Study published in Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational (Bali, Indonesia, September 2007), published by the ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific (2008); Harvey Rice, \u0022Businessman will return to Nigeria to face charges \/ Accused of bilking nation\u0027s treasury,\u0022 The Houston Chronicle, November 21, 2003, accessed at http:\/\/www.chron.com\/CDA\/archives\/archive.mpl?id=2003_3709885.\n"},{"Case ID":"ARW-166","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha \/ Raj Arjandas Bhojwani Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (Abacha,1993-1998) \/ Businessman and contractor for Nigerian government (Bhojwani)","Jurisdiction of Asset Recovery":"Jersey","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"2013","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Letter of Request","Basis for Intl Cooperation":"Criminal Justice (International Co-operation) Jersey Law 2001 [Letter of Request sent by Nigeria\u0027s civil attorney, Mr. Monfrini to Nigeria to seek evidence]","Contributing Factors in Asset Recovery":"Ongoing cooperation and existing sharing agreement (Source:  Federal Ministry of Justice, \u0022FG assures speedy prosecution of criminal and civil cases; reveals more Abacha loots are being recovered,\u0022 undated statement posted June 30, 2013.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"","Case Summary":"\n\tAccording to a statement posted on the website of Nigeria\u0027s Federal Ministry of Justice, the Minister of Justice stated that GBP 22.5 million confiscated in Jersey were repatriated to Nigeria. (Source: \u00a0Federal Ministry of Justice, \u0022FG assures speedy prosecution of criminal and civil cases; reveals more Abacha loots are being recovered,\u0022 undated statement posted June 30, 2013.)\n\n\t\u00a0\n\n\tIn 2010, Mr. Bhojwani was convicted in Jersey and concealing $40 million of his illicit proceeds in bank account in the jurisdiction. \u00a0According to the February 23, 2010 Judgment by the Jersey Royal Court (Samedi Division), the Prosecution alleged that in 1996 and 1997, Mr. Bhojwani \u0022negotiated with officials serving as part of the military dictatorship of General Abacha, who was at the time the de facto President of Nigeria. \u00a0The contracts were for the supply of vehicles to the military, and it is alleged that the contracts were at a significantly inflated price such that an ollegal surplus of about US $130 milllion came into the applicant\u0027s bank accounts in Jersey. \u00a0It is alleged that the surplus was transferred by the applicant to bank accounts in other countries linked to the Abacha regime.\u0022 \u00a0 \u00a0According to the judgment, the Attorney General of Jersey indicated that \u0027In the event that Mr. Bhojwani is convicted in Jersey and the assets that represent the proceeds of his crime are lawfully confiscated then I will of course consider the possibility of a legal agreement to share assets.\u0022 \u00a0The investigation was initiated by a letter of request, sent in 2002, by Nigeria\u0027s private attorney, Mr. Enrico Monfrini to Jersey authorities. (Source: AG v. Bhojwani, 2010 JRC 042, Judgment dated February 23, 2010.) \u00a0His conviction was affirmed by the Jersey Appeals Court in February 2011; the Appeals Court also upheld the assessment of GBP 65,000 in prosecution costs against Mr. Bhojwani, calling the sum modest for a complex case. \u00a0(Sources: \u00a0Raj Arjandas Bhojwani v. The Attorney General, Jersey Court of Appeals, 2011 JCA 034 and 2011 JCA 035, both dated February 10, 2011.) \u00a0 In June 2011, the Government of Jersey stated that, \u0022It is now anticipated that discussions will take place with the government of Nigeria regarding the repatriation of some of the confiscated funds which are held in Jersey. Approximately US$170 million connected with the Abacha investigations has already been returned by Jersey to the Nigerian authorities as part of previous asset sharing agreements.\u0022 (Source: States of Jersey, \u0022Funds confiscated from money launderer,\u0022 June 7, 2011.)","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate.  (Source:  Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....  According to the Royal Court of the Isle of Jersey, Mr. Bhojwani was convicted of two counts of converting the proceeds of criminal conduct and one count of removing the proceeds of criminal conduct, contrary to art. 34(1)(b) of the Proceeds of Crime (Jersey) Law 1999.  (Source: Attorney General v. Bhojwani, 2010 JLR Note 34 (June 25, 2010), accessed at http:\/\/www.jerseylaw.je\/Judgments\/JerseyLawReports\/Display.aspx?url=cases\\JLR2010\\JLR10N034.htm.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Attorney General\u0027s Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General; N.M. Santos Costa (for the Attorney General of Nigeria)","Jurisdiction of Asset Recovery: Courts Involved":"Royal Court (Samedi Division)","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Jersey_Bhojwani_2010_JLR_Note_34 .pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Jersey_Bhojwani_2010_JRC_042_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bhojwani_v_Atty_Genl_2011_JCA_034, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bhojwani_v_Atty_Genl_2011_JCA_035, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bhojwani_Jersey_Confiscation_BBC_Jun_8_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Bhojwani_Jersey_Confiscation_PR_Jun_7_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Jersey_Bhojwani_2010_JLR_Note_34 .pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Jersey_Bhojwani_2010_JRC_042_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bhojwani_v_Atty_Genl_2011_JCA_034, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bhojwani_v_Atty_Genl_2011_JCA_035, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bhojwani_Jersey_Confiscation_BBC_Jun_8_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Bhojwani_Repatriation_Nigeria_Min_Justice_Jun_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Jersey_Bhojwani_2010_JLR_Note_34 .pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Jersey_Bhojwani_2010_JRC_042_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bhojwani_v_Atty_Genl_2011_JCA_034, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bhojwani_v_Atty_Genl_2011_JCA_035, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Bhojwani_Jersey_Confiscation_BBC_Jun_8_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Bhojwani_v_Atty_Genl_2011_JCA_034.pdf","Sources ":"\n\tFederal Ministry of Justice, \u0022FG assures speedy prosecution of criminal and civil cases; reveals more Abacha loots are being recovered,\u0022 undated statement posted June 30, 2013, at http:\/\/www.nigeria.gov.ng\/2012-10-29-11-09-25\/news\/429-fg-assures-speedy...\n\n\t\u00a0\n\n\tAttorney General v. Raj Arjandas Bhojwani, 2010 JRC 042, Judgment dated February 23, 2010, and Attorney General v. Bhojwani, 2010 JLR Note 34 (June 25, 2010),; Raj Arjandas Bhojwani v. The Attorney General, Jersey Court of Appeals, 2011 JCA 034 and 2011 JCA 035, both dated February 10, 2011. \u00a0All judgements can be accessed at: http:\/\/www.jerseylaw.je\/judgments\/jerseylawreports\/JLRHomePage.aspx; States of Jersey, \u0022Funds confiscated from money launderer,\u0022 June 7, 2011, at http:\/\/www.gov.je\/News\/2011\/Pages\/BhowaniConfiscation.aspx. \u00a0See also, BBC News, \u0022Man in money launder scam with dictator to pay [GBP] 26.5m,\u0022 June 8, 2011, accessed at http:\/\/www.bbc.co.uk\/news\/world-europe-jersey-13699045\n"},{"Case ID":"ARW-167","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sani Abacha \/ Swiss Mutual Legal Assistance Treaty Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"President (1993-1998)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1998","Asset Recovery End":"2007","UNCAC Offenses Implicated":"Art.16, Art.17, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"MLAT","Contributing Factors in Asset Recovery":"\u0022Thanks to the thorough investigation in the Geneva domestic criminal proceedings, the criminal origin of the funds was clearly demonstrated.\u0022  (Source: Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets [Peter Lang, 2008]).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$723,000,000","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Part of worldwide settlement with recovered funds to be used to fund projects in the health, education, water, electricity and road sectors; monitoring responsibility held by the World Bank.  (Source:  \u0022Utilization of Repatriated Abacha Loot, Results of the Field Monitoring Exercise,\u0022 Report Prepared by the World Bank with Cooperation from the Federal Ministry of Finance (December 2006)).","Case Summary":"According to the Swiss Ministry of Foreign Affairs, $700 million were returned to Nigeria. \u00a0(Source: Swiss Ministry of Foreign Affairs, September 30, 2009; see also, The Federal Authorities of the Swiss Confederation, \u0022Out-of-court settlement in the Abacha case - Nigeria to receive more than a billion USD; The countries concerned cooperate in the implementation of the settlement,\u0022 April 17, 2002.) \u00a0In 2001, the Abacha family and associates reached an agreement with the Nigerian government to release $1.3 billion frozen in Switzerland, Liechtenstein and Luxembourg in exchange for being able to keep $100 million. According to Attorney Enrico Monfrini (lawyer for Nigeria), \u0022Thanks to the thorough investigation in the Geneva domestic criminal proceedings, the criminal origin of the funds was clearly demonstrated...On 19 August 2004, the Federal Office of Justice agreed to transmit to Nigeria all the assets in Switzerland beneficially owned by the Abacha family, waiving the condition of a prior judicial forfeiture decision in Nigeria,\u0022 \u00a0This decision was upheld for the most part by the Swiss Supreme Court in February 2005. \u00a0The Abacha family did not \u0022attempt to reverse the presumption by proving that the balance of the attached funds was not of criminal origin.\u0022 \u00a0(Source: Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets [Peter Lang, 2008]; See also, Chronology and related court documents in the Abacha case in ICC FraduNet, at http:\/\/www.icc-ccs.org\/home\/resources\/118-leading-cases\/697-abacha-case).\nUpdate (December 2017): According to the MOU between Nigeria, Switzerland, and the World Bank, signed in December 2017, Switzerland had returned $723 million to Nigeria by 2005. Based on this, the total amount of retruned assets for this case entry was updated from $700 million to $723 million. Also see ARW-250.\u00a0","Disposition of Criminal Case(s)":"According to a 2008 article by Attorney Enrico Monfrini, an appeal was pending before the Nigerian Supreme Court in the criminal cases arising from charges filed in 2000 and 2001 against Mr. Abacha\u0027s sons and associate. (Source: Enrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008), accessed at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C....","Jurisdiction of Origin: Investigative Agency":"Special Panel established to investigate Abacha looting","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Office of Justice","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Monfrini Crettol \u0026 Partners (Attorneys Enrico Monfrini and Yves Klein) - asset recovery","Jurisdiction of Asset Recovery: Courts Involved":"Geneva Canton Courts","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Switzerland_127_II_198_Jun_5_2001.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Switzerland_Accounts_Frozen_Federal_Office_Justice_PR_Oct_14_1999.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Switzerland_Anti-Corruption_Newsletter_Nov_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Switzerland_Assets_Handed_Over_Federal_Office_Justice_Feb_16_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Abacha_Switzerland_Monfrini_Art_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Abacha_Settlement_Switzerland_Press_Rel_Apr_17_2002.pdf","Sources ":"Swiss Ministry of Foreign Affairs, September 30, 2009; The Federal Authorities of the Swiss Confederation, \u0022Out-of-court settlement in the Abacha case - Nigeria to receive more than a billion USD; The countries concerned cooperate in the implementation of the settlement,\u0022 April 17, 2002, at http:\/\/www.admin.ch\/aktuell\/00089\/index.html?lang=en\u0026msg-id=23391.\n\u00a0\nSwiss Federal Office of Justice Press Releases: \u0022Abacha assets to be handed over to Nigeria, Switzerland doesn\u0027t provide refuge for funds of criminal origin,\u0022 February 16, 2005; \u0022Abacha\u0027s accounts frozen as provisional measure,\u0022 October 14, 1999, and others at http:\/\/www.ejpd.admin.ch\/ejpd\/en;\n\u00a0\nEnrico Monfrini, \u0022The Abacha Case,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Bern: Peter Lang AG, 2008) and at also available at http:\/\/www.mcswisslaw.com\/pages_e\/2008%20Monfrini%20-%20The%20Abacha%20C.... \u00a0Among the Swiss court decisions cited by Mr. Monfrini are: \u00a0ATF 1A.157\/2001 and 1A.158\/2001 (December 7, 2001); ATF 1A.49-54\/2002 (April 23 2003), ATF 115 1b 517; ATF 123 II 134; ATF 123 II 268; ATF 123 II 595; ATF 1A.215\/2004 (February 7, 2005). \u00a0See also, 127 II 198, extract from Judgment of Cour de droit public [Court of Public Law], June 5, 2001, in the case of Abacha and Bagudu, Chambre d\u0027accusacion du canton de Geneva (administrative appeal) [challenge of right to inspect files on bank records pursuant to MLAT request by Nigeria].\n\u00a0\nChronology and related court documents in the Abacha case can be accessed at ICC FraduNet, at http:\/\/www.icc-ccs.org\/home\/resources\/118-leading-cases\/697-abacha-case.\u00a0\n"},{"Case ID":"ARW-34","Case Title (Name of Public Official or Entity Allegedly Involved)":"Charles Taylor \/ Guus Kouwenhoven","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Liberia","Position of Public Official(s) (yrs in office)":"President (Taylor, 1997-2003) \/ Head of the Oriental Timber Corporation (Kouwenhoven, 2000-2003)","Jurisdiction of Asset Recovery":"Netherlands","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2003","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\u0022Guus Kouwenhoven was de-listed from the travel ban and assets freeze lists by the Committee in December 2008. However, the Panel notes that in April 2010 the Supreme Court of the Netherlands overturned a 2008 ruling by the Court of Appeal which cleared businessman Guus Kouwenhoven of charges of involvement in illegal arms deals and war crimes during the civil war in Liberia from 2000 to 2003.  The Court of Appeal will now have to re-examine the case and make a new judgement. The Panel recalls that Kouwenhoven was head of the Oriental Timber Corporation during the regime of President Charles Taylor.\u0022  (Source:  Court Press Release, April 20, 2010, accessed at http:\/\/www.rechtspraak.nl\/Gerechten\/HogeRaad\/Actualiteiten. See also, summary of Mr. Kouwenhoven\u0027s case and court decisions at the Hague Justice Portal, accessed at http:\/\/www.haguejusticeportal.net\/index.php?id=6412.)","Disposition of Criminal Case(s)":"According to the Special Court for the Sierra Leone, in September 2013, Mr. Taylor\u0027s appeal was denied. \u00a0(Source: \u00a0Special Court for the Sierra Leone, In the Appeals Chamber, Judgment of September 23, 2013, accessed at http:\/\/www.sc-sl.org\/LinkClick.aspx?fileticket=t14fjFP4jJ8%3D\u0026tabid=5).\u00a0","Jurisdiction of Origin: Investigative Agency":"United Nations Special Court for the Sierra Leone","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"United Nations Special Court for the Sierra Leone","Jurisdiction of Origin: Courts Involved":"United Nations Special Court for the Sierra Leone","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Asset Recovery: Courts Involved":"Court of Appeal; Supreme Court; District Court of the Hague","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Netherlands_Global_Witness_GVH_SCt_ Apr_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Netherlands_Hoge Raad_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Special_Court_Sierra_Leone_May_3_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taylor_Appeal_Judgment_Sep_23_2013_0.pdf","Sources ":"The Special Court for the Sierra Leone, Web Homepage, accessed on May 3, 2011, at http:\/\/www.sc-sl.org\/; Judgment, Chamber of Appeals, September 23, 2013, accessed at http:\/\/www.sc-sl.org\/LinkClick.aspx?fileticket=t14fjFP4jJ8%3D\u0026tabid=53; Court press release, April 20, 2010, available at http:\/\/www.rechtspraak.nl\/Gerechten\/ HogeRaad\/Actualiteiten. See also, Global Witness, \u0022Global Witness welcomes Dutch court decision to retry timber baron Guus Kouwenhoven for crimes committed during Liberian war,\u0022 April 21, 2010, accessed at http:\/\/www.globalwitness.org\/library\/global-witness-welcomes-dutch-court... See also, \u0022Guus Kouwenhoven,\u0022 The Hague Justice Portal, http:\/\/www.haguejusticeportal.net\/index.php?id=6412 (last accessed on July 18, 2012).\n"},{"Case ID":"ARW-36","Case Title (Name of Public Official or Entity Allegedly Involved)":"Charles Taylor \/ Two Unnamed Associates","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Liberia","Position of Public Official(s) (yrs in office)":"President (Taylor, 1997-2003) \/ Unknown (Two Unnamed Associates)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2003","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Letter of Request","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"[Unknown Status of Recovery]","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"$1,468,320","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"According to a July 23, 2003 press release by the Swiss Federal Department of Justice, \u0022Around 2 million Swiss francs has been frozen in accounts held by two persons associated with the Liberian president Charles Taylor. No accounts held directly by President Taylor have been found, however.\u0022 The press release also noted that \u0022The Federal Office of Justice (FOJ) has delegated enactment of the legal assistance application from the Special Court for Sierra Leone to the Office of the Attorney General of Switzerland.\u0022 The Federal Office of Justice had issued a prior statement stating that acting on a June 19, 2003 request by the Special Court for Sierre Leone, that it had ordered that any accounts of Liberian President Charles Taylor and further persons be blocked as a provisional measure. (Source: Federal Department of Justice and Police, \u00222 million frozen in Taylor case,\u0022 press release dated July 23, 2003, posted at http:\/\/www.bj.admin.ch\/bj\/en\/home\/dokumentation\/medieninformationen\/2003...).","Disposition of Criminal Case(s)":"According to the Special Court for the Sierra Leone, in September 2013, Mr. Taylor\u0027s appeal was denied. (Source: Special Court for the Sierra Leone, In the Appeals Chamber, Judgment of September 23, 2013, accessed at http:\/\/www.sc-sl.org\/LinkClick.aspx?fileticket=t14fjFP4jJ8%3D\u0026tabid=5). Unknown as to the unnamed associates.","Jurisdiction of Origin: Investigative Agency":"United Nations Special Court for the Sierra Leone","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"United Nations Special Court for the Sierra Leone","Jurisdiction of Origin: Courts Involved":"United Nations Special Court for the Sierra Leone","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Office of Justice","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Office of the Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Special_Court_Sierra_Leone_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Switzerland_EJPD_PR_Jul_23_2003.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Switzerland_EJPD_PR_Jun_23_2003.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Taylor_Appeal_Judgment_Sep_23_2013.pdf","Sources ":"Swiss Federal Office of Justice, \u00222 million frozen in Taylor case,\u0022 Press Release dated July 23, 2003, posted at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2003\/ref_... Swiss Federal Office of Justice, \u0022Taylor\u0027s accounts blocked as provisional measure,\u0022 Press Release dated June 23, 2003, at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2003\/ref_.... \u00a0The Special Court for the Sierra Leone Website Homepage, accessed on May 3, 2011, at http:\/\/www.sc-sl.org\/; Judgment, Chamber of Appeals, September 23, 2013, accessed at http:\/\/www.sc-sl.org\/LinkClick.aspx?fileticket=t14fjFP4jJ8%3D\u0026tabid=53\n"},{"Case ID":"ARW-37","Case Title (Name of Public Official or Entity Allegedly Involved)":"Charles Taylor \/ Viktor Bout \/ Richard Chichakli","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Liberia","Position of Public Official(s) (yrs in office)":"President (Taylor, 1997-2003) \/ Close Associate (Bout)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2010","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"\n\tIn February 2010, the U.S. District Court for the Southern District of New York court unsealed a 9-count indictment against Mr. Bout and his chief financial manager Richard Ammar Chichakli. \u00a0The indictment included forfeiture allegations for more than $1.7 million alleged to have been laundered through New York banks to other banks in the U.S. and noted that the U.S. Department of Treasury had blocked the U.S. accounts of Bout-associated companies in violations of US sanctions against the former Taylore regime. Both men are on the UN Security Council Resolution 1521 asset freeze list. (Source: Indictment in U.S. v. Bout and Chichakli, Case No. 1:09-cr-1002 (S.D.N.Y.), unsealed February 17, 2010 and Press Release by U.S. Attorney\u0027s Office for the Southern District of New York on same date; Superseding Indictment filed on October 25, 2013 against Richard Chichakli). \u00a0On November \u00a016, Mr. Bout was extradited from Thailand to the U.S. (Source: Seth Mydans, \u0022Thailand Extradites Russian Arms Suspect to the U.S.,\u0022 New York Times, November 16, 2010.) \u00a0In April 2012, Mr. Bout was convicted and sentenced in another case against him in the U.S. District Court for the \u00a0Southern District of New York on terrorism-related charges; he appealed the conviction to the U.S. Court of Appeals, Second Circuit. (Source: U.S. v. Bout, Case No. 1:08-cr-00365 (S.D.N.Y.), Judgment in a Criminal Case filed April 9, 2012. US Appeals Court case no. 12-1487).\n\n\t\u00a0","Disposition of Criminal Case(s)":"In April 2012, Mr. Bout was sentenced on terrorism-related charges in the U.S. District Court for the Southern District of New York; he has appealed the conviction to the US Court of Appeals. \u00a0(US v. Bout, Case No. 1:08-cr-00365 (S.D.N.Y.) \u00a0According to the U.S. Government\u0027s indictment, Mr. Bout (and Mr. Chichakli) also faces money laundering, wire fraud and conspiracy charges in a separate case pertaining to violations of US Sanctions against the former Taylor regime before the U.S. District Court for the Southern District of New York. (US v. Bout and Chichakli, Case No. 1:09-cr-01002 (S.D.N.Y.), Indictment unsealed on February 17, 2010).","Jurisdiction of Origin: Investigative Agency":"United Nations Special Court for Sierra Leone","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"United Nations Special Court for Sierra Leone","Jurisdiction of Origin: Courts Involved":"United Nations Special Court for Sierra Leone","Jurisdiction of Asset Recovery: Investigative Agency":"Drug Enforcement Agency; Assistance provided by Department of Justice, Office of International Affairs and Department of State; INTERPOL","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Southern District of New York","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_Case_108-cr-00365_SDNY_Court_Docket_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_Extradition_NYT_Nov_16_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_Indictment_Feb_17_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_Indictment_PR_Feb_17_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_ML_DktRpt_May3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_ML_DktRpt_Pulled_Dec_3_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_Terrorism_DktRpt_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bout_SDNY_Arms_Conviction_WSJ_CC_Nov_2_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bout_SDNY_Arms_Conviction_WSJ_CC_Nov_2_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_Case_108-cr-00365_SDNY_Court_Docket_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_Extradition_NYT_Nov_16_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_Indictment_Feb_17_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_Indictment_PR_Feb_17_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_ML_DktRpt_May3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_ML_DktRpt_Pulled_Dec_3_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Taylor_Bout_SDNY_Terrorism_DktRpt_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bout_SDNY_Arms_Conviction_WSJ_CC_Nov_2_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bout_SDNY_Sanctions_Chichakli_Supersede_Indict_Oct_25_2013.pdf","Sources ":"U.S. v. Bout and Chichakli, Case No. 1:09-cr-1002 (S.D.N.Y.), Indictment unsealed on February 17, 2010 and Superseding Indictment (Chichakli) filed October 25, 2013); \u00a0United States Attorney\u0027s Office for the Southern District of New York Press Release, \u0022U.S. Announces New Indictment against International Arms Dealer Viktor Bout and American Co-Conspirator for \u00a0Money Laundering, Wire Fraud and Conspiracy,\u0022 February 17, 2010. \u00a0See also, US v. Bout, Case No. 1:08-cr-00365 (S.D.N.Y.), Judgment in a Criminal Case filed April 6, 2012; Notice of appeal filed April 7, 2012. \u00a0Seth Mydans, \u0022Thailand Extradites Russian Arms Suspect to U.S.,\u0022 New York Times, November 16, 2010; Samuel Rubenfeld, \u0022Viktor Bout Convicted In Arms-Dealing Case,\u0022 Wall Street Journal Corruption Currents, November 2, 2011, accessed at http:\/\/blogs.wsj.com\/corruption-currents\/2011\/11\/02\/viktor-bout-convicte...\n"},{"Case ID":"ARW-38","Case Title (Name of Public Official or Entity Allegedly Involved)":"Charles Warwick Reid","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"","Position of Public Official(s) (yrs in office)":"Deputy Crown Prosecutor (1975-1989)","Jurisdiction of Asset Recovery":"New Zealand","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1986","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.15, Art.20","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Cooperation by Hong Kong and New Zealand","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"At his 1990 sentencing in Hong Kong, Charles Warwick Reid was ordered to pay HK $12.4 million (the value of his unexplainable assets).  However, the funds in his Singaporean bank account had disappeared, and Mr. Reid never paid the fine.  The Attorney General of Hong Kong pursued a civil case on behalf of the Crown in New Zealand to seize the three properties Mr. Reid owned in New Zealand. In 1993, the Privy Council in London held that the properties were held in constructive trust for the Crown.  (Source: Attorney General for Hong Kong v. Reid, 1993 UKPC 2 [November 1, 1993]).  A week after his release from Hong Kong and return to New Zealand, however, he was re-arrested on another bribery charge and again forced to forfeit properties that represented the proceeds of his corrupt activities. The High Court of Auckland ordered the seizure of Mr. Reid\u0027s assets, which included his family home in Tauranga, the Bay BodyFit Gymnasium, and his family trust funds.  In a deal reached with Crown lawyers in 1997, Charles Warwick Reid dropped his appeal against the ruling, and the Reids were allowed to rent their former home at market rates for a period of six years, until their youngest child turned sixteen. (Source: AFP, \u0022Ex-HK Prosecutor Warwick Reid gives up fight to keep assets,\u0022 October 17, 1997.)","Disposition of Criminal Case(s)":"According to a judgment by the Hong Kong Court of Appeals, Mr. Reid pleaded guilty to violation of section 10(1)(b) of the Prevention of Bribery Ordinance and, in July 1990, he was sentenced by the Hong Kong High Court to an 8-year prison term. (Source: In the Matter of an Application for Leave to Apply for Judicial review and in the Matter of Charles Warwick Reid, Case No. CACV 149\/2003, Judgement dated January 12, 1994.)","Jurisdiction of Origin: Investigative Agency":"Independent Commission Against Corruption; [Philippines Immigration officers, 1990 - illegal entry]","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General ","Jurisdiction of Origin: Courts Involved":"Magistrates Court, High Court","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Herbert Smith, London Agents for Russell McVeagh McKenzie Bartleet \u0026 Co (for Attorney General of Hong Kong, Privy Council)","Jurisdiction of Asset Recovery: Courts Involved":"High Court of Auckland, Court of Appeal of New Zealand, United Kingdom Privy Council","Documents":"","Sources ":"AG for Hong Kong v. Reid, 1993 UKPC 2 (01 November 1993) (on appeal from the Court of Appeal of New Zealand, Civil Appeal No. 44 of 1992) (available through www.bailii.org) and Index of Reference including Reasons for Judgment of the Court of Appeal of New Zealand (December 19, 1991) and Judgment of Court of Appeal of New Zealand (March 18, 1992); In the Matter of an Application for Leave to Apply for Judicial Review and in the Matter of Charles Warwick Reid, Case No. CACV 149\/1993, Judgement dated January 12, 1994, accessed at http:\/\/legalref.judiciary.gov.hk\/lrs\/common\/ju\/judgment.jsp; See also, \u0022Senior Government Counsel Bribery Case,\u0022 as part of the landmark cases section of the Hong Kong Independent Commission Against Corruption website, at http:\/\/www.icac.org.hk\/new_icac\/eng\/cases\/ddpp\/dcont_01.htm.\n"},{"Case ID":"ARW-42","Case Title (Name of Public Official or Entity Allegedly Involved)":"Chinese National #1 (unnamed)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"China","Position of Public Official(s) (yrs in office)":"Unknown","Jurisdiction of Asset Recovery":"Australia","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Other ","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Australia - China law enforcement cooperation and establishment of Australia\u0027s Equitable Sharing Program (Source: \u0022Equitable Sharing Program,\u0022 on the website of the Australian Government, Attorney-General\u0027s Department, Overview of the Proceeds of Crime Act 2002, accessed at http:\/\/www.ag.gov.au\/agd\/WWW\/ncphome.nsf\/Page\/POCA_funding_for_Non-Government_Agencies.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$2,561,820","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"Citing obligation under the United Nations Convention Against Corruption to share profits of crime where assistance in the recovery of those profits contributes to legal enforcement cooperation, the Australian government made the following payment under its equitable sharing program: AUD $3,372,807.49 to the Chinese Government for money recovered in Australia by the Australian Federal Police, regarding a matter involving a Chinese national, who was wanted in China for embezzlement and fraud offenses. (Source: \u0022Equitable Sharing Program,\u0022 on the website of the Australian Government, Attorney-General\u0027s Department, Overview of the Proceeds of Crime Act 2002, accessed at http:\/\/www.ag.gov.au\/agd\/WWW\/ncphome.nsf\/Page\/POCA_funding_for_Non-Gover....)","Disposition of Criminal Case(s)":"According to the website of Australia\u0027s Attorney General on the Equitable Sharing Program under the Proceeds of Crime Act, the Chinese national was \u0022wanted in China for embezzlement and fraud charges.\u0022 (Source: http:\/\/www.ag.gov.au\/agd\/WWW\/ncphome.nsf\/Page\/POCA_funding_for_Non-Gover..., last accessed on May 3, 2011.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Australian Federal Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"http:\/\/\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Australia_ATTY_GENL_ESP_May_3_2011.pdf","Sources ":"\u0022Equitable Sharing Program,\u0022 on the website of the Australian Government, Attorney-General\u0027s Department, Overview of the Proceeds of Crime Act 2002, accessed at http:\/\/www.ag.gov.au\/agd\/WWW\/ncphome.nsf\/Page\/POCA_funding_for_Non-Gover....\n"},{"Case ID":"ARW-43","Case Title (Name of Public Official or Entity Allegedly Involved)":"Chinese National #2 (unnamed)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"China","Position of Public Official(s) (yrs in office)":"Unknown","Jurisdiction of Asset Recovery":"Australia","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"","UNCAC Offenses Implicated":"Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Other ","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Australia - China law enforcement cooperation and establishment of Australia\u0027s Equitable Sharing Program (Source: \u0022Equitable Sharing Program,\u0022 on the website of the Australian Government, Attorney-General\u0027s Department, Overview of the Proceeds of Crime Act 2002, accessed at http:\/\/www.ag.gov.au\/agd\/WWW\/ncphome.nsf\/Page\/POCA_funding_for_Non-Government_Agencies.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$3,873,950","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"Citing obligation under the United Nations Convention Against Corruption to share profits of crime where assistance in the recovery of those profits contributes to legal enforcement cooperation, the Australian government made the following payment under its equitable sharing program: AUD $4,160,259.81 to the Chinese Government for money recovered in Australia by the Australian Federal Police, regarding a matter involving a Chinese national, who was wanted in China for money laundering offenses. (Source: \u0022Equitable Sharing Program,\u0022 on the website of the Australian Government, Attorney-General\u0027s Department, Overview of the Proceeds of Crime Act 2002, accessed at http:\/\/www.ag.gov.au\/agd\/WWW\/ncphome.nsf\/Page\/POCA_funding_for_Non-Gover....)","Disposition of Criminal Case(s)":"According to the website of the Australia\u0027s Attorney General on the Equitable Sharing Program under the Proceeds of Crime Act, the Chinese government assisted in \u0022the investigation and prosecution of a Chinese national for money laundering offences.\u0022 (Source: http:\/\/www.ag.gov.au\/agd\/WWW\/ncphome.nsf\/Page\/POCA_funding_for_Non-Gover..., last accessed on May 3, 2011.)","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Australian Federal Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"http:\/\/\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Australia_ATTY_GENL_ESP_May_3_2011_0.pdf","Sources ":"\u0022Equitable Sharing Program,\u0022 on the website of the Australian Government, Attorney-General\u0027s Department, Overview of the Proceeds of Crime Act 2002, accessed at http:\/\/www.ag.gov.au\/agd\/WWW\/ncphome.nsf\/Page\/POCA_funding_for_Non-Gover....\n"},{"Case ID":"ARW-44","Case Title (Name of Public Official or Entity Allegedly Involved)":"CODELCO \/ Juan Pablo Davila","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Chile","Position of Public Official(s) (yrs in office)":"Chief commodities futures trader, CODELCO (1989-1994)","Jurisdiction of Asset Recovery":"Cayman Islands","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1995","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Early warning to bank putting it on notice that it may hold proceeds from fraud which encouraged it to report the funds in order not to risk liability as constructive trustee under Cayman laws. (Source: Website of the Government of Cayman Islands \u0022Forfeiting Proceeds of Corruption,\u0022 last accessed on February 28, 2011, at http:\/\/www.gov.ky\/portal\/page?_pageid=1142,1687439\u0026_dad=portal\u0026_schema=PORTAL).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to the 2002 decision by the Grand Court of the Cayman Islands, as part of his sentence in Chile, Mr. Davila was ordered to pay US$186,183,060 in damages to Codelco.  (Source:   Corporacion Nacional del Cobre de Chile v. Interglobal Incorporated and Avendano Sabugao, 2002 CILR 298 (May 23, 2002))  According to the official website of the Government of Cayman Islands, \u0022In the matter of Re Codelco an early warning to the bank putting it on notice that it may hold accounts which contained the proceeds of official corruption visited on a large scale upon the State-owned copper producing enterprise of the State of Chile, caused the bank voluntarily to freeze the accounts. In responding as it did, the bank\u0027s primary early concern was to avoid its own civil liability as a constructive trustee; but this allowed the Chilean Government time to get discovery orders against the bank for disclosure of information about the accounts and ultimately to freeze the accounts and recover the proceeds. This resulted also in information being disclosed for use in proceedings in other jurisdictions to recover other assets and by the U.S. Commodity Futures Trading Commission [CFTC] in proceedings taken against some of the co-conspirators, employees of a large futures brokerage firm and who were regulated by the CFTC.\u0022 (Source: Website of the Government of Cayman Islands, \u0022Forfeiting Proceeds of Corruption,\u0022 last accessed on October 18, 2010 at http:\/\/www.gov.ky\/portal\/page?_pageid=1142,1687439\u0026_dad=portal\u0026_schema=P...).","Disposition of Criminal Case(s)":"According to a 2002 decision by the Cayman Islands Grand Court, \u0022Following criminal proceedings in Chile, Davila was found guilty of, inter alia, fraud against the state and the crime of presentation of false documents in a criminal proceeding. The latter relates to his production of the fabricated Drexel Burnham documentation. Davila was sentenced to a total of eight years\u0027 imprisonment.\u0022","Jurisdiction of Origin: Investigative Agency":"[Congressional and criminal proceedings in Chile]","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Consejo de Defensa de Estado","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General; Ritchie \u0026 Duckworth (G.F. Ritchie, Charles Adams, representing CODELCO)","Jurisdiction of Asset Recovery: Courts Involved":"Grand Court","Documents":"","Sources ":"Corporacion Nacional del Cobre de Chile v. Interglobal Incorporated and Avendano Sabugao, 2002 CILR 298, Judgment dated May 23, 2002, accessed at http:\/\/www.caymanjudicial-legalinfo.com.ky\/judgments\/Cayman-Islands-Law-... \nDeutsch-Sudamerikanische Bank A.G. v. Corporacion Nacionale del Cobre de Chile and Attorney General, 1996 CILR 1, Judgment dated December 9th, 1995, accessed at http:\/\/www.caymanjudicial-legalinfo.ky\/Judgments\/Cayman-Islands-Law-Repo....  \nSee also Website of the Government of Cayman Islands \u0022Forfeiting Proceeds of Corruption,\u0022 last accessed on February 28, 2011, at http:\/\/www.gov.ky\/portal\/page?_pageid=1142,1687439\u0026_dad=portal\u0026_schema=P...\n"},{"Case ID":"ARW-45","Case Title (Name of Public Official or Entity Allegedly Involved)":"Daniel Arap Moi \/ Anglo-Leasing Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kenya","Position of Public Official(s) (yrs in office)":"President (1978-2002)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"2004","UNCAC Offenses Implicated":"Art.17, Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Other","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"According to a Kenyan government audit report, during the investigation by the Kenya Anti-Corruption Commission  into Anglo Leasing, some of the credit supplier companies involved voluntarily refunded the full amounts relating to their contracts without prompting or explanation:  (Source: \u0022Special Audit on Procurement of Passport Issuing Equipment By the Department of Immigration, Office of the Vice-President and Ministry of Home Affairs.\u0022 Report of the The Public Accounts Committee to the Kenyan National Assembly, Ninth Parliament - Fifth Session. March 2006. page 16ff.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$13,248,234","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to a Kenyan government audit report, during the investigation by the Kenya Anti-Corruption Commission (led by John Githongo) into Anglo Leasing, some of the credit supplier companies involved voluntarily refunded the full amounts relating to their contracts without prompting or explanation:  Leyland Export Ltd. returned $910,000 (from the Export Lease Purchase project); Anglo Leasing \u0026 Finance Ltd. returned $4,744,444 (from the Forensic Science Laboraties project) and EUR 956,700 (from the Immigration ISDCS project); Infotalent Ltd. returned EUR 5,287,164 (from the Kenyan Police Law and Order (E Cops) project).  The $4.7 million from Anglo Leasing was remitted by the Schroder and Co Bank AG of Zurich on behalf of its client, but Mr. Githongo commented that no one in the government knew who actually had sent the money.  (Source: \u0022Special Audit on Procurement of Passport Issuing Equipment By the Department of Immigration, Office of the Vice-President and Ministry of Home Affairs.\u0022 Report of the The Public Accounts Committee to the Kenyan National Assembly, Ninth Parliament - Fifth Session. March 2006. page 16ff.)","Disposition of Criminal Case(s)":"None","Jurisdiction of Origin: Investigative Agency":"Kenya Anti-Corruption Commission; Kenya National Assembly, Public Accounts Committee","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"High Court; Court of Appeal of Kenya at Nairobi","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"","Sources ":"Special Audit on Procurement of Passport Issuing Equipment By the Department of Immigration, Office of the Vice-President and Ministry of Home Affairs,\u0022 Report of the The Public Accounts Committee to the Kenyan National Assembly, Ninth Parliament - Fifth Session. March 2006, at 16ff, accessed at website of Transparency International Kenya, http:\/\/www.tikenya.org\/documents\/pac_report06.pdf; \nProfile of Daniel Toroitich arap Moi from the Official Website of State House, Kenya, accessed at http:\/\/www.statehousekenya.go.ke\/presidents\/moi\/profile.htm.\n"},{"Case ID":"ARW-46","Case Title (Name of Public Official or Entity Allegedly Involved)":"Daniel Arap Moi \/ Anglo-Leasing Case \/ First Mercantile Securities Corporation","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kenya","Position of Public Official(s) (yrs in office)":"President (1978-2002)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction; Domestic Criminal Investigation","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"Unknown Amounts Frozen","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"NA","Agreement for Returned Assets - Description":"NA","Case Summary":"In June 2014, the Office of the Attorney General of Switzerland announced that \u0022as part of its own criminal investigation into the Anglo Leasing case, [the OAG] has requested support from the Kenyan judicial authorities to obtain evidence of a possible predicate offence to money laundering.\nCompanies based in Switzerland are suspected of being involved in the Kenyan Anglo Leasing scandal and related assets are believed to have been moved to Switzerland. This is the starting point for the OAG\u0027s criminal proceedings against three suspects, which began in April 2009 following a report from the Money Laundering Reporting Office (MROS).\nSince then, the OAG has successfully identified and frozen several bank accounts in Switzerland. Financial transfers were assessed and the results of the comprehensive cash flow analysis of cross-border links led the OAG to request mutual legal assistance from various states. England, Scotland and Jersey have already provided the OAG with a considerable amount of useful information.\nThe OAG is now requesting Kenya for active mutual legal assistance in order to obtain evidence of the predicate offence committed outside Switzerland. The suspected predicate offence to money laundering is the alleged bribery of Kenyan public officials in return for the award of lucrative government contracts. The OAG has requested the transmission of evidence obtained in the course of the Kenyan criminal proceedings in the Anglo Leasing scandal. Assistance from the Kenyan judicial authorities is therefore essential and their contribution will be decisive to the success of the Swiss criminal investigation.\nThe OAG has previously granted mutual legal assistance to Kenya, providing the Kenya Anti-Corruption Commission with documents on Swiss links to the Anglo Leasing affair and on the associated funds that were identified in Switzerland (See OAG press release dated 20.09.2012: https:\/\/www.news.admin.ch\/message\/index.html?long=de\u0026msg-id=46040).\u0022 (Source: Switzerland, Office of the Attorney General Media Releases:  \u0022Anglo Leasing affair: Office of the Attorney General of Switzerland requests Kenya for mutual legal assistance,\u0022 June 20, 2014.)\nOn July 16, 2010, in the matter between the Kenya Anti-Corruption Commission and First Mercantile Securities Corporation, the Court of Appeal of Kenya at Nairobi set aside a ruling by the lower court which had permitted First Mercantile to have set aside the request for mutual legal assistance made by the anti-corruption agency to the Swiss authorities in connection with its investigation into the Anglo-Leasing scandal.  (Source: Between Kenya Anti-Corruption Commission and First Mercantile Securities Corporation, In H.C. Misc. C.C. No. 695 of 2007, Civil Appeal 194 of 2008, July 16, 2010).   As explained in the court\u0027s judgment, on July 22, 2002, the Government of Kenya entered into an US$811,787,000 agreement with First Mercantile Securities Corporation.  The Postal Corporation of Kenya had wanted to purchase telecommunications equipment from an American company, but neither the Government of Kenya or the Postal Corporation could immediately pay the $811 million in lump sum.  The court then writes \u0022But for some unexplained reason\u0022 instead of the Postal Corporation, the Government of Kenya entered into a contract with First Mercantile to finance the purchase.  The 2002 contract required the Government to make installment payments to First Mercantile.  In 2003, the Anti-Corruption and Economic Crimes Act came into force and established the Kenya Anti-Corruption Commission.  According to the Court, the Government of Kenya made payments to First Mercantile up to June 14, 2004, leaving an outstanding balance of US $5,936,910.09, when \u0022For some reason or reasons which we need not concern ourselves with the in the judgment, GOK [Government of Kenya] thereafter refused to pay any further instalments. We only need to point out that this agreement is one of those now notoriously referred to in Kenya as the Anglo-Leasing Scandal.  when it stopped the payments.\u0022  In December 2005, First Mercantile sued the Kenyan government for unpaid sums.  In May 2007, the Director of the Kenyan Anti-Corruption Commission sent a letter of request to the Federal Office of Justice and Police Section of Mutual Assistance in Criminal Matters, which stated that the Commission \u0022is investigating in the present case serious criminal offences which include breach of laws, procedures and regulations, corrupt transactions with agents, in which Government of Kenya officials acting on false and or fradulent information, awarded a contract for US$12.8 million.  About US$6.8 million was paid out to First Mercantile Securities Corporation, Tortala, Succursale de Geneva, a subsidiary of First Mercantile Securities Corporation, British Virgin Islands...to Swiss Bank Accounts which is the reason for the present request for MLA is make to Swiss Authorities.\u0022  A month after the request was made, the company filed suit in June 2007, in the High Court in Nairobi to seek an order to prohibit the Anti-Corruption Commission\u0027s mutual legal assistance request and to stay enforcement of the letter of request for assistance.  The High Court granted leave which also operated as a stay on the assistance request.   The Court of Appeals reversed, writing, in part, that the Anti-Corruption Commission is independent of the Government of Kenya and that it \u0022can investigate GOK [Government of Kenya] officials if they are suspected to have been involved in corrupt practices or to have committed economic crimes.\u0022  Moreover, it was up to the Swiss government to  agree to the request or not.  The Court stated that one of the grounds presented by the Commission as the basis for its mutual legal assistance request was that Kenya was a signatory to the United Nations Convention on Corruption.  The Court wrote, \u0022We have already held that the Appellant [Anti-Corruption Commission] was entitled to issue the LMA [Letter for Mutual Assistance]  under section 12(3) of its creating statute and we see no reason to go into the question on principles of international law.\u0022 (Source: Id.)","Disposition of Criminal Case(s)":"None","Jurisdiction of Origin: Investigative Agency":"Kenya Anti-Corruption Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Kenya Anti-Corruption Commission","Jurisdiction of Origin: Courts Involved":"High Court of Nairobi; Court of Appeal of Kenya at Nairobi","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Office of Justice and Police, Section of Mutual Assistance in Criminal Matters","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Office of the Attorney General of Switzerland","Jurisdiction of Asset Recovery: Courts Involved":"NA","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Moi_Profile_Statehousekenya_Gov_Apr_29_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Moi_Special_Audit_Security_Projects_Mar_2006.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Anglo_Leasing_Switzerland_OAG_MLA_Request_to_Kenya_Jun_20_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Moi_Profile_Statehousekenya_Gov_Apr_29_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Moi_Special_Audit_Security_Projects_Mar_2006.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Anglo_Leasing_Switzerland_Dossiers_to_Kenya_Sep_20_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Moi_Profile_Statehousekenya_Gov_Apr_29_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Moi_Special_Audit_Security_Projects_Mar_2006.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Anglo_Leasing_Special_Audit_Security_Projects_Mar_2006.pdf","Sources ":"Between Kenya Anti-Corruption Commission and First Mercantile Securities Corporation, In H.C. Misc. C.C. No. 695 of 2007, Civil Appeal 194 of 2008, Court of Appeal of Kenya at Nairobi (July 16, 2010), accessed at http:\/\/kenyalaw.org\/Downloads_FreeCases\/76031.pdf; Profile of Daniel Toroitich arap Moi from the Official Website of State House, Kenya, accessed at http:\/\/www.statehousekenya.go.ke\/presidents\/moi\/profile.htm.\nSwitzerland, Office of the Attorney General Media Releases:  \u0022Anglo Leasing affair: Office of the Attorney General of Switzerland requests Kenya for mutual legal assistance,\u0022 June 20, 2014, at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=53434 and \u0022Further legal assistance dossiers handed over to Kenya,\u0022 September 20, 2012, at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026long=de\u0026msg-id=46040\n"},{"Case ID":"ARW-47","Case Title (Name of Public Official or Entity Allegedly Involved)":"Daniel Arap Moi \/ World Duty Free Company Limited","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kenya","Position of Public Official(s) (yrs in office)":"President (1978-2002)","Jurisdiction of Asset Recovery":"International Centre for Settlement of Investment Disputes, Washington, D.C.","Jurisdiction of Asset Description":"Location of Recovery Effort","Asset Recovery Start":"1998","Asset Recovery End":"2006","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Other ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"The Article 9(2)(c) of the Agreement of 27th April 1989 provided that any arbitration shall apply English law while Article 10(A) provided that the Agreement shall be governed by Kenyan law.  The Tribunal noted that the provisions were \u0022perhaps awkwardly worded.  for present purposes, however, no practical difficulty arises from their apparent inconsistency,\u0022 in voiding the contract under both English and Kenyan laws and public policy.  (Award of September 25, 2006, at 49).  The Tribunal also held that \u0022Mr. Ali\u0027s payment was received corruptly by the Kenyan head of state; it was a covert bribe; and accordingly its receipt is not legally to be imputed to Kenya itself.\u0022 (Award of September 25, 2006, at 54).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"Avoidance of monetary damages in commercial arbitration case filed against Government of Kenya","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to the December 2010 Asset Recovery Handbook by the Stolen Asset Recovery Initiative, \u0022In 1989, Kenya initially entered into an agreement with World Duty Free Company (WDF) for construction, maintenance, and operation of duty-free complexes at Nairobi and Mombasa international airports.  In obtaining the contract, WDF paid bribes to the former Kenyan president, Daniel arap Moi. Subsequently, in 1998, WDF was placed under receivership by the High Court in Kenya; and a formal judgment and decree was made in 2001, transferring beneficial ownership to the receiver.  In disputing the order before the ICSID, WDF claimed that Kenya had unlawfully destroyed its contractual rights through the receivership order. The government of Kenya argued that WDF\u0027s procurement of the agreement through bribes was a breach of English and Kenyan laws applicable to the contract, as well as breach of international public policy, and that the government was lawfully entitled to avoid contract obligations.\u0022 (Source:  Asset Recovery Handbook (Stolen Asset Recovery Initiative, December 2010) at 167).  The Arbitration Tribunal noted that \u0022former President of Kenya, Mr. Daniel arap Moi, was not a party to these arbitration proceedings and was not legally represented in these proceedings.  He was not heard as a witness... The Tribunal decided on the dispute submitted to it on the evidence adduced and the submissions made by the parties to the case.\u0022  (Source: In the Proceeding Between World Duty Free Company Limited and The Republic of Kenya, ICSID Case No. ARB\/00\/7, Award of September 25, 2006.)   World Duty Free Company Limited, a company incorporated in the Isle of Man, had requested the arbitration on June 16, 2000.  The request was registered by the ICSID purusant to Article 36(3) of the ICSID Convention on the Settlement of Investment Disputes between States and Nationals of Other States.   World Duty Free was managed by Mr. Nasir Ibrahim Ali; in 1991, the Al-Ghurair family which had owned WDF sold its shares and as a result, Mr. Ali held in his own name 10% of the World Duty Free shares and 90% of the stock was registered in the name of Dinky International SA, whose shareholders were Mr. Ali at 90% and rest owned by his wife.  Mr. Ali\u0027s $2 million payment to then President Moi is described in his written statement to the Tribunal (Award of September 25, 2006, at 37-38.)  The Tribunal wrote, \u0022It remains nonetheless a highly disturbing feature in this case that the corrupt recipient of the Claimant\u0027s bribe was more than an officer of the State but its most senior officer, the Kenyan President; and that it is Kenya which is here advancing as a complete defence to the Claimant\u0027s [World Duty Free\u0027s] claims the illegalities of its own former President.  Moreover, on the evidence before this Tribunal, the bribe was apparently solicited by the Kenyan President and not wholly initiated by the Claimant.  Although the Kenyan President has now left office and is no longer immune from suit under the Kenyan Constitution, it appears that no attempt has been made by Kenya to prosecute him for corruption or to recover the bribe in civil proceedings.\u0022 (Award of September 25, 2006, at 59.)","Disposition of Criminal Case(s)":"None","Jurisdiction of Origin: Investigative Agency":"Kenyan Anti-Corruption Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Kenyan Anti-Corruption Commission","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Government of Kenya represented at proceedings by: Attorney General of Kenya, Counsel from law firm of Freshfields Bruckhaus Deringer, Director of Public Prosecutions, Senior Assistant Commissioner Police of Kenya","Jurisdiction of Asset Recovery: Courts Involved":"International Centre for Settlement of Investment Disputes (Washington, D.C.)","Documents":"","Sources ":"World Duty-Free Company Limited v. The Republic of Kenya, ICSID Case No. ARB\/00\/7, Award of September 25, 2006, accessed at http:\/\/ita.law.uvic.ca\/documents\/WDFv.KenyaAward.pdf;  \nJean-Pierre Brun, Larissa Gray, Clive Scott and Kevin M. Stephenson, Asset Recovery Handbook: A Guide for Practitioners (Stolen Asset Recovery Initiative, December 2010), \u0022Box 8.5: World Duty Free Company Limited v. The Republic of Kenya,\u0022 at 167.  \nSee also, \u0022World Duty Free v The Republic of Kenya: a Unique Precedent?,\u0022 Summary of Chatham House International Law Discussion Group meeting, March 28, 2007, with main speaker Constantine Partasides, Partner, International Arbitration Group, Freshfields Bruckhaus Deringer who represented Government of Kenya in the arbitration proceedings, accessed at http:\/\/www.chathamhouse.org.uk\/files\/9129_il280307.pdf; \nProfile of Daniel Toroitich arap Moi from the Official Website of State House, Kenya, accessed at http:\/\/www.statehousekenya.go.ke\/presidents\/moi\/profile.htm.\n"},{"Case ID":"ARW-49","Case Title (Name of Public Official or Entity Allegedly Involved)":"Denis Sassou Nguesso","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Congo, Republic of","Position of Public Official(s) (yrs in office)":"President (1979-1992 and 1997-present)","Jurisdiction of Asset Recovery":"France","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2007","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"[Ongoing Case, but Transparency International stated that this is the first time French courts allowed such a complaint by nongovernmental organizations to proceed. Source: Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision: The complaint filed by Transparency International France is ruled admissible,\u0022 November 9, 2010.]","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"In November 2010, the French Supreme Court held that the complaint filed by Transparency International France  and SHERPA against Mr. Sassou Nguesso may proceed.  The organizations had filed their \u0022Biens Mal Acquis\u0022 (Improperly acquired property) complaint against Omar Bongo, Denis Sassou Nguesso and Teodoro Obiang and their relatives.  With regard to Mr. Sassou Nguesso and his relatives, the complaint alleged that they had acquired real estate, including 18 properties, one hundred and twelve bank accounts and fleet of automobiles including at least one vehicle estimated to be worth EUR 172,321.  (Source: Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision, The complaint by Transparence International France is ruled admissible,\u0022 November 9, 2010.)","Disposition of Criminal Case(s)":"In November 2010, the French Supreme Court held that the complaint (\u0022Biens Mal Acquis\u0022\/Improperly Acquired Property) filed by Transparency International France and SHERPA against Mr. Sassou Nguesso may proceed.  (Sources: Supreme Court of France, Case No. 6092, decision of November 9, 2010, L\u0027association Transparence International France, partie civile, reversing High Court of Paris, section 2, judgment of October 29, 2009; Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision, The complaint by Transparence International France is ruled admissible,\u0022 November 9, 2010.)","Jurisdiction of Origin: Investigative Agency":"NA","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Transparency International France, SHERPA (civil complaint)","Jurisdiction of Asset Recovery: Courts Involved":"La Cour de Cassation, Chambre Criminelle (Supreme Court)","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sassou_Nguesso_France_SCt_Nov_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sassou_Nguesso_Transparency_Intl_PR_Nov_9_2010.docx, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sassou_Nguesso_US_DOS_Congo_Profile_Dec_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Sassou_Nguesso_France_%20Mediapart_Oct_11_2013.pdf","Sources ":"Supreme Court of France, Case No. 6092, decision of November 9, 2010, L\u0027association Transparence International France, partie civile, reversing High Court of Paris, section 2, judgment of October 29, 2009. See also Transparency International Press Release, \u0022\u0027Biens Mal Acquis\u0027 Case: French Supreme Court Overrules Court of Appeal\u0027s Decision, The complaint by Transparence International France is ruled admissible,\u0022 November 9, 2010, posted at http:\/\/www.transparency.org\/news_room\/latest_news\/press_releases_nc\/2010... US Department of State, Background Note: Republic of the Congo (December 2010), accessed at http:\/\/www.state.gov\/r\/pa\/ei\/bgn\/2825.htm; Mediapart, \u0022A Paris, le shopping de la corruption du clan Sassou Nguesso,\u0022 October 11, 2013, at http:\/\/www.mediapart.fr\/journal\/international\/101013\/paris-le-shopping-d...\n"},{"Case ID":"ARW-50","Case Title (Name of Public Official or Entity Allegedly Involved)":"Diepreye Alamieyeseigha (Cyprus)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Governor (1999-2005)","Jurisdiction of Asset Recovery":"Cyprus","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Nigeria\u0027s lawyers in the civil case carried out the enforcement of the judgment in Cyprus. (Source: StAR Case Study, attached PDF)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"Nigeria brought a civil suit against Santolina Investment Corporation, an entity that was the purported owner of properties purchased with Mr. Alamieyeseigha\u0027s criminal proceeds and in relation to approximately GBP 1 million on deposit in Cyprus (as of the date of EWHC judgment in related case on December 1, 2007, equivalent of U.S. $2,062,470). According to a case study by the Stolen Asset Recovery (StAR) Initiative, a July 2008 judgment by a United Kingdom court led to the confiscation of assets in the United Kingdom, Cyprus and Denmark. Nigeria\u0027s lawyers in the civil case carried out the enforcement of the judgment in Cyprus. (Source: StAR Case Study, accessed at http:\/\/www1.worldbank.org\/publicsector\/star_site\/documents\/Case_Studies_....)","Disposition of Criminal Case(s)":"According to the December 3, 2007 UK High Court decision in Nigeria v. Santolina Investment Corp and Ors, Mr. Alamieyeseigha entered a guilty plea in Nigeria\u0027s High Court to six counts of making false declaration of assets. According to the same judgment, Mr. Alamieyeseigha was arrested at Heathrow Airport in September 2005 by officers of the Metropolitan Police and initially remanded but later granted bail. In breach of his bail requirements, he left UK and returned to Nigeria in November 2005. (Source: Nigeria v. Santolina Investment Corp and Ors, [2007] EWHC 3053 (Q.B.)) \u00a0In March 2013, he was pardoned in Nigeria. (Source: \u00a0BBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013.)","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Courts Involved":"Federal High Court (Lagos)","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Edwards Angell Palmer \u0026 Dodge LLP (James Maton, Tim Daniel)","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC_3053 (QB).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Case_Study.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_Pardon_BBC_News_Mar_13_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC_3053 (QB).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Case_Study.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_StAR_Case_Study_0.pdf","Sources ":"\n\tStolen Asset Recovery (StAR) Initiative Case Study, \u0022Diepreye Alamieyeseigha\u0022 (attached PDF); Republic of Nigeria v. Santolina \u0026 Ors, [2007] EWHC 3053 (QB), Judgment dated December 3, 2007.\n\n\t\u00a0\n\n\tBBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013, at http:\/\/www.bbc.com\/news\/world-africa-21769047.\n"},{"Case ID":"ARW-51","Case Title (Name of Public Official or Entity Allegedly Involved)":"Diepreye Alamieyeseigha (Denmark)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Governor (1999-2005)","Jurisdiction of Asset Recovery":"Denmark","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2007","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.15, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Nigeria\u0027s lawyers in the civil case carried out the enforcement of the judgment in Denmark. (Source: StAR Case Study, attached PDF)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"Nigeria brought a civil suit against Santolina Investment Corporation, an entity that was the purported owner of properties purchased with Mr. Alamieyeseigha\u0027s criminal proceeds and in relation to approximately GBP 1 million on deposit in Cyprus (as of the date of EWHC judgment in related case on December 1, 2007, equivalent of U.S. $2,062,470). According to a case study by the Stolen Asset Recovery (StAR) Initiative, a July 2008 judgment by a United Kingdom court led to the confiscation of assets in the United Kingdom, Cyprus and Denmark. Nigeria\u0027s lawyers in the civil case carried out the enforcement of the judgment in Denmark. (Source: StAR Case Study, accessed at http:\/\/www1.worldbank.org\/publicsector\/star_site\/documents\/Case_Studies_....)","Disposition of Criminal Case(s)":"According to the December 3, 2007 UK High Court decision in Nigeria v. Santolina Investment Corp and Ors, Mr. Alamieyeseigha entered a guilty plea in Nigeria\u0027s High Court to six counts of making false declaration of assets. According to the same judgment, Mr. Alamieyeseigha was arrested at Heathrow Airport in September 2005 by officers of the Metropolitan Police and initially remanded but later granted bail. In breach of his bail requirements, he left UK and returned to Nigeria in November 2005. (Source: Nigeria v. Santolina Investment Corp and Ors, [2007] EWHC 3053 (Q.B.)) \u00a0In March 2013, he was pardoned in Nigeria. (Source: \u00a0BBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013.)","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Courts Involved":"Federal High Court (Lagos)","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Edwards Angell Palmer \u0026 Dodge LLP (James Maton, Tim Daniel)","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC_3053 (QB).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Case_Study.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_Pardon_BBC_News_Mar_13_2013_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC_3053 (QB).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Case_Study.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_StAR_Case_Study.pdf","Sources ":"\n\tStolen Asset Recovery (StAR) Initiative Case Study, \u0022Diepreye Alamieyeseigha,\u0022 (attached PDF); Republic of Nigeria v. Santolina \u0026 Ors, [2007] EWHC 3053 (QB), Judgment dated December 3, 2007.\n\n\t\u00a0\n\n\tBBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013, at http:\/\/www.bbc.com\/news\/world-africa-21769047.\n"},{"Case ID":"ARW-52","Case Title (Name of Public Official or Entity Allegedly Involved)":"Diepreye Alamieyeseigha (South Africa)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Governor (1999-2005)","Jurisdiction of Asset Recovery":"South Africa","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2005","Asset Recovery End":"2007","UNCAC Offenses Implicated":"Art.15, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"The use by South Africa\u0027s Asset Forfeiture Unit of non-conviction based confiscation proceedings allowed the authorities to seize property by demonstration of the illegal origin of the funds used to acquire it, but before the criminal prosecution concluded in Nigeria. (Source: StAR Case Study, \u0022Diepreye Alamieyeseigha\u0022).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"In February 2006, the Asset Forfeiture Unit of the National Prosecuting Authority of South Africa secured a court order to freeze a residential property belonging to Mr. Alamieyeseigha on the Cape Town waterfront. An application to freeze, first the rental income from the apartment and later his interest in the apartments themselves, was successful. United Kingdom\u0027s High Court also notes that (Mr. Alamieyeseigha\u0027s corporate vehicle) Santolina Investment Corporation\u0027s bank statements from the \u0022principal Royal Bank of Scotland account where a sum of GBP949,000 was paid out, apparently to acquire a property.\u0022 (Sources: Stolen Asset Recovery (StAR) Initiative Case Study, \u0022Diepreye Alamieyeseigha.\u0022 Republic of Nigeria v. Santolina \u0026 Ors., [2007] EWHC 3053 (QB), Judgment dated December 3, 2007). Funds were returned to Nigeria following the sale of the property in January 2007.\u00a0 According to an article by attorneys Tim Daniel and James Maton, who had represented Nigeria in the UK civil proceedings, \u0022Nigeria successfully intervened in the proceeding seeking an order for the return of the proceeds of sale.\u0022\u00a0 (Source: James Maton and Tim Daniel, \u0022The Kleptocrat\u0027s Portfolio Decisions,\u0022 in Draining Development? Controlling Flows of Illicit Funds from Developing Countries, Peter Reuter, ed., (The World Bank, 2012) at 433-434.)","Disposition of Criminal Case(s)":"According to the December 3, 2007 UK High Court decision in Nigeria v. Santolina Investment Corp and Ors, Mr. Alamieyeseigha entered a guilty plea in Nigeria\u0027s High Court to six counts of making false declaration of assets. According to the same judgment, Mr. Alamieyeseigha was arrested at Heathrow Airport in September 2005 by officers of the Metropolitan Police and initially remanded but later granted bail. In breach of his bail requirements, he left UK and returned to Nigeria in November 2005. (Source: Nigeria v. Santolina Investment Corp and Ors, [2007] EWHC 3053 (Q.B.)) \u00a0In March 2013, he was pardoned in Nigeria. (Source: \u00a0BBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013.)","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Courts Involved":"Federal High Court (Lagos)","Jurisdiction of Asset Recovery: Investigative Agency":"The National Prosecuting Authority of South Africa, Asset Forfeiture Unit","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"The National Prosecuting Authority of South Africa, Asset Forfeiture Unit; Edwards Angell Palmer \u0026 Dodge LLP (James Maton, Tim Daniel)","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC_3053 (QB).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Case_Study.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_Pardon_BBC_News_Mar_13_2013_1.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC_3053 (QB).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Case_Study.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_StAR_Case_Study_1.pdf","Sources ":"\n\tRepublic of Nigeria v. Santolina \u0026 Ors., [2007] EWHC 3053 (QB), Judgment dated December 3, 2007; Stolen Asset Recovery (StAR) Initiative Case Study, \u0022Diepreye Alamieyeseigha\u0022 (attached PDF).\u00a0\n\n\t\u00a0\n\n\tJames Maton and Tim Daniel, \u0022The Kleptocrat\u0027s Portfolio Decisions,\u0022 in Draining Development? Controlling Flows of Illicit Funds from Developing Countries, Peter Reuter, ed., (The World Bank, 2012) at 433-434.\n\n\t\u00a0\n\n\tBBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013, at http:\/\/www.bbc.com\/news\/world-africa-21769047.\n"},{"Case ID":"ARW-54","Case Title (Name of Public Official or Entity Allegedly Involved)":"Diepreye Alamieyeseigha (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Governor (1999-2005)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2005","Asset Recovery End":"2010","UNCAC Offenses Implicated":"Art.15, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Administrative Confiscation; Private Civil Action; Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Effective cooperation between Nigerian and United Kingdom authorities (Nigeria\u0027s Economic and Financial Crimes Commission, United Kingdom\u0027s London Metropolitan Police (Source: Stolen Asset Recovery (StAR) initiative Case Study, \u0022Diepreye Alamieyeseigha\u0022; United Kingdom court\u0027s denial of Mr. Alamieyeseigha\u0027s petition of immunity as state governor, a ruling upheld by the High Court (Source: R on the application of Diepreye Solomon Peter Alamieyeseigha v. CPS [2005] EWHC 2704 (Admin).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to a case study by the Stolen Asset Recovery Initiative, the recovery in the case consisted of (1) $1.5 million in cash seized at the time of arrest and (2) $2.7 million held in bank accounts [Royal Bank of Scotland PLC, Santolina Investment Corporation account in excess of GBP 1.8 million] and London real estate worth $15 million [4 properties registered under Solomon \u0026 Peters Ltd. as sole proprietor]. In May 2006, a London court ordered confiscation of the seized cash pursuant to the Proceeds of Crime Act, after Mr. Alamieyeseigha skipped bail and returned to Nigeria; bank accounts and London real estate were confiscated pursuant to a December 2007 United Kingdom High Court summary judgment; and a July 2008 judgment left to confiscation of remaining assets in the United Kingdom, Denmark and Cyprus. Pursuant to his July 2007 plea in Nigerian High Court, he was sentenced to a two-year prison term and his assets in Nigeria were ordered seized. (Source: StAR Case Study, \u0022Diepreye Alamieyeseigha\u0022).","Disposition of Criminal Case(s)":"According to the December 3, 2007 UK High Court decision in Nigeria v. Santolina Investment Corp and Ors, Mr. Alamieyeseigha entered a guilty plea in Nigeria\u0027s High Court to six counts of making false declaration of assets. \u00a0According to the same judgment, Mr. Alamieyeseigha was arrested at Heathrow Airport in September 2005 by officers of the Metropolitan Police and initially remanded but later granted bail. \u00a0In breach of his bail requirements, he left UK and returned to Nigeria in November 2005. \u00a0(Source: Nigeria v. Santolina Investment Corp and Ors, [2007] EWHC 3053 (Q.B.)) \u00a0In March 2013, he was pardoned in Nigeria. (Source: \u00a0BBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013.)","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Courts Involved":"Federal High Court (Lagos)","Jurisdiction of Asset Recovery: Investigative Agency":"London Metropolitan Police, Proceeds of Corruption Unit","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service; Edwards Angell Palmer \u0026 Dodge LLP (James Maton, Tim Daniel)","Jurisdiction of Asset Recovery: Courts Involved":"England and Wales High Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2005_EWHC_2704 (Admin).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC 437 (Ch).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC_3053 (QB).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Case_Study.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Handbook.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Transparency_Intl_UK_Recovering_Looted_Gains_June_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_Pardon_BBC_News_Mar_13_2013_2.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2005_EWHC_2704 (Admin).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC 437 (Ch).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_2007_EWHC_3053 (QB).rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Case_Study.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_StAR_Handbook.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Transparency_Intl_UK_Recovering_Looted_Gains_June_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_StAR_Case_Study_2.pdf","Sources ":"\n\tJean-Pierre Brun, Larissa Gray, Clive Scott, and Kevin M. Stephenson, Asset Recovery Handbook: A Guide for Practitioners, (StAR Initiative, December 2010), \u00221.3.3 Case of Diepreye Alamieyeseigha,\u0022 at 17-18, \u00a0accessed at \u00a0http:\/\/star.worldbank.org\/star\/publication\/asset-recovery-handbook; R on the application of Diepreye Solomon Peter Alamieyeseigha v. CPS [2005] EWHC 2704 (Admin) [UK High Court ruling upholding the Crown Court\u0027s denial of Alamieyeseigha petition on immunity]; Federal Republic of Nigeria v. Santolina Investment Corporation and Others [2007] EWHC 437 (Ch) and [2007] EWHC 3053 (QB). See also Transparency International UK, \u0022Combating Money Laundering and Recovering Looted Gains: Raising the UK\u0027s Game,\u0022 June 2009.\u00a0\n\n\t\u00a0\n\n\tBBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013, at http:\/\/www.bbc.com\/news\/world-africa-21769047.\n"},{"Case ID":"ARW-55","Case Title (Name of Public Official or Entity Allegedly Involved)":"Diepreye Alamieyeseigha (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Governor (1999-2005)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Both actions brought through the US Department of Justice\u0027s Kleptocracy Asset Recovery Initiative","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"Value of Massachusetts account and estimated value of Maryland house","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"\n\tThe United States obtained Default Judgments in Maryland (house valued at over $700,000) and in Massachusetts against approximately $400,000 in a Fidelity investment account. (Sources: US v. Real Property titled in the name of Solomon \u0026 Peters, located at 504 Pleasant Drive..., Case No. 8:11-cv-00662-RWT (D. Md.), Default Judgment of May 24, 2013; US v. The Contents of Account Number Z44-343021, Case No. 1:11-cv-10606-RWZ (D. Mass.), Order Final Judgment and Forfeiture filed June 13, 2012). \u00a0The forfeiture actions had been brought under the Justice Department\u0027s Kleptocracy Asset Recovery Initiative. \u00a0(Source: \u00a0U.S. Department of Justice, \u0022Assistant Attorney General Lanny A. Bruer of the Criminal Divison Speaks at the Franz-Hermann Bruner Memorial Lecture at the World Bank,\u0022 May 25, 2011.) \u00a0\u00a0\n\n\t\u00a0\n\n\tAccording to the complaint in the case, the residence\u0027s owner of record is Solomon \u0026 Peters, Ltd. a now defunct company incorporated in the British Virgin Islands. (Source: US v. Real Property titled in the name of Solomon \u0026 Peters, located at 504 Pleasant Drive..., Case No. 8:11-cv-00662-RWT (D. Md.), Verified Complaint for Forfeiture filed March 11, 2011.)\n\n\t\u00a0\n\n\tAccording to a June 13, 2012 Order for Final Judgment and Forfeiture issued by the US federal court in Massachusetts, \u0022The contents of account number Z44-343021 held at Fidelity Brokerage Services, LLC., Boston, Massachusetts, in the name of Nicholas Aiyegbemi d\/b\/a\/ Inadinov and Co. OAO, which account is believed to contain approximately $386,080, and all assets traceable thereto,\u0022 were forfeited to the United States after all those parties with potential claims to the funds were notified but did not respond. \u00a0(Source: US v. The Contents of Account Number Z44-343021, Case No. 1:11-cv-10606-RWZ (D. Mass.), Order Final Judgment and Forfeiture filed June 13, 2012; \u00a0Verified Complaint for Forfeiture In Rem filed April 8, 2011.)\u00a0\u00a0","Disposition of Criminal Case(s)":"According to the December 3, 2007 UK High Court decision in Nigeria v. Santolina Investment Corp and Ors, Mr. Alamieyeseigha entered a guilty plea in Nigeria\u0027s High Court to six counts of making false declaration of assets. \u00a0According to the same judgment, Mr. Alamieyeseigha was arrested at Heathrow Airport in September 2005 by officers of the Metropolitan Police and initially remanded but later granted bail. \u00a0In breach of his bail requirements, he left UK and returned to Nigeria in November 2005. \u00a0(Source: Nigeria v. Santolina Investment Corp and Ors, [2007] EWHC 3053 (Q.B.)) \u00a0In March 2013, he was pardoned in Nigeria. (Source: \u00a0BBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013.)","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Courts Involved":"Federal High Court (Lagos)","Jurisdiction of Asset Recovery: Investigative Agency":"Homeland Security Investigation\u2019s Asset Identification \u0026 Removal Group (AIRG) in Baltimore, Immigration and Customs Enforcement","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section; United States Attorney\u0027s Office for the District of Maryland","Jurisdiction of Asset Recovery: Courts Involved":"District Court for the District of Maryland; District Court for the District of Massachusetts","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_US_DOJ_Lanny_Breuer_Speech_at_World_Bank_May_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_MD_Complaint_8-11-cv-00662-RWT_March_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_MD_Court_Docket_Report_Oct_26_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_Mass_Complaint_1-11-cv-10606-RWZ_April_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_Mass_Docket_Report_Oct_26_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_MD_Forfeit_DOJ_PR_May_31_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_US_DOJ_Lanny_Breuer_Speech_at_World_Bank_May_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_MD_Complaint_8-11-cv-00662-RWT_March_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_MD_Court_Docket_Report_Oct_26_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_Mass_Complaint_1-11-cv-10606-RWZ_April_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_Mass_Docket_Report_Oct_26_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_US_MD_Decree_Forfeiture_May_24_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_US_DOJ_Lanny_Breuer_Speech_at_World_Bank_May_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_MD_Complaint_8-11-cv-00662-RWT_March_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_MD_Court_Docket_Report_Oct_26_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_Mass_Complaint_1-11-cv-10606-RWZ_April_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alamieyeseigha_Mass_Docket_Report_Oct_26_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alamieyeseigha_Pardon_BBC_News_Mar_13_2013_3.pdf","Sources ":"\n\n\t\tUS Department of Justice press release, \u0022Rockville, Md., Property Purchased with Nigerian Corruption Proceeds Forfeited Through Justice Department\u2019s Kleptocracy Initiative,\u0022 May 31, 2013, at http:\/\/www.justice.gov\/opa\/pr\/2013\/May\/13-crm-628.html; U.S. Department of Justice, \u0022Assistant Attorney General Lanny A. Bruer of the Criminal Divison Speaks at the Franz-Hermann Bruner Memorial Lecture at the World Bank,\u0022 May 25, 2011, accessed at http:\/\/www.justice.gov\/criminal\/pr\/speeches\/2011\/crm-speech-110525.html;\u00a0\n\n\t\t\u00a0\n\n\t\tUS v. Real Property titled in the name of Solomon \u0026 Peters, located at 504 Pleasant Drive..., Case No. 8:11-cv-00662-RWT (D. Md.), Verified Complaint for Forfeiture filed March 11, 2011; \u00a0Default judgment of May 24, 2013;\u00a0\n\n\t\t\u00a0\n\n\t\tUS v. The Contents of Account Number Z44-343021, Case No. 1:11-cv-10606-RWZ (D. Mass.), Verified Complaint for Forfeiture In Rem filed April 8, 2011 and Order of Final Judgment and Forfeiture, filed June 13, 2012. \u00a0\n\n\t\t\u00a0\n\n\t\tBBC News, \u0022Nigeria pardons Goodluck Jonathan ally, Alamieyeseigha,\u0022 March 13, 2013, at http:\/\/www.bbc.com\/news\/world-africa-21769047.\n\n\u00a0\n"},{"Case ID":"ARW-57","Case Title (Name of Public Official or Entity Allegedly Involved)":"Edemar Cid Ferreira\/ Banco Santos, S.A. Art Repatriation Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Brazil","Position of Public Official(s) (yrs in office)":"Founder and Former President of Banco Santos (unspecified-2006)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2007","Asset Recovery End":"","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT; Letter of Request","Basis for Intl Cooperation":"Treaty between the United States and Brazil on Mutual Legal Assistance in Criminal Matters; Letter of Request (INTERPOL)","Contributing Factors in Asset Recovery":"The U.S. Attorney for the Southern District of New York thanked the Brazilian authorities for their assistance with the investigation.    (Source: U.S. Attorney for the Southern District of New York Press Release, \u0022Manhattan U.S. Attorney Returns Two Paintings Linked to Bank Fraud to Brazilian Government,\u0022 September 21, 2010.)","Status of Asset Recovery ":"Completed (in part) and Ongoing (in part)","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$4,000,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to the September 21, 2010 press release by the U.S. Attorney for the Southern District of New York, two paintings appraised at more than $4 million were repatriated to Brazil. \u00a0The paintings had once belonged to Mr. Ferrerira, and as part of the investigations into his case, the 6th Federal Criminal Court Specialized in Crimes Against the National Financial System and Money Laundering of Sao Paulo\/SP also ordered the search, seizure and confiscation of assets that Mr. Ferrerira, his associates and members of his family acquired with unlawfully obtained funds from Banco Santos. \u00a0The assets included the artwork which had been smuggled into the United States. \u00a0In 2007, Sao Paulo sought INTERPOL\u0027s assistance, and INTERPOL and the Government of Brazil sought the assistance by the United States. \u00a0The U.S. Immigration and Customs Enforcement located and seized the artworks, and in 2008, the U.S. filed the civil asset forfeiture complaint. \u00a0 Two artworks -- Liechtenstein\u0027s \u0022Modern Painting with Yellow Interweave\u0022 and Joaquin Torres-Garcia\u0027s \u0022Figures dans une structure\u0022 -- were forfeited to the U.S. on August 16, 2010 and July 16, 2010, respectively. \u00a0Other artworks -- Jean Michel Basquiat\u0027s \u0022Hannibal\u0022 valued at about $8 million and a sculpture known as the \u0022Roman Togatus\u0022 -- have also been forfeited to the U.S. An appeal is pending. (Source: US v. The painting known as \u0022Hannibal\u0022 et al, Case No. 1:08-cv-01511-RJS (S.D.N.Y.), Order of Forfeiture filed May 10, 2013 and Order filed September 17, 2013.) \u00a0The Default Judgment as to the Liechtenstein (US v. The Painting Known as \u0022Hannibal,\u0022 et al, Case No. 1:08-cv-01511-RJS (S.D.N.Y.), filed August 16, 2010.) \u00a0In May 2014, the US Immigration and Customs Enforcement (ICE) announced the repatriation of the Poliakoff painting to Brazil. (Source: ICE, \u0022ICE returns masterpiece linked to bank fraud to Brazilian government,\u0022 May 9, 2014.)\u00a0","Disposition of Criminal Case(s)":"According to the February 13, 2008 Verified Complaint filed in U.S. District Court for the Southern District of New York, Mr. Ferreira was sentenced in December 2006 by the 6th Federal Criminal Court Specialized in Crimes Against the National Financial System and Money Laundering of Sao Paulo\/SP to 21 years\u0027 imprisonment for crimes against the national financial system and money laundering,  (Source: US v. The Painting Known as \u0022Hannibal\u0022 by Jean-Michel Basquiat, Case No. 1:08-cv-01511-RJS (S.D.N.Y.), Verified Complaint filed on February 13, 2008.)","Jurisdiction of Origin: Investigative Agency":"Federal Police","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"State Prosecutor   ","Jurisdiction of Origin: Courts Involved":"6th Federal Criminal Court Specialized in Crimes Against the National Financial System and Money Laundering of Sao Paulo\/SP","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Immigration and Customs Enforcement, Cultural Property Art and Antiquities Unit; INTERPOL","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Southern District of New York, Asset Forfeiture Unit","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_SDNY_PR_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_Two_Paintings_Returned_SDNY_PR_Sept_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferreira_SDNY_Complaint_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Liechtenstein_Painting_SDNY_Default_Judgment_Aug_16_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/US-v_Broadening_Info_Second_Circuit_Appeal_Case_Summary_Nov_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ferreira_Liechenstein_Painting_Default_Judgment_Aug_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_SDNY_PR_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_Two_Paintings_Returned_SDNY_PR_Sept_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferreira_SDNY_Complaint_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Liechtenstein_Painting_SDNY_Default_Judgment_Aug_16_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/US-v_Broadening_Info_Second_Circuit_Appeal_Case_Summary_Nov_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/US-v_Broadening_Info_Second_Circuit_Appeal_Case_Summary_Nov_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_SDNY_PR_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_Two_Paintings_Returned_SDNY_PR_Sept_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferreira_SDNY_Complaint_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Liechtenstein_Painting_SDNY_Default_Judgment_Aug_16_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/US-v_Broadening_Info_Second_Circuit_Appeal_Case_Summary_Nov_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ferreira_US_Forfeiture_Order_May_10_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_SDNY_PR_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_Two_Paintings_Returned_SDNY_PR_Sept_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferreira_SDNY_Complaint_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Liechtenstein_Painting_SDNY_Default_Judgment_Aug_16_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/US-v_Broadening_Info_Second_Circuit_Appeal_Case_Summary_Nov_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ferreira_US_Forfeit_Order_Case_Close_Sep_17_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_SDNY_PR_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferrerira_Two_Paintings_Returned_SDNY_PR_Sept_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ferreira_SDNY_Complaint_Feb_13_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Liechtenstein_Painting_SDNY_Default_Judgment_Aug_16_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/US-v_Broadening_Info_Second_Circuit_Appeal_Case_Summary_Nov_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ferreira_ICE_Painting_Return_Brazil_May_9_2014.pdf","Sources ":"\n\tU.S. Attorney for the Southern District of New York Press Releases, \u0022Manhattan U.S. Attorney Returns Two Paintings Linked to Bank Fraud to Brazilian Government,\u0022 September 21, 2010, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/September10\/brazilrepatria... and \u0022United States Files Action to Forfeit Basquiat Painting \u0022Hannibal\u0022 Valued at $8 million,\u0022 February 13, 2008. \u00a0U.S. v. The Painting Known as \u0022Hannibal,\u0022 Case No. 1:08-cv-01511-RJS (SDNY), Verified Complaint filed on February 13, 2008; \u00a0Default Judgment filed August 16, 2010 (accessed at http:\/\/www.bancosantos.com.br\/Ceremony%20Obras%20de%20Arte%2020102109.pdf), Order of Forfeiture filed May 10, 2013 and Order filed September 17, 2013; US v. Broadening-Info Enterprises, Inc., Docket No. 10-5204 (2nd Cir.), Case Summary as of November 2, 2011.\n\n\tUS Immigration and Customs Enforcement, \u0022ICE returns masterpiece linked to bank fraud to Brazilian government,\u0022 May 9, 2014, at http:\/\/www.ice.gov\/news\/releases\/1405\/140509newyork.htm\n"},{"Case ID":"ARW-60","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ferdinand and Imelda Marcos (WestLB account)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"President (F. Marcos,1965-1986); First Lady, Governor of Metro Manila and Minister of Human Settlements (I. Marcos. Governor and Minister from 1978-1986)","Jurisdiction of Asset Recovery":"Singapore","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1998","Asset Recovery End":"2014","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"\n\tIn February 2014, $29 million that had been held in the WestLB account were returned to the Philippines; the monies had been part of the asset return from the Marcos Swiss accounts. \u00a0(Source: \u00a0\u0022Philippines seize {GBP] 17.6m from Marcos accounts,\u0022 The Guardian\/Associated Press, February 12, 2014). \u00a0The return follows a December 2013 decision by the Singapore Appeals Court in favor of the Government of the Philippines\u0027 claim to the funds over that of Marcos era human rights victims and the Marcos-associated Liechtenstein foundations under whose names the Swiss accounts were originally held. \u00a0 (Source: \u00a0The Republic of the Philippines v. Maler Foundation and others and other appeals, [2013] SGCA 66, 30 December 2013).\u00a0\n\n\t\u00a0\n\n\tIn August 2012, the Singapore High Court dismissed claims by the Government of the Philippines, Marcos-associated foundations and the Marcos-era human rights victims to funds being held at the WestLB Bank. \u00a0The High Court held that the Philippine National Bank (PNB) held title to the funds. \u00a0(Source: \u00a0WestLB AG v. Philippine National Bank and others, [2012] SGHC 162 (August 10, 2012); The Philippines Presidential Commission on Good Goverment noted that other parties to the action had appealed and on \u0022All parties to the appeal were heard by the Singapore Court of Appeal on 7 February 2013; the Court subsequently appointed an amicus curiae to help resolve a number of issues under consideration.\u0022 \u00a0(Source: PCGG Annual Report 2012, at 11.). \u00a0\n\n\t\u00a0\n\n\tBetween April 1998 and July 1998, Switzerland had released the Marcos-related assets it had frozen to the PNB to hold as escrow agent. \u00a0The PNB, in turn, deposited some of the funds at West LB AG in Singapore. \u00a0The Marcos-era human rights victims filed claim to enforce the judgment for recovery that they had obtained in the Hawaiian courts. \u00a0On January 30, 2004, West LB filed for interpleader relief. \u00a0In December 2006, Singapore High Court dismissed others\u0027 claims to the funds. (Source: \u00a0WestLB AG v. Philippines National Bank [2007] 1 SLR 967). \u00a0However, in March 2008, the Singapore Court of Appeals overturned the lower court\u0027s decision. \u00a0(Source: Republic of the Philippines v. Maler Foundation and others, Civil Appeal 7 of 2007, decision dated March 24, 2008.) \u00a0In its 2012 decision, the High Court stated that \u0022While this court sympathises with the HRVs\u2019 [Human Rights Victims\u0027] plight during the rule of Ferdinand E Marcos, it must act in a principled manner when dealing with such questions of law and is bound by the enunciated principles to reject the HRVs\u2019 claim. This result is of course unfortunate, since, as confirmed by the chairman of the PCGG [Presidential Commission on Good Government] during cross-examination, no compensation of the HRVs has taken place out of the sum in excess of US$600m which has been recovered by the Republic from the Marcos Estate. However, some comfort may be drawn from the testimony of the chairman of PCGG confirming that legislation for the compensation of the HRVs is being debated. There is thus some hope that the HRVs will soon receive the redress they long await.\u0022 \u00a0(Source: \u00a0WestLB AG v. Philippine National Bank and others, [2012] SGHC 162 (August 10, 2012)). \u00a0\n\n\t\u00a0","Disposition of Criminal Case(s)":"A trial in the U.S. District Court for the Southern District of New York on criminal racketeering and fraud charges concluded in an acquittal for Mrs. Marcos.  Mr. Marcos had also been indicted in the case, but the court had deemed him too ill to stand trial. (Sources: US v. Tantoco, et al, Case No. 1-87-cr-598-JFK (S.D.N.Y.), Docket Report accessed on January 2, 2011 and Indictment of October 22, 1988, obtained from US National Archives; Craig Wolff, \u0022The Marcos Verdict; Marcos Is Cleared of All Charges In Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990.)  On April 21, 2010, the GMA News reported that \u0022According to records of the Philippine anti-graft court Sandiganbayan as of 2005, Mrs. Marcos continues to face 11 criminal charges and 25 civil cases.\u0022  (Source: Sohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....)","Jurisdiction of Origin: Investigative Agency":"Presidential Commission on Good Government","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Presidential Commission on Good Government","Jurisdiction of Origin: Courts Involved":"Sandiganbayan; Supreme Court of the Republic of the Philippines","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Kohn Swift \u0026 Graf PC (Attorney Robert A. Swift) [Interpleader Proceedings, representing human rights victims]","Jurisdiction of Asset Recovery: Courts Involved":"High Court; Court of Appeals; Supreme Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_Appeals_Court_Maler_Foundation_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_Recovery_GMANEWS_June_29_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_WestLB_1_SLR_2007.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/PCGG_Annual_Report_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_Appeals_Court_Maler_Foundation_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_Recovery_GMANEWS_June_29_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_WestLB_1_SLR_2007.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Singapore_WestLB%20AG%20v%20Phil_Natl_Bank_Aug_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_Appeals_Court_Maler_Foundation_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_Recovery_GMANEWS_June_29_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_WestLB_1_SLR_2007.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Singapore_WestLB_Appeals_Ct_Decision_2013_SGCA_66.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_Appeals_Court_Maler_Foundation_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_Recovery_GMANEWS_June_29_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Singapore_WestLB_1_SLR_2007.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Singapore_WestLB_AR_Guardian_Feb_12_2014.pdf","Sources ":"\n\tThe Republic of the Philippines v. Maler Foundation and others and other appeals, [2013] SGCA 66, 30 December 2013, accessed at file:\/\/\/C:\/Users\/j.w\/Downloads\/[2013]%20SGCA%2066%20(1).pdf; \u0022Philippines seize {GBP] 17.6m from Marcos accounts,\u0022 The Guardian\/Associated Press, February 12, 2014;WestLB AG v. Philippine National Bank and others, [2012] SGHC 162 (August 10, 2012); \u00a0WestLB AG v. Philippines National Bank [2007] 1 SLR 967; \u00a0Republic of the Philippines v. Maler Foundation and others, Civil Appeal 7 of 2007, Singapore Court of Appeals decision dated March 24, 2008, copy of actual decision accessed at http:\/\/claimants1081.files.wordpress.com\/2008\/03\/singapore-ct-appeals-de...); Presidential Commission on Good Government Annual Report 2012\n\n\t\u00a0\n\n\tGMA News, \u0022Time Short for RP to Track Marcos Money - PCGG Execs,\u0022 June 29 , 2010 accessed at http:\/\/www.gmanews.tv\/story\/194745\/time-short-for-rp-to-track-marcos-mon... Sophia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....\n"},{"Case ID":"ARW-61","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ferdinand and Imelda Marcos (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"President (F. Marcos,1965-1986); First Lady, Governor of Metro Manila and Minister of Human Settlements (I. Marcos. Governor and Minister from 1978-1986)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1986","Asset Recovery End":"2004","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"International Mutual Assistance in Criminal Matters","Contributing Factors in Asset Recovery":"First case under the Federal Act on International Mutual Assistance in Criminal Matters (IMAC) enacted in January 1983 (Source: Stolen Asset Recovery Initiative Case Study, \u0022Ferdinand Marcos\u0022; Voluntary reporting of Marcos assets by Swiss banks immediately after the Marcoses fled the Philippines which led to automatic freezing of the reported funds; International Mutual Assistance in Criminal Matters (Switzerland) (Source: Jovito R. Salonga, Presidential Plunder: The Quest for the Marcos Ill-Gotten Wealth (Regina Publishing, 2000).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$683,000,000","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Monies returned from Switzerland were to be used for the Agrarian Reform Fund and to establish a  human rights victims fund; Responsibility for monitoring was placed with the Committee on Audit of the Republic of the Philippines.  (Source: Republic of the Philippines, Commission on Audit, Management Services Report No. 2006-01, \u0022Utilization of the Forfeited Swiss Deposits for the Implementation of the Comprehensive Agrarian Reform Program (CARP)).","Case Summary":"\n\tIn 2004, Switzerland released $683 million in funds to the Philippines Treasury, following a July 2003 Philippine Supreme Court decision ordering forfeiture of the Marcos Swiss deposits. \u00a0The $683 million represents sum of the $356 million frozen and accumulated interest. (Source: Merceditas Gutierrez Ombudsman, Republic of the Philippines, \u0022Ferdinand E. Marcos (Philippines): A Case Study,\u0022 in ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational (Bali, 5-7 September 2007.) \u00a0As stated in the Swiss Federal Office of Justice Press Release of August 5, 2003, \u0022The Marcos case began in 1986 when the Federal Council ordered bank accounts to be frozen. In 1990, the Swiss Federal Supreme Court approved the handover to the Phillippines of bank documents relating to the Marcos family, but ruled that the actual return of assets would be conditional upon a final and absolute judgment by a Phillippine court. In 1997, the Court established that the majority of the Marcos foundation assets were of criminal origin and permitted their transfer to a escrow account in Manila, even though no Phillippine court ruling had yet been issued. \u00a0The Swiss Federal Supreme Court set two conditions for this advance transfer, however. The Phillippines had to provide an assurance that the confiscation or repayment of the assets in question would be handled through judicial proceedings that complied with the principles of the International Civil and Political Rights Pact, and the Phillippine government also had to undertake to brief the Swiss authorities regularly on the judicial confiscation and repayment proceedings, as well as on the precautions and procedures pertaining to compensation for victims of violations of human rights under the Marcos regime. \/ \u00a0No further decision required from Swiss authorities \/ Once the Federal Office of Justice (at the time: the Federal Office of Police Matters) had declared the guarantee given by the Phillippines to be satisfactory and the Swiss Federal Supreme Court had dismissed appeals against the ruling, the assets could be transferred in 1998 to a escrow account with the Phillippine National Bank in Manila. Following the confiscation ruling of the Phillippine Supreme Court on 15 July 2003, which confirmed the view of the Swiss Federal Supreme Court with regard to the criminal origin of the monies seized, the Phillippine government may now dispose of the assets, worth some USD 683 million. No further decisions are due on the part of the Swiss authorities. The Phillippine parliament is currently debating legislation under which the Marcos assets would be used for land reform and to compensate the victims of human rights violations.\u0022 (Source: Federal Office of Justice Press Release, \u0022Philippines given access to over USD 683 million \/ Confiscation ruling closes Marcos case,\u0022 August 5, 2003.)\n\n\t\u00a0\n\n\tFollowing the August 2012 Singapore Court decision (and in New York in the Arelma Deposit case), the PCGG stated, \u0022Considering these positive de- velopments in 2012, the Commission decided to remit a portion of the [Contingency\/Litigation Fund \u2013 specifically US$10 mil-lion or PhP422.83 million \u2013 to the Bureau of the Treasury. (Source: PCGG Annual Report 2012)\n\n\t\u00a0\n\n\tIn February 2013, the Human Rights Victims Reparations and Recognition Act was approved, \u00a0creating an independent Human Rights Victims\u0027 Claims Board to administer a compensation fund of P10 billion (US$230.8 million) for Marcos era human rights victims. \u00a0(Source: \u00a0Republic Act 10368, AN ACT PROVIDING FOR REPARATION AND RECOGNITION OF VICTIMS OF HUMAN RIGHTS VIOLATIONS DURING THE MARCOS REGIME, DOCUMENTATION OF SAID VIOLATIONS, APPROPRIATING FUNDS THEREFOR AND FOR OTHER PURPOSES, at http:\/\/www.gov.ph\/downloads\/2013\/02feb\/20130225-RA-10368-BSA.pdf). \u00a0In November 2014, the Philippines legislature passed Joint Resolution 16, extending to May 2015 the deadline for victims to file claims. \u00a0(Source: Senate of the Philippines, \u0022Bill passed to give martial law victims more time to file claims; ethnic origin to be included in national census,\u0022 November 18, 2014, at https:\/\/www.senate.gov.ph\/press_release\/2014\/1118_prib1.asp).","Disposition of Criminal Case(s)":"A trial in the U.S. District Court for the Southern District of New York on criminal racketeering and fraud charges concluded in an acquittal for Mrs. Marcos.  Mr. Marcos had also been indicted in the case, but the court had deemed him too ill to stand trial. (Sources: US v. Tantoco, et al, Case No. 1-87-cr-598-JFK (S.D.N.Y.), Docket Report accessed on January 2, 2011 and Indictment of October 22, 1988, obtained from US National Archives; Craig Wolff, \u0022The Marcos Verdict; Marcos Is Cleared of All Charges In Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990.)  On April 21, 2010, the GMA News reported that \u0022According to records of the Philippine anti-graft court Sandiganbayan as of 2005, Mrs. Marcos continues to face 11 criminal charges and 25 civil cases.\u0022  (Source: Sohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....)","Jurisdiction of Origin: Investigative Agency":"Presidential Commission on Good Government","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Presidential Commission on Good Government","Jurisdiction of Origin: Courts Involved":"Sandiganbayan; Supreme Court of the Republic of the Philippines","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Office of Justice","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Federal Supreme Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Ombudsman_Case_Study_ADB_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_BGER_125_II_411.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_Sandiganbayan_Jul_15_2003.rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_StAR_Briones_Case_Study.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_US683M_EJPD_PR_Aug_5_2003.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/PCGG_Annual_Report_2012_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Ombudsman_Case_Study_ADB_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_BGER_125_II_411.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_Sandiganbayan_Jul_15_2003.rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_StAR_Briones_Case_Study.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_US683M_EJPD_PR_Aug_5_2003.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Phil_Reparations_Act_20130225-RA-10368-BSA.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Ombudsman_Case_Study_ADB_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_BGER_125_II_411.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_Sandiganbayan_Jul_15_2003.rtf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_StAR_Briones_Case_Study.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Switzerland_US683M_EJPD_PR_Aug_5_2003.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Phil_Joint_Resln_16_Nov_2014.pdf","Sources ":"\n\tMerceditas Gutierrez, Ombudsman, Republic of the Philippines, \u0022Ferdinand E. Marcos (Philippines): A Case Study,\u0022 in ADB\/OECD Anti-Corruption Initiative for Asia and the Pacific, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific, Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational (Bali, 5-7 September 2007), accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf; Swiss federal court decisions, including 125 II 411 (1999 decision on Marcos case and request for judicial assistance by Philippines), as contained in assetrecovery.org case study on Marcos; Swiss Federal Office of Justice Press Releases including, \u0022Philippines given access to over USD 683 million,\u0022 August 5, 2003, at http:\/\/www.ejpd.admin.ch\/content\/ejpd\/en\/home\/dokumentation\/mi\/2003\/ref_... Republic of the Philippines v. Sandiganbayan, Ferdinand E. Marcos, and others, Republic of the Phillippines Supreme Court. G.R. No. 152154, Judgment of July 15, 2003 (Supreme Court of the Republic of Philippines decisions can be accessed at: http:\/\/www.worldlii.org\/ph\/); please see also case study by Professor Leonor Briones, in \u0022Stolen Asset Recovery (StAR) Initiative: Challenges, Opportunities, and Action Plan,\u0022 at 21; Jovito R. Salonga, Presidential Plunder: the Quest for the Marcos Ill-Gotten Wealth (U.P. Center for Leadership, Citizenship and Democracy \u0026 Regina Publishing Co. 2000); PCGG Annual Report 2012;\u00a0\n\n\t\u00a0\n\n\tPhilippines Republic Act 10368, Human Rights Victims Reparation and Recognition Act, at http:\/\/www.gov.ph\/downloads\/2013\/02feb\/20130225-RA-10368-BSA.pdf; Senate of the Philippines, \u0022Bill passed to give martial law victims more time to file claims; ethnic origin to be included in national census,\u0022 November 18, 2014, at https:\/\/www.senate.gov.ph\/press_release\/2014\/1118_prib1.asp;\n\n\t\u00a0\n\n\tSophia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....\n"},{"Case ID":"ARW-62","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ferdinand and Imelda Marcos \/ Accounts in names of associates","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"President (F. Marcos,1965-1986); First Lady, Governor of Metro Manila and Minister of Human Settlements (I. Marcos. Governor and Minister from 1978-1986) \/ Associates (Names Unknown)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2003","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Unspecified","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"International Mutual Assistance in Criminal Matters","Contributing Factors in Asset Recovery":"[Unknown Status]","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"$15,000,000 (as of 2003)","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"The Swiss Federal Office of Justice press release of August 5, 2003 included this mention: \u0022The Office of the District Attorney IV for Canton of Zurich subsequently released assets worth approximately USD 30 million because the Phillippine authorities were unable to provide evidence that they were still pursuing criminal proceedings against the individuals concerned. Around USD 10 million remain frozen in Switzerland. The Phillippine judicial authorities will therefore have to issue a ruling on the confiscation of USD 15.5 million in the names of persons associated with the Marcos case.\u0022 (Source: Swiss Federal Office of Justice Press Release, \u0022Philippines given access to over USD 683 million, Confiscation ruling closes Marcos case,\u0022 August 5, 2003.)","Disposition of Criminal Case(s)":"A trial in the U.S. District Court for the Southern District of New York on criminal racketeering and fraud charges concluded in an acquittal for Mrs. Marcos.  Mr. Marcos had also been indicted in the case, but the court had deemed him too ill to stand trial. (Sources: US v. Tantoco, et al, Case No. 1-87-cr-598-JFK (S.D.N.Y.), Docket Report accessed on January 2, 2011 and Indictment of October 22, 1988, obtained from US National Archives; Craig Wolff, \u0022The Marcos Verdict; Marcos Is Cleared of All Charges In Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990.)  On April 21, 2010, the GMA News reported that \u0022According to records of the Philippine anti-graft court Sandiganbayan as of 2005, Mrs. Marcos continues to face 11 criminal charges and 25 civil cases.\u0022  (Source: Sohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....)","Jurisdiction of Origin: Investigative Agency":"Presidential Commission on Good Government","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Presidential Commission on Good Government","Jurisdiction of Origin: Courts Involved":"Sandiganbayan, Supreme Court of the Republic of the Philippines","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"District Attorney IV for Canton of Zurich","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"","Sources ":"Swiss Federal Office of Justice Press Release, \u0022Philippines given access to over USD 683 million, Confiscation ruling closes Marcos case,\u0022 August 5, 2003; Sophia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....\n"},{"Case ID":"ARW-63","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ferdinand Marcos and Imelda Marcos (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"President (F.Marcos,1965-1986); First Lady, Governor of Metro Manila and Minister of Human Settlements (I. Marcos. Governor and Minister from 1978-1986)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1986","Asset Recovery End":"2006","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation; Private Civil Action; Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"The Mutual Legal Assistance Treaty in Criminal Matters","Contributing Factors in Asset Recovery":"Pro Bono lawyers in New York, New Jersey, California, District of Columbia, Texas and elsewhere (Philippine treasury was bankrupt and the Presidential Commission on Good Government had limited financial resources to pay overseas lawyers).  In New York, an unprecedented granting of a temporary injunction request by local courts although no underlying case had yet been filed in the Philippines; additional criminal and civil suits filed against Marcos associates also resulted in their cooperation and agreements to forfeit properties and return cash held overseas.  (Source: Jovito R. Salonga, Presidential Plunder: the Quest for the Marcos Ill-Gotten Wealth (U.P. Center for Leadership, Citizenship and Democracy \u0026 Regina Publishing Co. 2000)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to a 2007 case study by Merceditas Gutierrez, Ombudsman of the Republic of Philippines, from 1986 to 2006, the total value of the assets recovered in the U.S. is less than $50 million.  They include: (1) in New Jersey, funds in a bank account and two residences at Princeton Pike and Cherry Hill used by Marcos children (amount not given); (2) administrative settlement relating to four New York buildings (40 Wall Street, Crown Building, Herald Center, and at 200 Madison Avenue); (3) settlement agreements that led to recovery of properties such as the Olympic Tower Apartment, Pendleton Drive property, the Cedars, Summit Drive Beverly Hills, Lindenmere estate and the Makiki Heights property; (4) seizure of various jewelry, art, and other valuables; and (5) funds in Sanwa Bank and shares in California Overseas Bank and Redwood Bank.  (Sources: Merceditas Gutierrez, \u0022Ferdinand E. Marcos (Philippines): A Case Study,\u0022 in the Asian Development Bank, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific: Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational (Bali, September 5-7, 2007); for the New Jersey recovery:  Jovito R. Salonga, Presidential Plunder: the Quest for the Marcos Ill-Gotten Wealth (U.P. Center for Leadership, Citizenship and Democracy \u0026 Regina Publishing Co. 2000).  The Philippines\u0027 Presidential Commission on Good Government\u0027s January 2011 reported listed among assets recovered, Ms. Marcos\u0027 Hawaii jewelry collection, estimated in value PhP 112,500,000 (approx. US$2.5 million).  (Source: The Presidential Commission on Good Government, 100 Day Report and Plan of Action, \u0022LIST OF SURRENDERED\/RECOVERED ASSETS, as of 17 January 2011.\u0022","Disposition of Criminal Case(s)":"A trial in the U.S. District Court for the Southern District of New York on criminal racketeering and fraud charges concluded in an acquittal for Mrs. Marcos.  Mr. Marcos had also been indicted in the case, but the court had deemed him too ill to stand trial. (Sources: US v. Tantoco, et al, Case No. 1-87-cr-598-JFK (S.D.N.Y.), Docket Report accessed on January 2, 2011 and Indictment of October 22, 1988, obtained from US National Archives; Craig Wolff, \u0022The Marcos Verdict; Marcos Is Cleared of All Charges In Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990.)  On April 21, 2010, the GMA News reported that \u0022According to records of the Philippine anti-graft court Sandiganbayan as of 2005, Mrs. Marcos continues to face 11 criminal charges and 25 civil cases.\u0022  (Source: Sohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....)","Jurisdiction of Origin: Investigative Agency":"Presidential Commission on Good Government","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Presidential Commission on Good Government","Jurisdiction of Origin: Courts Involved":"Sandiganbayan, Supreme Court of the Republic of the Philippines","Jurisdiction of Asset Recovery: Investigative Agency":"Numerous","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Center for Constitutional Rights; numerous other pro bono attorneys","Jurisdiction of Asset Recovery: Courts Involved":"Supreme Court; U.S. District Court for the Central District of California;  U.S. District Court for Hawaii; U.S. District Court for the Southern District of New York; New Jersey court (exact venue not known).","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Ombudsman_Case_Study_ADB_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_SDNY_Indictment_1_of_3.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_SDNY_Indictment_2_of_3.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_SDNY_Indictment_3_of_3.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Chaikin_Tracking_Proceeds.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_NY_Buildings_2nd_Cir_806_ f.2d_344 (1986).pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_SDNY_Cleared_NYT_Jul_3_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_PCGG_-100-day-report-and-plan-of-action1\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_PCGG_-100-day-report-and-plan-of-action1.pdf","Sources ":"Merceditas Gutierrez, \u0022Ferdinand E. Marcos (Philippines): A Case Study,\u0022 in the Asian Development Bank, Asset Recovery and Mutual Legal Assistance in Asia and the Pacific: Proceedings of the 6th Regional Seminar on Making International Anti-Corruption Standards Operational (Bali, September 5-7, 2007), accessed at http:\/\/www.adb.org\/Documents\/Books\/Asset-Recovery\/Asset-Recovery.pdf. New Jersey recovery is discussed in Jovito R. Salonga, Presidential Plunder: the Quest for the Marcos Ill-Gotten Wealth (U.P. Center for Leadership, Citizenship and Democracy \u0026 Regina Publishing Co. 2000). Republic of the Philippines v. Marcos, et al, Case No. 86-cv-3859-MRP (C.D. Cal) and Central Bank of the Philippines v. Marcos, et al, Case No. 86-cv-0213 (Hawaii) and Settlement Agreement and Partial Release of Claim, as cited in Dr. David Chaikin, \u0022Tracking the Proceeds of Organised Crime - The Marcos Case,\u0022 presented at the Transnational Crime Conference (Canberra, March 9-10, 2000), accessed at http:\/\/www.aic.gov.au\/events\/aic%20upcoming%20events\/2000\/~\/media\/confer.... U.S. v. Tantoco, et al, Case No. 1:87-cr-00598-JFK (S.D.N.Y.), copy of Indictment obtained from the U.S. National Archives; Craig Wolff, \u0022The Marcos Verdict; Marcos Cleared of All Charges in Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990. Civil Litigation re: New York properties: U.S. v. Marcos, et al, 806 F.2d 344 (2nd Cir. 1986); Sohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica... The Presidential Commission on Good Government, 100 Day Report and Plan of Action, \u0022LIST OF SURRENDERED\/RECOVERED ASSETS, as of 17 January 2011,\u0022 accessed at http:\/\/pcgg.gov.ph\/100-day-report-and-plan-of-action\/\n"},{"Case ID":"ARW-64","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ferdinand Marcos and Imelda Marcos \/ Arelma Deposit Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"President (F. Marcos,1965-1986); First Lady, Governor of Metro Manila and Minister of Human Settlements (I. Marcos. Governor and Minister from 1978-1986)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1990","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"$40,000,000 (approximate)","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"According to a decision by the U.S. Supreme Court, in 1972, Ferdinand Marcos formed the Arelma S.A. entity under the laws of Panama and around the same time, opened an account under its name at the brokerage firm of Merrill, Lynch, Pierce, Fenner \u0026 Smith, Inc. in New York and deposited $2 million.\u00a0\u00a0 A class action by the Marcos\u0027 human rights victims resulted in a nearly $2 billion judgment for the \u0022Pimentel class,\u0022 which claimed a right to enforce its judgment by attaching the Arelma assets.  (The cases brought by the human rights victims have been consolidated and is now referred to as \u0022Estate of Ferdinand E. Marcos Human Rights Litigation.\u0022)  The ownership in Arelma was represented by two bearer share certificates that are held in escrow by the Philippine National Bank (PNB), after being transferred there in 1990 by an order of the Swiss Federal Supreme Court. (Source:  In the Supreme Court of the United States, Brief for the United States as Amicus Curiae in Estate of Roger Roxas et al v. Pimentel, et. al. and Republic of the Philippines v. Pimentel, et. al. Nos. 06-1039 and 06-1042).  The Philippines claimed ownership of the Arelma deposit of approximately $35 million based on its custody of the Arelma shares, but citing claims to the funds by the Marcos\u0027 human rights victims, Merrill Lynch filed an interpleader motion to request the courts to settle ownership of the funds.  Litigation is ongoing in the United States, as of early March 2011.  In April 2012, the Philippines Supreme Court upheld a previous ruling by the\u00a0Sandiganbayan  anti-graft court,\u00a0forfeiting the Arelma assets to the Republic of Philippines.\u00a0 The Supreme Court denied petitions filed by\u00a0Mrs. Marcos and her son who had challenged the Sandiganbayan\u0027s decision.\u00a0 (Source:  Republic of the Philippines Supreme Court, Ferdinand R. Marcos, Jr. v. Republic of the Philippines, G.R. No. 189434\u00a0and Imelda Romualdez-Marcos v. Republic of Philippines, G.R. No. 189505,\u00a0Decision, April 25, 2012; reaffirmed in Decision of March 12, 2014.) \u00a0In June 2012, the New York Court of Appeals upheld the\u00a0New York State Appellate Court decision a year earlier which held that the case of Swezey (representing the class of human rights victims) v. Merrill Lynch, et al,  cannot proceed without the participation of the Republic of Philippines, making reference to the\u00a0Philippines\u0027 Supreme Court\u00a0ruling that the Arelma assets belonged to the People of the Philippines and should be returned to them.\u00a0(Sources: Swezey v. Merrill Lynch, Pierce, Fenner, et al, National Bank of Philippines, et al (Intervenor),\u00a0\u00a0New York Court of Appeals, No. 88 (June 26, 2012); \u00a02011 NY Slip Op 05208 [appellate court decision].)\u00a0 The New York Court of Appeals decision noted that the Arelma assets, now approximately $40 million, were transferred,\u00a0pursuant to a court order, by Merrill Lynch to the custody of the New York City\u0027s Commissioner of Finance. (Swezey v. Merrill Lynch, Pierce, Fenner, et al, National Bank of Philippines, et al (Intervenor),\u00a0 New York Court of Appeals, No. 88 (June 26, 2012), at fn 6.)","Disposition of Criminal Case(s)":"A trial in the U.S. District Court for the Southern District of New York on criminal racketeering and fraud charges concluded in an acquittal for Mrs. Marcos.  Mr. Marcos had also been indicted in the case, but the court had deemed him too ill to stand trial. (Sources: US v. Tantoco, et al, Case No. 1-87-cr-598-JFK (S.D.N.Y.), Docket Report accessed on January 2, 2011 and Indictment of October 22, 1988, obtained from US National Archives; Craig Wolff, \u0022The Marcos Verdict; Marcos Is Cleared of All Charges In Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990.)  On April 21, 2010, the GMA News reported that \u0022According to records of the Philippine anti-graft court Sandiganbayan as of 2005, Mrs. Marcos continues to face 11 criminal charges and 25 civil cases.\u0022  (Source: Sohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....)","Jurisdiction of Origin: Investigative Agency":"Presidential Commission on Good Government","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Presidential Commission on Good Government","Jurisdiction of Origin: Courts Involved":"Sandiganbayan, Supreme Court of the Republic of the Philippines","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Kohn Swift \u0026 Graf PC (Attorney Robert A. Swift, on behalf of Human Rights Victims)","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Hawaii; Ninth Circuit Court of Appeals; Supreme Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_AP_Feb_24_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Judgment_Civil_Jan_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Judgment_Contempt_Jan_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Notice_Appeal_Feb_24_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_NYT_Mar_1_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Order_Atty_Fees_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Order_Distribution_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Order_Finders_Fee_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Texas_Del_Prado_Complaint_Apr_8_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Texas_Del_Prado_Order_Settlement_Nov_16_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Texas_Fifth_Circuit_Apr_5_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_NY_Appellate_Court_Decision_Jun_16_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Arelma_Deposit_NYS_Appellate_Decision_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_AP_Feb_24_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Judgment_Civil_Jan_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Judgment_Contempt_Jan_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Notice_Appeal_Feb_24_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_NYT_Mar_1_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Order_Atty_Fees_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Order_Distribution_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Order_Finders_Fee_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Texas_Del_Prado_Complaint_Apr_8_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Texas_Del_Prado_Order_Settlement_Nov_16_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Texas_Fifth_Circuit_Apr_5_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_NY_Appellate_Court_Decision_Jun_16_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Arelma_Phil_Supreme_Ct_Decision_Apr_25_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_AP_Feb_24_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Judgment_Civil_Jan_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Judgment_Contempt_Jan_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Notice_Appeal_Feb_24_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_NYT_Mar_1_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Order_Atty_Fees_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Order_Distribution_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Hawaii_Order_Finders_Fee_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Texas_Del_Prado_Complaint_Apr_8_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Texas_Del_Prado_Order_Settlement_Nov_16_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Texas_Fifth_Circuit_Apr_5_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_NY_Appellate_Court_Decision_Jun_16_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_Arelma_Phil_Supreme_Ct_Decision_Mar_12_2014.pdf","Sources ":"\u00a0Republic of the Philippines, et al v. Pimentel, et al, 128 S.Ct. 2180 (2008) and subsequent decisions in Merrill Lynch, Fenner \u0026 Smith v. ENC Corp., 535 F.3d 1010; 2008 U.S. App. LEXIS 16468 (9th Cir. 2008); Appeal after remand at, Remanded by Merrill Lynch, Pierce, Fenner \u0026 Smith v. Arelma 2009 U.S. App. LEXIS 25051 (9th Cir., Nov. 13, 2009) at http:\/\/claimants1081.wordpress.com\/arelma-case\/; \u00a0Republic of the Philippines Supreme Court, Ferdinand R. Marcos, Jr. v. Republic of the Philippines, G.R. No. 189434 and Imelda Romualdez-Marcos v. Republic of Philippines, G.R. No. 189505, Decision, April 25, 2012, accessed at http:\/\/sc.judiciary.gov.ph\/jurisprudence\/2012\/april2012\/189434.htm and March 12, 2014 decision at http:\/\/sc.judiciary.gov.ph\/pdf\/web\/viewer.html?file=\/jurisprudence\/2014\/... See also Dr. Jaime S. Bautista, \u0022Recovery of the Marcos Assets,\u0022 accessed at http:\/\/www.unafei.or.jp\/english\/pdf\/PDF_ThirdGGSeminar\/Third_GGSeminar_P... Swezey v. Merrill Lynch, Pierce, Fenner, et al, National Bank of Philippines, et al (Intervenor), \u00a0New York Court of Appeals, No. 88 (June 26, 2012). \u00a0Swezey v. Merrill Lynch, Pierce, Fenner, et al, National Bank of Philippines, et al (Intervenor), \u00a02011 NY Slip Op 05208, accessed at http:\/\/iapps.courts.state.ny.us\/lawReporting\/Search (and also available at http:\/\/law.justia.com\/cases\/new-york\/appellate-division-first-department....)\n"},{"Case ID":"ARW-65","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ferdinand Marcos and Imelda Marcos \/ Estate of Ferdinand E. Marcos Human Rights Litigation","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"President (F. Marcos,1965-1986); First Lady, Governor of Metro Manila and Minister of Human Settlements (I. Marcos. Governor and Minister from 1978-1986)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1986","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.15, Art.16, Art.17, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"Letter of Request","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Much of the $7.5 million recovered by the Marcos\u0027 era human rights victims resulted from the settlement of the Texas case, in which judicial assistance was provided by the Philippines and Hong Kong.  (Source: In Re: Estate of Ferdinand E. Marcos Human Rights Litigation, Case No. 1:03-cv-11111-MLR (MDL-00840-MLR) (D. Hawaii). The U.S. Fifth Circuit Court of Appeals also  held that the Full Faith and Credit clause of the U.S. Constitution requires a state to give a judgment on a judgment rendered by a different state court equal dignity to a judgment rendered by its own state court.  (Source: Del Prado v. B N Development Company, Inc. et al, Case No. 09-10581 (5th Cir. 2010), citing Roche v. McDonald, 275 U.S. 449 (1928). ","Status of Asset Recovery ":"Completed (in part) and Ongoing (in part)","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$7,526,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"See also related entry, \u0022Ferdinand Marcos and Imelda Marcos \/ Vilma Bautista New York Art Case \/ Human Rights victims\u0027 Settlement.\u0022 \nIn January 2011, the U.S. District Court for the District of Hawaii authorized the distribution of $1,000 to each of the 7,526 eligible members of the class action brought by victims of the Marcos era human rights violations. The Court held that $10,261,000 were available in the Class Settlement Fund (comprised of $286,000 from pre-2010 executions and $9,975,000 net from the Texas class action settlement, Del Prado v. BN Development Company Inc et al, Case No. 4:05-cv-00234-Y; and included the following Colorado actions: De Leon v. Imelda R. Marcos et al., No. 09-CV-2216, and 135 Randomly Selected Class Claimants and the Plaintiff Class as Designated in the Judgment of February 3, 1995 v. Denman Investment Corporation, Inc. et al, No. 05-CV-702). The Court ordered the funds to be distributed as follows: $7,526,000 to 7,526 eligible class members, the vast majority of whom reside in the Philippines; $50,000 advanced to the attorneys for the cost of distribution; $1,402,288 in plaintiff\u0027s attorney fees and $847,952 in reimbursable costs for their work for the past 25 years; $300,000 to Alan Meeker in finders fee for locating the Marcos-related properties in Texas and Colorado; $10,000 to Jerry Pimentel as the next of kin to deceased Mariano Pimentel for Mariano Pimentel\u0027s services as a class representative in the Texas and Colorado actions; $5,000 to Ferdinand De Leon, for services as class representative. The order is in partial satisfaction of a 1995 judgment for $2 billion that was awarded to the human rights victims, who registered the judgment in Illinois, and in turn, in Texas. In 2010, a federal court in Northern District of Texas approved a settlement agreement between the human rights victims and seven companies that held legal ownership to properties in Texas and Colorado that the claimants had alleged were beneficially owned by the Marcoses. Hong Kong provided judicial assistance in the Texas case. On January 25, 2011, Judge Manuel Real also handed down a Judgment of Contempt against Imelda R. Marcos, Ferdinand E. Marcos and the Estate of Ferdinand E. Marcos in the amount of $353,600,000. The Court held that it had jurisdiction over a contempt order of May 26, 1995 which provided a daily sanction of $100,000 against the Marcoses for refusing to furnish information and using the frozen assets of the estate, and that a total of 3,536 days had elapsed since the Contempt Order. On February 24, the Marcoses\u0027 attorneys filed an appeal against the Judgment of Contempt. (Source: In Re: Estate of Ferdinand E. Marcos Human Rights Litigation, Case No. 1:03-cv-11111-MLR (MDL-00840-MLR) (D. Hawaii), Order Authorizing Distribution to Eligible Class Members from the Settlement Fund, Order for Interim Award of Attorneys Fees and Reimbursement of Expenses, and Order for Finders Fee and Incentive Fee, all issued on January 13, 2011; Judgment of Contempt and Judgment in a Civil Case, both filed on January 25, 2011; Notice of Appeal, filed on February 24, 2011.)","Disposition of Criminal Case(s)":"A trial in the U.S. District Court for the Southern District of New York on criminal racketeering and fraud charges concluded in an acquittal for Mrs. Marcos.  Mr. Marcos had also been indicted in the case, but the court had deemed him too ill to stand trial. (Sources: US v. Tantoco, et al, Case No. 1-87-cr-598-JFK (S.D.N.Y.), Docket Report accessed on January 2, 2011 and Indictment of October 22, 1988, obtained from US National Archives; Craig Wolff, \u0022The Marcos Verdict; Marcos Is Cleared of All Charges In Racketeering and Fraud Case,\u0022 New York Times, July 3, 1990.)  On April 21, 2010, the GMA News reported that \u0022According to records of the Philippine anti-graft court Sandiganbayan as of 2005, Mrs. Marcos continues to face 11 criminal charges and 25 civil cases.\u0022  (Source: Sohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....)","Jurisdiction of Origin: Investigative Agency":"Presidential Commission on Good Government","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Presidential Commission on Good Government","Jurisdiction of Origin: Courts Involved":"Sandiganbayan; Supreme Court of the Republic of Philippines","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Kohn Swift \u0026 Graf PC (Attorney Robert A. Swift); Attorney Sherry P. Broder, Liaison Counsel; and Others [for Human Rights Victims Class];  Kabayashi, Sugita \u0026 Goda (Attorneys Lex R. Smith, Joseph A. Stewart, Maria Y. Yang) [for Estate of Ferdinand E. Marcos]","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Hawaii and Ninth Circuit Court of Appeals; U.S. District Court for the Northern District of Texas and Fifth Circuit Court of Appeals; U.S. District Court for the District of Colorado","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_9th_Circuit_Decision_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_535_F3d_1010_2008_Leagle.com, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Sandiganbayan_Business_World_Jan_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_US_Supreme_Court_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Bautista.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Sandiganbayan_GMANews_Aug_31_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_New_Sandiganbayan_GMANEWS_Jun_17_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_Hawaii_Judgment_Civil_Jan_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_9th_Circuit_Decision_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_535_F3d_1010_2008_Leagle.com, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Sandiganbayan_Business_World_Jan_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_US_Supreme_Court_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Bautista.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Sandiganbayan_GMANews_Aug_31_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_New_Sandiganbayan_GMANEWS_Jun_17_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_Hawaii_Judgment_Contempt_Jan_25_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_9th_Circuit_Decision_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_535_F3d_1010_2008_Leagle.com, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Sandiganbayan_Business_World_Jan_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_US_Supreme_Court_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Bautista.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Sandiganbayan_GMANews_Aug_31_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_New_Sandiganbayan_GMANEWS_Jun_17_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_Hawaii_Order_Distribution_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_9th_Circuit_Decision_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_535_F3d_1010_2008_Leagle.com, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Sandiganbayan_Business_World_Jan_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_US_Supreme_Court_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Bautista.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Sandiganbayan_GMANews_Aug_31_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_New_Sandiganbayan_GMANEWS_Jun_17_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_Hawaii_Order_Atty_Fees_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_9th_Circuit_Decision_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_535_F3d_1010_2008_Leagle.com, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Sandiganbayan_Business_World_Jan_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_US_Supreme_Court_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Bautista.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Sandiganbayan_GMANews_Aug_31_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_New_Sandiganbayan_GMANEWS_Jun_17_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_Hawaii_Order_Finders_Fee_Jan_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_9th_Circuit_Decision_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_535_F3d_1010_2008_Leagle.com, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Sandiganbayan_Business_World_Jan_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_US_Supreme_Court_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Bautista.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Sandiganbayan_GMANews_Aug_31_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_New_Sandiganbayan_GMANEWS_Jun_17_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_Texas_Del_Prado_Order_Settlement_Nov_16_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_9th_Circuit_Decision_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_535_F3d_1010_2008_Leagle.com, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Sandiganbayan_Business_World_Jan_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_US_Supreme_Court_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Bautista.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Sandiganbayan_GMANews_Aug_31_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_New_Sandiganbayan_GMANEWS_Jun_17_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_Texas_Del_Prado_Second_Complaint_Aug_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_9th_Circuit_Decision_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_535_F3d_1010_2008_Leagle.com, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Sandiganbayan_Business_World_Jan_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_US_Supreme_Court_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Bautista.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Sandiganbayan_GMANews_Aug_31_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_New_Sandiganbayan_GMANEWS_Jun_17_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_Texas_Del_Prado_Complaint_Apr_8_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_9th_Circuit_Decision_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Merrill_Lynch_535_F3d_1010_2008_Leagle.com, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_Sandiganbayan_Business_World_Jan_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Arelma_US_Supreme_Court_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_Imelda_Road_Vindication_GMANEWS_Apr_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Bautista.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_Sandiganbayan_GMANews_Aug_31_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Marcos_US_Arelma_New_Sandiganbayan_GMANEWS_Jun_17_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Marcos_US_Hawaii_NYT_Mar_1_2011_0.pdf","Sources ":"In Re: Estate of Ferdinand E. Marcos Human Rights Litigation, Case No. 1:03-cv-11111-MLR (MDL-00840-MLR) (D. Hawaii), Order Authorizing Distribution to Eligible Class Members from the Settlement Fund, Order for Interim Award of Attorneys Fees and Reimbursement of Expenses, and Order for Finders Fee and Incentive Fee, all issued on January 13, 2011; Judgment of Contempt and Judgment in a Civil Case, both filed on January 25, 2011; Notice of Appeal, filed on February 24, 2011. See also, Del Prado v. B N Development Company Inc et al, Case No. 4:05-cv-00234-Y, Complaint filed on April 8, 2005 and Second Amended Complaint filed on August 9, 2010; Order Granting Motion for Final Approval of Settlement, November 16, 2010; Del Prado v. B N Development Company, Inc. et al, Case No. 09-10581 (5th Cir. 2010), Opinion filed on April 5, 2010. See also, Seth Mydans, \u0022First Payments Are Made to Victims of Marcos Rule,\u0022 New York Times, March 1, 2011; Teresa Cerojano, \u0022Marcos victims in Philippines to get compensation,\u0022 Associated Press, February 24, 2011. Colorado actions included in the Texas settlement agreement are: De Leon v. Imelda R. Marcos et al., No. 09-CV-2216, and 135 Randomly Selected Class Claimants and the Plaintiff Class as Designated in the Judgment of February 3, 1995 v. Denman Investment Corporation, Inc. et al, No. 05-CV-702 (D. Col.); Sohpia Regina M. Dedace, \u0022Imelda Marcos and her road to vindication,\u0022 GMA News, April 21, 2010, accessed at http:\/\/www.gmanews.tv\/story\/188960\/imelda-marcos-and-her-road-to-vindica....\n"},{"Case ID":"ARW-66","Case Title (Name of Public Official or Entity Allegedly Involved)":"Fexngxia Sun","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"China","Position of Public Official(s) (yrs in office)":"Employee of Jiangsu Nuclear Power Corporation (State Owned Enterprise) (inclusive 1999-2000)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2010","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Unspecified","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"MLAT between the United States and Switzerland","Contributing Factors in Asset Recovery":"[Unknown Status]","Status of Asset Recovery ":"Unknown","Stage in Asset Recovery Chain":"Unknown [no confirmation that U.S. warrant of arrest in rem has been executed]","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"In 2009, the U.S.-based Control Components Inc. pleaded guilty to violation of the Travel Act in relation to improper payments to foreign officials.  Fexngxia Sun is one of the Chinese officials who allegedly received bribes from Control Components.  In April 2010, the U.S. filed a complaint against assets held by Fexngxia Sun in account no. 257-572688 at Union Bank of Switzerland, including $100,600 and proceeds thereof. In May 2010, a Warrant of Arrest in rem was issued by the U.S. District Court for the District of Columbia.  (Sources: U.S. v. All assets held in the name of Fexngxia Sun, account no. 257-572688 at Union Bank of Switzerland AG, Case No. 1:10-cv-00637-RBW (D.D.C.), Verified Complaint for Forfeiture In Rem, filed on April 23, 2010 and Warrant of Arrest In Rem dated May 18, 2010.)  According to the Court Docket Report, the case was terminated on August 31, 2011. (Source: Sources: U.S. v. All assets held in the name of Fexngxia Sun, account no. 257-572688 at Union Bank of Switzerland AG, Case No. 1:10-cv-00637-RBW (D.D.C.), Court Docket Report retrieved on November 2, 2011.)","Disposition of Criminal Case(s)":"Unknown as to Fexngxia Sun.  For details on completed and ongoing criminal proceedings in the U.S. against Control Component Inc. and related individuals, please see U.S. Department of Justice website at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/control-components.html.","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sun_Switzerland_Forfeiture_Complaint_Apr_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sun_Switzerland_Warrant_Arrest_May_18_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sun_DDC_Court_Docket_Rept_Nov_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Sun_DDC_Court_Dkt_Rept_Nov_2011.pdf","Sources ":"U.S. v. All assets held in the name of Fexngxia Sun, account no. 257-572688 at Union Bank of Switzerland AG, Case No. 1:10-cv-00637-RBW (D.D.C.), Verified Complaint for Forfeiture In Rem, filed on April 23, 2010 and Warrant of Arrest In Rem dated May 18, 2010 (last document filed in the Court Docket), Court Docket Report retrieved on November 2, 2011).  \nInformation on criminal proceedings against Control Components Inc. can be found at U.S. Department of Justice website: http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/control-components.html.\n"},{"Case ID":"ARW-67","Case Title (Name of Public Official or Entity Allegedly Involved)":"Fexngxia Sun","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"China","Position of Public Official(s) (yrs in office)":"Employee of Jiangsu Nuclear Power Corporation (State Owned Enterprise) (inclusive 1999-2000)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2010","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"[Unknown status]","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"In 2009, the U.S.-based Control Components Inc. pleaded guilty to violation of the Travel Act in relation to improper payments to foreign officials.  Fexngxia Sun is one of the Chinese officials who allegedly received bribes from Control Components.  In April 2010, the U.S. filed a complaint against assets held by Fexngxia Sun in account no. 257-572688 at Union Bank of Switzerland, including $100,600 and proceeds thereof. In May 2010, a Warrant of Arrest in rem was issued by the U.S. District Court for the District of Columbia. (Sources: U.S. v. All assets held in the name of Fexngxia Sun, account no. 257-572688 at Union Bank of Switzerland AG, Case No. 1:10-cv-00637-RBW (D.D.C.), Verified Complaint for Forfeiture In Rem, filed on April 23, 2010 and Warrant of Arrest In Rem dated May 18, 2010.)  According to the Court Docket Report, the case was terminated on August 31, 2011. (Source: U.S. v. All assets held in the name of Fexngxia Sun, account no. 257-572688 at Union Bank of Switzerland AG, Case No. 1:10-cv-00637-RBW (D.D.C.), Court Docket Report retrieved on November 2, 2011.)","Disposition of Criminal Case(s)":"Unknown as to Fexngxia Sun.  For details on completed and ongoing criminal proceedings in the U.S. against Control Component Inc. and related individuals, please see U.S. Department of Justice website at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/control-components.html.","Jurisdiction of Origin: Investigative Agency":"N\/A","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Origin: Courts Involved":"N\/A","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Columbia","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sun_US_Forfeiture_Complaint_Apr_23_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sun_US_Warrant_Arrest_May_18-2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Sun_DDC_Court_Docket_Rept_Nov_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Sun_DDC_Court_Dkt_Rept_Nov_2011_0.pdf","Sources ":"U.S. v. All assets held in the name of Fexngxia Sun, account no. 257-572688 at Union Bank of Switzerland AG, Case No. 1:10-cv-00637-RBW (D.D.C.), Verified Complaint for Forfeiture In Rem, filed on April 23, 2010 and Warrant of Arrest In Rem dated May 18, 2010 (last document filed in the Court Docket Report); Court Docket Report retrieved on November 2, 2011.  \nInformation on criminal proceedings against Control Components Inc. can be found at U.S. Department of Justice website: http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/control-components.html.\n"},{"Case ID":"ARW-68","Case Title (Name of Public Official or Entity Allegedly Involved)":"Frederick Jacob Titus Chiluba","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Zambia","Position of Public Official(s) (yrs in office)":"President (1991-2002)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"As summarized in a 2009 report by Transparency International UK, \u0022Civil proceedings were brought by Zambia in the High Court against Dr. Chiluba and nineteen of his alleged associates. The case in the London civil courts concerned three separate claims:  The Zamtrop Conspiracy...The MOFED Claim...[which] ultimately failed...[and] The BK Conspiracy....On May 4, 2007, Zambia obtained judgment against Dr. Chiluba and some of his co-defendants for about U.S. $46 million.  Judgment was obtained against Dr. Chiluba\u0027s lawyer Iqbal Meer....However, on 31 July 2008 Mr  Meer successfully appealed the judgment against him, persuading the Court of Appeal that he had not known or suspected the dishonesty of his clients.\u0022  (Sources: Transparency International UK, \u0022Combating Money Laundering and Recovering Looted Gains: Raising the UK\u0027s Game, June 2009; AG of Zambia v Meer Care \u0026 Desai and others [2007] EWHC 952 (Ch) and [2007] EWHC 1540 (Ch).  See also, AG of Zambia v. Meer Care \u0026 Desai and others [2008] EWCA Civ 1007 (31 July 2008), paragraph 6 descriptionof the Zamtrop account and paragraph 8 description of the BK conspiracy.)","Disposition of Criminal Case(s)":"According to the New York Times, Mr. Chiluba was acquitted on August 18, 2009 by a court in Lusaka, Zambia. (Source: Celia W. Dugger, \u0022Former President of Zambia Is Acquitted,\u0022 New York Times, August 18, 2009.)","Jurisdiction of Origin: Investigative Agency":"Task Force on Corruption (established 2002)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General of Zambia","Jurisdiction of Origin: Courts Involved":"[Lusaka, Zambia]","Jurisdiction of Asset Recovery: Investigative Agency":"Serious Fraud Office; Office for the Supervision of Solicitors; Grant Thornton (asset tracing, on behalf of Zambia and some of the defendants)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"DLA Piper UK LLP (Michael Sullivan Q.C. and Hannah Brown) (representing Government of Zambia)","Jurisdiction of Asset Recovery: Courts Involved":"England and Wales High Court; Court of Appeal","Documents":"","Sources ":"AG of Zambia v. Meer Care and Desai and others [2008] EWCA Civ. 1007, [2007] EWHC 952 (Ch) and other decisions in the case, available at www.bailii.org (British and Irish Legal Information Institute); \nTransparency International UK report, \u0022Combating Money Laundering and Recovering Looted Gains: Raising the UK\u0027s Game,\u0022 (June 2009) which can be downloaded at http:\/\/www.transparency.org.uk\/publications, box on right, \u0022Recommended Reading.\u0022  \nSee also, Faustin M. Kabewe and Aaron Chungu v. the United Kingdom, 2967\/08 [2010]  ECHR 251 (2 February 2010), at http:\/\/bailii.org\/eu\/cases\/ECHR\/2010\/251.html.  \nCelia W. Dugger, \u0022Former President of Zambia Is Acquitted,\u0022 New York Times, August 18, 2009, accessed at http:\/\/www.nytimes.com\/2009\/08\/18\/world\/africa\/18zambia.html.\n"},{"Case ID":"ARW-70","Case Title (Name of Public Official or Entity Allegedly Involved)":"Haiti Teleco \/ Jean Rene Duperval","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Haiti","Position of Public Official(s) (yrs in office)":"Director of International Affairs, Haiti Teleco (2003-2004)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"As part of his sentencing, Mr. Duperval was ordered to forfeit $497,331 in proceeds of crime. (Source: U.S. v. Esquenazi, et al,  Case No. 1:09-cr-21010-MGC (S.D. Fla.), Superseding Indictment filed July 12, 2011; Order of Forfeiture, May 21, 2012.)   According to the US Government\u0027s Forfeiture motion, \u0022The evidence at trial also showed that he laundered the $497,331 in the United States through the bank accounts of two South Florida companies, Crossover Records and Telecom Consulting Services, owned by his siblings.\u0022  (Source: US v. Duperval, Case No. 1:09-cr-21010 (S.D.Fla.), United States\u0027 Motion for Entry of Forfeiture Money Judgment at Sentencing and Incorporated Memorandum of Law, filed May 18, 2012.)","Disposition of Criminal Case(s)":"According to a US Department of Justice Press Release, in May 2012, \u0022Jean Rene Duperval, a former director of international relations for Telecommunications D\u2019Haiti S.A.M. (Haiti Teleco), a Haitian state-owned telecommunications company, was sentenced today to nine years in prison for his role in a scheme to launder bribes paid to him by two Miami-based telecommunications companies.\u0022 (Source: US Department of Justice press release, \u0022Former Haitian Government Official Sentenced to Nine Years in Prison for Role in Scheme to Launder Bribes,\u0022\nMay 21, 2012.)","Jurisdiction of Origin: Investigative Agency":"Haiti\u0027s financial intelligence unit, the Unite Centrale de Renseignements Financiers (UCREF), the Bureau des Affaires Financieres et Economiques (BAFE), which is a specialized component of the Haitian National Police, and the Ministry of Justice and Public Security","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Internal Revenue Service, Criminal Investigations -  Miami Field Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney\u0027s Office for the Southern District of Florida","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of Florida","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duperval_US_SDFLA_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duperval_US_SDFLA_Indictment_Dec_8_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Duperval_Joseph_Order_Set_Trial_Date_SDFLA_Sep_1_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Joseph_Superseding_Indictment_July_12_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Superseding_Indictment_DOJ_PR_Jul_13_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Haiti_Teleco_Duperval_Govt_Mtn_Forfeiture_May_18_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duperval_US_SDFLA_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duperval_US_SDFLA_Indictment_Dec_8_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Duperval_Joseph_Order_Set_Trial_Date_SDFLA_Sep_1_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Joseph_Superseding_Indictment_July_12_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Superseding_Indictment_DOJ_PR_Jul_13_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Haiti_Teleco_Duperval_Judgment_May_22_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duperval_US_SDFLA_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duperval_US_SDFLA_Indictment_Dec_8_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Duperval_Joseph_Order_Set_Trial_Date_SDFLA_Sep_1_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Joseph_Superseding_Indictment_July_12_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Superseding_Indictment_DOJ_PR_Jul_13_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Haiti_Teleco_Duperval_Order_Forfeiture_May_21_2012.pdf","Sources ":"U.S. v. Esquenazi, et al,  Case No. 1:09-cr-21010-MGC (S.D. Fla.), Superseding Indictment filed July 12, 2011; Judgment, May 21, 2012; Order of Forfeiture, May 21, 2012, all accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/esquenazij.html;\nUS Department of Justice Press Release, \u0022Former Haitian Government Official Sentenced to Nine Years in Prison for Role in Scheme to Launder Bribes,\u0022 May 21, 2012, accessed at  http:\/\/www.justice.gov\/opa\/pr\/2012\/May\/12-crm-656.html;\nUS v. Duperval, Case No. 1:09-cr-21010 (S.D.Fla.), United States\u0027 Motion for Entry of Forfeiture Money Judgment at Sentencing and Incorporated Memorandum of Law, filed May 18, 2012, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/esquenazij\/2012-05-18-d....\n"},{"Case ID":"ARW-72","Case Title (Name of Public Official or Entity Allegedly Involved)":"Haiti Teleco \/ Robert Antoine \/ Joel Esquenazi \/ Carlos Rodriguez \/ Juan Diaz","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Haiti","Position of Public Official(s) (yrs in office)":"Director of International Affairs, Haiti Teleco (2001-2003)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Criminal Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Cooperation in investigation but mechanism unknown","Contributing Factors in Asset Recovery":"Antonio Perez (Controller of the Bribe Giver company) pleaded guilty in April 2009 and named Mr. Antoine as a recipient of the bribes.  Assistance provided by a number of Government of Haiti\u0027s investigative agencies was acknowledged by the U.S. Department of Justice. Source: U.S. Department of Justice Press Release, \u0022Ex funcionario gubernamental de Haiti sentenciado a prision por su papel en conspiracion de lavado de dinero relacionada con ardid de soborno en el extranjero,\u0022 June 2, 2010, posted at http:\/\/www.justice.gov\/opa\/pr\/2010\/June\/10-crm-639-spanish.html.); Close and specific collaboration among the U.S. authorities and Haitian authorities such as the financial intelligence unit, national police and the Ministry of Justice and Public Security (Source: StAR Asset Recovery Handbook (December 2010), \u0022Box 9.5 Important Role of the Jurisdiction Harmed by Corruption -- A Case Example from Haiti,\u0022 at 183.)  ","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"$1,852,209.39 in restitution was ordered as part of Mr. Antoine\u0027s judgment in a criminal case heard in U.S. District Court for the Southern District of Florida.  A discussion between the U.S. and Haitian authorities regarding the sharing of the proceeds is ongoing, as of December 2010. (Source: StAR Asset Recovery Handbook (December 2010), \u0022Box 9.5 Important Role of the Jurisdiction Harmed by Corruption -- A Case Example from Haiti,\u0022 at 183.  The judgment in Mr. Antoine\u0027s case noted \u0022see victims list\u0022 but this was not available through Pacer.)  In its press release, the U.S. Department of Justice acknowledged the assistance by various agencies of the Government of Haiti in the investigation. (Sources: U.S. v. Joel Esquenazi, Carlos Rodriguez, Robert Antoine, Jean Rene Duperval and Marguerite Grandison, Case No. 09-CR-21010-JEM (S.D. Fla.), Indictment filed December 4, 2009; U.S. v. Robert Antoine, et al, Case No. 1:09-21010-CR-MARTINEZ-3 (S.D. Fla.), Order of Forfeiture filed on June 2, 2010; U.S. v. Robert Antoine, Case No. 1:09-21010-CR-MARTINEZ-3 (S.D. Fla.), Judgment in a Criminal Case, filed on June 9, 2010.)  On November 3, 2011, Mr. Esquenazi and Mr. Rodriguez were sentenced to pay $2.2 million in restitution (joint and several liability with one another and with their other co-defendants Antoine Perez and Jean Fourcand) in the same case.  (US v. Esquenazi and U.S. v. Rodriguez, Case No. 09-cr-21020-JEM (S.D. Fla.), Amended Judgment in a Criminal Case filed November 3, 2011.)  On August 4, 2010, Juan Diaz, a defendant in a related case, was also ordered to pay restitution in the amount of $73,824.20 to the Government of Haiti.  (US v. Diaz, Case No. 09-cr-20346-JEM (S.D. Fla.), Judgment in a criminal case and sentencing hearing transcript, both filed August 5, 2010.)","Disposition of Criminal Case(s)":"According to the U.S. Department of Justice press release, Mr. Antoine pleaded guilty on March 12, 2010, to conspiracy to commit money laundering.   (Source: U.S. Department of Justice Press Release, \u0022 Former Haitian Government Official Sentenced to Prison for His Role in Money Laundering Conspiracy Related to Foreign Bribery Scheme,\u0022 June 2, 2010.)","Jurisdiction of Origin: Investigative Agency":"Haiti\u2019s financial intelligence unit, the Unite Centrale de Renseignements Financiers (UCREF), the Bureau des Affaires Financieres et Economiques (BAFE), which is a specialized component of the Haitian National Police, and the Ministry of Justice and Public Security","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Internal Revenue Service, Criminal Investigations - Miami Field Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Southern District of Florida; Department of Justice, Criminal Division, Fraud Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of Florida","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_StAR_Handbook_Haiti_Teleco.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Factual_Agreement_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Forfeiture_Order_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Indictment_Dec_4_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Sentencing_DOJ_PR_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Judgment_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Sentencing_Hearing_Transcript_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Esquenazi_Amended_Judgment_Nov_3_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Rodriguez_Amended_Judgment_Nov_3_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Diaz_DOJ_Factual_Agreement_May_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_StAR_Handbook_Haiti_Teleco.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Factual_Agreement_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Forfeiture_Order_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Indictment_Dec_4_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Sentencing_DOJ_PR_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Judgment_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Sentencing_Hearing_Transcript_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Esquenazi_Amended_Judgment_Nov_3_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Rodriguez_Amended_Judgment_Nov_3_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Haiti_Teleco_Diaz_Judgment_Aug_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_StAR_Handbook_Haiti_Teleco.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Factual_Agreement_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Forfeiture_Order_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Indictment_Dec_4_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Sentencing_DOJ_PR_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Judgment_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Sentencing_Hearing_Transcript_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Esquenazi_Amended_Judgment_Nov_3_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Rodriguez_Amended_Judgment_Nov_3_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Haiti_Teleco_Diaz_Sentencing_Hearing_Transcript_Aug_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_StAR_Handbook_Haiti_Teleco.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Factual_Agreement_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Forfeiture_Order_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Indictment_Dec_4_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Sentencing_DOJ_PR_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Judgment_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Sentencing_Hearing_Transcript_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Esquenazi_Amended_Judgment_Nov_3_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Rodriguez_Amended_Judgment_Nov_3_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Haiti_Teleco_Esquenazi_Amended_Judgment_Nov_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_StAR_Handbook_Haiti_Teleco.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Factual_Agreement_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Forfeiture_Order_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Indictment_Dec_4_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Antoine_US_Sentencing_DOJ_PR_Jun_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Judgment_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Diaz_Sentencing_Hearing_Transcript_Aug_2010, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Esquenazi_Amended_Judgment_Nov_3_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Haiti_Teleco_Rodriguez_Amended_Judgment_Nov_3_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Haiti_Teleco_Rodriguez_Amended_Judgment_Nov_3_2011.pdf","Sources ":"U.S. v. Joel Esquenazi, Carlos Rodriguez, Robert Antoine, Jean Rene Duperval and Marguerite Grandison, Case No. 09-CR-21010-JEM (S.D. Fla.), Indictment filed December 4, 2009 and Factual Agreement filed March 12, 2010; U.S. v. Robert Antoine, et al, Case No. 1:09-21010-CR-MARTINEZ-3 (S.D. Fla.), Order of Forfeiture filed on June 2, 2010; U.S. v. Robert Antoine, Case No. 1:09-21010-CR-MARTINEZ-3 (S.D. Fla.), Judgment in a Criminal Case, filed on June 9, 2010; U.S. Department of Justice Press Release, \u0022 Former Haitian Government Official Sentenced to Prison for His Role in Money Laundering Conspiracy Related to Foreign Bribery Scheme,\u0022 June 2, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/June\/10-crm-639.html.  See also, StAR Asset Recovery Handbook (December 2010), \u0022Box 9.5 Important Role of the Jurisdiction Harmed by Corruption - A Case Example from Haiti,\u0022 at 183; US v. Esquenazi and U.S. v. Rodriguez, Case No. 09-cr-21020-JEM (S.D. Fla.), Amended Judgment in a Criminal Case filed November 3, 2011; US v. Diaz, Case No. 09-cr-20346-JEM (S.D. Fla.), Judgment in a criminal case and sentencing hearing transcript, both filed August 5, 2010.\n"},{"Case ID":"ARW-75","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hendra Rahardja","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Indonesia","Position of Public Official(s) (yrs in office)":"President \/ CEO of PT Bank Harapan Sentosa (?-1997)","Jurisdiction of Asset Recovery":"Australia","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1991","Asset Recovery End":"2008","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation; Other ","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"The Australian court decision noted that the Government of Hong Kong had provided evidence pursuant to Australia\u0027s Mutual Legal Assistance Treaty request (Source: CDPP - In the matter of S.19 of the Proceeds of Crime Act 2002; In the matter of Funds in a bank account; In the matter of Sunshine Worldwide Holdings Limited and South East Group Limited, 62 NSWLR 400 [2005])","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$493,647 ([Australia Attorney General - Euitable Sharing Program; compared to $3 million reported in Jakarta Post article that was posted at Indonesian Embassy Ottawa website; please see sources]","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to the March 1, 2005 Judgment by Australia\u0027s New South Wales Supreme Court, \u0022It was contended that the crimes of the deceased Rahardja produced a total loss to the Central Bank of Indonesia of A$390 million of which some A$38.5 million came to Australia.\u0022 (Source: CDPP - In the Matter of S.19 of the Proceeds of Crime Act 2002; In the Matter of Funds in a Bank Account; In the Matter of Sunshine Worldwide Holdings Limited and South East Group Limited [2005] NSWSC 117.) According to a January 23, 2008 Jakarta Post article posted on the website of the Indonesian Embassy in Ottawa and citing an official of the Indonesian Justice and Human Rights Ministry, $3 million was returned from Australia. Australia was said to also be helping repatriate another $3 million from Hong Kong. Hendra Rahardja had fled to Australia, and was convicted in absentia in 2002 by Indonesia for misuse of Bank of Indonesia liquidity support funds. Indonesia had ordered him to pay $280 million in indemnities. An Australian court decision in 2008 cited a 2003 affidavit by the Australian Federal Police investigator, who contended that some $26 million in Hendra Rahardja\u0027s criminal proceeds were found to have come to Australia. [Source: CDPP - In the matter of S.19 of the Proceeds of Crime Act 2002; In the matter of Funds in a bank account; In the matter of Sunshine Worldwide Holdings Limited and South East Group Limited, 62 NSWLR 400 (2005), at para 29.] The website of the Attorney General of Australia noted that as part of Australia\u0027s Equitable Sharing Program established under United Nations Convention Against Corruption (UNCAC) provisions as well as Australia\u0027s Proceeds of Crime Act, $493,647.07 was provided to the Indonesian Government for assistance in the Hendra Rahardja matter. (Source: http:\/\/www.ag.gov.au\/agd\/WWW\/ncphome.nsf\/Page\/POCA_funding_for_Non-Gover...)","Disposition of Criminal Case(s)":"According to the March 1, 2005 Judgment by Australia\u0027s New South Wales Supreme Court, \u0022The deceased [Hendra Rahardja]  had been convicted in Indonesia on 18 March 2002 in absentia of charges relating to this matter and was sentenced to life imprisonment and fined 30 million rupiah.\u0022  (Source: CDPP - In the Matter of S.19 of the Proceeds of Crime Act 2002; In the Matter of Funds in a Bank Account; In the Matter of Sunshine Worldwide Holdings Limited and South East Group Limited [2005] NSWSC 117.)","Jurisdiction of Origin: Investigative Agency":"Department of Justice of the Republic of Indonesia [extradition]","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Australian Federal Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Commonwealth Director of Public Prosecutions; Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"New South Wales Supreme Court [civil asset recovery]; Federal Court of Australia, New South Wales District Registry [extradition proceedings]","Documents":"","Sources ":"CDPP - In the matter of S.19 of the Proceeds of Crime Act 2002; In the matter of Funds in a bank account; In the matter of Sunshine Worldwide Holdings Limited and South East Group Limited, 62 NSWLR 400 [2005]; \nAbdul Khalik, \u0022Indonesia Recovers $3 million Bank Bosses Stashed in Australia,\u0022 Jakarta Post, January 23, 2008, posted on the website of the Indonesian Embassy, Ottawa, at http:\/\/www.indonesia-ottawa.org\/information\/details.php?type=news_copy\u0026i... \nWorking Group Report, Australia\/ Indonesia Working Group on Legal Cooperation (Denpasar, 26-27 June 2006), accessed at \u0022http:\/\/www.ag.gov.au\/www\/agd\/rwpattach.nsf\/VAP\/(CFD7369FCAE9B8F32F341DBE097801FF)~9WGLC+REPORT+Final1.doc\/$file\/9WGLC+REPORT+Final1.doc - - Cached\u0022; \nEmbassy of the Republic of Indonesia Canberra, \u0022Press Release on the Death of Hendra Rahardja,\u0022 No. 58\/Pen\/I\/03, January 27, 2003.\n"},{"Case ID":"ARW-76","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hendra Rahardja (Hong Kong SAR, China)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Indonesia","Position of Public Official(s) (yrs in office)":"President \/ CEO of PT Bank Harapan Sentosa (?-1997)","Jurisdiction of Asset Recovery":"Hong Kong SAR, China","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"[Unknown Status of Recovery]","Status of Asset Recovery ":"Unknown","Stage in Asset Recovery Chain":"Unknown","Assets Frozen (USD)":"$3,000,000 (secondary source)","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unknown","Case Summary":"According to the March 1, 2005 Judgment by Australia\u0027s New South Wales Supreme Court, \u0022It was contended that the crimes of the deceased Rahardja produced a total loss to the Central Bank of Indonesia of A$390 million of which some A$38.5 million came to Australia.\u0022  (Source: CDPP - In the Matter of S.19 of the Proceeds of Crime Act 2002; In the Matter of Funds in a Bank Account; In the Matter of Sunshine Worldwide Holdings Limited and South East Group Limited [2005] NSWSC 117.)  According to the International Centre for Asset Recovery, in February 2009, an official of the \u0022Hong Kong Ministry of Justice would confirm only that USD 3 million was frozen in Hong Kong, despite press reports of larger amounts concealed in that jurisdiction.\u0022  (Source: http:\/\/www.assetrecovery.org\/kc\/node\/88a69af9-f1fe-11dd-acdc-479fc5e02d5a.)  At the time of Hendra Rahardja\u0027s case in Indonesia, Hong Kong and Indonesia did not have a bilateral Mutual Legal Assistance Treaty (they signed one in 2008).  The lack of an MLAT betwen the two jurisdictions cited as one of the reasons Australia was acting as intermediary between the two jurisdictions.  (Source:  Working Group Report, Australia\/ Indonesia Working Group on Legal Cooperation (Denpasar, 26-27 June 2006), at 5: \u0022In particular, the group discussed recent developments in the Hendra Rahardja case, including Australia\u2019s recent mutual assistance request to Hong Kong requesting a portion of the assets identified and restrained in Hong Kong be returned to Indonesia.)","Disposition of Criminal Case(s)":"According to the March 1, 2005 Judgment by Australia\u0027s New South Wales Supreme Court, \u0022The deceased had been convicted in Indonesia on 18 March 2002 in absentia of charges relating to this matter and was sentenced to life imprisonment and fined 30 million rupiah.\u0022  (Source: CDPP - In the Matter of S.19 of the Proceeds of Crime Act 2002; In the Matter of Funds in a Bank Account; In the Matter of Sunshine Worldwide Holdings Limited and South East Group Limited [2005] NSWSC 117.)","Jurisdiction of Origin: Investigative Agency":"Unspecfied","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"","Sources ":"CDPP - In the matter of S.19 of the Proceeds of Crime Act 2002; In the matter of Funds in a bank account; In the matter of Sunshine Worldwide Holdings Limited and South East Group Limited, 62 NSWLR 400 [2005] (notes Hong Kong government\u0027s assistance to Australian investigation), accessed at the website of New South Wales Government LawLink: http:\/\/www.lawlink.nsw.gov.au\/scjudgments\/2005nswsc.nsf\/0000000000000000... \nWorking Group Report, Australia\/ Indonesia Working Group on Legal Cooperation (Denpasar, 26-27 June 2006), accessed at \u0022http:\/\/www.ag.gov.au\/www\/agd\/rwpattach.nsf\/VAP\/(CFD7369FCAE9B8F32F341DBE097801FF)~9WGLC+REPORT+Final1.doc\/$file\/9WGLC+REPORT+Final1.doc - - Cached\u0022;\nInternational Centre for Asset Recovery, \u0022Hendra Rahardja Case Study,\u0022 at http:\/\/www.assetrecovery.org\/kc\/node\/88a69af9-f1fe-11dd-acdc-479fc5e02d5a.\n"},{"Case ID":"ARW-77","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hosni Mubarak (various jurisdictions)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Egypt","Position of Public Official(s) (yrs in office)":"President (1981-2011)","Jurisdiction of Asset Recovery":"Various, unnamed jurisdictions","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Not Identified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"Unspecified","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"According to the note verbale dated 7 October 2011 from the Permanent Mission of Egypt to the United Nations (Vienna) addressed to the United Nations Office on Drugs and Crime, Corruption and Economic Crime Branch, \u0022Given the large number of cases reported to the Prosecutor-General\u2019s office in the aftermath of Egypt\u2019s 25 January 2011 revolution, the office has opened an investigation into thousands of reports against officials in the former regime for obtaining financial gain from corruption for themselves or others. A large number of those officials have been brought to stand criminal trial, notably the former Head of State, his two sons and many former ministers. Because of the complex ties those persons had and the great power they wielded by virtue of their former prominent public functions, they were able to transfer vast sums of money gained from crimes of corruption out of the country, which impeded its development. The Prosecutor-General\u2019s office thus promptly submitted requests for mutual legal assistance to various countries of the world, based on the provisions of the Convention, enquiring whether the said indicted persons had transferred funds and, if so, requesting the freezing and seizure of those funds and their return to Egypt. However, many substantive and procedural difficulties have been encountered in executing those requests, inter alia, those described [in the note verbale and accompanying annex.]\u0022  (Source: Note verbale dated 7 October 2011 from the Permanent Mission of Egypt to the United Nations (Vienna) addressed to the United Nations Office on Drugs and Crime, Corruption and Economic Crime Branch, Submitted to the United Nations Conference of the States Parties to the United Nations Convention against Corruption.)","Disposition of Criminal Case(s)":"According to the New York Times and other sources, in May 2014, Mr. Mubarak was convicted on charge of embezzlement and sentenced to three years\u0027 imprisonment. (Source: \u00a0David Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014.)","Jurisdiction of Origin: Investigative Agency":"Prosecutor-General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor-General\u0027s Office","Jurisdiction of Origin: Courts Involved":"Cairo Appeals Court","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"http:\/\/\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_UNCAC_COSP_Note_2011.pdf, http:\/\/\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_Embezzlement_Verdict_NYTimes_May_21_2014_3.pdf","Sources ":"\n\tNote verbale dated 7 October 2011 from the Permanent Mission of Egypt to the United Nations (Vienna) addressed to the United Nations Office on Drugs and Crime, Corruption and Economic Crime Branch, Submitted to the United Nations Conference of the States Parties to the United Nations Convention against Corruption, accessed at http:\/\/www.unodc.org\/documents\/treaties\/UNCAC\/COSP\/session4\/V1186327e.pdf;\n\n\t\u00a0\n\n\tDavid Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014, at http:\/\/www.nytimes.com\/2014\/05\/22\/world\/middleeast\/hosni-mubarak-trial.html\n"},{"Case ID":"ARW-78","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hosni Mubarak (European Union)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Egypt","Position of Public Official(s) (yrs in office)":"President (1981-2011)","Jurisdiction of Asset Recovery":"European Union","Jurisdiction of Asset Description":"Location of Recovery Effort","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"\n\tOn November 26, 2012, the Council of the European Union announced that it had taken steps to facilitate the return of misappropriated funds to the Egyptian authorities: \u00a0\u0022The new legislative framework authorises EU member states to release frozen assets on the basis of judicial decisions recognized in EU member states. Once the necessary judicial steps have been taken, this should enable the release and return to the Egyptian and Tunisian authorities of funds frozen under EU sanctions against the former Mubarak and Ben Ali regimes. In addition, the amended legislation will facilitate the exchange of information between EU member states and the relevant authorities in Tunisia and Egypt so as to assist in the recovery of misappropriated funds. [ \u00a0] \u00a0Since January 2011, [ \u00a0] \u00a09 persons responsible for the misappropriation of Egyptian state funds, including former President Hosni Mubarak, have had their assets in the EU frozen since March 2011.\u0022 \u00a0(Source: Council of the European Union, Press Statement, 16078\/12, November 26, 2012.)\u00a0\n\n\t\u00a0\n\n\tThe European Union had originally issued Council Regulation - (EU) No 270\/2011 of 21 March 2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Egypt, including freeze on assets belonging to Mr. Mubarak and others - in March 2011. (Source: Council Regulation (EU) No 270\/2011 of 21 March 2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Egypt.) \u00a0 The Council Decision has been renewed on several occasions, including most recently with the Council Decision 2016\/411 of March 18, 2016, extending the period of restrictive measures until March 22, 2017. (Source: Official Journal of the European Union, at http:\/\/eur-lex.europa.eu\/legal-content\/EN\/TXT\/HTML\/?uri=CELEX:32016D0411...)","Disposition of Criminal Case(s)":"According to the New York Times and other sources, in May 2014, Mr. Mubarak was convicted on charge of embezzlement and sentenced to three years\u0027 imprisonment. (Source: \u00a0David Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014.)","Jurisdiction of Origin: Investigative Agency":"Prosecutor-General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor-General\u0027s Office","Jurisdiction of Origin: Courts Involved":"Cairo Appeals Court","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Asset Recovery: Courts Involved":"NA","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_European_Union_Regulation_No_270_2011_Mar_21_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Trial_Postponed_to_December_BBC_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_EU_Council_AR_Statement_Nov_26_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_European_Union_Regulation_No_270_2011_Mar_21_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Trial_Postponed_to_December_BBC_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_Embezzlement_Verdict_NYTimes_May_21_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_European_Union_Regulation_No_270_2011_Mar_21_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Trial_Postponed_to_December_BBC_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_EU%20Council%20Decision_2016_411_March%202016.pdf","Sources ":"\n\n\t\tCouncil of the European Union, Press Statement, 16078\/12, November 26, 2012, at http:\/\/www.consilium.europa.eu\/\/uedocs\/cms_data\/docs\/pressdata\/EN\/foraff...\n\n\t\t\u00a0\n\n\t\tCouncil Regulation (EU) No 270\/2011\n\n\t\tof 21 March 2011 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Egypt, accessed at http:\/\/eur-lex.europa.eu\/LexUriServ\/LexUriServ.do?uri=OJ:L:2011:076:0004... \u00a0Council Decision 2016\/411 of 18 March 2016, at http:\/\/eur-lex.europa.eu\/legal-content\/EN\/TXT\/HTML\/?uri=CELEX:32016D0411...\n\n\t\t\u00a0\n\n\t\tDavid Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014, at http:\/\/www.nytimes.com\/2014\/05\/22\/world\/middleeast\/hosni-mubarak-trial.html\n\n\u00a0\n"},{"Case ID":"ARW-79","Case Title (Name of Public Official or Entity Allegedly Involved)":"Hosni Mubarak (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Egypt","Position of Public Official(s) (yrs in office)":"President (1981-2011)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty ","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"\n\tIn the November 2014 speech by the President of the Swiss Confederation to the Arab Forum on Asset Recovery (AFAR III), Mr. Didier Burkhalter stated that, \u0022Our aim is therefore to verify the origin of the USD 650 million frozen in the Egyptian context [ \u00a0] in order to be able to return them should their illicit origin be established.\u0022 \u00a0(Source: \u0022Progress and challenges of asset recovery: a shared effort and responsibility,\u0022 November 1, 2014, at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=55048)\n\n\t\u00a0\n\n\tIn January 2014, the Swiss Office of the Attorney General announced that it would seek Egypt\u0027s assistance, stating: \u0022During the past couple of months, the Office of the Attorney General has thoroughly analysed the case of Egypt and reviewed it in depth. Priority has been accorded to establishing the facts, the relationships between the persons under investigation - all Egyptian nationals associated with former president Mubarak - and to analysing bank accounts and flows of financial assets.\n\n\t\u00a0\n\n\tWhat is decisive in Switzerland\u0027s criminal investigation, as in all cases of money laundering, is the question of whether the predicate offences can be shown to have been committed outside of Switzerland. The cooperation of the Egyptian judicial authorities is vital since the alleged criminal acts or predicate offences to money laundering took place almost exclusively in Egypt. Consequently, the Office of the Attorney General will be contacting the competent Egyptian authorities in the next couple of days and actively requesting legal assistance as provided for under the Swiss Act on Mutual Assistance in Criminal Matters (IMAC) and the Swiss Criminal Procedure Code (CrimPC).\u0022 \u00a0(Source: Swiss Office of Attorney General, \u0022Arab Spring: Swiss Attorney General to request legal assistance from Egypt,\u0022 January 31, 2014.)\n\n\t\u00a0\n\n\tAccording to the May 11, 2011 statement by the Swiss Federal Department of Foreign Affairs, CHF 410 million (US$428,373,000) in assets held by Egyptian individuals belonging to the former Mubarak government had been frozen in Switzerland. \u00a0The statement noted: \u0022The freezing of these assets does not demonstrate their legal or illegal origin. Thus, it is now up to the Egyptian judicial authorities to determine, through criminal proceedings, whether these assets were illicitly acquired. \u00a0Switzerland hopes to be able to quickly return to the Egyptian people all frozen assets whose origin is proved by the Egyptian authorities to be illegal. It is ready to cooperate with the Egyptian authorities on international mutual legal assistance.\u0022 (Source: Swiss Federal Department of Foreign Affairs, \u0022Swiss delegation of experts in Cairo,\u0022 May 11, 2011.) \u00a0On February 11, 2011, the Swiss Government announced that it had passed a special ordinance blocking any assets in Switzerland of the former President Mubarak and parties close to him. \u00a0The special ordinance (revised February 16) remains valid for three years. (Source: \u00a0Federal Department of Foreign Affairs Media Release, \u0022Federal Council orders freezing of any assets of Egypt\u0027s former President Hosni Mubarak in Switzerland,\u0022 February 11, 2011, provides links to the special ordinances.) \u00a0According to the Swiss Federal Department of Foreign Affairs, \u0022The ordinance on freezing assets, which was originally limited to three years, was extended at the beginning of 2014 for a further three years to allow more time for criminal investigations in Egypt into the origins of the funds.\u0022 (Source: \u0022Freezing of assets,\u0022 at https:\/\/www.eda.admin.ch\/eda\/en\/fdfa\/foreign-policy\/financial-centre-eco...)\n\n\t\u00a0","Disposition of Criminal Case(s)":"According to the New York Times and other sources, in May 2014, Mr. Mubarak was convicted on charge of embezzlement and sentenced to three years\u0027 imprisonment. (Source: \u00a0David Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014.)","Jurisdiction of Origin: Investigative Agency":"Prosecutor-General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor-General\u0027s Office","Jurisdiction of Origin: Courts Involved":"Cairo Appeals Court","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Federal Prosecutors Office; Office of Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_Annex_final.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Swiss_Admin_PR_Feb_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Swiss_Asset_Frozen_Amount_Washingtonpost_May_2_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Funds_Located_NYT_Feb_18_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_Feb_16_2011_Amendement.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_vom2_Feb_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Trial_Postponed_to_December_BBC_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_Swiss_OAG_Release_Jan_31_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_Annex_final.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Swiss_Admin_PR_Feb_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Swiss_Asset_Frozen_Amount_Washingtonpost_May_2_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Funds_Located_NYT_Feb_18_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_Feb_16_2011_Amendement.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_vom2_Feb_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Trial_Postponed_to_December_BBC_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_Embezzlement_Verdict_NYTimes_May_21_2014_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_Annex_final.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Swiss_Admin_PR_Feb_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Swiss_Asset_Frozen_Amount_Washingtonpost_May_2_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Funds_Located_NYT_Feb_18_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_Feb_16_2011_Amendement.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_vom2_Feb_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Trial_Postponed_to_December_BBC_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_Swiss_Ordinance_Extend_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_Annex_final.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Swiss_Admin_PR_Feb_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Swiss_Asset_Frozen_Amount_Washingtonpost_May_2_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Funds_Located_NYT_Feb_18_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_Feb_16_2011_Amendement.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Switzerland_Ordinance_vom2_Feb_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Mubarak_Trial_Postponed_to_December_BBC_Oct_30_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Mubarak_Swiss_Pres_AFARIII_Speech_Nov_2014.pdf","Sources ":"\n\tSpeech by the President of the Swiss Confederation, Mr. Didier Burkhalter, at the Arab Forum on Asset Recovery (AFAR III), November 1, 2014, \u0022Progress and challenges of asset recovery: a shared effort and responsibility,\u0022 \u00a0at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=55048;\n\n\t\u00a0\n\n\tSwiss Office of Attorney General, \u0022Arab Spring: Swiss Attorney General to request legal assistance from Egypt,\u0022 January 31, 2014, at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=51874;\n\n\t\u00a0\n\n\tVerordnung uber Massnahmen gegen gewisse Personen aus der Arabischen Republik Agypten, vom 2. February 11, 2011 and revised on February 16, 2011, and accessed at official website of the Swiss Federal Confederation government website: http:\/\/www.admin.ch\/dokumentation\/gesetz\/00068\/index.html?lang=de\u0026unters... \u00a0\u0022Freezing of assets,\u0022 at https:\/\/www.eda.admin.ch\/eda\/en\/fdfa\/foreign-policy\/financial-centre-eco... (last accessed February 6, 2015)\n\n\t\u00a0\n\n\tFederal Department of Foreign Affairs Media Release, \u0022Federal Council orders freezing of any assets of Egypt\u0027s former President Hosni Mubarak in Switzerland,\u0022 February 11, 2011.\u00a0\n\n\t\u00a0\n\n\tSwiss Federal Department of Foreign Affairs, \u0022Swiss delegation of experts in Cairo,\u0022 May 11, 2011, accessed at http:\/\/www.eda.admin.ch\/eda\/en\/home\/recent\/media\/single.html?id=39108\n\n\t\u00a0\n\n\tDavid Kirkpatrick, \u0022Mubarak Gets 3 Years for Embezzlement, and His Sons Get 4,\u0022 New York Times, May 21, 2014, at http:\/\/www.nytimes.com\/2014\/05\/22\/world\/middleeast\/hosni-mubarak-trial.html\n\n\t\u00a0\n\n\tSwissinfo.ch, \u0022Federal Court rules in favour of Egypt,\u0022 May 10, 2012, at \u00a0http:\/\/www.swissinfo.ch\/eng\/politics\/foreign_affairs\/Federal_Court_rules... \u0022Swiss mulls restitution of Mubarak\u0027s funds to Egypt,\u0022 September 4, 2013, at http:\/\/www.swissinfo.ch\/eng\/politics\/Swiss_mull_restitution_of_Mubarak_f...\n"},{"Case ID":"ARW-81","Case Title (Name of Public Official or Entity Allegedly Involved)":"IBM \/ Banco de la Nacion Officials (Alfredo Adaco, Mario Dadone, Genaro Contartese, Hugo Gaggero)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Argentina","Position of Public Official(s) (yrs in office)":"Officials of State Owned Enterprise","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1994","Asset Recovery End":"2010, Ongoing","UNCAC Offenses Implicated":"Art.16, Art.19, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Settlement agreement by defendants ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"","Case Summary":"In June 1999, Switzerland returned $4.5 million in suspected bribe funds to Argentina.  (Source: Swiss Ministry of Foreign Affairs, September 30, 2009).  According to a 2010 report by the Argentina\u0027s Ministry of Justice Office of Anticorruption report, total of $18,286,683 were recovered in the related cases.  (Source: Republic of Argentina, Ministerio de Justicia, Seguridad y Derechos Humanos, Oficina anticorrupcion, \u0022Recupero de Activos en Casos de Corrupcion,\u0022 2010, at 37-38.)","Disposition of Criminal Case(s)":"According to a report by the Argentina\u0027s Ministry of Justice, the defendants in the case pleaded guilty. (Source: epublic of Argentina, Ministerio de Justicia, Seguridad y Derechos Humanos, Oficina anticorrupcion, \u0022Recupero de Activos en Casos de Corrupcion,\u0022 2010, at http:\/\/www.anticorrupcion.gov.ar\/documentos\/Recupero%20de%20Activos%20-%....)  For information on IBM\u0027s U.S. cases, please see Shearman \u0026 Sterling law firm\u0027s Foreign Corruption Practices Act database at http:\/\/fcpa.shearman.com\/index.php.","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Ministerio Publico Procuracion General de la Nacion","Jurisdiction of Origin: Courts Involved":"C\u00e1mara de Casaci\u00f3n penal.","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Switzerland_ACCA_2001.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Banco_Nacion_Status_Lanacion_Mar_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Transparency_Intl_Progress_Report_on_OECD_Convention_Enforcement_July2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Banco_Nacion_Argentina_Plea_Agreement\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/IBM_Banco_Nacion_Status_Lanacion_Mar_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Switzerland_ACCA_2001.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Banco_Nacion_Status_Lanacion_Mar_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Transparency_Intl_Progress_Report_on_OECD_Convention_Enforcement_July2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Banco_Nacion_Argentina_Plea_Agreement\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/IBM_Banco_Nacion_Argentina_Plea_Agreement.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Switzerland_ACCA_2001.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Banco_Nacion_Status_Lanacion_Mar_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Transparency_Intl_Progress_Report_on_OECD_Convention_Enforcement_July2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Banco_Nacion_Argentina_Plea_Agreement\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Transparency_Intl_Progress_Report_on_OECD_Convention_Enforcement_July2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Switzerland_ACCA_2001.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Banco_Nacion_Status_Lanacion_Mar_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Transparency_Intl_Progress_Report_on_OECD_Convention_Enforcement_July2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/IBM_Banco_Nacion_Argentina_Plea_Agreement\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Recupero%20de%20Activos%20-%20form%20red.pdf","Sources ":"Swiss Ministry of Foreign Affairs, September 30, 2009; American Corporate Counsel Association, 2001 Annual Meeting report, \u0022605 Current Challenges to Complying with the Foreign Corrupt Practices Act,\u0022 at 18-19, last accessed on October 12, 2010 at http:\/\/www.acc.com\/vl\/public\/ProgramMaterial\/loader.cfm?csModule=securit... \u00a0Phone interview with Argentine Attorney (November 2010). \u00a0See also, La Nacion, \u0022Jueces y personajes que se repiten,\u0022 March 9, 2011, accessed at http:\/\/www.lanacion.com.ar\/1355847-jueces-y-personajes-que-se-repiten; Transparency International, Progress Report 2011, Enforcement of the OECD Anti-Bribery Convention, \u0022Argentina,\u0022 at 14-15, accessed at http:\/\/www.transparency.org\/publications\/publications\/conventions\/oecd_r... and plea agreement between government of Argentina and Banco de la Nacion defendants, accessed at http:\/\/www.mpf.gov.ar\/biblioteca\/newsletter\/n176\/ibm-acta-acuerdo-defini... Republic of Argentina, Ministerio de Justicia, Seguridad y Derechos Humanos, Oficina anticorrupcion, \u0022Recupero de Activos en Casos de Corrupcion,\u0022 2010, at http:\/\/www.anticorrupcion.gov.ar\/documentos\/Recupero%20de%20Activos%20-%....\n"},{"Case ID":"ARW-82","Case Title (Name of Public Official or Entity Allegedly Involved)":"IBM \/ Banco de la Nacion Officials (Alfredo Adaco, Mario Dadone, Genaro Contartese, Hugo Gaggero)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Argentina","Position of Public Official(s) (yrs in office)":"Officials of State Owned Enterprise","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"","Asset Recovery End":"1997","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Other","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Unspecified (Commercial settlement)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"This case concerns the bribery paid in 1994 by IBM\u0027s Argentine subsidiary to Banco de la Nacion officials to secure a contract with the bank.  After litigation, IBM agreed to reimburse Banco de la Nacion $34 million in losses.  (Source: \u0022Argentina: IBM to Reimburse U.S. $34 mil to Banco Nacion,\u0022 South American Business Information, November 10, 1997, cited in Wlimer, Cutler and Pickering, \u0022Foreign Corrupt Practices Act Updates IBM Consents to Civil Penalty and SEC Cease and Desist Order Based on Argentine Bribe Scandal,\u0022 January 12, 2001.)  According to an Argentine attorney knowledgeable about the case, this is the first case in Argentina of a plea agreement in a criminal action involving public officials and corruption.   In 2009, the officials agreed to the plea deal, but once it was approved by the court, they appealed it as their final sentence, on statute of limitations grounds.  As of November 17, 2010, nearly 16 years after the bribery, the case was on appeal in the Argentine Supreme Court.","Disposition of Criminal Case(s)":"According to an Argentine attorney familiar with the case of Banco de la Nacion officials, as of November 2010, their appeal was pending before the Argentine Supreme Court. (Source: StAR researcher phone interview, November 2010).  For information on IBM\u0027s U.S. cases, please see Shearman \u0026 Sterling law firm\u0027s Foreign Corruption Practices Act database at http:\/\/fcpa.shearman.com\/index.php.","Jurisdiction of Origin: Investigative Agency":"Unspecified (Commercial settlement)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Ministerio Publico Procuracion General de la Nacion","Jurisdiction of Origin: Courts Involved":"C\u00e1mara de Casaci\u00f3n penal.","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Department of Justice, Securities and Exchange Commission","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Department of Justice, Securities and Exchange Commission","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Columbia","Documents":"","Sources ":"Securities and Exchange Commission v. International Business Machines Corp., 1:00-cv-030400 (D.D.C. Dec. 21, 2000), Case Digest at Shearman and Sterling FCPA Website, at http:\/\/fcpa.shearman.com\/?mode=form\u0026id=132; \nIn the Matter of International Business Machines Corp., Administrative Proceeding File No. 3-13097, Rel. No. 34-43761 (Dec. 21, 2000), posted at http:\/\/www.sec.gov\/litigation\/admin\/34-43761.htm; \nWilmer, Cutler \u0026 Pickering, \u0022Foreign Corrupt Practices Act Updates IBM Consents to Civil Penalty and SEC Cease and Desist Order Based on Argentine Bribe Scandal,\u0022 January 12, 2001, accessed at http:\/\/www.wilmerhale.com\/files\/Publication\/506aff4a-d418-4046-9dad-18c6... \nResearcher phone interview with Argentine attorney (November 2010).\n"},{"Case ID":"ARW-87","Case Title (Name of Public Official or Entity Allegedly Involved)":"Jean Claude \u0022Baby Doc\u0022 Duvalier (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Haiti","Position of Public Official(s) (yrs in office)":"President (1971-1986)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1986","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"International Mutual Assistance on Criminal Matters (ended January 2010)","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"On Appeal","Assets Frozen (USD)":"$6,556,090","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\n\t\tAccording to a Federal Administrative Court (FAC) press release, on September 23, 2013, the FAC ruled against Mr. Duvalier and co-complainants and upheld the freezing of their assets ordered by the Federal Council in 2002. In its decision of September 24, 2013, the FAC also upheld the asset forfeiture proceedings launched by the Federal Department of Finance (FDF) on behalf of the Swiss Confederation on April 29, 2011. \u00a0The press release stated, \u0022In its decision of 24 September 2013, the FAC confirmed that these asset forfeiture proceedings were valid because the assets in question had been obtained illicitly. Specifically, the FAC felt that Jean- Claude Duvalier and his entourage did not demonstrate that the increase in their assets had resulted from activities unrelated to their role as public officials. Moreover, the level of corruption of the Haitian state was notoriously high during the period in which they had held public office. It was therefore concluded that the conditions determining the illicit origin of the assets in question were met.\u0022 \u00a0These assets have been frozen since 2002. \u00a0Both decisions may be subject to appeal before the Federal Supreme Court, but barring an appeal, the way is now clear for the restitution procedure of these seized assets to be launched (Source: Federal Administrative Court press release, \u0022FAC confirms freezing and forfeiture of Duvalier assets\u0022, September 25, 2013; See also text of decision: \u0022Extrait de l\u0027arr\u00eat de la Cour III \u00a0dans la cause D\u00e9partement f\u00e9d\u00e9ral des finances contre Fondation Brouilly, Jean-Claude Duvalier, hoirie de feue Simone Ovide Duvalier, compos\u00e9e de Jean-Claude Duvalier, Nicole Duvalier, Marie-Denise Duvalier et Simone Duvalier, et Mich\u00e8le Benett-Duvalier C\u20122528\/2011 du 24 septembre 2013,\u0022 BVGE 2013\/40).\u00a0\n\n\t\t\u00a0\n\n\t\tAccording to the Swiss Federal Department of Foreign Affairs, the funds were frozen by a 2010 Federal Council decision of, which followed the January 2010 \u00a0judgment by the Federal Court \u0022which put an end to the mutual legal assistance between Haiti and Switzerland, this freezing order has avoided a return of the assets to the Duvalier family. The freezing remained in force until the entry into force of the Act on the Restitution of Illicit Asset (LRAI). This law was accepted by Parliament in the autumn session 2010 and is entered into force on 1 February 2011. The Duvalier assets have then been frozen on the basis of article 14 RIAA. The Confederation took legal action before the Federal Administrative Court to enable frozen assets to be forfeited in April 2011, further to the decision of the Federal Council to ask the Federal Department of Finance (FDF) to initiate proceedings for the forfeiture of the Duvalier funds frozen in Switzerland. (Source: Swiss Federal Department of Foreign Affairs, \u0022Illicit assets of politically exposed persons (PEPs),\u0022 last modification March 20, 2012, at http:\/\/www.eda.admin.ch\/eda\/en\/home\/topics\/finec\/intcr\/poexp.html.)\u00a0\n\n\u00a0","Disposition of Criminal Case(s)":"\n\tOn October 4, 2014, Mr. Duvalier passed away. Prior to his death, the charges against him in Haiti had been voided on grounds of expiration of statute of limitations. \u00a0(Source: The Economist, \u0022Obituary: Baby Doc Duvalier,\u0022 October 11, 2014). \u00a0On January18, 2013, Haitian prosecutors charged Mr. Duvalier with corruption and embezzlement, and he was taken into police custody (Source: \u00a0New York Times, Jean-Cluade Duvalier, accessed at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/d\/jeanclaude_...) \u00a0According to an Amnesty International press release, after three failures to appear to court hearings, the latest on February 21, 2013, \u00a0the Court of Appeal had asked the Public Prosecutor to issue a warrant ordering the former president to appear before the court on February 28, 2013. \u00a0Mr. Duvalier had appeared in court on February 28, 2013 and entered a plea of not guilty. (Sources: Amnesty International press release, \u0022Haiti: Jean-Claude Duvalier\u2019s presence in Court brings hope to victims,\u0022 \u00a0March 1, 2013 accessed at http:\/\/www.amnesty.org\/en\/news\/haiti-jean-claude-duvalier-s-presence-cou... NBCnews.com, \u0022Ex-Haiti dictator \u0027Baby Doc\u0027 Duvalier faces corruption charges for first time since revolt,\u0022 February 28, 2013, accessed at \u00a0http:\/\/worldnews.nbcnews.com\/_news\/2013\/02\/28\/17136615-ex-haiti-dictator....\n\n\t\u00a0\n\n\tAccording to an April 2011 report by Human Rights Watch, criminal proceedings had been instituted in Haiti against Mr. Duvalier on charges of financial crimes, after he left Haiti in 1986. \u00a0These pending proceedings were reinstituted when Mr. Duvalier returned to Haiti in January 2011. \u00a0(Source: \u00a0Haiti\u0027s Rendezvous with History, \u0022The proceedings against Duvalier,\u0022 Human Rights Watch, April 14, 2011, accessed at http:\/\/www.hrw.org\/en\/node\/97889\/section\/4.)","Jurisdiction of Origin: Investigative Agency":"Investigating Judge (Juge d\u0027instruction)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"State Prosecutor (Commissaire du gouvernement) ","Jurisdiction of Origin: Courts Involved":"Unknown","Jurisdiction of Asset Recovery: Investigative Agency":"Le juge d\u0027instruction du canton de Geneve","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Office federal de la justice; Monfrini Crettol \u0026 Partners (Attorneys Enrico Monfrini and Yves Klein)","Jurisdiction of Asset Recovery: Courts Involved":"Chambre d\u0027accusation genevoise; Tribunal federal, Federal Administration Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Haiti_Charges_Filed_HRW_Apr_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_136 IV 4_Jan_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_Fed_Ct_Decision_Jan_2010_ICAR.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_Return_Illicit_Assets_Act.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_UN_News_Feb_13_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Duvalier_Swiss_Fed_Admin_Court_PR_25_Sep_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Haiti_Charges_Filed_HRW_Apr_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_136 IV 4_Jan_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_Fed_Ct_Decision_Jan_2010_ICAR.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_Return_Illicit_Assets_Act.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_UN_News_Feb_13_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Duvalier_Swiss_Fed_Admin_Court_Decision_Sept_2013_40.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Haiti_Charges_Filed_HRW_Apr_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_136 IV 4_Jan_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_Fed_Ct_Decision_Jan_2010_ICAR.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_Return_Illicit_Assets_Act.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Switzerland_UN_News_Feb_13_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Duvalier_Obituary_Economist_Oct_11_2014.pdf","Sources ":"\n\n\t\tSwiss Federal Administrative Court Press Release, \u0022FAC confirms freezing and confiscation of Duvalier assets,\u0022 September 25, 2013; Swiss Federal Department Foreign Affairs, \u00a0\u0022Illicit assets of politically exposed persons (PEPs)\u0022;\u00a0\n\n\t\t\u00a0\n\n\t\tSwiss Federal Administrative Court, \u0022Extrait de l\u0027arr\u00eat de la Cour III \u00a0dans la cause D\u00e9partement f\u00e9d\u00e9ral des finances contre Fondation Brouilly, Jean-Claude Duvalier, hoirie de feue Simone Ovide Duvalier, compos\u00e9e de Jean-Claude Duvalier, Nicole Duvalier, Marie-Denise Duvalier et Simone Duvalier, et Mich\u00e8le Benett-Duvalier C\u20122528\/2011 du 24 septembre 2013,\u0022 BVGE 2013\/40, at http:\/\/www.bvger.ch\/?lang=en;\u00a0\n\n\t\t\u00a0\n\n\t\tSwiss federal court decision 136 IV 4 (January 12, 2010), accessed at http:\/\/www.bger.ch\/index\/juridiction\/jurisdiction-inherit-template\/juris... \u00a0\n\n\t\t\u00a0\n\n\t\tText of the Swiss \u0022Return of Illicit Assets Act,\u0022 accessed at website of the Swiss Federal Deapartment of Foreign Affairs, http:\/\/www.eda.admin.ch\/etc\/medialib\/downloads\/edazen\/topics\/finec\/intcr... \u00a0\n\n\t\t\u00a0\n\n\t\tHaiti\u0027s Rendezvous with History, \u0022The proceedings against Duvalier,\u0022 Human Rights Watch, April 14, 2011, accessed at http:\/\/www.hrw.org\/en\/node\/97889\/section\/4;\n\n\t\t\u00a0\n\n\t\tThe Economist, \u0022Obituary: Baby Doc Duvalier,\u0022 October 11, 2014, at http:\/\/www.economist.com\/news\/obituary\/21623568-jean-claude-baby-doc-duv...\n\n\u00a0\n"},{"Case ID":"ARW-88","Case Title (Name of Public Official or Entity Allegedly Involved)":"Jean Claude \u0022Baby Doc\u0022 Duvalier (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Haiti","Position of Public Official(s) (yrs in office)":"President (1971-1986)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Location of Recovery Effort","Asset Recovery Start":"1988","Asset Recovery End":"1990","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"A United Kingdom court granted a worldwide Mareva freezing order even though, as it noted, the Duvaliers were not in England and there was no evidence that they had assets in the UK.  However, the Court pointed out that the Duvaliers had used English solicitors in connection with dealings with the assets and all of the documentary evidence in relation to such dealings was therefore located in England which was adjudged a sufficient connection with England.  (Source: New Law Journal, \u0022Disarming litigation\r\nterrorists John Fordham explains how devastating freezing injunctions can be,\u0022 May 9, 2008 [Discussion of Republic of Haiti v Duvalier [1990] 1 QB 202, [1989] 1 All ER 456], accessed at http:\/\/www.venezlon.co.uk\/old\/pdf\/disarming_litigation.pdf; Republic of Haiti v Duvalier [1990] 1 QB 202, [1989] 1 All ER 456.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$0","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"On October 4, 2014, Mr. Duvalier passed away. Prior to his death, the charges against him in Haiti had been voided on grounds of expiration of statute of limitations. (Source: The Economist, \u0022Obituary: Baby Doc Duvalier,\u0022 October 11, 2014). On January18, 2013, Haitian prosecutors\u00a0charged Mr. Duvalier with corruption and embezzlement, and he was taken into police custody (Source: \u00a0New York Times,\u00a0Jean-Cluade Duvalier, accessed at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/d\/jeanclaude_...)\u00a0\u00a0According to an Amnesty International press release, after three failures to appear to court hearings, the latest on February 21, 2013, \u00a0the Court of Appeal asked the Public Prosecutor to\u00a0issue a warrant ordering the former president to appear before the court on February 28, 2013.\u00a0\u00a0Mr. Duvalier appeared in court on February 28, 2013 and entered a plea of not guilty. (Sources: Amnesty International press release, \u0022Haiti: Jean-Claude Duvalier\u2019s presence in Court brings hope to victims,\u0022 \u00a0March 1, 2013 accessed at http:\/\/www.amnesty.org\/en\/news\/haiti-jean-claude-duvalier-s-presence-cou... NBCnews.com, \u0022Ex-Haiti dictator \u0027Baby Doc\u0027 Duvalier faces corruption charges for first time since revolt,\u0022 February 28, 2013, accessed at \u00a0http:\/\/worldnews.nbcnews.com\/_news\/2013\/02\/28\/17136615-ex-haiti-dictator.... According to an April 2011 report by Human Rights Watch, criminal proceedings had been instituted in Haiti against Mr. Duvalier on charges of financial crimes, after he left Haiti in 1986. These pending proceedings were reinstituted when Mr. Duvalier returned to Haiti in January 2011. (Source: Haiti\u0027s Rendezvous with History, \u0022The proceedings against Duvalier,\u0022 Human Rights Watch, April 14, 2011, accessed at http:\/\/www.hrw.org\/en\/node\/97889\/section\/4.)","Disposition of Criminal Case(s)":"On January 18, 2013, Haitian prosecutors\u00a0charged Mr. Duvalier with corruption and embezzlement, and he was taken into police custody (Source: \u00a0New York Times,\u00a0Jean-Cluade Duvalier, accessed at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/d\/jeanclaude_...)\u00a0\u00a0According to an Amnesty International press release, after three failures to appear to court hearings, the latest on February 21, 2013, \u00a0the Court of Appeal asked the Public Prosecutor to\u00a0issue a warrant ordering the former president to appear before the court on February 28, 2013.\u00a0\u00a0Mr. Duvalier appeared in court on February 28, 2013 and entered a plea of not guilty. (Sources: Amnesty International press release, \u0022Haiti: Jean-Claude Duvalier\u2019s presence in Court brings hope to victims,\u0022 \u00a0March 1, 2013 accessed at http:\/\/www.amnesty.org\/en\/news\/haiti-jean-claude-duvalier-s-presence-cou... NBCnews.com, \u0022Ex-Haiti dictator \u0027Baby Doc\u0027 Duvalier faces corruption charges for first time since revolt,\u0022 February 28, 2013, accessed at \u00a0http:\/\/worldnews.nbcnews.com\/_news\/2013\/02\/28\/17136615-ex-haiti-dictator.... The trial is still ongoing.\u00a0 According to an April 2011 report by Human Rights Watch, criminal proceedings had been instituted in Haiti against Mr. Duvalier on charges of financial crimes, after he left Haiti in 1986. These pending proceedings were reinstituted when Mr. Duvalier returned to Haiti in January 2011. (Source: Haiti\u0027s Rendezvous with History, \u0022The proceedings against Duvalier,\u0022 Human Rights Watch, April 14, 2011, accessed at http:\/\/www.hrw.org\/en\/node\/97889\/section\/4.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Watson, Farley \u0026 Williams; Slaughter \u0026 May","Jurisdiction of Asset Recovery: Courts Involved":"Queens Bench","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_Haiti_Charges_Filed_HRW_Apr_14_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_UK_1_QB_202_[1990].pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Duvalier_UK_Mareva_New_Law_Journal_May_9_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Duvalier_Obituary_Economist_Oct_11_2014_0.pdf","Sources ":"Republic of Haiti and others v Duvalier and others, [1990] 1 QB 202 (Obtained from the U.S. Library of Congress); See also New Law Journal, \u0022Disarming litigation terrorists John Fordham explains how devastating freezing injunctions can be,\u0022May 9, 2008 (Discussion of Republic of Haiti v Duvalier [1990] 1 QB 202, [1989] 1 All ER 456); Haiti\u0027s Rendezvous with History, \u0022The proceedings against Duvalier,\u0022 Human Rights Watch, April 14, 2011, accessed at http:\/\/www.hrw.org\/en\/node\/97889\/section\/4; The Economist, \u0022Obituary: Baby Doc Duvalier,\u0022 October 11, 2014, at http:\/\/www.economist.com\/news\/obituary\/21623568-jean-claude-baby-doc-duv...\n"},{"Case ID":"ARW-90","Case Title (Name of Public Official or Entity Allegedly Involved)":"John H. O\u0027Halloran","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Trinidad and Tobago","Position of Public Official(s) (yrs in office)":"People\u0027s National Movement official (1956-1970), Chairman of the Trinidad and Tobago Racing Authority (inclusive 1980-1981)","Jurisdiction of Asset Recovery":"Canada","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1983","Asset Recovery End":"1991","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Unspecified","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In 1985, Mr. O\u0027Halloran went to Canada, where he died.  The Republic of Trinidad and Tobago, Trinidad and Tobago (B.W.I.A. International) Airways Corporation, Trinidad-Tesoro Petroleum Company Limited and Trinidad and Tobago Racing Authority brought a civil suit in Toronto, Canada to recover damages from Mr. O\u0027Halloran\u0027s estate.  On June 3, 1991, the Ontario Court of Justice issued a judgment ordering Mr. O\u0027Halloran\u0027s estate to pay the sum of $7.65 million to the Government of Trinidad and Tobago, Trinidad and Tobago (B.W.I.A. International) Airways Corporation, and the Trinidad and Tobago Racing Authority, as well as all of the plaintiffs\u0027 court costs. (Source: Republic of Trinidad and Tobago, Trinidad and Tobago (B.W.I.A. International) Airways Corporation, Trinidad-Tesoro Petroleum Company Limited, and Trinidad and Tobago Racing Authority v. John Frederick Cameron, Litigation Administrator for the Estate of John H. O\u0027Halloran, et al, Court file No. 29841\/88, Ontario Court of Justice (General Division) Judgment of June 3, 1991.)","Disposition of Criminal Case(s)":"According to the summary by the University of West Indies Library of Mr. O\u0027Halloran\u0027s papers, in 1983, Mr. O\u0027Halloran was charged by the Government of Trinidad and Tobago.with accepting bribes.  (Source: The University of the West Indies at St. Augustine, Trinidad and Tobago, The Alma Jordan Library, Special Collections, \u0022O\u0027Halloran Papers,\u0022 accessed at   http:\/\/www.mainlib.uwi.tt\/divisions\/wi\/collsp\/summaries\/ohalloran.htm.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"N\/A","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"McMillan Binch, Barristers \u0026 Solicitors (Attorneys William G. Horton and Paul G. MacDonald)","Jurisdiction of Asset Recovery: Courts Involved":"Ontario Court of Justice (General Division)","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_Canada_Ontario_Judgment_Jun_3_1991.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/O%27Halloran_Wallace_Company_FCPA_Traceinternational_Compendium.pdf","Sources ":"Republic of Trinidad and Tobago, Trinidad and Tobago (B.W.I.A. International) Airways Corporation, Trinidad-Tesoro Petroleum Company Limited, and Trinidad and Tobago Racing Authority v. John Frederick Cameron, Litigation Administrator for the Estate of John H. O\u0027Halloran, et al, Court file No. 29841\/88, Ontario Court of Justice (General Division) Judgment of June 3, 1991, obtained with the assistance of Toronto Region Court Services Division, Ontario Ministry of the Attorney General.  \nSee also, US v. Rodriguez (Sam P. Wallace Co.), Case No. 83-0044 (D.P.R.), Information filed March 11, 1983.\n"},{"Case ID":"ARW-91","Case Title (Name of Public Official or Entity Allegedly Involved)":"John O\u0027Halloran\/ Tesoro Petroleum Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Trinidad and Tobago","Position of Public Official(s) (yrs in office)":"People\u0027s National Movement official (1956-1970), Chairman of the Trinidad and Tobago Racing Authority (inclusive 1980-1981)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1989","Asset Recovery End":"1990","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Unknown","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"In July 1990, then-Attorney General of Trinidad and Tobago Selwyn Richardson obtained a settlement from Tesoro Petroleum for some $7.5 million in connection with the company\u0027s bribery case. The law firm of Wilmer Cutler in Washington, DC was counsel to the government.   (Source: Trinidad and Tobago, House of Representatives Parliamentary Proceedings, July 27, 1990.)","Disposition of Criminal Case(s)":"According to the summary by the University of West Indies Library of Mr. O\u0027Halloran\u0027s papers, in 1983, Mr. O\u0027Halloran was charged by the Government of Trinidad and Tobago.with accepting bribes.  (Source: The University of the West Indies at St. Augustine, Trinidad and Tobago, The Alma Jordan Library, Special Collections, \u0022O\u0027Halloran Papers,\u0022 accessed at   http:\/\/www.mainlib.uwi.tt\/divisions\/wi\/collsp\/summaries\/ohalloran.htm.)","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Wilmer Cutler law firm","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_SDNY_Docket_Rpt_TT v Tesoro_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Trinidad_Parliament_Tesoro_Jul_27_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Company_FCPA_Traceinternational_Compendium.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Judgment.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_SEC_Complaint.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Trace_Intl_Summary.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/O%27Halloran_Wallace_Company_FCPA_Traceinternational_Compendium_1.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_SDNY_Docket_Rpt_TT v Tesoro_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Trinidad_Parliament_Tesoro_Jul_27_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Company_FCPA_Traceinternational_Compendium.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Judgment.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_SEC_Complaint.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Trace_Intl_Summary.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/O%27Halloran_US_SDNY_Docket_Rpt_TT%20v%20Tesoro_1990_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_SDNY_Docket_Rpt_TT v Tesoro_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Trinidad_Parliament_Tesoro_Jul_27_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Company_FCPA_Traceinternational_Compendium.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Judgment.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_SEC_Complaint.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Trace_Intl_Summary.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/O%27Halloran_US_Trinidad_Parliament_Tesoro_Jul_27_1990_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_SDNY_Docket_Rpt_TT v Tesoro_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Trinidad_Parliament_Tesoro_Jul_27_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Company_FCPA_Traceinternational_Compendium.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Judgment.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_SEC_Complaint.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Trace_Intl_Summary.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/O%27Halloran_US_Wallace_Judgment.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_SDNY_Docket_Rpt_TT v Tesoro_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Trinidad_Parliament_Tesoro_Jul_27_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Company_FCPA_Traceinternational_Compendium.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Judgment.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_SEC_Complaint.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Trace_Intl_Summary.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/O%27Halloran_US_Wallace_SEC_Complaint.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_SDNY_Docket_Rpt_TT v Tesoro_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Trinidad_Parliament_Tesoro_Jul_27_1990.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Company_FCPA_Traceinternational_Compendium.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Judgment.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_SEC_Complaint.pdf.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/O\u0027Halloran_US_Wallace_Trace_Intl_Summary.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/O%27Halloran_US_Wallace_Trace_Intl_Summary.pdf","Sources ":"Trinidad and Tobago, House of Representatives Parliamentary Proceedings, July 27, 1990; The Republic of Trinidad and Tobago v. Tesoro Petroleum Corporation, et al, 1:89-civ-01663-LLS (S.D.N.Y.) (filed March 10, 1989; settled and closed June 29, 1990), case files not available through Pacer but cause of action was civil Racketeer Influenced and Corrupt Organizations Act. See also, US v. Rodriguez (Sam P. Wallace Co.), Case No. 83-0044 (D.P.R.), Information filed March 11, 1983, accessed at Trace International Compendium.\n"},{"Case ID":"ARW-94","Case Title (Name of Public Official or Entity Allegedly Involved)":"Joshua Dariye \/ Joyce Oyebanjo","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria","Position of Public Official(s) (yrs in office)":"Governor (Dariye, 1999-2006) \/ Associate (Oyebanjo)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"2007","UNCAC Offenses Implicated":"Art.17, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"The UK\u0027s Foreign \u0026 Commonwealth Office stated that the \u0022The return of [Dariye\/Oyebanjo -related] assets fulfils the UK\u0027s commitments under Chapter V of the United Nations Convention Against Corruption and is the result of continued co-operation with the Nigerian authorities.\u0022  (Source: UK Foreign and Commonwealth Office Press Release, \u0022UK Returns Stolen Funds to Nigeria,\u0022 April 24, 2009.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to evidence presented to the United Kingdom Parliament\u0027s International Development Committee by the UK Department for International Development, GBP 115,000 in the Joshua Dariye case and GBP 185,000 in Mr. Dariye\u0027s associate Joyce Oyebanjo\u0027s case have been returned to Nigeria. (Source: UK Parliament, International Development Committee, \u0022Supplementary written evidence submitted by The Department for International Development (DFID),\u0022 June 2012.)  Ms. Oyebanjo had been arrested by the London Metropolitan Police in 2004 and subsequently convicted of assisting Chief Dariye to retain the benefits of criminal conduct contrary to section 93A(1)(a) of the Criminal Justice Act 1988. (Sources: Nigeria v. Dariye, Claim no. HC 07-C00169 filed January 25, 2007 in the UK High Court of Justice Chancery Division; UK Foreign and Commonwealth Office Press Release, \u0022UK Returns Stolen Funds to Nigeria,\u0022 April 24, 2009; Transparency International UK, \u0022Combating Money Laundering and Recovering Looted Gains: Raising the UK\u0027s Game,\u0022 Appendix 1: Summaries of Recent Criminal and Civil Cases against Politically Exposed Persons in the UK, June 2009.)","Disposition of Criminal Case(s)":"According to the website of Nigeria\u0027s Economic and Financial Crimes Commission, Mr. Dariye\u0027s trial in Nigeria was contined to October 2010. (Source: Economic \u0026 Financial Crimes Commission, \u0022EFCC On-Going High Profile Cases,\u0022 2007-2010, posted at http:\/\/www.efccnigeria.org\/index.php?option=com_docman\u0026task=doc_view\u0026gid...).  According to the January 25, 2007 Particulars of Claim filed by the Government of Nigeria in its UK civil claim against Mr. Dariye, on September 2, 2004, Mr. Dariye was arrested and interviewed by the Metropolitan Police in London.  After he failed to answer Police bail on December 14, 2004 and returned to Nigeria, a warrant was issued for his arrest on charges of money laundering and obtaining services by deception. (Source:  Nigeria v. Dariye, Claim No. HC07-00169, High Court of Justice (Chancery Division).","Jurisdiction of Origin: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Economic and Financial Crimes Commission","Jurisdiction of Origin: Courts Involved":"FTC Hgh Court - Gudu","Jurisdiction of Asset Recovery: Investigative Agency":"Metropolitan Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service","Jurisdiction of Asset Recovery: Courts Involved":"Southwark Crown Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Dariye_UK_FCO_Return_Apr_24_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Dariye_UK_FRN v Dariye\u0026Dariye_Approved Judgment_Mar_12_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Dariye_UK_FRN_v_Dariye_and_Dariye_2007_EWHC_0169_Jan_25_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Transparency_Intl_UK_Recovering_Looted_Gains_June_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Dariye_UK_FRN%20v%20Dariye%26Dariye_Approved%20Judgment_Mar_12_2007.pdf","Sources ":"UK Parliament, International Development Committee, \u0022Supplementary written evidence submitted by The Department for International Development (DFID),\u0022 June 2012, accessed at http:\/\/www.publications.parliament.uk\/pa\/cm201213\/cmselect\/cmintdev\/130\/... UK Foreign and Commonwealth Office Press Release, \u0022UK Returns Stolen Funds to Nigeria,\u0022 April 24, 2009, accessed at http:\/\/ukinnigeria.fco.gov.uk\/en\/news\/?view=PressR\u0026id=17622693 10\/; Nigeria v. Joshua Chibi Dariye and Valentina Dariye, Claim No: HC 07 C00169, filed January 25, 2007 in the High Court of Justice, Chancery Division; Transparency International UK, \u0022Combating Money Laundering and Recovering Looted Gains: Raising the UK\u0027s Game,\u0022 Appendix 1: Summaries of Recent Criminal and Civil Cases against Politically Exposed Persons in the UK (June 2009).\n"},{"Case ID":"ARW-95","Case Title (Name of Public Official or Entity Allegedly Involved)":"Juthamas Siriwan (Jersey)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Thailand","Position of Public Official(s) (yrs in office)":"Governor of Tourism (2002-2006)","Jurisdiction of Asset Recovery":"Jersey","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution (US)","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case (in U.S.)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Unknown","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"\n\tAs of May 22, 2016, the US criminal case was ongoing. \u00a0( U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Court Docket Report as of May 22, 2016.)\n\n\t\u00a0\n\n\tIn January 2009, United States authorities filed a criminal indictment against Ms.Siriwan and her daughter on charges of violating the Foreign Corrupt Practices Act; their indictment includes criminal forfeiture allegations against bank accounts located in Isle of Jersey (HSBC Bank International Limited, Acct #11108670 in amount of $411,434.80; Singapore (Citibank Bank, Acct #0259766-001 in the amount of $543,456.79 and Standard Chartered Bank, Acct #25-0-852573-6); United Kingdom (HSBC Bank PLC, Acct #22751518). \u00a0The indictment also noted that under Section 152 of Thailand\u0027s Penal Code, it is unlawful for any government official, having the duty of managing or looking after any activity, to take the interest for the benefit of herself or another person concerning such activity. (Source: U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Indictment filed January 28, 2009.) \u00a0According to Ms. Siriwan\u0027s Court Docket Report, on April 7, 2011, the U.S. District Court for the Central District granted the U.S. Government\u0027s ex-parte application seeking the extradition of Ms. Siriwan and her daughter\/co-defendant. \u00a0(Source: US v. Siriwan, 2:09-cr-00081 (C.D. Cal.), Court Docket Report.) \u00a0","Disposition of Criminal Case(s)":"\nAccording to the Joint Status Report and Indictment filed by Thai Special Prosecutor (Exh A in Thai and Exh B in English translation), Ms. Siriwan has been charged with violations of Thai laws pertaining to conduct of Thai officials and the Criminal Code pertaining to acceptance of bribery. The US criminal case against Ms. Siriwan is ongoing as of May 22, 2016. (Source: US v. Siriwan, Case No. 2:09-cr-81 (C.D. Cal), Joint Status Report of the Parties filed on October 13, 2015 and Exhibits A and B; Court Docket Report as of May 22, 2016.)\n\n\u00a0","Jurisdiction of Origin: Investigative Agency":"National Anti-Corruption Commission of Thailand; Attorney General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Special Prosecutor Office, Special Case Department 2","Jurisdiction of Origin: Courts Involved":"Criminal Court","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_USG_Supplemental_Resp_Jan_11_2013_1.pdf","Sources ":"U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), \u00a0Indictment filed January 28, 2009; \u00a0Joint Stipulation to Continue Hearing Date; and Order filed October 17, 2011; Government\u0027s Third Supplemental Brief in Opposition to Defendant\u0027s Motion to Dismiss and Exhibit A, filed January 11, 2013; Status Report by US and Exhibit A (Letter by Thailand\u0027s Office of the National Anti-Corruption Commission) filed March 10, 2014; Joint Status Report of the Parties and Exhibits A and B,filed October 13, 2015 and Court Docket Report as of May 22, 2016.)\n"},{"Case ID":"ARW-96","Case Title (Name of Public Official or Entity Allegedly Involved)":"Juthamas Siriwan (Singapore)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Thailand","Position of Public Official(s) (yrs in office)":"Governor of Tourism (2002-2006)","Jurisdiction of Asset Recovery":"Singapore","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture (US)","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case ","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Unknown","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tAs of May 22, 2016, the US criminal case was ongoing. \u00a0( U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Court Docket Report as of May 22, 2016.)\n\n\t\u00a0\n\n\tIn January 2009, United States authorities filed a criminal indictment against Ms.Siriwan and her daughter on charges of violating the Foreign Corrupt Practices Act; their indictment includes criminal forfeiture allegations against bank accounts located in Isle of Jersey (HSBC Bank International Limited, Acct #11108670 in amount of $411,434.80; Singapore (Citibank Bank, Acct #0259766-001 in the amount of $543,456.79 and Standard Chartered Bank, Acct #25-0-852573-6); United Kingdom (HSBC Bank PLC, Acct #22751518). \u00a0The indictment also noted that under Section 152 of Thailand\u0027s Penal Code, it is unlawful for any government official, having the duty of managing or looking after any activity, to take the interest for the benefit of herself or another person concerning such activity. (Source: U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Indictment filed January 28, 2009.)\u00a0\n\n\t\u00a0","Disposition of Criminal Case(s)":"According to the Joint Status Report and Indictment filed by Thai Special Prosecutor (Exh A in Thai and Exh B in English translation), Ms. Siriwan has been charged with violations of Thai laws pertaining to conduct of Thai officials and the Criminal Code pertaining to acceptance of bribery. The US criminal case against Ms. Siriwan is ongoing as of May 22, 2016. (Source: US v. Siriwan, Case No. 2:09-cr-81 (C.D. Cal), Joint Status Report of the Parties filed on October 13, 2015 and Exhibits A and B; Court Docket Report as of May 22, 2016.)","Jurisdiction of Origin: Investigative Agency":"National Anti-Corruption Commission of Thailand; Attorney General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Special Prosecutor Office, Special Case Department 2","Jurisdiction of Origin: Courts Involved":"Criminal Court","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_USG_Supplemental_Resp_Jan_11_2013_3.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_USG_Supp_Resp_Thai_Govt_Exhibit_A_Jan_11_2013_2.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_Status_Rept_Mar_10_2014_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Court_Docket_Report_May_3_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_US_Indictment_Jan_28_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Court_Docket_Report_Nov_2_2011, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_CDCAL_Order_Hearing_Motion_to_Dismiss_Set_for_Nov_21_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_Status_Exhibit_A_Filed_Mar_10_2014_0.pdf","Sources ":"U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), \u00a0Indictment filed January 28, 2009; \u00a0Joint Stipulation to Continue Hearing Date; and Order filed October 17, 2011; Government\u0027s Third Supplemental Brief in Opposition to Defendant\u0027s Motion to Dismiss and Exhibit A, filed January 11, 2013; Status Report by US and Exhibit A (Letter by Thailand\u0027s Office of the National Anti-Corruption Commission) filed March 10, 2014; Joint Status Report of the Parties and Exhibits A and B,filed October 13, 2015 and Court Docket Report as of May 22, 2016.)\n"},{"Case ID":"ARW-97","Case Title (Name of Public Official or Entity Allegedly Involved)":"Juthamas Siriwan (Thailand)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Thailand","Position of Public Official(s) (yrs in office)":"Governor of Tourism (2002-2006)","Jurisdiction of Asset Recovery":"Thailand","Jurisdiction of Asset Description":"Undertaking Recovery Effort","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Ongoing Case   ","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Before Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\nAs of May 22, 2016, the US criminal case was ongoing. \u00a0( U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Court Docket Report as of May 22, 2016.)\n\n\n\tThe March 2014 letter by Thailand\u0027s Office of National Anti-Corruption Commission and December 14, 2012 letter (please see \u0022Disposition of Criminal Case\u0022) by the Thai Ministry of Foreign Affairs follow a March 2010 letter by Thailand\u0027s Office of the National Anti-Corruption Commission to the California court in the case of Gerald and Patricia Green (the convicted bribe givers) had stated that Thailand had initiated investigations into the alleged corrupt conduct of the former tourism government and other Thai nationals in the case. \u00a0(Sources: US v. Siriwan, Case No. 2:09-cr-81 (C.D. Cal), Status Report and Exhibit A filed March 10, 2014; U.S. v. Green, Case No. 2:08-cr-00059-GW (C.D. Cal.), Government\u0027s Supplemental Sentencing Memorandum for Defendants Gerald Green and Patricia Green and Exhibit E (Letter by the National Anti-Corruption Commission of Thailand regarding their investigation of the Juthamas Siriwan bribery case), both filed on March 12, 2010.) \u00a0","Disposition of Criminal Case(s)":"According to the Joint Status Report and Indictment filed by Thai Special Prosecutor (Exh A in Thai and Exh B in English translation), Ms. Siriwan has been charged with violations of Thai laws pertaining to conduct of Thai officials and the Criminal Code pertaining to acceptance of bribery. The US criminal case against Ms. Siriwan is ongoing as of May 22, 2016. (Source: US v. Siriwan, Case No. 2:09-cr-81 (C.D. Cal), Joint Status Report of the Parties filed on October 13, 2015 and Exhibits A and B; Court Docket Report as of May 22, 2016.)","Jurisdiction of Origin: Investigative Agency":"National Anti-Corruption Commission of Thailand; Attorney General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Special Prosecutor Office, Special Case Department 2","Jurisdiction of Origin: Courts Involved":"Criminal Court","Jurisdiction of Asset Recovery: Investigative Agency":"National Anti-Corruption Commission of Thailand","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"N\/A","Jurisdiction of Asset Recovery: Courts Involved":"Criminal Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_Thailand_NACC_Investig_Bangkok_Post_Aug_14_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_Thailand_NACC_Letter_Filed_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_Thailand_USG_Sentencing_Memo_Mar_12_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_USG_Supplemental_Resp_Jan_11_2013_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_Thailand_NACC_Investig_Bangkok_Post_Aug_14_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_Thailand_NACC_Letter_Filed_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_Thailand_USG_Sentencing_Memo_Mar_12_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_USG_Supp_Resp_Thai_Govt_Exhibit_A_Jan_11_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_Thailand_NACC_Investig_Bangkok_Post_Aug_14_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_Thailand_NACC_Letter_Filed_Mar_12_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siriwan_Thailand_USG_Sentencing_Memo_Mar_12_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siriwan_US_CDCA_Status_Rept_Mar_10_2014_1.pdf","Sources ":"\n\n\t\tU.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), \u00a0Indictment filed January 28, 2009; \u00a0Joint Stipulation to Continue Hearing Date; and Order filed October 17, 2011; Government\u0027s Third Supplemental Brief in Opposition to Defendant\u0027s Motion to Dismiss and Exhibit A, filed January 11, 2013; Status Report by US and Exhibit A (Letter by Thailand\u0027s Office of the National Anti-Corruption Commission) filed March 10, 2014; Joint Status Report of the Parties and Exhibits A and B,filed October 13, 2015 and Court Docket Report as of May 22, 2016.)\n\n\t\tU.S. v. Green, Case No. 2:08-cr-00059-GW (C.D. Cal.), Government\u0027s Supplemental Sentencing Memorandum for Defendants Gerald Green and Patricia Green and Exhibit E (Letter by the National Anti-Corruption Commission of Thailand regarding their investigation of the Juthamas Siriwan bribery case), both filed on March 12, 2010.\n\n\t\t\u00a0\n\n\t\tSee also Bangkok Post, \u0022US wants Juthamas extradited,\u0022 August 4, 2012, at http:\/\/www.bangkokpost.com\/news\/local\/305892\/us-wants-juthamas-extradited\n\n\u00a0\n"},{"Case ID":"ARW-98","Case Title (Name of Public Official or Entity Allegedly Involved)":"Juthamas Siriwan (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Thailand","Position of Public Official(s) (yrs in office)":"Governor of Tourism (2002-2006)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2009","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.16, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture (U.S.)","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Unknown","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tAs of May 22, 2016, the US criminal case was ongoing. \u00a0( U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Court Docket Report as of May 22, 2016.)\u00a0\n\n\t\u00a0\n\n\tIn January 2009, United States authorities filed a criminal indictment against Ms. Siriwan and her daughter on charges of money laundering and transporting funds to support unlawful activity. The indictment included criminal forfeiture allegations against bank accounts located in Isle of Jersey (HSBC Bank International Limited, Acct #11108670 in amount of $411,434.80; Singapore (Citibank Bank, Acct #0259766-001 in the amount of $543,456.79 and Standard Chartered Bank, Acct #25-0-852573-6); United Kingdom (HSBC Bank PLC, Acct #22751518). \u00a0The indictment also noted that under Section 152 of Thailand\u0027s Penal Code, it is unlawful for any government official, having the duty of managing or looking after any activity, to take the interest for the benefit of herself or another person concerning such activity. (Source: U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Indictment filed January 28, 2009.) \u00a0Ms. Siriwan has filed a Motion to Dismiss the Indictment in January 2012. (Source: \u00a0U.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), Court Docket Report, entry for January 30, 2012.)\u00a0","Disposition of Criminal Case(s)":"According to the Joint Status Report and Indictment filed by Thai Special Prosecutor (Exh A in Thai and Exh B in English translation), Ms. Siriwan has been charged with violations of Thai laws pertaining to conduct of Thai officials and the Criminal Code pertaining to acceptance of bribery. The US criminal case against Ms. Siriwan is ongoing as of May 22, 2016. (Source: US v. Siriwan, Case No. 2:09-cr-81 (C.D. Cal), Joint Status Report of the Parties filed on October 13, 2015 and Exhibits A and B; Court Docket Report as of May 22, 2016.)","Jurisdiction of Origin: Investigative Agency":"National Anti-Corruption Commission of Thailand; Attorney General\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Special Prosecutor Office, Special Case Department 2","Jurisdiction of Origin: Courts Involved":"Criminal Court","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"","Sources ":"\n\n\n\t\t\tU.S. v. Siriwan, et al., Case No. 2:09-CR-00081 (C.D. Cal.), \u00a0Indictment filed January 28, 2009; \u00a0Joint Stipulation to Continue Hearing Date; and Order filed October 17, 2011; Government\u0027s Third Supplemental Brief in Opposition to Defendant\u0027s Motion to Dismiss and Exhibit A, filed January 11, 2013; Status Report by US and Exhibit A (Letter by Thailand\u0027s Office of the National Anti-Corruption Commission) filed March 10, 2014; Joint Status Report of the Parties and Exhibits A and B,filed October 13, 2015 and Court Docket Report as of May 22, 2016.)\n\n\t\t\t\u00a0\n\n\t\t\tThe indictment can also be downloaded at the U.S. Department of Justice website: http:\/\/www.justice.gov\/criminal\/fraudsiriwan.html.\/fcpa\/cases\/.\n\n\t\t\t\u00a0\n\n\t\t\tSee also Bangkok Post, \u0022US wants Juthamas extradited,\u0022 August 4, 2012 "},{"Case ID":"ARW-162","Case Title (Name of Public Official or Entity Allegedly Involved)":"Samuel Gichuru \/ CB (Chris) Okemu","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Kenya","Position of Public Official(s) (yrs in office)":"former Kenya Lighting and Power Company Chief Executive Officer, (Gichuru, 1984-2003; joined in 1974 as assistant company secretary) \/ Member of Parliament (Okemu)","Jurisdiction of Asset Recovery":"Jersey","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Criminal Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"Extradition Request by Jersey to Kenya","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"$34,343","Assets Adjudicated, Not Yet Returned (USD)":"$5,168,360","Assets Returned (USD)":"","Agreement for Returned Assets":"NA","Agreement for Returned Assets - Description":"N\/A","Case Summary":"In February 2016, the Jersey Royal Court ordered the confiscation of amounts totalling US$9.8 million from the accounts of Windward Trading Limited. \u00a0The Court stated, \u0022The defendant company has pleaded guilty to four counts of money laundering offences involving a total of \u00a32,599,050 and US$2,971,743 respectively acquired or possessed by the defendant company between 29th July, 1999, and 19th October, 2001. The defendant company received and held the proceeds of criminal conduct perpetrated by its controlling mind and beneficial owner, Samuel Gichuru. The company knowingly enabled Gichuru to obtain substantial bribes paid to him while he held public office in Kenya. The company played a vital role without which corruption on a grand scale is impossible: money laundering.\u00a0\n2. Gichuru was the chief executive of Kenya\u2019s power utility, the Kenya Power \u0026 Lighting Company (\u201cKPLC\u201d) from November 1984 until February 2003. He accepted bribes from foreign businesses that contracted with that company during his term of office and hid them in Jersey.\u0022 The Court also stated that the confiscated assets totalling about $5.17 million \u0022will be transferred to the Criminal Offences Confiscation Fund with a view to their repatriation to Kenya, the victim of the offending.\u0022 (Source: Attorney General v. Windward Trading Limited, [2016] JRC 48A, February 24, 2016.)\u00a0\n\u00a0\nAccording to the April 25, 2008 Jersey Royal Court decision in an action between Samuel Gichuru and Walbrook Trustees (Jersey) Limited, et al (respondents) and Chief Officer of the States of Jersey Police (Party convened), Mr. Gichuru was the chief executive officer of the Kenya Lighting and Power Company, a majority state-owned entity. \u00a0 He stated that in Kenya public servants were not barred from running their own businesses until 2003 and he had wide-ranging commercial and business operations. \u00a0In 1981, Mr. Gichuru opened a bank account in Jersey. He also stated that the account was opened for the receipt of fees which he earned from business introductions and as a consultant. \u00a0In about 1986, he was advised by the Jersey office of Deloitte \u0026 Touche (forerunner to the respondents, \u0022Walbrook\u0022) that his needs would be better served by having a company. Accordingly in August 1986 Windward Trading Limited was incorporated in Jersey. Walbrook is the administrator of Windward and provides its directors and secretary. \u00a0Windward had bank accounts with HSBC Bank Plc and the Royal bank of Scotland International Limited, to which Walbrook provided signatories to the accounts. \u00a0The Court stated that Mr. Gichuru is the beneficial owner of Windward and the various Walbrook entities hold the shares as nominees for him. In May 2002, Walbrook filed a Suspicious Activity Report with the police and the police did not give consent to Walbrook making any payments and Walbrook refused to make any payments from Windward to Mr. Gichuru since then. \u00a0On August 21, 2003, a notice under the Investigation of Fraud (Jersey) Law 1990 was issued by the Attorney General demaning documents and information. In October 2003, Mr. Gichuru was informed that the Finnish authorities had sought information from the Jersey authorities about him and Windward. (Source: Between Samuel K. Gichuru and Walbrook, et al, 2008 JRC 068 (Jersey Royal Court, Samedi Division, April 25, 2008). \u00a0 August 17, 2011 post by the Kenyan Anti-Corruption Commission, \u0022Okemo and Gichuru are wanted in the Island of Jersey to face 53 charges over commissions paid by international and local companies for KPLC [Kenya Power and Lighting Company] business, mostly between 1999 and 2002, totaling 4,459,572 Sterling pounds, 786,853 Danish kronor and 3,207,360 US dollars (Kshs 902 million in total).\u0022 \u00a0Jersey is seeking their extradition from Kenya. \u00a0(Source: Kenyan Anti-Corruption Commission Current News 2011, posted August 17, 2011 (Carole Maina, \u0022KACC Told to Wait in Gichuru, Okemo Suit,\u0022 The Star, August 13, 2011). \u00a0See also, NTV Kenya coverage of August 2011 extradition proceedings at http:\/\/www.ntv.co.ke\/News\/Extradition+hearing\/-\/471778\/1213790\/-\/13oh4k7....)","Disposition of Criminal Case(s)":"According to an October 29, 2013 news article posted on the Kenyan Ethics and Anti Corruption Commission, it had commenced an investigation against Okemo and Gichuru. \u00a0(Source: \u0022 EACC Probes Okemo and Gichuru,\u0022 October 29, 2013.) \u00a0Windward Trading Limited - the account holder of the assets deemed to be proceeds of bribery payments received by Mr. Gichuru, entered a guilty plea in the Isle of Jersey to four counts of money laundering. The plea had been entered into by Zedra Trust Company Limited, which acquired the trust business of Barclays Wealth in January 2016 and as a result, provided two corporate directors to Windward Trading Limited. \u00a0(Source: Attorney General v. Windward Trading Limited, [2016] JRC 048A, February 24, 2016.)","Jurisdiction of Origin: Investigative Agency":"Kenyan Anti-Corruption Commission","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Director of Public Prosecutions","Jurisdiction of Origin: Courts Involved":"High Court","Jurisdiction of Asset Recovery: Investigative Agency":"Attorney General\u0027s Office, Solicitor General","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney General\u0027s Office, Solicitor General","Jurisdiction of Asset Recovery: Courts Involved":"Royal Court (Samedi Division)","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Jersey_Royal_Court_Walbrook_2008_JRC_068.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_KACC_Failed_Amnesty_Jul_29_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_KACC_Files_to_Join_Extradition_Suit_KAC_Whatsnew_Aug_10_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Okema_KACC_Post_KACC_told-to-wait_Aug_17_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Okema_NTV_Extradition_Hearing_Aug_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Gichuru_Okemo_EACC_Investigation_Commence_Oct_29_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Jersey_Royal_Court_Walbrook_2008_JRC_068.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_KACC_Failed_Amnesty_Jul_29_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_KACC_Files_to_Join_Extradition_Suit_KAC_Whatsnew_Aug_10_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Okema_KACC_Post_KACC_told-to-wait_Aug_17_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Okema_NTV_Extradition_Hearing_Aug_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Gichuru_KACC_Failed_Amnesty_Jul_29_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Jersey_Royal_Court_Walbrook_2008_JRC_068.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_KACC_Failed_Amnesty_Jul_29_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_KACC_Files_to_Join_Extradition_Suit_KAC_Whatsnew_Aug_10_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Okema_KACC_Post_KACC_told-to-wait_Aug_17_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Okema_NTV_Extradition_Hearing_Aug_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Gichuru_KACC_Files_to_Join_Extradition_Suit_KAC_Whatsnew_Aug_10_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Jersey_Royal_Court_Walbrook_2008_JRC_068.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_KACC_Failed_Amnesty_Jul_29_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_KACC_Files_to_Join_Extradition_Suit_KAC_Whatsnew_Aug_10_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Okema_KACC_Post_KACC_told-to-wait_Aug_17_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Gichuru_Okema_NTV_Extradition_Hearing_Aug_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Gichuru_Jersey_AG-v-Windward%20Trading%20Limited_2016_JRC_48A_24-Feb-2016.pdf","Sources ":"Attorney General v. Windward Trading Limited, [2016] JRC 48A, February 24, 2016, at https:\/\/www.jerseylaw.je\/judgments\/unreported\/Pages\/[2016]JRC048A.aspx;\n\u00a0\nKenya Ethics and Anti Corruption Commission, \u0022EACC Probes Okemo and Gichuru,\u0022 October 29, 2013,\u0022 at http:\/\/www.eacc.go.ke\/media.ASP?ID=501; Kenya Anti-Corruption Commission Press Release posted August 17, 2011 (Jillo Kadida, \u0022KACC files to join Okemo, Gichuru Extradition Suit,\u0022 The Star, August 10, 2011), accessed at http:\/\/www.kacc.go.ke\/pressreleases.ASP?ID=323;\u00a0\n\u00a0\nKenyan Ethics and Anti-Corruption Commission Current News 2011, posted August 17, 2011 (Carole Maina, \u0022KACC Told to Wait in Gichuru, Okemo Suit,\u0022 The Star, August 13, 2011), accessed at http:\/\/www.kacc.go.ke\/whatsnew.asp?id=324;\u00a0\n\u00a0\nKACC Current News - Year 2011, \u0022Amnesty to Avoid Prosecution,\u0022 etc. posted July 29, 2011, accessed at http:\/\/www.kacc.go.ke\/whatsnew.asp?id=307. \u00a0\n\u00a0\nSee also, NTV Kenya coverage of August 2011 extradition proceedings at http:\/\/www.ntv.co.ke\/News\/Extradition+hearing\/-\/471778\/1213790\/-\/13oh4k7...);\u00a0\n\u00a0\nBetween Samuel K. Gichuru and Walbrook, et al, 2008 JRC 068 (Jersey Royal Court, Samedi Division, April 25, 2008).\n"},{"Case ID":"ARW-170","Case Title (Name of Public Official or Entity Allegedly Involved)":"Sanjaya Bahel \/ Nishan Kohli","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United Nations","Position of Public Official(s) (yrs in office)":"Chief of the Commodity Procurement Section, Procurement Division (1998-2003); Chief of the Commercial Activities Service in the UN Postal Administration (2003-2006): Bahel); Son of close friend of Bahel (Kohli)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2006","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16, Art.19","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution, Criminal Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"Cooperation by the United Nations Office of Investigative Oversight Services\/Procurement Task Force","Contributing Factors in Asset Recovery":"United Nations waiver of immunity of Mr. Bahel; cooperation in the investigation by the United Nations Office of Investigative Oversight Services\/Procurement Task Force (Sources:  United States v. Bahel, Docket No. 08-3327-cr (2nd Cir.), Judgment dated October 31, 2011; United States Attorney\u0027s Office for the Southern District of New York Press Release, \u0022United Nations Procurement Official Sentenced to 8 Years in Prison on Corruption Charges,\u0022 April 1, 2008.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$1,447,450.80","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the Press Release by the United States Attorney\u0027s Office for the Southern District of New York, on April 1, 2008, Mr. Bahel, \u0022former Chief of the Commodity Procurement Section within the Procurement Division of the United Nations (\u201cUN\u201d), was sentenced today in Manhattan federal court to 97 months in prison on his convictions for accepting hundreds of thousands of dollars\u2019 worth of benefits from a UN vendor in exchange for his assistance in awarding tens of millions of dollars\u2019 worth of UN contracts to the vendor.\u0022  (Source: United States Attorney\u0027s Office for the Southern District of New York Press Release, \u0022United Nations Procurement Official Sentenced to 8 Years in Prison on Corruption Charges,\u0022 April 1, 2008.)  Nishan Kohli was the son of a close friend of Mr. Bahel whose companies were involved in the corruption scheme.  As noted in the August 8, 2008 Stipulation and Order filed in US v. Nishan Kohli, on June 27, 2008, the US District Court ordered Mr. Bahel to pay restitution in the amount of $932,165.30 to the United Nations, of which $846,067.43 was to compensate the United Nations for the legal expenses that the UN incurred between February 2006 and June 2007, as a result of the US Government\u0027s investigation and prosecution of Mr. Bahel.  The UN also sought (and was granted) restitution from Mr. Kohli in the amount of $515,285.41, the amount the UN incurred between February 2006 and October 2006, prior to Mr. Kohli\u0027s cooperation with the US Government in its investigation and prosecution. (Source: US v. Nishan Kohli, Case No. 1:06-cr-00918-2-TPG (S.D.N.Y.), Stipulation and Order filed August 8, 2008 and Judgment in a Criminal Case filed August 26, 2008).","Disposition of Criminal Case(s)":"According to his Judgment in a Criminal Case, Mr. Bahel was convicted in 2008 following a jury trial, in the US District Court for the Southern District of New York, on six counts of fraud and bribery related charges.  (Source: US v. Sanjaya Bahel, Case No. 1:06-cr-00918-1TPG (S.D.N.Y.), Judgment in a Criminal Case filed June 30, 2008).  His conviction was upheld by the Second Circuit appeals court. (Source:  United States v. Bahel, Docket No. 08-3327-cr (2nd Cir.), Judgment dated October 31, 2011.)  According to his Judgment in a Criminal Case, Mr. Kohli pleaded guilty, in December 2006, to one count bribery concerning an organization receiving federal funds.  (Source: US v. Nishan Kohli, Case No. 1:06-cr-00918-2-TPG (S.D.N.Y.), Judgment in a Criminal Case filed August 26, 2008).","Jurisdiction of Origin: Investigative Agency":"United Nations Office of Investigative Oversight Services \/ Procurement Task Force","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation; United Nations Office of Investigative Oversight\r\nServices \/ Procurement Task Force","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney for the Southern District of New York","Jurisdiction of Asset Recovery: Courts Involved":"US District Court for the Southern District of New York","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bahel_SDNY_Docket_Report_Nov_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bahel_SDNY_Superseding_Indictment_Apr_11_2007.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bahel_SDNY_Judgment_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bahel_SDNY_Sentencing_Press_Release_Apr_1_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bahel_SDNY_Satisfaction_Judgement_Jul_18_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Bahel_US_2nd_Circuit_Decision_Uphold_Conviction_Restitution_Oct_26_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kohli_SDNY_Judgment_Aug_26_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kohli_SDNY_Stipulation_Order_Restitution_Aug_8_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kohli_SDNY_Satisfaction_Judgement_Jun_8_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Bahel_SDNY_Superseding_Indictment_Apr_11_2007.pdf","Sources ":"US v. Sanjaya Bahel, Case No. 1:06-cr-00918-1-TPG (S.D.N.Y.), Court Docket Report as of November 4, 2011; Superseding Indictment (S3) filed April 11, 2007; Judgment in a Criminal Case filed Judgment in a Criminal Case filed June 30, 2008; Satisfaction of Judgment filed July 18, 2011; United States v. Bahel, Docket No. 08-3327-cr (2nd Cir.), Judgment dated October 31, 2011. US v. Nishan Kohli, Case No. 1:06-cr-00918-2-TPG (S.D.N.Y.), Judgment in a Criminal Case filed August 26, 2008 and Stipulation and Order filed August 8, 2008; Satisfaction of Judgment filed June 8, 2009; United States Attorney\u0027s Office for the Southern District of New York Press Release, \u0022United Nations Procurement Official Sentenced to 8 Years in Prison on Corruption Charges,\u0022 April 1, 2008, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/April08\/bahelsentencingpr.pdf\n"},{"Case ID":"ARW-130","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (Austria)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"Austria","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"NA","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a March 1, 2011 statement by the National Bank of Austria, pursuant to European Union regulations, $1.2 billion in Libyan assets had been located and frozen in Austrian financial institutions; it was yet to be determined how much of those assets belonged to late-Mr. Qaddafi, his family and associates who fell under the EU sanctions regulations. (Source: Oesterreichische Nationalbank of Austria, Press Release \u0022\u00d6sterreich friert Verm\u00f6genswerte der Familie Gaddafi ein,\u0022 March 1, 2011.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"National Bank of Austria","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Oesterreichische Nationalbank of Austria, Press Release \u0022\u00d6sterreich friert Verm\u00f6genswerte der Familie Gaddafi ein,\u0022 March 1, 2011, accessed at http:\/\/www.oenb.at\/de\/presse_pub\/aussendungen\/2011\/2010q1\/pa_20110301_oe... New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_...\n"},{"Case ID":"ARW-129","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (Australia)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"Australia","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"United Nations Security Council Sanctions","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"$0","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"NA","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to Media Release by the Reserve Bank of Australia, on March 9, 2011, the Australian Government directed the Bank, \u0022to take steps under the Banking (Foreign Exchange) Regulations 1959 to implement autonomous targeted financial sanctions against certain key persons associated with the Qadhafi regime in Libya.\u0022  (Source: Reserve Bank of Australia Media Release No. 2011-05, \u0022Banking (Foreign Exchange) Regulations 1959 Sanctions Against Libya,\u0022 March 9, 2011.  On October 19, 2011, the Reserve Bank of Australia issued an updated Media List and \u0022Attachment A\u0022 sanctions list that included 35 persons and 12 entities.  (Sources: Reserve Bank of Australia Media Release No. 2011-23, \u0022Banking (Foreign Exchange) Regulations 1959 Sanctions Against Syria and Libya - Amendments to the Annexes,\u0022 October 19, 2011 and Attachment A.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Reserve Bank of Australia","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Reserve Bank of Australia Media Release No. 2011-23, \u0022Banking (Foreign Exchange) Regulations 1959 Sanctions Against Syria and Libya \u2013 Amendments to the Annexes,\u0022 October 19, 2011, accessed at http:\/\/www.rba.gov.au\/media-releases\/2011\/mr-11-23.html and Attachment A (Sanctions List), accessed at http:\/\/www.rba.gov.au\/media-releases\/2011\/mr-11-23-attach-a.html; Reserve Bank of Australia Media Release No. 2011-05, \u0022Banking (Foreign Exchange) Regulations 1959 Sanctions Against Libya,\u0022 March 9, 2011, accessed at http:\/\/www.rba.gov.au\/media-releases\/2011\/mr-11-05.html; New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_...\n"},{"Case ID":"ARW-131","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (Canada)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"Canada","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"United Nations Security Council sanctions","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a statement issued by the Canadian Foreign Minister, in September 2011, \u0022Canada has also secured from the United Nations Security Council\u0027s sanctions committee an exemption to unfreeze $2.2 billion worth of Libyan assets for humanitarian needs. \u0022These funds will help the Libyan people in the short and medium term; this money will help the new Libya get back on its feet.\u0022 (Source: Ministry of Foreign Affairs and International Trade, Statement by Minister Baird Updating Canada\u0027s Involvement in Libya, No. 262 - September 13, 2011, accessed at http:\/\/www.international.gc.ca\/media\/aff\/news-communiques\/2011\/262.aspx?....) \nAccording to the Press Release issued by the Canadian Prime Minister\u0027s Office, in September 2011, the Canadian government lifted Canada\u0027s unilteral sanctions that had been imposed on the Libyan government: \u0022These sanctions were passed under the Special Economic Measures Act and were in addition to the sanctions imposed by the United Nations in Security Council Resolutions 1970 and 1973. The sanctions imposed by the UN remain in effect until they are lifted by the United Nations Security Council.\u0022  (Source: Prime Minister of Canada Stephen Harper, Press Release, \u0022PM announces that Canada has lifted economic sanctions against Libya,\u0022 September 1, 2011, accessed at http:\/\/www.pm.gc.ca\/eng\/media.asp?category=1\u0026featureId=6\u0026pageId=26\u0026id=4315.)  The Prime Minister had announced the imposition of sanctions by Canada against the Qaddafi government, including asset freezes against Mr. Qaddafi and members of his family. (Source:  Government of Canada, \u0022Statement by the Prime Minister of Canada on Implementing Sanctions Against Libya,\u0022 February 27, 2011.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Qaddafi_Canada_Prime_Minister_Statement_Feb_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Qaddafi_NYT_Topic_Update_Oct_25_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Qaddafi_Canada_FA_Ministry_Statement_Sep_13_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Qaddafi_Canada_Prime_Minister_Statement_Feb_27_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Qaddafi_NYT_Topic_Update_Oct_25_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Qaddafi_Canada_PM_Lift_Sanctions_Sep_11_2011.pdf","Sources ":"Ministry of Foreign Affairs and International Trade, Statement by Minister Baird Updating Canada\u0027s Involvement in Libya, No. 262 - September 13, 2011, accessed at http:\/\/www.international.gc.ca\/media\/aff\/news-communiques\/2011\/262.aspx?... Prime Minister of Canada Stephen Harper, Press Release, \u0022PM announces that Canada has lifted economic sanctions against Libya,\u0022 September 1, 2011, accessed at http:\/\/www.pm.gc.ca\/eng\/media.asp?category=1\u0026featureId=6\u0026pageId=26\u0026id=4315; Government of Canada, \u0022Statement by the Prime Minister of Canada on Implementing Sanctions Against Libya,\u0022 Canada News Centre, February 27, 2011, accessed at http:\/\/news.gc.ca\/web\/article-eng.do?mthd=advSrch\u0026crtr.page=10\u0026nid=59286... New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_...\n"},{"Case ID":"ARW-132","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (European Union)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"European Union","Jurisdiction of Asset Description":"Undertaking Recovery Effort","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"United Nations Security Council sanctions","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the Official Journal of the European Union, on February 28, 2011, the European Union imposed sanctions and asset freezes against Mr. Qaddafi and related individuals and entities. The measure, European Council \u0022Decision 2011\/137\/CFSP concerning restrictive measures in view of the situation in Libya ( 1 ), implementing United Nations Security Council Resolution (UNSCR) 1970 (2011)\u0022 have subsequently been amended a number of times, including most recently on September 28, 2011.  (Sources: Official Journal of the European Union, \u0022COUNCIL REGULATION (EU) No 965\/2011 of 28 September 2011 amending Regulation (EU) No 204\/2011 concerning restrictive measures in view of the situation in Libya\u0022 and \u0022COUNCIL DECISION 2011\/137\/CFSP of 28 February 2011 concerning restrictive measures in view of the situation in Libya.\u0022)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Official Journal of the European Union, \u0022COUNCIL REGULATION (EU) No 965\/2011 of 28 September 2011 amending Regulation (EU) No 204\/2011 concerning restrictive measures in view of the situation in Libya,\u0022 accessed at http:\/\/eur-lex.europa.eu\/LexUriServ\/LexUriServ.do?uri=OJ:L:2011:253:0008... Official Journal of the European Union, \u0022COUNCIL DECISION 2011\/137\/CFSP of 28 February 2011 concerning restrictive measures in view of the situation in Libya,\u0022 accessed at http:\/\/eur-lex.europa.eu\/LexUriServ\/LexUriServ.do?uri=OJ:L:2011:058:0053... New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_...\n"},{"Case ID":"ARW-133","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (Germany)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"Germany","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"An article by the German Missions in the United States reported that at the September 2011 Libya Conference in Paris, Prime Minister Merkel stated \u0022Libyan assets blocked while Gaddafi was still in power are now to be unfrozen, among them one billion of the seven billion euros in Germany, which the United Nations has agreed to unfreeze, according to Merkel. These funds must now be used to rebuild the country.\u0022  (Source:  German Missions in the United States, \u0022Merkel Pledges Support at Libya Conference in Paris,\u0022 September 2, 2011.)  According to an article by Germany\u0027s Federal Foreign Office, pursuant to sanctions imposed by the European Union, Foreign Minister Westerwelle stated that \u0022Germany had acted swiftly to implement the sanctions. Libyan assets worth billions had been frozen in German banks.\u0022 (Source: Federal Foreign Office, \u0022Stepping up the pressure on the Libyan regime,\u0022 last updated March 14, 2011.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"German Missions in the United States, \u0022Merkel Pledges Support at Libya Conference in Paris,\u0022 September 2, 2011, accessed at http:\/\/www.germany.info\/Vertretung\/usa\/en\/__pr\/P__Wash\/2011\/09\/02__Libya... Federal Foreign Office, \u0022Stepping up the pressure on the Libyan regime,\u0022 last updated March 14, 2011, accessed at http:\/\/www.auswaertiges-amt.de\/EN\/Aussenpolitik\/Laender\/Aktuelle_Artikel... New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_...\n"},{"Case ID":"ARW-134","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (Sweden)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"Sweden","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a March 23, 2011 statement by Sweden\u0027s Finansinspektionen (Financial Supervisory Authority), pursuant to the European Union Sanctions Regulation concerning restrictive measures with regard to the situation in  Libya, Swedish financial institutions had reported to the Financial Authority that a total of more than 10 billion kronor had been frozen to date.  Citing confidentiality rules, the Financial Authority did not release additional information. (Source: Government of Sweded, Finansinpektionen, \u0022Frysta libyska tillg\u00e5ngar i Sverige,\u0022 March 23, 2011.)  According to the Wall Street Journal, Sweden froze nearly $1.6 billion in Libyan assets. (Source:  Wall Street Journal Corruption Currents Blog, \u0022Sweden Freezes Nearly $1.6 Billion In Libyan Assets,\u0022 March 23, 2011.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Government of Sweden Finansinspektionen, \u0022Frysta libyska tillg\u00e5ngar i Sverige,\u0022 March 23, 2011, accessed at http:\/\/www.fi.se\/Utredningar\/Skrivelser\/Listan\/Frysta-libyska-tillgangar... New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_... Wall Street Journal Corruption Currents Blog, \u0022Sweden Freezes Nearly $1.6 Billion In Libyan Assets,\u0022 March 23, 2011, accessed at http:\/\/blogs.wsj.com\/corruption-currents\/2011\/03\/23\/sweden-freezes-nearl...\n"},{"Case ID":"ARW-135","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"\n\tAccording to the Swiss Federal Department on Foreign Affairs, \u0022On February 21, the Federal Council decided with immediate effect to block any assets in Switzerland of Moammar Gaddafi and those who are closely associated to him. The Ordinance was established on the basis of Article 184, par. 3 of the Swiss Constitution. \u00a0On March 30, the Federal Council adopted a new ordinance to replace that which had been issued on 21 February. Emerging against the backdrop of the implementation of the financial sanctions decided by the UN Security Council with regard to Libya, this new ordinance is no longer based on Article 184, para. 3 of the Swiss Constitution, but rather on Art. 2 of the 22 March 2002 Federal Act on the Implementation of International Sanctions (Embargo Act).\u0022 (Source: Swiss Federal Department of Foreign Affairs, \u0022Freeze on assets,\u0022 last modification July 14, 2011, accessed at http:\/\/www.eda.admin.ch\/eda\/en\/home\/topics\/finec\/intcr\/poexp\/sperr.html - which provides links to relevant Swiss government media releases and ordinances.) \u00a0On May 2, 2011, the Washington Post reported that \u0022Financial regulators in Switzerland had identified in Swiss banks assets worth almost $416 million that may belong to the embattled Libyan leader or the government [ \u00a0] The announcement was made by Swiss President and Foreign Minister Micheline Calmy-Rey at a diplomatic meeting in the Tunisian capital Tunis and confirmed for the Washington Post by a Swiss foreign ministry spokesman.\u0022 (Source: James V. Grimaldi, \u0022Gaddafi, other leaders had almost $1 billion in Swiss banks,\u0022 Washington Post, May 6, 2011.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"Swiss Federal Department of Foreign Affairs, \u0022Freeze on assets,\u0022 last modification July 14, 2011, accessed at http:\/\/www.eda.admin.ch\/eda\/en\/home\/topics\/finec\/intcr\/poexp\/sperr.html (provides links to relevant Swiss government media releases and ordinances); State Secretariat for Economic Affairs, Measures against Libya, at http:\/\/www.seco.admin.ch\/themen\/00513\/00620\/00622\/04634\/index.html?lang=fr New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_... James V. Grimaldi, \u0022Gaddafi, other leaders had almost $1 billion in Swiss banks,\u0022 Washington Post, May 2, 2011, accessed at http:\/\/www.washingtonpost.com\/world\/middle-east\/gaddafi-other-leaders-ha...\n"},{"Case ID":"ARW-136","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Other (International Sanctions); Case in Investigatory\/Asset Restraint Stage","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Completed (in part) and Ongoing (in part)","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the UK Foreign and Commonwealth Office, \u0022The Government has today taken action to freeze the assets of Colonel Muammar Abu Minyar al Qadhafi, members of his family and those acting on their behalf or at their direction.  The individuals subject to an asset freeze are: Colonel Muammar Abu Minyar al-Qadhafi, Aisha Muammar Qadhafi (daughter), Hannibal Muammar Qadhafi (son), Khamis Muammar Qadhafi (son). Mutassim Qadhafi (son) and Saif al-Islam Qadhafi (son).\u0022  (Source: UK Foreign and Commonwealth Office, \u0022Libya update: Political action taken by UK government,\u0022 February 27, 2011.) According to the United Kingdom\u0027s Foreign and Commonwealth Office, \u0022In response to specific requests and with UN agreement, the UK has also made available Libyan assets frozen under the UN sanctions regime.  1.86 billion Libyan dinar bank notes that were printed in the UK before the current crisis have been delivered to Libya to help the Libyan population meet their basic needs.\u0022 (Source: UK Foreign and Commonwealth Office,\u0022Libya,\u0022 accessed on October 31, 2011, at http:\/\/www.fco.gov.uk\/en\/global-issues\/mena\/libya\/.)  On August 26, 2011, the Guardian reported that the UK was seeking to unfreeze some of the GBP 12 billion frozen in the UK.  (Source: Jo Adetunji, \u0022Libyan assets to be unfrozen, including \u00a31bn worth of dinar banknotes, British diplomats seek to unblock \u00a312bn worth of assets held in UK, including notes printed for Gaddafi regime,\u0022 the Guardian, August 26, 2011.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Chancellor of the Exchequer; Department for  Business, Innovation and Skills (export controls)","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"UK Foreign and Commonwealth Office, \u0022Libya update: Political action taken by UK government,\u0022 February 27, 2011 and copy of Order, accessed at http:\/\/www.fco.gov.uk\/en\/news\/latest-news\/?view=News\u0026id=557710282; UK Foreign and Commonwealth Office,\u0022Libya,\u0022 accessed on October 31, 2011, at http:\/\/www.fco.gov.uk\/en\/global-issues\/mena\/libya\/; Jo Adetunji, \u0022Libyan assets to be unfrozen, including \u00a31bn worth of dinar banknotes, British diplomats seek to unblock \u00a312bn worth of assets held in UK, including notes printed for Gaddafi regime,\u0022 the Guardian, August 26, 2011, accessed at http:\/\/www.guardian.co.uk\/world\/2011\/aug\/26\/libyan-assets-banknotes-free... New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_...\n"},{"Case ID":"ARW-140","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) - World Health Organization Recovery case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"Netherlands","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"United Nations Security Council sanctions","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Approval of the UN Sanctions Committee to unfreeze funds and provide to the World Health Organization (Source: The Netherlands, Ministry of Foreign Affairs, \u0022Netherlands unfreezes Libyan assets for medical supplies,\u0022 August 15, 2011.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Other","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"The UN Sanctions Committee approved the transfer of funds to the United Nations World Health Organization, for medical supplies to people in Benghazi and other areas of fighting","Case Summary":"According to a news release by The Netherlands\u0027 Ministry of Foreign Affairs, \u0022The Netherlands is freeing up \u20ac100 million of the Libyan regime\u2019s assets that are frozen in the Netherlands at the urgent request of the World Health Organization. The WHO will use the funds to distribute medical supplies, of which there is currently an acute shortage in Libya, among the Libyan population.  The Netherlands can release the money to the WHO because the UN sanctions committee has given its approval. The medical supplies will go to people in Benghazi and other rebel-held areas, areas where there is fighting, and areas still controlled by the Gaddafi regime. The Netherlands is the first country to provide this kind of financial assistance to Libya\u2019s stricken healthcare sector.  Minister of Foreign Affairs Uri Rosenthal has described the unfreezing of the assets as a good example of how sanctions should work. \u2018I always say that sanctions should cut off the regime without hurting the population. That is exactly what is happening now, with Gaddafi\u2019s frozen funds being used to save Libyan lives,\u2019 he said.\u0022 (Source: The Netherlands, Ministry of Foreign Affairs, \u0022Netherlands unfreezes Libyan assets for medical supplies,\u0022 August 15, 2011.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"The Netherlands, Ministry of Foreign Affairs, \u0022Netherlands unfreezes Libyan assets for medical supplies,\u0022 August 15, 2011, accessed at http:\/\/www.minbuza.nl\/en\/news\/2011\/08\/netherlands-unfreezes-libyan-asset... New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_...\n"},{"Case ID":"ARW-139","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) - Netherlands Asset Return","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"Netherlands","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"United Nations Security Council sanctions","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Transitional Financial Mechanism set up by the International Contact Group for Libya. The mechanism has safeguards in place to ensure responsible spending.  The funds will go towards humanitarian needs, such as food and medicines, and education and salaries. (Source: The Netherlands Ministry of Foreign Affairs, \u0022The Netherlands unfreezes 2 billion dollars\u2019 worth of Libyan assets,\u0022 September 12, 2011.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"According to a news article by the Netherlands Ministry of Foreign Affairs, \u0022The money, which came from the Libyan Central Bank, will be made available to the National Transitional Council (NTC) through the Transitional Financial Mechanism set up by the International Contact Group for Libya. The mechanism has safeguards in place to ensure responsible spending.  The funds will go towards humanitarian needs, such as food and medicines, and education and salaries.\u0022 (Source: The Netherlands Ministry of Foreign Affairs, \u0022The Netherlands unfreezes 2 billion dollars\u2019 worth of Libyan assets,\u0022 September 12, 2011.)","Case Summary":"According to a news article by The Netherlands Ministry of Foreign Affairs, on September 12, 2011, the Netherlands agreed to unfreeze US $2 billion in Libyan assets that had previously been blocked by the Dutch government.  (Source: The Netherlands Ministry of Foreign Affairs, \u0022The Netherlands unfreezes 2 billion dollars\u2019 worth of Libyan assets,\u0022 September 12, 2011.)  In August 2011, the (UK) Telegraph reported that the Netherlands had frozen some EUR 3.1 billion in Libyan assets. (Source: The Telegraph, \u0022Libya: Netherlands gives \u00a387 million of frozen assets to WHO, August 16, 2011.)","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"The Netherlands Ministry of Foreign Affairs, \u0022The Netherlands unfreezes 2 billion dollars\u2019 worth of Libyan assets,\u0022 September 12, 2011, accessed at http:\/\/www.minbuza.nl\/en\/news\/2011\/09\/the-netherlands-unfreezes-2-billio... New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_... The Telegraph, \u0022Libya: Netherlands gives \u00a387 million of frozen assets to WHO, August 16, 2011, accessed at http:\/\/www.telegraph.co.uk\/news\/worldnews\/africaandindianocean\/libya\/870...\n"},{"Case ID":"ARW-138","Case Title (Name of Public Official or Entity Allegedly Involved)":"Muammar el-Qaddafi (and related entities and individuals) (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Libya","Position of Public Official(s) (yrs in office)":"President (1969-2011)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2011","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.20","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"United Nations Security Council Resolutions 1970 and 1973","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"United Nations Security Council Resolutions 1970 and 1973","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"","Case Summary":"According to the December 16, 2011 Fact Sheet by the US Department of Treasury, \u0022In conjunction with action taken at the United Nations (UN), the U.S. Department of the Treasury today issued General License No. 11, unblocking more than $30 billion in assets of the Government of Libya. [ ]  As of today\u2019s action, the only Libyan government assets still blocked under U.S. law are funds of the LIA and its subsidiaries, including the Libyan Africa Investment Portfolio (LAIP).  Both the LIA and the LAIP remain listed at the UN.  The property and interests in property of certain members of the Qadhafi family, certain senior members of the Qadhafi regime, and certain entities in which they have an interest also remain blocked.\u0022 (Source: US Department of the Treasury, \u0022Fact Sheet: Lifting Sanctions on the Government of Libya,\u0022 December 16, 2011.) \nOn February 25, 2011, President Barack Obama had issued an Executive Order entitled \u0022Blocking Property and Prohibiting Certain Transactions Related to Libya.\u0022  President Obama based the Executive Order under powers granted to him under the International Emergency Economic Powers Act and the National Emergencies Act.  The Executive Order applied to Mr. Muammar Qadhafi, members of his government, members of his family and close associates.  (Source: The White House, Executive Order, Blocking Property and Prohibiting Certain Transactions Related to Libya, February 25, 2011).","Disposition of Criminal Case(s)":"Mr. Qaddafi passed away on October 20, 2011 (Source: New York Times, \u0022Muammar el Qaddafi\u0022); as of October 31, 2011 cases in investigatory stage as to other individuals and entities.","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Department of the Treasury","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Qaddafi_US_Asset_Freeze_Executive_Order_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Qaddafi_US_Treasury_Dept_Statement_Sep_1_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Qaddafi_NYT_Topic_Update_Oct_25_2011.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Qaddafi_US_Treasury_Lift_Sanctions_Govt_Libya_Dec_16_2011.pdf","Sources ":"US Department of the Treasury, \u0022Fact Sheet: Lifting Sanctions on the Government of Libya,\u0022 December 16, 2011, accessed at http:\/\/www.treasury.gov\/press-center\/press-releases\/Pages\/tg1387.aspx; The White House, Executive Order, Blocking Property and Prohibiting Certain Transactions Related to Libya, February 25, 2011, accessed at http:\/\/www.treasury.gov\/resource-center\/sanctions\/Programs\/Documents\/201... New York Times, \u0022Muammar el-Qaddafi,\u0022 accessed on October 31, 2011 at http:\/\/topics.nytimes.com\/top\/reference\/timestopics\/people\/q\/muammar_el_...\n"},{"Case ID":"ARW-15","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ananias Tumukunde","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Uganda","Position of Public Official(s) (yrs in office)":"Science and Technology Advisor to President (inclusive 2008)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"2012","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution, Criminal Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"NA","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"First conviction in overseas corporate corruption case by the City of London Police Overseas Anti-Corruption Unit since its establishment in June 2006. ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$55,000","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unknown","Case Summary":"According to the Norton Rose law firm Case Study cited in the July 13, 2011 United Kingdom\u0027s UNCAC Self-Assessment Report, Mr. Tumukunde made contact with Niels Tobiasen, the Managing Director of CBRN Team Ltd., a security specialist, regarding the procurement of training and security equipment for the Ugandan army in the run-up to the Commonwealth Heads of Government Meeting, held in Kampala in 2007.  CBRN Team Ltd. signed a contract with Mr. Tumukunde worth GBP 210,000 for the equipment, but Tobiasen reportedly agreed and made five \u0027local payments\u0027 totalling around GBP 83,000 to Tumukunde and a Ugandan army officer, Rusoke Tagaswire, between 2007 and 2008.  The purported agency payments in fact were inducements that went directly into two bank accounts opened by Tumukunde and Tagaswire in the UK. The London Police received information of Tumukunde\u0027s plans to travel to the UK and Tumukunde was arrested by Scotland Yard at Heathrow Airport. (Tobiasen later pleaded guilty to making corrupt payments to Tobiasen. Source: City of London Police Statement, \u0022Guilty plea to bribery sets legal landmark,\u0022 July 27, 2010.)  On September 22, 2008, Tumukunde pleaded guilty, before His Honour Judge Wadsworth in the Southwark Crown Court to accepting corrupt payments and was sentenced to 12 months\u0027 imprisonment; he also signed a disclaimer releasing the GBP 52,800 [US $96,681.60] from his bank account into the custody of the City of London Police for restitution.  (Source: Norton Rose (law firm), \u0022Case Study: CBRN Team Ltd (non-FCPA).\u0022)   Written evidence presented by the UK\u0027s Department for International Development (DFID) to the Parliament\u0027s International Development Committee stated that GBP35,000 has been returned in the case involving Mr. Tumukunde. (Source: UK Parliament, International Development Committee, \u0022Supplementary written evidence submitted by The Department for International Development (DFID),\u0022 June 2012.)","Disposition of Criminal Case(s)":"According to the United Kingdom\u0027s UNCAC Self-Assessment Report of  July 13, 2011, Mr. Tumukunde pleaded guilty and was sentenced on 22 September 2008 by the Southwark Crown Court to 12 months imprisonment for receiving corrupt payments in relation to a contract with a British company (CBRN Team Ltd) for training and equipment for the Ugandan Army.  The UK Report noted that \u0022(Although charges under the Public Bodies Corrupt Practices Act 1889 could have been used, it was decided to prosecute for money laundering offences).\u0022  (Source: UK Self-Assessment Report, at 24.)","Jurisdiction of Origin: Investigative Agency":"NA","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"City of London Police, Overseas Anti-Corruption Unit","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service","Jurisdiction of Asset Recovery: Courts Involved":"Southwark Crown Court","Documents":"","Sources ":"UK Parliament, International Development Committee, \u0022Supplementary written evidence submitted by The Department for International Development (DFID),\u0022 June 2012, accessed at http:\/\/www.publications.parliament.uk\/pa\/cm201213\/cmselect\/cmintdev\/130\/... United Nations Office on Drugs and Crime, \u0022United Nations Convention against Corruption, United Kingdom Self-Assessment for United Nations Convention against Corruption - Chapters III and IV,\u0022 July 13, 2011, accessed at  http:\/\/www.unodc.org\/documents\/treaties\/UNCAC\/SA-Report\/UK_UNCAC_4.11.20...  \nNorton Rose (law firm), \u0022Case Study: CBRN Team Ltd (non-FCPA),\u0022 accessed at http:\/\/www.nortonrose.com\/expertise\/business-ethics-and-anti-corruption\/... \nCity of London Police Statement, \u0022Guilty plea to bribery sets legal landmark,\u0022 July 27, 2010, accessed at  http:\/\/www.cityoflondon.police.uk\/CityPolice\/Departments\/ECD\/anticorrupt....  \nSee also Paul Lewis and Rob Evans, \u0022Ugandan is jailed in UK bribery crackdown,\u0022 The Guardian, September 23, 2008, accessed at http:\/\/www.guardian.co.uk\/uk\/2008\/sep\/23\/ukcrime.law\/print\n"},{"Case ID":"ARW-83","Case Title (Name of Public Official or Entity Allegedly Involved)":"Instituto Nacional de Seguros (INS) and Instituto Costarricense de Electricidad (ICE) \/ Julian Messent","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Costa Rica","Position of Public Official(s) (yrs in office)":"Officials at State-Owned Entities","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2006","Asset Recovery End":"2012","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution, Criminal Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"\u0022Following elections in Costa Rica in 2002, officials in INS and ICE were replaced. Enquiries were made into the contract with PWS and questions\r\nwere raised about payments made under it. The Foreign and Commonwealth Office referred the case to the SFO in October 2005 and the case was\r\naccepted for investigation in August 2006.\u0022  (Source: UK Serious Fraud Office Press Release, \u0022Insurance Broker jailed for bribing Costa Rican\r\nofficials,\u0022 October 26, 2010.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$157,399","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Please see summary field for explanation","Case Summary":"In upholding Mr. Messent;s sentece, the Court of Appeals stated that, \u0022The government of Costa Rica, and therefore the citizens of Costa Rica, were in effect made to pay for the corruption of their own officials by foreigners and therefore they suffered a loss of not far short of the original $2 million as a result of the appellant\u0027s [Mr. Messent\u0027s] corrupt behaviour.\u0022  (Source: Messent, R. v [2011] EWCA Crim 644 (01 March 2011))  The Court also stated that, \u0022in the context of the observations in the 2004 United Convention against Corruption, we remind ourselves that corruption \u0027undermines a government\u0027s ability to provide basic services\u0027.\u0022 (Source: Ibid.)\nAccording to the October 26, 2010 press release by the UK Serious Fraud Office, UK insurance broker Julian Messent was sentenced to imprisonment \u0022after admitting making or authorising corrupt payments of almost US $2 million to Costa Rican officials in the state insurance company, Instituto Nacional de Seguros (INS) and the national electricity and telecommunications provider Instituto Costarricense de Electricidad (ICE). He was ordered to pay \u00a3100,000 compensation within 28 days to the Republic of Costa Rica or serve an additional 12 months imprisonment if he fails to do so.  Following a joint investigation by the Serious Fraud Office and the City of London Police which opened in 2006, Julian Messent (d.o.b. 20\/02\/60), who was a director of London-based insurance business PWS International Ltd (\u0022PWS\u0022), pleaded guilty at Southwark Crown Court to two counts of making corrupt payments between February 1999 and June 2002, contrary to s1 (1) of the Prevention of Corruption Act 1906. The sentence passed was 21 months imprisonment on each count to run concurrently. He also asked for 39 similar offences to be taken into consideration.\u0022 (Source: UK Serious Fraud Office Press Release, \u0022Insurance Broker jailed for bribing Costa Rican officials,\u0022 October 26, 2010.) The Press Release noted that there were ongoing prosecution in Costa Rica of the alleged bribe recipients and that the SFO was cooperating with the Costa Rican authorities in the matter.  Written evidence presented by the UK\u0027s Department for International Development (DFID) to the Parliament\u0027s International Development Committee stated that US$100,000 has been returned to Costa Rica  in the case involving Mr. Messent. (Source: UK Parliament, International Development Committee, \u0022Supplementary written evidence submitted by The Department for International Development (DFID),\u0022 June 2012.) \nAccording to the Serious Fraud Office\u0027s submission to the UK Parliament, \u0022There were a number of practical problems involved in the transmission of the payment to the authorities in Costa Rica. There has been discussion as well as to which organisation in Costa Rica should benefit from the funds.\u0022 (Source: UK Parliament, House of Commons, International Development Committee, \u0022Financial Crime and Development, Eleventh Report of Session 2010-12,\u0022 15 November 2011.)","Disposition of Criminal Case(s)":"According to the October 26, 2010 press release by the UK Serious Fraud Office, UK insurance broker \u0022Julian Messent was sentenced today to 21 months\u0027 imprisonment after admitting making or authorising corrupt payments of almost US $2 million to Costa Rican officials.\u0022 (Source: UK Serious Fraud Office Press Release, \u0022Insurance Broker jailed for bribing Costa Rican officials,\u0022 October 26, 2010.).  His sentence was upheld in 2011 by the England and Wales Court of Appeal (Criminal Division).  (Source: Messent, R. v [2011] EWCA Crim 644 (01 March 2011))","Jurisdiction of Origin: Investigative Agency":"Unspecified","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Origin: Courts Involved":"Unspecified","Jurisdiction of Asset Recovery: Investigative Agency":"Serious Fraud Office, City of London Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service","Jurisdiction of Asset Recovery: Courts Involved":"Southwark Crown Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Messent_Plea_UK_SFO_Press_Release_Oct_26_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Messent_UK_Appeals_Court_Judgment_Mar_1_2011.doc, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Messent_Plea_UK_SFO_Press_Release_Oct_26_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Messent_UK_SFO_Sentencing_PR_Oct_26_2010.pdf","Sources ":"\n\tMessent, R. v [2011] EWCA Crim 644 (01 March 2011), at http:\/\/www.bailii.org\/ew\/cases\/EWCA\/Crim\/2011\/644.html;\n\n\t\u00a0\n\n\tUK Serious Fraud Office Press Release, \u0022Insurance Broker jailed for bribing Costa Rican officials,\u0022 October 26, 2010, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-20...\n\n\t\u00a0\n\n\t\u00a0UK Parliament, International Development Committee, \u0022Supplementary written evidence submitted by The Department for International Development (DFID),\u0022 June 2012, accessed at http:\/\/www.publications.parliament.uk\/pa\/cm201213\/cmselect\/cmintdev\/130\/...\n\n\t\u00a0\n\n\tUK Parliament, House of Commons, International Development Committee, \u0022Financial Crime and Development\n\n\tEleventh Report of Session 2010-12,\u0022 15 November 2011, accessed at http:\/\/www.publications.parliament.uk\/pa\/cm201012\/cmselect\/cmintdev\/847\/....\n"},{"Case ID":"ARW-48","Case Title (Name of Public Official or Entity Allegedly Involved)":"David B. Chalmers, Jr. \/ Bayoil (USA) Inc. \/ Bayoil Supply \u0026 Trading, Limited (UN Oil-for-Food)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United States","Position of Public Official(s) (yrs in office)":"NA","Jurisdiction of Asset Recovery":"Iraq [Development Fund for Iraq], United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2005","Asset Recovery End":"2008","UNCAC Offenses Implicated":"Art. 2, Art.14, Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution, Criminal Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"In announcing the guilty pleas, the United States Attorney for the Southern District of New York, Mr. Michael Garcia \u0022praised the work of the Federal Bureau of Investigation, Criminal and Counterintelligence Divisions. He also expressed appreciation to the United States Treasury Department, Office of Foreign Assets Control; the United States Department of State; the United Nations Office of Legal Affairs; and the former Independent Inquiry Committee into the United Nations Oil-for-Food Program for their assistance in this investigation.\u0022 (Source: United States Attorney\u0027s Office for the Southern District of New York Press Release, \u0022U.S. ANNOUNCES FOUR GUILTY PLEAS IN OIL-FOR-FOOD CASE,\u0022 August 17, 2007.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$9,016,151.4","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to a press release by the United States Attorney\u0027s Office for the Southern District of New York, on August 7, 2007, David B. Chalmers, Jr. and his companies - Bayoil (USA) Inc., and Bayoil Supply \u0026 Trading, Limited - pleaded guilty to one count of conspiracy to commit wire fraud, in relation to their involvement in a kick-back scheme related to the UN Oil-for-Food program in Iraq.  (Source: United States Attorney\u0027s Office for the Southern District of New York Press Release, \u0022U.S. ANNOUNCES FOUR GUILTY PLEAS IN OIL-FOR-FOOD CASE,\u0022 August 17, 2007).  As described in the Order of Restitution in the case, as part of their sentencing,  Chalmers and the Bayoil companies had been ordered to pay restitution of $9,016,151.40, for which they had joint and several liability; the March 25, 2008 Order of Restitution ordered the three to pay the restitution to the Development Fund of Iraq, in care of Ambassador Srood Najib, to be used as restitution for the benefit of the Iraqi people. (Source: US v. Chalmers, et al, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Order of Restitution filed on March 25, 2008.)   The Development Fund of Iraq was established on May 21, 2003, by United Nations Security Council Resolution 1483 and originally overseen by the Coalition Provisional Authority, then by the Interim Iraqi government with the oversight of the International Advisory and Monitoring Board for Iraq; as of July 2011, the Government of Iraq assumed full autonomy for the proceeds of the Development Fund for Iraq. (Source: United Nations Security Council Press Statement, SC\/10307, IK\/636, \u0022Security Council Statement on the Development Fund for Iraq,\u0022 June 30, 2011.)","Disposition of Criminal Case(s)":"According to the Order of Restitution filed in US v. Chalmers, et al, on August 7, 2007, David B. Chalmers, Jr. and his companies - Bayoil (USA) Inc., and Bayoil Supply \u0026 Trading, Limited - pleaded guilty to one count of conspiracy to commit wire fraud, in violation of Section 1349 of Title 18, United States Code. (Source: US v. Chalmers, et al, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Order of Restitution filed on March 25, 2008.)","Jurisdiction of Origin: Investigative Agency":"Independent Inquiry Committee into the United Nations Oil-for-Food Program ","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, Criminal and Counterintelligence Divisions","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"United States Attorney for the Southern District of New York","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York","Documents":"","Sources ":"United States Attorney\u0027s Office for the Southern District of New York Press Release, \u0022U.S. ANNOUNCES FOUR GUILTY PLEAS IN OIL-FOR-FOOD CASE,\u0022 August 17, 2007, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/August07\/chalmersdionissie... \nUS v. Chalmers, et al, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Order of Restitution filed on March 25, 2008 and Court Docket Report as of October 26, 2011, both accessed via PACER; \nUnited Nations Security Council Press Statement, SC\/10307, IK\/636, \u0022Security Council Statement on the Development Fund for Iraq,\u0022 June 30, 2011, accessed at http:\/\/www.un.org\/News\/Press\/docs\/2011\/sc10307.doc.htm.\n"},{"Case ID":"ARW-74","Case Title (Name of Public Official or Entity Allegedly Involved)":"Halliburton \/ Kellogg Brown \u0026 Root LLC (TSKJ Consortium Nigeria Settlement)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United States","Position of Public Official(s) (yrs in office)":"NA","Jurisdiction of Asset Recovery":"Nigeria","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2010","Asset Recovery End":"2010","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine \/ Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Settlement agreement (Source: Hallliburton Press Release, \u0022Halliburton Confirms Agreement to Settle with Federal Government of Nigeria,\u0022 December 21, 2010.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$35,000,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a December 21, 2010 Press Release by Halliburton, as part of its agreement with the Federal Government of Nigeria (FGN), \u0022Halliburton agreed to pay US$32.5 million to the FGN and to pay an additional US$2.5 million for FGN\u0027s attorneys\u0027 fees and other expenses. Among other provisions, Halliburton agreed to provide reasonable assistance int the FGN\u0027s effort to recover amounts frozen in a Swiss bank account of a former TSKJ [the joint venture in develpment of the natural gas liqufaction project on Bonny Island, Nigeria] agent.\u0022 (Source: Hallliburton Press Release, \u0022Halliburton Confirms Agreement to Settle with Federal Government of Nigeria,\u0022 December 21, 2010; 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice by Mr. Mohammed Bello Adoke, SAN, Honourable Attorney-General of the Federation and Minister of Justice, 22 December 2010.)  Background to the Bonny Island project and misconduct are described in US v. Kellogg Brown \u0026 Root LLC, Case No. 4:09-cr-00071 (S.D. Tex.), Plea Agreement and Statement of Facts filed on February 11, 2009.  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.","Disposition of Criminal Case(s)":"According to a December 21, 2010 Press Release by Halliburton, pursuant to an agreement with the Federal Government of Nigeria (FGN), \u0022all lawsuits and charges against KBR and Halliburton corporate entities and associated persons have been withdrawn, the FGN agreed not to bring any further criminal charges or civil claims against those entities or persons.\u0022 (Source: Hallliburton Press Release, \u0022Halliburton Confirms Agreement to Settle with Federal Government of Nigeria,\u0022 December 21, 2010.)","Jurisdiction of Origin: Investigative Agency":"NA","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Ministry of Justice, Attorney General; Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"","Sources ":"Hallliburton Press Release, \u0022Halliburton Confirms Agreement to Settle with Federal Government of Nigeria,\u0022 December 21, 2010, accessed at www.halliburton.com\/public\/news\/pubsdata\/press_release\/2010\/corpnws_1221... \n2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice by Mr. Mohammed Bello Adoke, SAN, Honourable Attorney-General of the Federation and Minister of Justice, 22 December 2010; \nBBC News, \u0022Nigeria drops Dick Cheney bribery charges,\u0022 December 17, 2010 (quoting EFCC spokesman Femi Babafemi), accessed at http:\/\/www.bbc.co.uk\/news\/world-africa-12018900.\u00a0 \nSee also,\u00a0US v. Kellogg Brown \u0026 Root LLC, Case No. 4:09-cr-00071 (S.D. Tex.), Plea Agreement and Statement of Facts filed on February 11, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/kelloggb\/02-11-09kbr-pl....\n"},{"Case ID":"ARW-73","Case Title (Name of Public Official or Entity Allegedly Involved)":"Halliburton \/ Kellogg Brown \u0026 Root LLC (TSKJ Consortium Nigeria Settlement \/ Swiss Account)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nigeria, United States","Position of Public Official(s) (yrs in office)":"NA","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2010","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Unspecified (Arising out of nonprosecution agreement between Government of Nigeria and Halliburton)","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Unknown","Stage in Asset Recovery Chain":"Unknown","Assets Frozen (USD)":"$135,000,000","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unknown","Case Summary":"According to a December 21, 2010 Press Release by Halliburton, as part of its agreement with the Federal Government of Nigeria (FGN), \u0022Halliburton agreed to pay US$32.5 million to the FGN and to pay an additional US$2.5 million for FGN\u0027s attorneys\u0027 fees and other expenses. Among other provisions, Halliburton agreed to provide reasonable assistance int the FGN\u0027s effort to recover amounts frozen in a Swiss bank account of a former TSKJ [the joint venture in develpment of the natural gas liqufaction project on Bonny Island, Nigeria] agent.\u0022 (Source: Hallliburton Press Release, \u0022Halliburton Confirms Agreement to Settle with Federal Government of Nigeria,\u0022 December 21, 2010; see also BBC News, \u0022Nigeria drops Dick Cheney bribery charges,\u0022 December 17, 2010 (quoting EFCC spokesman Femi Babafemi as stating that the settlement had been reached and mention of frozen foreign account.)\u00a0 The\u00a02010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice by Mr. Mohammed Bello Adoke, SAN, Honourable Attorney-General of the Federation and Minister of Justice, also noted the Halliburton settlement.\u00a0 (22 December 2010). Background to the Bonny Island project and misconduct are described in US v. Kellogg Brown \u0026 Root LLC, Case No. 4:09-cr-00071 (S.D. Tex.), Plea Agreement and Statement of Facts filed on February 11, 2009.  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.","Disposition of Criminal Case(s)":"According to a December 21, 2010 Press Release by Halliburton, pursuant to an agreement with the Federal Government of Nigeria (FGN), \u0022all lawsuits and charges against KBR and Halliburton corporate entities and associated persons have been withdrawn, the FGN agreed not to bring any further criminal charges or civil claims against those entities or persons.\u0022 (Source: Hallliburton Press Release, \u0022Halliburton Confirms Agreement to Settle with Federal Government of Nigeria,\u0022 December 21, 2010.)","Jurisdiction of Origin: Investigative Agency":"NA","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"US: Department of Justice (Fraud Section); Nigeria: Ministry of Justice, Economic and Financial Crimes Commission","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"","Sources ":"\n\tHallliburton Press Release, \u0022Halliburton Confirms Agreement to Settle with Federal Government of Nigeria,\u0022 December 21, 2010, accessed at www.halliburton.com\/public\/news\/pubsdata\/press_release\/2010\/corpnws_1221... BBC News, \u0022Nigeria drops Dick Cheney bribery charges,\u0022 December 17, 2010 (quoting EFCC spokesman Femi Babafemi), accessed at http:\/\/www.bbc.co.uk\/news\/world-africa-12018900; 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice by Mr. Mohammed Bello Adoke, SAN, Honourable Attorney-General of the Federation and Minister of Justice (22 December 2010).\u00a0 See also, US v. Kellogg Brown \u0026 Root LLC, Case No. 4:09-cr-00071 (S.D. Tex.), Plea Agreement and Statement of Facts filed on February 11, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/kelloggb\/02-11-09kbr-pl...\n"},{"Case ID":"ARW-143","Case Title (Name of Public Official or Entity Allegedly Involved)":"Noble Corporation (Nigeria Settlement)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Switzerland","Position of Public Official(s) (yrs in office)":"Unspecified Officials","Jurisdiction of Asset Recovery":"Nigeria","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2010","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Settlement agreement (Source: Noble Corporation, US Securities and Exchange Commission Form 8-K, January 31, 2011.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$2,500,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the Form 8-K filed by the Noble Corporation with the US Securities and Exchange Commission, the Nigerian Economic and Financial Crimes Commission and the Nigerian Attorney General\u0027s Office investigation related to the same activities as previously settled by Noble Corporation with the U.S. Department of Justice and the Securities Exchange Commission under the U.S. Foreign Corrupt Practices Act of certain reimbursement payments made by the company\u0027s Nigerian affiliate to customs agents in Nigeria.  The company stated that as part of the January 28, 2011 Non-prosecution agreement executed by a subsidiary of Noble-Swiss with the Government of Nigeria, the Noble-Swiss subsidiary will pay $2.5 million to resolve all charges and claims of the Nigerian government. (Sources:  Noble Corporation, US Securities and Exchange Commission Form 8-K, January 31, 2011; US Department of Justice: In Re: Noble Corporation, Nonprosecution Agreement and Statement of Facts, dated November 4, 2010.)  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.","Disposition of Criminal Case(s)":"According to the Form 8-K filed by the Noble Corporation with the US Securities and Exchange Commission, the Nigerian Economic and Financial Crimes Commission and the Nigerian Attorney General\u0027s Office initiated an investigation into alleged misconduct but all charges were resolved through the execution of a non-prosecution agreement dated January 28, 2011 by a subsidiary of Noble-Swiss. (Source:  Noble Corporation, SEC Form 8-K, January 31, 2011.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Ministry of Justice, Attorney General; Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Courts Involved":"N\/A","Documents":"","Sources ":"Noble Corporation US Securities and Exchange Commission Form 8-K, filed January 31, 2011, accessed at www.sec.gov\/Archives\/edgar\/data\/1169055\/000095012311006909\/h79316e8vk.htm; US Securities and Exchange Commission, \u0022Form 8-K\u0022 (Explanation) at http:\/\/www.sec.gov\/answers\/form8k.htm; In Re: Noble Corporation, Nonprosecution Agreement and Statement of Facts, dated November 4, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/noble-corp\/11-04-10nobl...\n"},{"Case ID":"ARW-89","Case Title (Name of Public Official or Entity Allegedly Involved)":"JGC Corporation (TSKJ Consortium Nigeria Settlement)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Japan","Position of Public Official(s) (yrs in office)":"NA","Jurisdiction of Asset Recovery":"Nigeria","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2010","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine and Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Settlement Agreement (Source: JGC Corporation\u0027s January 31, 2011 Notice of Loss and Revisions of Earnings Forecasts for Fiscal Year Ending March 31, 2011.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the JGC Corporation\u0027s January 31, 2011 Notice of Loss and Revisions of Earnings Forecasts for Fiscal Year Ending March 31, 2011, JGC reached a settlement with the Nigerian authorities in January 2011 to settle charges arising from the Bonny Island\/LNG project.  The company agreed to pay 2.5 billion yen. (Source: JGC Corporation\u0027s January 31, 2011 Notice of Loss and Revisions of Earnings Forecasts for Fiscal Year Ending March 31, 2011.)  Background on the Bonny Island project, TSKJ joint venture and the JGC Corporation\u0027s settlement with the US Department of Justice are described in US v. JGC Corporation,  Case No. 4:11-cr-00260 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts filed April 6, 2011.  Please note that the exact date of Nigerian settlement is not known; January 31, 2011 was used as date for purposes of currency conversion from yen to US dollars.  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.","Disposition of Criminal Case(s)":"According to the JGC Corporation\u0027s January 31, 2011 Notice of Loss and Revisions of Earnings Forecasts for Fiscal Year Ending March 31, 2011, JGC reached a settlement with the Nigerian authorities in January 2011. No other details were noted in the company\u0027s notice. (Source: JGC Corporation\u0027s January 31, 2011 Notice of Loss and Revisions of Earnings Forecasts for Fiscal Year Ending March 31, 2011.)","Jurisdiction of Origin: Investigative Agency":"NA","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Ministry of Justice, Attorney General; Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Courts Involved":"N\/A","Documents":"","Sources ":"JGC Corporation\u0027s January 31, 2011 Notice of Loss and Revisions of Earnings Forecasts for Fiscal Year Ending March 31, 2011, accessed at http:\/\/www.jgc.co.jp\/en\/06ir\/pdf\/financial_statements-summary\/FY10\/fy10_... \nUS v. JGC Corporation,  Case No. 4:11-cr-00260 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts filed April 6, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/jgc-corp\/04-6-11jgc-cor....\n"},{"Case ID":"ARW-176","Case Title (Name of Public Official or Entity Allegedly Involved)":"Snamprogetti Netherlands BV and ENI S.p.A. (TSKJ Consortium Nigeria Settlement)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Italy, Netherlands","Position of Public Official(s) (yrs in office)":"NA","Jurisdiction of Asset Recovery":"Nigeria","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2010","Asset Recovery End":"2010","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"","Contributing Factors in Asset Recovery":"Settlement Agreement (Source: ENI\/Saipem company Press Release, \u0022Snamprogetti Netherlands BV enters agreement with Federal Government of Nigeria,\u0022 December 20, 2010.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$32,500,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a Press Release by the ENI company, as part of its subsidiary Snamprogetti Netherlands BV\u0027s settlement and non-prosecution agreement with the Nigerian authorities, Snamprogetti agreed to the payment of a criminal penalty of $30 million and of $2.5 million as reimbursement for legal costs and expenses incurred by the Nigerian authorities. In addition to dismissing all charges filed in Nigeria, the authorities agreed to renounce civil claims and criminal charges in any jurisdiction.  (Source: ENI\/Saipem company Press Release, \u0022Snamprogetti Netherlands BV enters agreement with Federal Government of Nigeria,\u0022 December 20, 2010.)  Background on the Bonny Island project, TSKJ joint venture and Snamprogetti Netherlands BV\u0027s settlement with the US Department of Justice are described in US v.Snamprogetti Netherlands BV, Case No. 4:10-cr-00460 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts, filed July 7, 2010.  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.","Disposition of Criminal Case(s)":"According to a Press Release by the ENI company, its subsidiary Snamprogetti Netherlands BV entered into a settlement and non-prosecution agreement with the Nigerian authorities to resolve an investigation into the activities of Snamprogetti, as member of the TSKJ consortium, in connection with contracts to build liquid natural [gas] faciltiies on Bonny Island, Nigeria. The Government of Nigeria agreed to dismiss all charges against Snamprogetti.  (Source: ENI\/Saipem company Press Release, \u0022Snamprogetti Netherlands BV enters agreement with Federal Government of Nigeria,\u0022 December 20, 2010.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Ministry of Justice, Attorney General; Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"","Sources ":"ENI\/Saipem company Press Release, \u0022Snamprogetti Netherlands BV enters agreement with Federal Government of Nigeria,\u0022 December 20, 2010, accessed at http:\/\/www.saipem.com\/site\/download.jsp?idDocument=2013\u0026instance=2; \nUS v.Snamprogetti Netherlands BV, Case No. 4:10-cr-00460 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts, filed July 7, 2010, accessed at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/snamprogetti\/07-07-10sn...\n"},{"Case ID":"ARW-174","Case Title (Name of Public Official or Entity Allegedly Involved)":"Siemens AG (Nigeria Settlement)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Germany","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"Nigeria","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2010","Asset Recovery End":"2010","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution and Fine and Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Settlement Agreement (Source: Siemens, \u0022Legal Proceedings,\u0022 May 4, 2011; The 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice by Mr. Mohammed Bello Adoke, SAN, Honourable Attorney-General of the Federation and Minister of Justice, also noted the Halliburton settlement.\u00a0 (22 December 2010).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$46,000,000 (secondary source)","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the May 4, 2011 Siemens Company Statement on Legal Proceedings against it around the world, \u0022As previously reported, the Nigerian Economic and Financial Crimes Commission (EFCC) was conducting an investigation into alleged illegal payments by Siemens to Nigerian public officials between 2002 and 2005. In October 2010, the EFCC filed charges with the Federal High Court in Abuja and the High Court of the Federal Capital Territory against \u2013 among others \u2013 Siemens Ltd. Nigeria (Siemens Nigeria), Siemens AG and former board members of Siemens Nigeria. On November 22, 2010, the Nigerian Government and Siemens Nigeria entered into an out of court settlement, obligating Siemens Nigeria to make a payment in the mid double-digit Euro million range to Nigeria in exchange for the Nigerian Government withdrawing these criminal charges and refraining from the initiation of any criminal, civil or other actions \u2013 such as a debarment \u2013 against Siemens Nigeria, Siemens AG, and Siemens employees.\u0022 (Source: Siemens, \u0022Legal Proceedings,\u0022 May 4, 2011.)\u00a0 The 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice by Mr. Mohammed Bello Adoke, SAN, Honourable Attorney-General of the Federation and Minister of Justice, also noted the Halliburton settlement.\u00a0 (22 December 2010).\u00a0 For background on the US Foreign Corrupt Practices Act case and settlement with Siemens A.G., please see US v. Siemens A.G., Case No. 08-cr-367-RJL (D.D.C.), Plea Agreement ans Statement of Offense, both filed December 15, 2008.  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.","Disposition of Criminal Case(s)":"According to the May 4, 2011 Siemens Company Statement on Legal Proceedings against it around the world, the criminal charges filed against it by the Nigerian Economic and Financial Crimes Commission (EFCC) was dismissed in November 2010, pursuant to a settlement agreement between Siemens and the Nigerian authorities. (Source: Siemens, \u0022Legal Proceedings,\u0022 May 4, 2011.)","Jurisdiction of Origin: Investigative Agency":"Munich Public Prosecutor\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Courts Involved":"High Court - Abuja, High Court of the Federal Capital Territory","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Fcpablog_Aug_4_2011_SERAP_Petition_to_EFCC.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Company_Statement_Legal_Proceedings_Worldwide_May_4_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_US_DOJ_Plea_Agreement_Dec_15_2008.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_US_DOJ_Statement_of_Offense_December_15_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Fcpablog.com_Aug_4_2011_SERAP_Petition_to_EFCC.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Fcpablog_Aug_4_2011_SERAP_Petition_to_EFCC.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Company_Statement_Legal_Proceedings_Worldwide_May_4_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_US_DOJ_Plea_Agreement_Dec_15_2008.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_US_DOJ_Statement_of_Offense_December_15_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens_Company_Statement_Legal_Proceedings_Worldwide_May_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Fcpablog_Aug_4_2011_SERAP_Petition_to_EFCC.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Company_Statement_Legal_Proceedings_Worldwide_May_4_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_US_DOJ_Plea_Agreement_Dec_15_2008.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_US_DOJ_Statement_of_Offense_December_15_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens_US_DOJ_Plea_Agreement_Dec_15_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Fcpablog_Aug_4_2011_SERAP_Petition_to_EFCC.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Company_Statement_Legal_Proceedings_Worldwide_May_4_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_US_DOJ_Plea_Agreement_Dec_15_2008.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_US_DOJ_Statement_of_Offense_December_15_2008.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens_US_DOJ_Statement_of_Offense_December_15_2008.pdf","Sources ":"The 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice by Mr. Mohammed Bello Adoke, SAN, Honourable Attorney-General of the Federation and Minister of Justice, also noted the Halliburton settlement.\u00a0 (22 December 2010). \nMarcus Cohen, David Elesinmogun \u0026 Obumneme Egwuatu, \u0022Will Nigeria Take Another Bite?,\u0022 FCPA Blog, August 4, 2011, accessed at http:\/\/www.fcpablog.com\/blog\/tag\/shell; \nSiemens, \u0022Legal Proceedings,\u0022 May 4, 2011, accessed at http:\/\/www.siemens.com\/press\/pool\/de\/events\/2011\/corporate\/2011-q2\/2011-... \nUS v. Siemens A.G., Case No. 08-cr-367-RJL (D.D.C.), Plea Agreement and Statement of Offense, both filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens-aktiengesellsch....\n"},{"Case ID":"ARW-185","Case Title (Name of Public Official or Entity Allegedly Involved)":"Tidewater, Inc. (Nigeria Settlement)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United States","Position of Public Official(s) (yrs in office)":"NA","Jurisdiction of Asset Recovery":"Nigeria","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2010","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Settlement Agreement (Source: Tidewater, Inc., US Securities and Exchange Commission Form 8-K filed March 3, 2011, at http:\/\/www.sec.gov\/Archives\/edgar\/data\/98222\/000119312511055141\/d8k.htm)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$6,300,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to Tidwater Inc.\u0027s March 3, 2011 Form 8-K filed with the US Securities and Exchange Commission, pursuant to a settlement agreement announced that day, Tidewater agreed to settle allegations that the Nigerian affiliate of a Swiss-based freight forwarder had made improper payments to government officials in Nigeria on behalf of Tidewater\u0027s foreign subsidiaries. The Nigerian investigation revolved around the same 2007 conduct detailed in Tidewater\u0027s settlements with the US Department of Justice and the Securities and Exchange Commission. Tidewater agreed to pay $6 million to the Government of Nigeria and an additional $300,000 for the Government of Nigeria\u0027s attorneys and other expenses. (Source: Technip Inc., SEC Form 8-K filed March 3, 2011.) Tidewater\u0027s settlements with the US Department of Justice and the Securities and Exchange Commission are detailed in: US v. Tidewater Marine International, Inc., Case No. 4:10-cr-00770 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts filed November 4, 2010; and US Securities and Exchange Commission, Litigation Release No. 21729 (November 4, 2010), in SEC v. Tidewater, Inc., Case No. 2:10-cv-04180 (E.D. La.), Complaint filed November 4, 2010. Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.","Disposition of Criminal Case(s)":"According to Technip Inc.\u0027s March 3, 2011 Form 8-K filed with the US Securities and Exchange Commission, pursuant to a settlement agreement announced that day, the Government of Nigeria had agreed to terminate its investigation into Tidewater\u0027s operations in Nigeria in 2007 and agreed not to bring criminal or civil claims against the company or associated persons in connection with those allegations. (Source: Technip Inc., SEC Form 8-K filed March 3, 2011.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Economic and Financial Crimes Commission","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Economic and Financial Crimes Commission; Attorney General","Jurisdiction of Asset Recovery: Courts Involved":"N\/A","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_Nigeria_Settlement_SEC_Form_8-K_Mar_3_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_US_DOJ_Deferred_Prosecution_Agreement_Nov_4_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_US_SEC_Complaint_Nov_4_2010.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_US_SEC_Litigation_Release_Nov_4_2010.PDF\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Tidewater_SEC_Complaint_Nov_4_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_Nigeria_Settlement_SEC_Form_8-K_Mar_3_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_US_DOJ_Deferred_Prosecution_Agreement_Nov_4_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_US_SEC_Complaint_Nov_4_2010.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_US_SEC_Litigation_Release_Nov_4_2010.PDF\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Tidewater_SEC_Litigation_Release_Nov_4_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_Nigeria_Settlement_SEC_Form_8-K_Mar_3_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_US_DOJ_Deferred_Prosecution_Agreement_Nov_4_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_US_SEC_Complaint_Nov_4_2010.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Tidewater_US_SEC_Litigation_Release_Nov_4_2010.PDF\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Tidewater_Nigeria_Settlement_SEC_Form_8-K_Mar_3_2011.pdf","Sources ":"Tidewater, Inc., US Securities and Exchange Commission Form 8-K filed March 3, 2011, at http:\/\/www.sec.gov\/Archives\/edgar\/data\/98222\/000119312511055141\/d8k.htm; US v. Tidewater Marine International, Inc., Case No. 4:10-cr-00770 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts filed November 4, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tidewater-intl\/11-04-10... US Securities and Exchange Commission, Litigation Release No. 21729 (November 4, 2010), in SEC v. Tidewater, Inc., Case No. 2:10-cv-04180 (E.D. La.), Complaint filed November 4, 2010, both accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21729.htm and http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21729.pdf.\n"},{"Case ID":"ARW-173","Case Title (Name of Public Official or Entity Allegedly Involved)":"Siemens AG (Italy Settlement)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Germany","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"Italy","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2004","Asset Recovery End":"2006","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Plea Bargain without Admission of Guilt or Responsibility (Source: Siemens, \u0022Legal Proceedings - Fiscal 2007,\u0022 November 8, 2007.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$8,522,530","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to the Complaint in US Securities and Exchange Commission, in 2004, a Milan judge issued a written opinion that Siemens viewed bribery at least as a possible business strategy and that \u0022Subsequently, Siemens, along with two of its PG managers, entered into a plea bargain with criminal authorities in Italy pursuant to which Siemens paid a \u20ac0.5 million fine, gave up \u20ac6.2 million in profits and was barred fiom selling gas turbines in Italy for one year.\u0022  (Source: US Securities and Exchange Commission v. Siemens AG, Case No. 1:08-cv-02167 (D.D.C.), Complaint filed December 12, 2008, para 23.)  According to a 2007 Siemens company statement, \u0022the agreement was In Italy, legal proceedings against two former employees ended when the \u201cpatteggiamento\u201d (plea bargaining procedure without the admission of guilt or responsibility) by the charged employees and Siemens AG entered into force in November 2006.\u0022  (Source: Siemens, \u0022Legal Proceedings - Fiscal 2007,\u0022 November 8, 2007.)","Disposition of Criminal Case(s)":"According to the Complaint in US Securities and Exchange Commission, in 2004, a Milan judge issued a written opinion that Siemens viewed bribery at least as a possible business strategy and that \u0022Subsequently, Siemens, along with two of its PG managers, entered into a plea bargain with criminal authorities in Italy pursuant to which Siemens paid a \u20ac0.5 million fine, gave up \u20ac6.2 million in profits and was barred from selling gas turbines in Italy for one year.\u0022  (Source: US Securities and Exchange Commission v. Siemens AG, Case No. 1:08-cv-02167 (D.D.C.), Complaint filed December 12, 2008, para 23.)","Jurisdiction of Origin: Investigative Agency":"Munich Public Prosecutor\u0027s Office","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Milan Pubilc Prosecutor","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Asset Recovery: Courts Involved":"Milan Judge","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_US_SEC_Complaint_DDC_Dec_12_2008.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Company_Statement_Legal_Proceedings_2007.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens_SEC_Amended_Complaint.pdf","Sources ":"US Securities and Exchange Commission v. Siemens AG, Case No. 1:08-cv-02167 (D.D.C.), Complaint filed December 12, 2008, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20829.pdf; \nSiemens, \u0022Legal Proceedings - Fiscal 2007,\u0022 November 8, 2007, accessed at http:\/\/www.siemens.com\/press\/pool\/de\/events\/jahrespk2007\/legal-proceedin....)\n"},{"Case ID":"ARW-175","Case Title (Name of Public Official or Entity Allegedly Involved)":"Siemens AG (World Bank and EBRD Settlements)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Germany","Position of Public Official(s) (yrs in office)":"","Jurisdiction of Asset Recovery":"World Bank","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Other (Administrative Sanctions)","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"N\/A","Contributing Factors in Asset Recovery":"Settlement Agreement (Source: The World Bank Press Release, \u0022Siemens to pay $100m to fight corruption as part of World Bank Group settlement,\u0022 Press Release No:2009\/001\/EXT, July 2, 2009.)","Status of Asset Recovery ":"Completed (in part) and Ongoing (in part)","Stage in Asset Recovery Chain":"Other","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$70,000,000 (granted and committed)","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Establishment of Siemens Integrity Initiative","Case Summary":"According to the World Bank Press Release of July 2, 2009, Siemens and the World Bank announced a comprehensive settlement agreement \u0022in the wake of the company\u2019s acknowledged past misconduct in its global business and a World Bank investigation into corruption in a project in Russia involving a Siemens subsidiary. The settlement includes a commitment by Siemens to pay $100 million over the next 15 years to support anti-corruption work.\u0022 (Source: The World Bank Press Release, \u0022Siemens to pay $100m to fight corruption as part of World Bank Group settlement,\u0022 Press Release No:2009\/001\/EXT, July 2, 2009.)  According to Siemens, \u0022Over 30 projects from over 20 countries were selected for funding in the first funding round and will receive an overall funding up to US$ 40 million.\u0022  In December 2014, Siemens announced the selected grantees in the first group of the second round.  (Source:  Siemens A.G., World Bank, European Investment Bank Joint Press Release, \u0022Siemens Integrity Initiative enters the second round,\u0022 December 10, 2014; See also Siemens A.G., Integrity Initiative at http:\/\/www.siemens.com\/about\/sustainability\/en\/core-topics\/collective-ac... and http:\/\/www.siemens.com\/about\/sustainability\/en\/core-topics\/collective-ac... [last accessed June 27, 2016].)","Disposition of Criminal Case(s)":"N\/A (Administrative Sanctions)","Jurisdiction of Origin: Investigative Agency":"World Bank Integrity Vice Presidency","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"World Bank Integrity Vice Presidency","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"World Bank Integrity Vice Presidency","Jurisdiction of Asset Recovery: Courts Involved":"","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_World_Bank_Settlement_WB_PR_Jul_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Integrity_Initiative_Overview_First_Round_Company_Website_Oct_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens-integrity-initiative-project-profiles-first-round_Sep_2011.PDF\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens_Integrity_Initiative_Overview_First_Round_Company_Website_Oct_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_World_Bank_Settlement_WB_PR_Jul_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Integrity_Initiative_Overview_First_Round_Company_Website_Oct_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens-integrity-initiative-project-profiles-first-round_Sep_2011.PDF\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens_World_Bank_Settlement_WB_PR_Jul_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_World_Bank_Settlement_WB_PR_Jul_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Integrity_Initiative_Overview_First_Round_Company_Website_Oct_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens-integrity-initiative-project-profiles-first-round_Sep_2011.PDF\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens-integrity-initiative-project-profiles-first-round_Sep_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_World_Bank_Settlement_WB_PR_Jul_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Integrity_Initiative_Overview_First_Round_Company_Website_Oct_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens-integrity-initiative-project-profiles-first-round_Sep_2011.PDF\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens_Integrity%20Initiative_Jan_2015.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_World_Bank_Settlement_WB_PR_Jul_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Integrity_Initiative_Overview_First_Round_Company_Website_Oct_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens-integrity-initiative-project-profiles-first-round_Sep_2011.PDF\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens_Integrity%20Initiative_Jan_2015_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_World_Bank_Settlement_WB_PR_Jul_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens_Integrity_Initiative_Overview_First_Round_Company_Website_Oct_2011.PDF, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Siemens-integrity-initiative-project-profiles-first-round_Sep_2011.PDF\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Siemens_Second_Round_Joint_PR_Dec_10_2014.pdf","Sources ":"\n\tThe World Bank Press Release, \u0022Siemens to pay $100m to fight corruption as part of World Bank Group settlement,\u0022 Press Release No:2009\/001\/EXT, July 2, 2009, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,contentMDK:22234573~pag...\n\n\t\u00a0\n\n\tSiemens A.G., World Bank, European Investment Bank Joint Press Release, \u0022Siemens Integrity Initiative enters the second round,\u0022 December 10, 2014, at http:\/\/www.siemens.com\/press\/pool\/de\/pressemitteilungen\/2014\/corporate\/P...\n\n\t\u00a0\n\n\tSiemens Integrity Initiative, at http:\/\/www.siemens.com\/about\/sustainability\/en\/core-topics\/collective-ac... and http:\/\/www.siemens.com\/about\/sustainability\/en\/core-topics\/collective-ac... (last accessed June 27, 2016.)\n"},{"Case ID":"ARW-1","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alain Gagnon \/ Archive Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Canada","Position of Public Official(s) (yrs in office)":"Financial Auditor, Department of Public Works and Government Services (exact years in office unknown, but at least from 1996-2007)","Jurisdiction of Asset Recovery":"Canada","Jurisdiction of Asset Description":"Undertaking Recovery Effort","Asset Recovery Start":"2008","Asset Recovery End":"2008","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Treaty Between the Government of the United States of America and the Government of Canada on Mutual Legal Assistance in Criminal Matters (1985 U.S.T. LEXIS 230)","Contributing Factors in Asset Recovery":"Mr. Gagnon pleaded guilty and as part of his plea agreement, he assigned his property to the victim, namely Her Majesty the Queen in Right of Canada.  In addition, when served with the Canadian restitution order, the U.S. investment firms liquidated his accounts and voluntarily remitted the funds to the Canadian agency.  (Source:  In re: Restraint of All Assets Held in the Name of Alain Gagnon In, etc. Case No. 1:08-mc-00260-PLF (D.D.C.), Official Supplemental Request by Canada to the United States of America, document 6-1 filed on April 13, 2009.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"Please see Alain Gagnon \/ Archive Case - Jurisdiction of Asset Recovery United States","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"As part of his 2008 plea agreement, Mr. Gagnon assigned his property to the victim, namely Her Majesty the Queen in Right of Canada, by executing a \u0022Deed of Assignment.\u0022 The properties included funds held in the U.S. in accounts under his name with the firm Options Express in Chicago, FX Solutions in New Jersey, and Forex Capital Markets in New York. On April 28, 2008, the U.S. District Court for the District of Columbia acted upon the January 4, 2008 Request for Assistance by the Canadian court and ordered those funds to be restrained. Upon being served with the Canadian Order, however, the law firm acting on behalf of FX Solutions issued a check payable to the Receiver General for Canada in the amount of CAD $46,828.04. In October 2008, the Public Works and Government Services\u0027 Legal Counsel and case agents followed up with Forex Capital Markets and Options Express; each of the firms liquidated the accounts and remitted to the Public Works and Government Services all of the money in the investment accounts: $19,533.40 by Forex Capital and $50,931.68 by Options Express. (Source: In re: Restraint of All Assets Held in the Name of Alain Gagnon In, etc. Case No. 1:08-mc-00260-PLF (D.D.C.), Official Supplemental Request by Canada to the United States of America, document 6-1 filed on April 13, 2009 which also includes an official translation of the Order of Restitution and Order to Revoke Restraining Order in Director of Criminal and Penal Prosecutions v. Alain Gagnon, Respondent and Her Majesty the Queen in the Right of Canada, FX Solutions, FOREX Capital Markers, Mis-en-case, No. 550-01-030814-075, 550-26-000342-070, Court of Quebec, Criminal and Penal Division, Province of Quebec, District of Hull, signed on August 21, 2008).","Disposition of Criminal Case(s)":"On August 21, 2008, Mr. Gagnon pleaded guilty to fraud and breach of trust by a public officer, and sentenced in November 2008.  He had been charged by the Director of Criminal and Penal Prosecutions in the Province of Quebec (Canada) of fraud, breach of trust by a public officer and laundering proceeds of crime.  (Source:  In re: Restraint of All Assets Held in the Name of Alain Gagnon In, etc. Case No. 1:08-mc-00260-PLF (D.D.C.), Official Supplemental Request by Canada to the United States of America, document 6-1 filed on April 13, 2009.)","Jurisdiction of Origin: Investigative Agency":"Royal Canadian Mounted Police","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Director of Criminal and Penal Prosecutions in the Province of Quebec (Canada); Department of Public Works and Government Services, Legal Counsel","Jurisdiction of Origin: Courts Involved":"Court of Quebec, Criminal and Penal Division  ","Jurisdiction of Asset Recovery: Investigative Agency":"Royal Canadian Mounted Police","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Director of Criminal and Penal Prosecutions in the Province of Quebec (Canada); Department of Public Works and Government Services, Legal Counsel","Jurisdiction of Asset Recovery: Courts Involved":"Court of Quebec, Criminal and Penal Division","Documents":"","Sources ":"In re: Restraint of All Assets Held in the Name of Alain Gagnon In, etc. Case No. 1:08-mc-00260-PLF (D.D.C.), Official Supplemental Request by Canada to the United States of America, document 6-1 filed on April 13, 2009, which includes an official translation of the Order of Restitution and Order to Revoke Restraining Order in Director of Criminal and Penal Prosecutions v. Alain Gagnon, Respondent and Her Majesty the Queen in the Right of Canada, FX Solutions, FOREX Capital Markers, Mis-en-case, No. 550-01-030814-075, 550-26-000342-070, Court of Quebec, Criminal and Penal Division, Province of Quebec, District of Hull, signed 21st day of August 2008.\n"},{"Case ID":"ARW-2","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alain Gagnon \/ Archive Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Canada","Position of Public Official(s) (yrs in office)":"Financial Auditor, Department of Public Works and Government Services (exact years in office unknown, but at least from 1996-2007)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"2008","UNCAC Offenses Implicated":"Art.17","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Other","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Treaty Between the Government of the United States of America and the Government of Canada on Mutual Legal Assistance in Criminal Matters (1985 U.S.T. LEXIS 230)","Contributing Factors in Asset Recovery":"Mr. Gagnon pleaded guilty and as part of his plea agreement, he assigned his property to the victim, namely Her Majesty the Queen in Right of Canada.  In addition, when served with the Canadian restitution order, the U.S. investment firms liquidated his accounts and voluntarily remitted the funds to the Canadian agency.  (Source:  In re: Restraint of All Assets Held in the Name of Alain Gagnon In, etc. Case No. 1:08-mc-00260-PLF (D.D.C.), Official Supplemental Request by Canada to the United States of America, document 6-1 filed on April 13, 2009.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$112,656.68","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"As part of his 2008 plea agreement, Mr. Gagnon assigned his property to the victim, namely Her Majesty the Queen in Right of Canada, by executing a \u0022Deed of Assignment.\u0022 The properties included funds held in the U.S. in accounts under his name with the firm Options Express in Chicago, FX Solutions in New Jersey, and Forex Capital Markets in New York.  On April 28, 2008, the U.S. District Court for the District of Columbia acted upon the January 4, 2008 Request for Assistance by the Canadian court and ordered those funds to be restrained.  Upon being served with the Canadian Order, however, the law firm acting on behalf of FX Solutions issued a check payable to the Receiver General for Canada in the amount of CAD $46,828.04.  In October 2008, the Public Works and Government Services\u0027 Legal Counsel and case agents followed up with Forex Capital Markets and Options Express; each of the firms liquidated the accounts and remitted to the Public Works and Government Services all of the money in the investment accounts: $19,533.40 by Forex Capital and $50,931.68 by Options Express. (Source: In re: Restraint of All Assets Held in the Name of Alain Gagnon In, etc. Case No. 1:08-mc-00260-PLF (D.D.C.), Official Supplemental Request by Canada to the United States of America, document 6-1 filed on April 13, 2009 which also includes an official translation of the Order of Restitution and Order to Revoke Restraining Order in Director of Criminal and Penal Prosecutions v. Alain Gagnon, Respondent and Her Majesty the Queen in the Right of Canada, FX Solutions, FOREX Capital Markers, Mis-en-case, No. 550-01-030814-075, 550-26-000342-070, Court of Quebec, Criminal and Penal Division, Province of Quebec, District of Hull, signed on August 21, 2008).","Disposition of Criminal Case(s)":"On August 21, 2008, Mr. Gagnon pleaded guilty to fraud and breach of trust by a public officer, and sentenced in November 2008.  He had been charged by the Director of Criminal and Penal Prosecutions in the Province of Quebec (Canada) of fraud, breach of trust by a public officer and laundering proceeds of crime.  (Source:  In re: Restraint of All Assets Held in the Name of Alain Gagnon In, etc. Case No. 1:08-mc-00260-PLF (D.D.C.), Official Supplemental Request by Canada to the United States of America, document 6-1 filed on April 13, 2009.)","Jurisdiction of Origin: Investigative Agency":"Royal Canadian Mounted Police","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Director of Criminal and Penal Prosecutions in the Province of Quebec (Canada); Department of Public Works and Government Services, Legal Counsel","Jurisdiction of Origin: Courts Involved":"Court of Quebec, Criminal and Penal Division  ","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Department of Justice, Criminal Division,  Asset Forfeiture and Money Laundering Section","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Columbia","Documents":"","Sources ":"In re: Restraint of All Assets Held in the Name of Alain Gagnon In, etc. Case No. 1:08-mc-00260-PLF (D.D.C.), Official Supplemental Request by Canada to the United States of America, document 6-1 filed on April 13, 2009, which includes an official translation of the Order of Restitution and Order to Revoke Restraining Order in Director of Criminal and Penal Prosecutions v. Alain Gagnon, Respondent and Her Majesty the Queen in the Right of Canada, FX Solutions, FOREX Capital Markers, Mis-en-case, No. 550-01-030814-075, 550-26-000342-070, Court of Quebec, Criminal and Penal Division, Province of Quebec, District of Hull, signed 21st day of August 2008.\n"},{"Case ID":"ARW-3","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alcatel-Lucent \/ Instituto Costarricense de Electricidad (ICE)  (Costa Rica Settlement Case)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Costa Rica","Position of Public Official(s) (yrs in office)":"President Miguel Angel Rodriguez (1998-2002) and other public officials, including Instituto Costarricense de Electricidad representatives","Jurisdiction of Asset Recovery":"France","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"2010","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"According to a U.S. Department of Justice Press Release, \u0022The settlement marked the first time in Costa Rica\u0027s history that a foreign corporation agreed to pay the government damages for corruption.\u0022 (Source:  U.S. Department of Justice Press Release, \u0022Alcatel-Lucent S.A. and Three Subsidiaries Agree to Pay $92 Million to Resolve Foreign Corrupt Practices Act Investigation,\u0022 December 27, 2010.); Concept of \u0022Social Damages\u0022 as basis for monetary damages first applied by Costa Rica in this case. (Source: Transparency International Blog, Ahernandez, \u0022Can bribes paid by private firms cause \u0027social damage\u0027?\u0022 January 26, 2010 at http:\/\/blog.transparency.org\/2010\/01\/26\/can-bribes-paid-by-private-firms-cause-%E2%80%9Csocial-damage%E2%80%9D\/.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$10,000,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"A copy of the Settlement Agreement between the Government of Costa Rica and Alcatel-Lucent was filed by the US Government as part of its Foreign Corrupt Practices Act case against Alcatel. (Source: US v. Alcatel-Lucent France S.A., et al, Case No. 1:10-cr-20906 (S.D.Fla.) and US v. Alcatel-Lucent, S.A., Case No. 1:10-cr-20907 (S.D.Fla), Government\u0027s Response to ICE\u0027s Petition for Victim Status and Restitution filed May 23, 2011, Exhibit 1: SETTLEMENT AGREEMENT BETWEEN ALCATEL-LUCENT FRANCE, AND THE OFFICE OF THE ATTORNEY GENERAL OF THE REPUBLIC, ON BEHALF OF THE COSTA RICAN STATE RELATING TO THE CIVIL RECOVERY ACTION INCLUDED IN CRIMINAL CASE 04-6835-647-PEA). According to a statement on its website, Alcatel-Lucent noted that it had entered into an agreement with the Costa Rican authorities to pay $10 million to settle civil claims in a corruption case in which it was alleged that the company had paid kickbacks to public officials, political parties and officials of the state-owned telecom company in return for a 2001 contract worth $149 million to supply cellular telephone equipment. The statement notes the company\u0027s earlier settlement with the U.S. authorities and continuing investigation by France. (Source: \u0022Alcatel-Lucent, September 2010: A responsible behaviour - Controversies\u0022 posted at the company\u0027s website at http:\/\/www.alcatel-lucent.com\/csr\/htm\/en\/pdf\/Controversies_Costa_Rica.pdf). One of the alleged officials who received the kickbacks is former Costa Rican president Miguel Angel Rodriguez. (Source: Acusacion de la Fiscalia, posted at http:\/\/www.nacion.com\/Generales\/Subsitios\/Sucesos\/2010\/ICEALCATEL.aspx) According to the U.S. Department of Justice, the case marks the first time in Costa Rica\u0027s history that a foreign corporation has agreed to pay the government damages for corruption. (Source: U.S. Department of Justice Press Release, \u0022Alcatel-Lucent S.A. and Three Subsidiaries Agree to Pay $92 Million to Resolve Foreign Corrupt Practices Act Investigation,\u0022 December 27, 2010.)","Disposition of Criminal Case(s)":"On April 28, 2011, former Costa Rican President Miguel Angel Rodriguez (1998-2002) was convicted and sentenced to five years\u0027 imprisonment for his role in the Alcatel bribery case. (Sources: Samuel Rubenfeld, \u0022Former Costa Rican President Sentenced to Prison over Alcatel Bribery,\u0022 Wall Street Journal Corruption Currents Blog, April 28, 2011; Indictment\/La Acusacion de la Fiscalia posted at http:\/\/www.nacion.com\/Generales\/Subsitios\/Sucesos\/2010\/ICEALCATEL.aspx).","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Attorney General and Prosecutor\u0027s Office (Costa Rica)","Jurisdiction of Origin: Courts Involved":"Unknown","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/10-crm-1481%20%20doj%20press%20release%20dec%202010%20settlement.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Acusacion_Rodriguez.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alcatel_Transparency_Intl_Blog_Jan_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alcatel_UK_Anti-Corruption_Forum_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alcatel-Lucent_Company_Statement_September_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Alcatel_Rodriguez_Conviction_Wall_Street_Journal_Apr_28_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/ICE DOJ Response_SDFLA_May_23_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/ICE%20DOJ%20Response_SDFLA_May_23_2011.pdf","Sources ":"La Acusacion de la Fiscalia, posted at http:\/\/www.nacion.com\/Generales\/Subsitios\/Sucesos\/2010\/ICEALCATEL.aspx; U.S. Department of Justice Press Release, \u0022Alcatel-Lucent S.A. and Three Subsidiaries Agree to Pay $92 Million to Resolve Foreign Corrupt Practices Act Investigation,\u0022 December 27, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/December\/10-crm-1481.html; \u0022Alcatel-Lucent, September 2010: A responsible behaviour - Controversies\u0022 posted at the company\u0027s website at http:\/\/www.alcatel-lucent.com\/csr\/htm\/en\/pdf\/Controversies_Costa_Rica.pdf; UK Anti-Corruption Forum, February 2010 Newsletter, posted at http:\/\/www.anticorruptionforum.org.uk\/acf\/upload\/newsletters\/2010-02.pdf); Transparency International Blog, Ahernandez, \u0022Can bribes paid by private firms cause \u0027social damage\u0027?\u0022 January 26, 2010 at http:\/\/blog.transparency.org\/2010\/01\/26\/can-bribes-paid-by-private-firms... US v. Alcatel-Lucent France S.A., et al, Case No. 1:10-cr-20906 (S.D.Fla.) and US v. Alcatel-Lucent, S.A., Case No. 1:10-cr-20907 (S.D.Fla), Government\u0027s Response to ICE\u0027s Petition for Victim Status and Restitution filed May 23, 2011, Exhibit 1: SETTLEMENT AGREEMENT BETWEEN ALCATEL-LUCENT FRANCE, AND THE OFFICE OF THE ATTORNEY GENERAL OF THE REPUBLIC, ON BEHALF OF THE COSTA RICAN STATE RELATING TO THE CIVIL RECOVERY ACTION INCLUDED IN CRIMINAL CASE 04-6835-647-PEA\n"},{"Case ID":"ARW-4","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alexander Yakovlev and Vladimir Kuznetsov \/ United Nations Oil-for-Food Programme","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United Nations","Position of Public Official(s) (yrs in office)":"United Nations Oil-for-Food Programme unit chief (Yakovlev, 1985-2005); United Nations budget advisory committee member (2000-2003) and chair (2004-2005) (Kuznetsov)","Jurisdiction of Asset Recovery":"Liechtenstein","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2005","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"In announcing Mr. Yakovlev\u0027s plea, Mr. David N. Kelley, then-United States Attorney for the Southern District of New York \u0022praised the investigative efforts of the Federal Bureau of Investigation. In addition, Mr. KELLEY thanked the United Nations Office of Investigative Oversight Services for its assistance in the investigation.\u0022 (Source: United States Attorney for the Southern District of New York, Press Release, \u0022Former U.N. Procurement Officer Pleads Guilty to Federal Charges Arising from His Receipt of Hundreds of Thousands of Dollars from Foreign Companies Doing Business with the U.N.,\u0022 August 8, 2005.); United Nations sharing of information with United States Attorney\u0027s Office for the Southern District of New York and UN waiver of immunity for Mr. Yakovlev (Source: Opening statement by UN Chief of Staff Mark Malloch-Brown at a press conference on the Oil-for-Food programme (8 August 2005).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"","Agreement for Returned Assets - Description":"NA","Case Summary":"Former United Nations officials Vladimir Kuznetsov and Alexander Yakovlev were charged with corruption and money laundering in U.S. federal court for their respective roles in the United Nations Oil-for-Food Programme case.  Mr. Kuznetsov was convicted of one count of money laundering following a jury trial in the U.S. District Court for Southern District of New York and ordered to pay a criminal fine of $73,671.  He satisfied this judgment on November 18, 2008.  His co-conspirator Alexander Yakovlev pleaded guilty in 2005 to three counts of wire fraud and money laundering.  As part of his plea agreement, Mr. Yakovlev had agreed to forfeit $900,000 held in bank accounts in Liechtenstein.  On December 22, 2010, the federal court for the Southern District of New York ordered the following accounts forfeited to the U.S. (pending any assertions of third-party claims):  (1) Liechtensteinische Landesbank AG and LLB Treuhand AG, 9490 Vaduz, Accounts numbered 208.63898 and 213.042.67, in the name of Alexander Yakovlev or Olga Yakoleva; and (2) LLB AG and LLB Treuhand AG, 9490 Vaduz, Accounts numbered 212.440.51 and 213.036.32 in the name of Angelus Finance Ltd, for which Alexander Yakovlev is the financial beneficiary.  On February 10, 2011, the court ented a Satisfaction of Forfeiture Money Judgment, noting that the accounts had been forfeited by the Principality of Liechtenstein.  (Sources: U.S. v. Kuznetsov, Case No. 1:05-cr-00916-DAB (S.D.N.Y.), Judgment filed in a criminal case, filed October 19, 2007; U.S. v. Yakovlev, Case No. 1:05-cr-00819-DAB (S.D.N.Y.), Consent Order of Forfeiture filed on December 22, 2010; Satisfaction of Forfeiture Money Judgment, filed February 10, 2011.)","Disposition of Criminal Case(s)":"On December 22, 2010, Mr. Yakovlev was sentenced to two years\u0027 supervised release.  (Source: US v. Yakovlev, Case No. 1:05-cr-00819-DAB (S.D.N.Y.), Judgment in a Criminal Case, filed on December 22, 2010.)   His sentence followed a guilty plea on August 8, 2005 on three counts:  conspiracy to commit wire fraud, wire fraud and conspiracy to commit money laundering. (Source: Id.)   Mr. Kuznetsov was sentenced, on October 12, 2007, to 51 months\u0027 imprisonment and two years\u0027 supervised release.  (Source: U.S. v. Kuznetsov, Case No. 1:05-cr-00916-DAB (S.D.N.Y.), Judgment filed in a criminal case, filed October 19, 2007.)","Jurisdiction of Origin: Investigative Agency":"Independent Inquiry Committee into the United Nations Oil-for-Food Programme; UN Office of Investigative Oversight Services","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney Daniel Gitner, Counsel for the United Nations (in Yakovlev matter) (Source: U.S. v. Yakovlev, Case No. 1:05-cr-00819-DAB (S.D.N.Y.), Order to reschedule sentencing, filed on October 27, 2010.)","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, UN Independent Inquiry Committee into the United Nations Oil-for-Food Programme","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Southern District of New York","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kuznetsov_Judgment_Oct_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_Consent_Order_Forfeiture_Dec_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_Judgment_Dec_22_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_Plea_USASDNY_PR_Aug_8_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_Satisfaction_Forfeiture_Judgment_Feb_10_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_UN_Third_Interim_Report_Aug_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_UN_Waiver_Immunity_UN_Statement_Aug_8_2005\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yakovlev_UN_Waiver_Immunity_UN_Statement_Aug_8_2005.pdf","Sources ":"U.S. v. Yakovlev, Case No. 1:05-cr-00819-DAB, Consent Order of Forfeiture filed on December 22, 2010, Judgment in a Criminal Case, filed on December 22, 2010 and Satisfaction of Forfeiture Money Judgment, filed February 10, 2011. See also, United Nations Independent Inquiry Committee into the United Nations Oil-for-Food Programme, Third Interim Report: The Conduct of Benon Sevan, The Conduct of Alexander Yakovlev, at http:\/\/www.iic-offp.org\/documents\/Third%20Interim%20Report.pdf. U.S. v. Kuznetsov, Case No. 1:05-cr-00916-DAB (S.D.N.Y.), Judgment filed in a criminal case, October 19, 2007; United States Attorney for the Southern District of New York Press Release, \u0022Former U.N. Procurement Officer Pleads Guilty to Federal Charges arising from His Receipt of Hundreds of Thousands of Dollars from Foreign Companies Doing Business with the U.N.,\u0022 August 8, 2005, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/August05\/yakovlevpleapr.pdf; Opening statement by UN Chief of Staff Mark Malloch-Brown at a press conference on the Oil-for-Food programme (8 August 2005), accessed at http:\/\/www.un.org\/News\/dh\/iraq\/oip\/open_stmnt_8aug05.htm\n"},{"Case ID":"ARW-5","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alexander Yakovlev and Vladimir Kuznetsov \/ United Nations Oil-for-Food Programme","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"United Nations","Position of Public Official(s) (yrs in office)":"United Nations Oil-for-Food Programme unit chief (Yakovlev, 1985-2005); United Nations budget advisory committee member (2000-2003) and chair (2004-2005) (Kuznetsov)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2005","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture; Criminal Fine","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"In announcing Mr. Yakovlev\u0027s plea, Mr. David N. Kelley, then-United States Attorney for the Southern District of New York \u0022praised the investigative efforts of the Federal Bureau of Investigation. In addition, Mr. KELLEY thanked the United Nations Office of Investigative Oversight Services for its assistance in the investigation.\u0022 (Source: United States Attorney for the Southern District of New York, Press Release, \u0022Former U.N. Procurement Officer Pleads Guilty to Federal Charges Arising from His Receipt of Hundreds of Thousands of Dollars from Foreign Companies Doing Business with the U.N.,\u0022 August 8, 2005.); United Nations sharing of information with United States Attorney\u0027s Office for the Southern District of New York and UN waiver of immunity for Mr. Yakovlev (Source: Opening statement by UN Chief of Staff Mark Malloch-Brown at a press conference on the Oil-for-Food programme (8 August 2005).","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"Former United Nations officials Vladimir Kuznetsov and Alexander Yakovlev were charged with corruption and money laundering in U.S. federal court for their respective roles in the United Nations Oil-for-Food Programme case.  Mr. Kuznetsov was convicted of one count of money laundering following a jury trial in the U.S. District Court for Southern District of New York and ordered to pay a criminal fine of $73,671.  He satisfied this judgment on November 18, 2008.  His co-conspirator Alexander Yakovlev pleaded guilty in 2005 to three counts of wire fraud and money laundering.  As part of his plea agreement, Mr. Yakovlev had agreed to forfeit $900,000 held in bank accounts in Liechtenstein.  On December 22, 2010, the federal court for the Southern District of New York ordered the following accounts forfeited to the U.S. (pending any assertions of third-party claims):  (1) Liechtensteinische Landesbank AG and LLB Treuhand AG, 9490 Vaduz, Accounts numbered 208.63898 and 213.042.67, in the name of Alexander Yakovlev or Olga Yakoleva; and (2) LLB AG and LLB Treuhand AG, 9490 Vaduz, Accounts numbered 212.440.51 and 213.036.32 in the name of Angelus Finance Ltd, for which Alexander Yakovlev is the financial beneficiary.  On February 10, 2011, the court ented a Satisfaction of Forfeiture Money Judgment, noting that the accounts had been forfeited by the Principality of Liechtenstein.  (Sources: U.S. v. Kuznetsov, Case No. 1:05-cr-00916-DAB (S.D.N.Y.), Judgment filed in a criminal case, filed October 19, 2007; U.S. v. Yakovlev, Case No. 1:05-cr-00819-DAB (S.D.N.Y.), Consent Order of Forfeiture filed on December 22, 2010; Satisfaction of Forfeiture Money Judgment, filed February 10, 2011.)","Disposition of Criminal Case(s)":"On December 22, 2010, Mr. Yakovlev was sentenced to two years\u0027 supervised release.  (Source: US v. Yakovlev, Case No. 1:05-cr-00819-DAB (S.D.N.Y.), Judgment in a Criminal Case, filed on December 22, 2010.)   His sentence followed a guilty plea on August 8, 2005 on three counts:  conspiracy to commit wire fraud, wire fraud and conspiracy to commit money laundering. (Source: Id.)   Mr. Kuznetsov was sentenced, on October 12, 2007, to 51 months\u0027 imprisonment and two years\u0027 supervised release.  (Source: U.S. v. Kuznetsov, Case No. 1:05-cr-00916-DAB (S.D.N.Y.), Judgment filed in a criminal case, filed October 19, 2007.)","Jurisdiction of Origin: Investigative Agency":"Independent Inquiry Committee into the United Nations Oil-for-Food Programme; UN Office of Investigative Oversight Services","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney Daniel Gitner, Counsel for the United Nations (in Yakovlev matter) (Source: U.S. v. Yakovlev, Case No. 1:05-cr-00819-DAB (S.D.N.Y.), Order to reschedule sentencing, filed on October 27, 2010.)","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, UN Independent Inquiry Committee into the United Nations Oil-for-Food Programme","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Southern District of New York","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Kuznetsov_Judgment_Oct_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_Consent_Order_Forfeiture_Dec_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_Judgment_Dec_22_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_Plea_USASDNY_PR_Aug_8_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_Satisfaction_Forfeiture_Judgment_Feb_10_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_UN_Third_Interim_Report_Aug_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Yakovlev_UN_Waiver_Immunity_UN_Statement_Aug_8_2005\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Yakovlev_UN_Waiver_Immunity_UN_Statement_Aug_8_2005_0.pdf","Sources ":"U.S. v. Yakovlev, Case No. 1:05-cr-00819-DAB, Consent Order of Forfeiture filed on December 22, 2010, Judgment in a Criminal Case, filed on December 22, 2010 and Satisfaction of Forfeiture Money Judgment, filed February 10, 2011. See also, United Nations Independent Inquiry Committee into the United Nations Oil-for-Food Programme, Third Interim Report: The Conduct of Benon Sevan, The Conduct of Alexander Yakovlev, at http:\/\/www.iic-offp.org\/documents\/Third%20Interim%20Report.pdf. U.S. v. Kuznetsov, Case No. 1:05-cr-00916-DAB (S.D.N.Y.), Judgment filed in a criminal case, October 19, 2007; United States Attorney for the Southern District of New York Press Release, \u0022Former U.N. Procurement Officer Pleads Guilty to Federal Charges arising from His Receipt of Hundreds of Thousands of Dollars from Foreign Companies Doing Business with the U.N.,\u0022 August 8, 2005, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/August05\/yakovlevpleapr.pdf.\n"},{"Case ID":"ARW-6","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alfonso Portillo (Switzerland)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Guatemala","Position of Public Official(s) (yrs in office)":"President (2000-2004)","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2012","Asset Recovery End":"Unknown","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Unknown","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Unknown","Stage in Asset Recovery Chain":"Unknown","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"As part of his plea agreement, Mr. Portillo admitted that while serving as President of Guatemala, he had received US$2.5 million from the government of China, Taiwan purportedly for the \u0022Libraries for Peace\u0022 project but was in exchange for Guatemala\u0027s continued recognition of China, Taiwan\u0027s sovereignty.  (Source: US v. Portillo, Case No. 1:09-cr-01142-RPP (S.D.N.Y.), Judgment in a criminal case filed June 11, 2014 and US Government Sentencing Memorandum filed May 12, 2014.)  The 2009 Indictment filed against Mr. Portillo by the U.S. Attorney\u0027s Office for the Southern District of New York had alleged that Mr. Portillo laundered the funds through bank accounts located in a number of jurisdictions, including Switzerland.  Two wire transfers were made in August 2004 (for $337,976.16 and 1,234,439.81 Euros) from accounts in France to accounts at Banco Audi Suisse S.A. in Switzerland held in the names of Mr. Portillo\u0027s former wife and daughter; in June 2005, a trust was established in Liechtenstein (the beneficiaries of which were Mr. Portillo\u0027s former wife and daughter) into which all the money maintained at the Banco Audi Suisse S.A. was transferred and thereafter, held in the name of the trust and two disbursements were made by the trust, in the sum of $8,000 to his daughter and $10,000 to his former wife in July 2006 and in September 2006, respectively, from the Banco Audi Suisse S.A. account. (Source: U.S. v. Portillo, Case No. 1:09-cr-01142-RPP (S.D.N.Y.), Indictment filed on December 1, 2009 and unsealed on January 25, 2010; Court Docket Report as of March 19, 2014.)  As part of his judgment in the US criminal case, Mr. Portillo consented to and was sentenced to forfeit US$2.5 million to the U.S. representing criminal proceeds.  (Source: US v. Portillo, Case No. 1:09-cr-01142-RPP (S.D.N.Y.), Judgment in a criminal case filed June 11, 2014.)","Disposition of Criminal Case(s)":"According to the US court records, Mr. Portillo pleaded guilty to one count of conspiracy to commit money laundering in the United States District Court for the Southern District of New York; in June 2014, he was sentenced to 70 months\u0027 imprisonment.  (Source: US v. Portillo, Case No. 1:09-cr-01142-RPP (S.D.N.Y.), Judgment in a Criminal Case, filed June 11, 2014)","Jurisdiction of Origin: Investigative Agency":"Comision Internacional Contra la Impunidad en Guatemala (International Commission Against Impunity in Guatemala)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Comision Internacional Contra la Impunidad en Guatemala (International Commission Against Impunity in Guatemala), Special Prosecutor\u0027s Office","Jurisdiction of Origin: Courts Involved":"Tribunal Undecimo de Sentencia Penal (Eleventh Court of Criminal Judgment)","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_SDNY_Dkt_Rept_as_of_Mar_19_2014_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Consent_Forfeiture_Order_May_22_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Judgment_June_11_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Sentencing_PR_May_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Indictment.pdf","Sources ":"U.S. v. Portillo, Case No. 1:09-cr-01142-RPP (S.D.N.Y.), Indictment filed on December 1, 2009, unsealed on January 25, 2010; US Government Sentencing Memorandum filed May 12, 2014; Judgment in a Criminal Case filed June 11, 2014.\n"},{"Case ID":"ARW-7","Case Title (Name of Public Official or Entity Allegedly Involved)":"Alfonso Portillo (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Guatemala","Position of Public Official(s) (yrs in office)":"President (2000-2004)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2009","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Request for Extradition","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"Consent Preliminary Order of Forfeiture","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"NA","Case Summary":"As part of his plea agreement, Mr. Portillo admitted that while serving as President of Guatemala, he had received US$2.5 million from the government of China, Taiwan purportedly for the \u0022Libraries for Peace\u0022 project but was in exchange for Guatemala\u0027s continued recognition of China, Taiwan\u0027s sovereignty. \u00a0(Source: US v. Portillo, Case No. 1:09-cr-01142-RPP (S.D.N.Y.), Judgment in a criminal case filed June 11, 2014 and US Government Sentencing Memorandum filed May 12, 2014.) \u00a0 The 2009 indictment filed by the U.S. Attorney for the Southern District of New York \u00a0alleged that the criminal proceeds had been laundered through a complex scheme involving close associates and family members and shell entities, involving banks in Florida and New York (as well those in England, France, Luxembourg, and Switzerland). \u00a0(Source: U.S. v. Portillo, Case No. 1:09-cr-01142-RPP (S.D.N.Y.), Indictment filed December 1, 2009 and unsealed on January 25, 2010.) \u00a0According to a US Department of State press briefing transcript of November 11, 2011, the US spokesman stated that \u0022We understand that President Colom has upheld the Guatemalan Constitutional Court\u2019s August 26 decision that authorized the extradition of former President Alfonso Portillo to the United States on charges of conspiracy to commit money-laundering.\u0022 \u00a0(Source: US Department of State Daily Press Briefing transcript, \u0022 U.S. Extradition Request for Former President Alfonso Portillo,\u0022 November 17, 2011, filed May 10, 2012 in US v. Portillo, 1:09-cr-01142 (SDNY), accessed via PACER.) \u00a0In May 2010, the US federal court for Southern District of New York denied Mr. Portillo\u0027s habeas petition which had challenged his custody in Guatemala based on the US extradition request. \u00a0(Source: US v. Portillo, Case No. 1:09-cr-01142 (SDNY), Opinion and Order filed May 10, 2012.) After the Indictment was unsealed, in 2010, Mr. Portillo was arrested in Guatemala, and detained pending his extradition to the United States. \u00a0In May 2013, he was extradited to the United States and remanded into custody. \u00a0(Source: \u00a0US v. Portillo, 1:09-cr-1142 (SDNY), Order of Remand May 28, 2013).","Disposition of Criminal Case(s)":"According to the US court records, Mr. Portillo pleaded guilty to one count of conspiracy to commit money laundering in the United States District Court for the Southern District of New York; in June 2014, he was sentenced to 70 months\u0027 imprisonment.  (Source: US v. Portillo, Case No. 1:09-cr-01142-RPP (S.D.N.Y.), Judgment in a Criminal Case, filed June 11, 2014)","Jurisdiction of Origin: Investigative Agency":"Comision Internacional Contra la Impunidad en Guatemala (International Commission Against Impunity in Guatemala)","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Comision Internacional Contra la Impunidad en Guatemala (International Commission Against Impunity in Guatemala), Special Prosecutor\u0027s Office","Jurisdiction of Origin: Courts Involved":"Tribunal Undecimo de Sentencia Penal (Eleventh Court of Criminal Judgment)","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Internal Revenue Service, New York Field Office; U.S. Drug Enforcement Administration, New York Field Division","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Southern District of New York","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_SDNY_Opinion_Extradition_May_10_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_SDNY_USG_Extradition_Request_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Mem_Law_Support_Portillo_Pre_Trial_Mtns_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Remand_May_28_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_SDNY_Dkt_Rept_as_of_Mar_19_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Judgment_June_11_2014_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Sentencing_PR_May_2014_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Consent_Forfeiture_Order_May_22_2014_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_US_SDNY_Ct_Dkt_Rept_03182014_to_07272014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Indictment_Dec_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Press_Release_Unseal_Indictment_Jan_25_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Portillo_SDNY_Status_Report_Jan_25_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Portillo_SDNY_Indictment_Dec_2009.pdf","Sources ":"U.S. v. Portillo, Case No. 1:09-cr-01142-RPP (S.D.N.Y), Indictment filed December 1, 2009 and unsealed on January 25, 2010, and Status Report by U.S. Attorney dated January 25, 2010; Press Release by the United States Attorney for the Southern District of New York, \u0022Manhattan U.S. Attorney Unseals Money Laundering Charge against Former President of Guatemala,\u0022 January 25, 2010, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/January10\/portilloalfonsoi... US Department of State Daily Press Briefing transcript, \u0022 U.S. Extradition Request for Former President Alfonso Portillo,\u0022 November 17, 2011, filed May 10, 2012 and Opinion and Order filed May 10, 2012, Order of Remand filed May 28, 2013, US Government Sentencing Memorandum filed May 12, 2014, and Judgment in a Criminal Case filed June 11, 2014, in US v. Portillo, Case No. 1:09-cr-01142 (SDNY), accessed via PACER.\n"},{"Case ID":"ARW-14","Case Title (Name of Public Official or Entity Allegedly Involved)":"Aluminum Bahrain B.S.C. \/ Alcoa Case (Private Civil Action)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Bahrain","Position of Public Official(s) (yrs in office)":"Senior Officials of State Owned Entity (unnamed)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"2008","Asset Recovery End":"2013","UNCAC Offenses Implicated":"Art.16, Art.18, Art.21","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Private civil action resulted in settlement agreement.","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"In October 2012, Alcoa Inc. announced that it had reached an $85 million settlement agreement with Aluminum Bahrain B.S.C. (\u0022Alba\u0022), a majority state owned enterprise to settle the civil suit that Alba had filed in 2008, in U.S. District Court for the Western District of Pennsylvania against the U.S. company and related parties. (Source: Aluminum Bahrain B.S.C. v. Alcoa, Inc., et al, Case No. 2:08-cv-00299-DWA (W.D. Pa.), Stipulation of Dismissal with Prejudice, filed October 9, 2012; Alcoa Press Release, \u0022Alcoa and Alba Resolve Civil Litigation,\u0022 October 9, 2012.) In 2009, it filed a similar suit in the Southern District of Texas against the Japanese company Sojitz Corporation and its U.S. affiliate, Sojitz Corporation of America. Alba alleged that the companies paid bribes to one or more senior officials of Alba and the Government of Bahrain in order to induce Alba to cede a controlling interest in that company to Alcoa and to overpay for alumina and in the Sojitz case, to secure below-market discounts on aluminum. In filing the civil Racketeer Influenced and Corrupt Organizations (RICO) suit against Alcoa, Alba sought damages in excess of $1 billion and in the Sojitz suit, $31 million in damages. According to Alcoa, the second of the two payments to Alba was completed in October 2013. (Source: Alcoa, Stakeholder Engagement, \u0022Committed to Ongoing, Transparent Engagement,\u0022 http:\/\/www.alcoa.com\/sustainability\/en\/info_page\/community_stakeholder.asp, accessed on July 27, 2014.)","Disposition of Criminal Case(s)":"The asset recovery resulted from a private civil action by the state owned entity.  In related enforcement actions by the US, in January 2014, Alcoa entered into settlements with the US Department of Justice and the Securities and Exchange Commission which included a guilty plea to one count of violation of the Foreign Corrupt Practices Act. (Source: US Department of Justice Press Release, \u0022Alcoa World Alumina Agrees to Plead Guilty to Foreign Bribery and Pay $223 Million in Fines and Forfeiture,\u0022 January 9, 2014.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Alcoa DOJ Enorcement: Federal Bureau of Investigation","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Pennsylvania and Texas: Akin Gump Strauss Hauer and Feld LLP (Lead Attorneys Colleen M. Coyle, Lauren B. Kerwin, Mark J. MacDougall);  Pennsylvania:  Buchanan Ingersoll \u0026 Rooney PC (Attorney Charles B. Gibbons); Department of Justice, Criminal Division, Fraud Section; U.S. Attorney\u0027s Office for the Southern District of Texas","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Western District of Pennsylvania and the U.S. District Court for the Southern District of Texas","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Complaint_Feb_27_2008.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Motion_Stay_Mar_20_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_Complaint_Dec_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_US_Justice_Department_Application_Intervene_May_27_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Aluminum_Bahrain_Amended_Complaint_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Complaint_Feb_27_2008.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Motion_Stay_Mar_20_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_Complaint_Dec_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_US_Justice_Department_Application_Intervene_May_27_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Aluminum_Bahrain_WDPA_Stipulation_Dismiss_Oct_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Complaint_Feb_27_2008.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Motion_Stay_Mar_20_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_Complaint_Dec_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_US_Justice_Department_Application_Intervene_May_27_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Aluminum_Bahrain_WDPA_Order_Reopen_Case_Nov_2011_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Complaint_Feb_27_2008.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Motion_Stay_Mar_20_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_Complaint_Dec_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_US_Justice_Department_Application_Intervene_May_27_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alba_Sojitz_US_SDTEX_Stipulation_Dismissal_Dec_21_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Complaint_Feb_27_2008.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Motion_Stay_Mar_20_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_Complaint_Dec_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_US_Justice_Department_Application_Intervene_May_27_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alba_Sojitz_US_SDTEX_Order_Dismissal_Jan_16_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Complaint_Feb_27_2008.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Motion_Stay_Mar_20_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_Complaint_Dec_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_US_Justice_Department_Application_Intervene_May_27_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/ALBA_Alcoa_US_DOJ_SEC_Settlement_PR_Jan_9_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Complaint_Feb_27_2008.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Motion_Stay_Mar_20_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_Complaint_Dec_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_US_Justice_Department_Application_Intervene_May_27_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Alba_Alcoa_Stakeholder%20Engagement_Jul_27_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Complaint_Feb_27_2008.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Motion_Stay_Mar_20_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_Complaint_Dec_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_US_Justice_Department_Application_Intervene_May_27_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/ALBA_Alcoa_WDPA_Judgment_Jan_09_2014.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Complaint_Feb_27_2008.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Alcoa_Motion_Stay_Mar_20_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_Complaint_Dec_18_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Aluminum_Bahrain_Sojitz_US_Justice_Department_Application_Intervene_May_27_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/ALBA_Alcoa_WDPA_Plea_Agreement_Jan_09_2014.pdf","Sources ":"\n\n\t\tAluminum Bahrain B.S.C. v. Alcoa, Inc., Alcoa World Alumina LLC, et al, Case No. 2:08-cv-00299-DWA (W.D. Pa.), First Amended Complaint filed on November 28, 2011; and Stipulation to Dismiss with Prejudice filed October 9, 2012; Aluminum Bahrain B.S.C. v. Sojitz Corporation and Sojitz Corporation of America, Case No. 4:09-cv-04032 (S.D. Tex), Complaint filed on December 18, 2009, and United States\u0027 Application to Intervene and Stay Proceedings in the Instant Proceedings filed on May 27, 2010; Stipulation and Order to Dismiss, filed December 21, 2012 and January 16, 2013 respectively; Alcoa Press Release, \u0022Alcoa and Alba Resolve Civil Litigation,\u0022 October 9, 2012, accessed at http:\/\/www.alcoa.com\/global\/en\/news\/news_detail.asp?pageID=2012100900636....\n\n\t\t\u00a0\n\n\t\tAlcoa, Stakeholder Engagement, \u0022Committed to Ongoing, Transparent Engagement,\u0022 at http:\/\/www.alcoa.com\/sustainability\/en\/info_page\/community_stakeholder.asp (accessed on July 27, 2014); US Department of Justice Press Release, \u0022Alcoa World Alumina Agrees to Plead Guilty to Foreign Bribery and Pay $223 Million in Fines and Forfeiture,\u0022 January 9, 2014, at http:\/\/www.justice.gov\/opa\/pr\/2014\/January\/14-crm-019.html.\n\n\u00a0\n"},{"Case ID":"ARW-16","Case Title (Name of Public Official or Entity Allegedly Involved)":"Angolagate","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"","Position of Public Official(s) (yrs in office)":"Unspecified","Jurisdiction of Asset Recovery":"Switzerland","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2000","Asset Recovery End":"2012","UNCAC Offenses Implicated":"Art.16, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Other","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"A monitoring solution for repatriated assets, involving Swiss bilateral aid channels was agreed upon with the administrative costs and fiduciary responsibilities borne by the Swiss Agency for Development and Cooperation (SDC) and implementation unit comprised of  SDC and Angolan representatives (Source: Ann Lugon-Moulin, \u0022Asset Recovery: Concrete Challenges for Development Assistance,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008).  ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"Agreement between Angola and Switzerland for returned funds to be allocated to humanitarian projects in Angola; eligible projects include reconstruction, health and sanitation units, improvement of public utilitites and assistance to displaced populations.  Monitoring to be undertaken by the Swiss Development and Co-operation Agency (which is part of the Swiss Ministry of Foreign Affairs).  (Source: Paul Gully-Hart, \u0022International asset recovery of corruption-related assets: Switzerland,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (2008).  SHP Programme website, www.psh-angola.net - projects to date: $4.2 million for vocational training in two provinces and mine clearance project.)","Case Summary":"\n\tOn December 17, 2012, the Swiss Federal Department of Foreign Affairs announced that Switzerland and Angola signed an agreement, whereby Switzerland will return $43 million (SFr39.5 million) in frozen assets to Angola. According to the press release from the Swiss Agency for Development and Cooperation, the backdrop to the restitution are judicial proceedings of the Geneva judicial authorities regarding alleged money laundering, which at the end of 2008 led to the confiscation of the assets now to be restituted. The money will be used to fund development projects that directly benefit the population of Angola. (Source: Swiss Agency for Development and Cooperation Press Release, December 17, 2012.) \u00a0According to the terms of the agreement, Switzerland and Angola will implement the agreement jointly. The Swiss Agency for Development and Cooperation (SDC) will be responsible for its implementation on behalf of Switzerland, and the funds will benefit similar purposes as the first asset return. (Source: \u00a0Gretta Fenner Zinkernagel and Kodjo Attisso, International Centre for Asset Recovery, \u201cReturning Stolen Assets - Learning from past practice: Selected case studies\u201d [2013]).\u00a0\n\n\t\u00a0\n\n\tIn 2005, Switzerland and Angola signed an agreement to return $21 million to Angola. The funds were allocated to humanitarian projects in Angola, and monitored by the Swiss Development and Co-operation Agency (which is part of the Swiss Ministry of Foreign Affairs). Eligible projects include reconstruction, health and sanitation units, improvement of public utilities and assistance to displaced populations. (Source: Paul Gully Hart, \u0022International asset recovery of corruption-related assets: Switzerland,\u0022 in Mark Pieth ed., Recovering Stolen Assets (2008). According to the Social and Humanitarian Programme\u0027s website, $4.2 million had been allocated for vocational training in two provinces and other (unspecified) sums for a mine clearance project and agricultural development. (Source: SHP Programme, \u0022The reached results so far,\u0022 accessed at http:\/\/www.psh-angola.net\/en\/Home\/Projects.). Please see also, Swiss Federal Department of Foreign Affairs, \u0022Angolan-Swiss Socio-humanitarian Programme (SHP): Priorities,\u0022 at http:\/\/www.ddc.admin.ch\/en\/Home\/Countries\/Eastern_and_Central_Africa\/Ang...","Disposition of Criminal Case(s)":"According to the press release by the Swiss Agency for Development and Cooperation, unspecified \u0022criminal proceedings initiated by the Geneva judicial authorities were done so in connection with the restructuring of the Angolan debt to the Russian Federation.:\u00a0 (Source:\u00a0 Swiss Agency for Development and Cooperation, \u0022Switzerland and Angola sign agreement on the return of Angolan funds currently blocked in Switzerland to benefit humanitarian projects,\u0022 November 1, 2005, accessed at http:\/\/www.deza.admin.ch\/en\/Home\/News\/Close_up?itemID=21008.)","Jurisdiction of Origin: Investigative Agency":"","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"","Jurisdiction of Origin: Courts Involved":"","Jurisdiction of Asset Recovery: Investigative Agency":"Geneva Judicial Authorities","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Geneva Judicial Authorities","Jurisdiction of Asset Recovery: Courts Involved":"Geneva Judicial Authorities","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_France_Three_Acquitted_Associated_Press_Apr_29_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_Switzerland_Dictators_Assets_Mar_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_Switzerland_PSH_Angola_Projects_to_Date.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Angolagate_Swiss_Development_Agency_Press_Release_Nov_2005.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_France_Three_Acquitted_Associated_Press_Apr_29_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_Switzerland_Dictators_Assets_Mar_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_Switzerland_PSH_Angola_Projects_to_Date.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Angolagate_Swiss_Asset_Return_PR_Dec_17_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_France_Three_Acquitted_Associated_Press_Apr_29_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_Switzerland_Dictators_Assets_Mar_11_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_Switzerland_PSH_Angola_Projects_to_Date.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Angolagate_US_Senate_Foreign_Corruption_Report_Feb_2010.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Angolagate_Swiss_ICAR_Case_Study_2013.pdf","Sources ":"Switzerland website at www.psh-angola.net (last accessed November 10, 2013); Switzerland Federal Department of Foreign Affairs, \u0022Dictators\u0027 assets (Potentate funds),\u0022 October 4, 2010, accessed at http:\/\/www.eda.admin.ch\/eda\/en\/home\/topics\/finec\/intcr\/poexp.html; Paul Gully-Hart, \u0022International asset recovery of corruption-related assets: Switzerland,\u0022 and Ann Lugon-Moulin, \u0022Asset Recovery: Concrete Challenges for Development Assistance,\u0022 in Mark Pieth, ed., Recovering Stolen Assets (Peter Lang, 2008). See also Swiss Agency for Development and Cooperation, \u0022Switzerland and Angola sign agreement on the return of Angolan funds currently blocked in Switzerland to benefit humanitarian projects,\u0022 November 1, 2005, accessed at http:\/\/www.deza.admin.ch\/en\/Home\/News\/Close_up?itemID=21008. Swiss Agency for Development and Cooperation Press Release, December 17, 2012, accessed at http:\/\/www.deza.admin.ch\/en\/Home\/News\/Close_up?itemID=217972; Gretta Fenner Zinkernagel and Kodjo Attisso, International Centre for Asset Recovery, \u201cReturning Stolen Assets - Learning from past practice: Selected case studies,\u0022 at http:\/\/www.baselgovernance.org\/fileadmin\/docs\/pdfs\/Events\/131024_Selecte...\n"},{"Case ID":"ARW-33","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ao Man Long (Hong Kong SAR, China)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"","Position of Public Official(s) (yrs in office)":"Secretary of Transport and Public Works (1999-2006)","Jurisdiction of Asset Recovery":"Hong Kong SAR, China","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1999","Asset Recovery End":"2009","UNCAC Offenses Implicated":"Art.16, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"The discrepancy between asset declarations filed by Mr. Ao and his wife as public officials and their assets was used as evidence against them.  Search of Mr. Ao\u0027s government-provided residence yielded a notebook containing details of his illegal bank accounts. (Source: Statements by the Commission Against Corruption in Macao SAR posted on its website.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$56,755,400","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to a public statement by the Macau Public Prosecution Office, US$56,755,400 has been recovered from Hong Kong SAR from bank accounts held in the names of inidividuals and companies of Mr. Ao and his family members.  (Source: \u0022The Public Prosecution Office has retrieved over HK$80,000,000 for the Macao SAR in the Ao Man Long case,\u0022 December 15, 2014, at http:\/\/www.mp.gov.mo\/en\/news\/2014\/news20141215en.pdf)\nAccording to Professor Simon N. M. Young of Hong Kong University Law School, due to an absence of a Mutual Legal Assistance Treaty between Macao and Hong Kong, Macao filed a civil suit to recover Mr. Ao\u0027s illicit assets from Hong Kong, SAR.  (Source: Simon N.M. Young, \u0022Why civil actions against corruption,\u0022 Journal of Financial Crime, Vol. 16, No. 2 (2009), pp. 144-159.)  Commission Against Corruption in Macao SAR stated on its website (February 5, 2009) that the Hong Kong High Court held the first hearing on February 4, 2009 concerning the recovery of the bribe money - HKD140 million deposited in 39 bank accounts and HKD80 million cash in different currencies kept in a safety deposit box.  (Source: http:\/\/www.ccac.org.mo\/en\/)  According to Macau News, in February 2009, the Hong Kong Court of First Instance Madame Justice Carlye Chu Fun-ling granted a judgment as part of the confiscation order sought by Macau\u0027s government to recover assets Mr. Ao and his relatives had retained in Hong Kong.  (Source: Macau News, \u0022\u0022Former Macau\u0027s secretary of transport and public works Ao Man Long to face second trial next week,\u0022 February 13, 2009.)  Civil actions are private in Hong Kong, and therefore, a copy of the judgment is not publicly available.  However, Hong Kong court decisions in the case initiated by Philip P.H. Wong, Kennedy, Y.H. Wong \u0026 Co. (a firm of solicitors) and Philip (Nominees) Limited challenging search warrants carried out by the Hong Kong\u0027s Independent Commission Against Corruption gives some insight into the Hong Kong authorities\u0027 role in the investigation of Mr. Ao\u0027s corporate entities formed through the corporate service provider. (Source: Between Philip P.H. Wong, Kennedy, Y.H. Wong \u0026 Co. (a firm of solicitors), Philip (Nominees) Limited and The Commissioner of the Independent Commission Against Corruption, CACV 4\/2008 and CACV 272\/2008, on appeal from HCAL No. 70 of 2007.)","Disposition of Criminal Case(s)":"According to statements by the Commission Against Corruption in Macao SAR, Mr. Ao was tried and convicted by the Macao Court of Final Appeal in two separate trials that ended in January 2008 and April 2009, respectively.  (Sources: Commission Against Corruption in Macao SAR, \u0022What\u0027s New - Detected Cases,\u0022 June 4, 2008 and \u0022What\u0027s New - Detected Cases,\u0022 April 22, 2009.)","Jurisdiction of Origin: Investigative Agency":"Commission Against Corruption of Macao SAR","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Macao Public Prosecutions Office","Jurisdiction of Origin: Courts Involved":"Macao Court of First Instance","Jurisdiction of Asset Recovery: Investigative Agency":"Independent Commission Against Corruption","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Attorney Jacky Cheung (private civil action)","Jurisdiction of Asset Recovery: Courts Involved":"Hong Kong Court of First Instance","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Assets_Macau_Daily_Times_Nov_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macao_Anti-Corruption_Commission_Feb_5_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Anti-Corruption_Commission_Detected_Case_Apr_4_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_News_Second_Trial_Feb_13_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Case_36_2007_Judgment_Jan_30_2008_Chinese.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Case_36_2007_Judgment_Jan_30_2008_Portuguese.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Case_53_2008_Judgment_Apr_22_2009_Chinese.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Case_53_2008_Judgment_Apr_22_2009_Portuguese.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Second_Trial_Judgment_Apr_22_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Wong_ICAC_Commissioner_CACV_4_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ao_HK_Explain_Assets_Macau_Daily_Nov_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Assets_Macau_Daily_Times_Nov_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macao_Anti-Corruption_Commission_Feb_5_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Anti-Corruption_Commission_Detected_Case_Apr_4_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_News_Second_Trial_Feb_13_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Case_36_2007_Judgment_Jan_30_2008_Chinese.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Case_36_2007_Judgment_Jan_30_2008_Portuguese.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Case_53_2008_Judgment_Apr_22_2009_Chinese.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Case_53_2008_Judgment_Apr_22_2009_Portuguese.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Second_Trial_Judgment_Apr_22_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Wong_ICAC_Commissioner_CACV_4_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ao_Macao_PPO_PR_Dec_15_2014.pdf","Sources ":"Statements by Commission Against Corruption in Macao SAR (April 22, 2009 and February 5, 2009) and others posted on its official website at http:\/\/www.ccac.org.mo\/en\/; \n\u0022The Public Prosecution Office has retrieved over HK$80,000,000 for the Macao SAR in the Ao Man Long case,\u0022 December 15, 2014, at http:\/\/www.mp.gov.mo\/en\/news\/2014\/news20141215en.pdf;\nMacau News, \u0022Former Macau\u0027s secretary of transport and public works Ao Man Long to face second trial next week,\u0022 February 13, 2009, accessed at http:\/\/www.macaunews.com.mo\/index.php?option=com_content\u0026task=view\u0026id=30... Simon N.M.Young, \u0022Why civil actions against corruption,\u0022 Journal of Financial Crime, Vol. 16, No. 2 (2009) at 144-159 (purchased online); Philip P.H. Wong, Kennedy, Y.H. Wong \u0026 Co. (a firm of solicitors), Philip (Nominees) Limited and The Commissioner of the Independent Commission Against Corruption, CACV 4\/2008 and CACV 272\/2008, on appeal from HCAL No. 70 of 2007. Macao court judgments in Mr. Ao\u0027s underlying cases:  Acordam No Tribunal de Ultima Instancia da Regiao Administrativa Especial de Macau, Processo no. 36\/2007 and Acordao do Tribunal de Ultima Instancia da Regiao Administrative Especial de Macau, Processo cmum colectivo No. 53\/2008 (in Portuguese and Chinese).\n"},{"Case ID":"ARW-35","Case Title (Name of Public Official or Entity Allegedly Involved)":"Ao Man Long (United Kingdom)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"","Position of Public Official(s) (yrs in office)":"Secretary of Transport and Public Works (1999-2006)","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"2015","UNCAC Offenses Implicated":"Art.16, Art.18, Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Mutual Legal Assistance Treaty between Hong Kong SAR, China and the United Kingdom; United Nations Convention against Corruption ","Contributing Factors in Asset Recovery":"According to Daniel Li, Deputy Commissioner of the Hong Kong Independent Commission Against Corruption (ICAC), \u0022This is one of the successful cases of cooperation between ICAC and other jurisdictions when asset recovery was involved.  All assets have been or are currently destined to be returned to Macao.  We could have taken the attitude that it is not our concern and simply carried out the minimal requirements of informing the Macao authorities and then sitting back and giving a minimal response, especially as this specific law germane to asset confiscation was not as such available between the two jurisdictions.  However we took up this challenge seriously; officers from Hong Kong and Macao worked tirelessly and enthusiastically, and, as a result, AO and his corrupt associates were deprived of vast profits from his criminal enterprise.\u0022 (Source: Daniel M C Li,  Deputy Commissioner and Head of Operations, Independent Commission Against Corruption, Hong Kong Special Administrative Region, \u0022Asset Recovery: Is Law Enforcement doing enough?, \u0022  The 4th IAACA Seminar, Dalian, People\u2019s Republic of China, 25 \u2013 28 June 2012.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"","Case Summary":"In November 2015, the Office of the Secretary for Administration and Justice of Macao SAR, China issued a statement announcing the return from UK of USD44,245,300 in corruption assets in Mr. Ao\u0027s case. According to the statement, Ms. Chan Hoi Fan, Secretary for Administration and Justice of the Macao Special Administrative Region, \u0022indicated that the UNCAC, as an international anti-corruption instrument, has established a very important legal system for fighting corruption at international level. The mechanisms for recovery of property and return of assets, in particular, provided the legal basis on which we are able to establish close cooperation with and to recover the illicit assets from the British Government. In 2010, with the strong support and assistance from the Central Government, the Macao SAR Government conveyed the request to the British Government via diplomatic channels for returning the corruption proceeds in Ao\u2019s case.\u0022 (Source:Office of the Secretary for Administration and Justice of Macao SAR, China, \u0022Most of the Illicit Assets Abroad in the Case of Ao Man Long Successfully Recovered,\u0022 November 3, 2015.)\nIn April 2007, the Commission Against Corruption in Macao SAR, China had reported on its location and seizure of more than 790 million patacas (USD$95 million) in Mr. Ao\u0027s accumulated assets, and stated that \u0022Until December 2006...the cash and bonds in Britain and other countries were equivalent to 275 million patacas.\u0022 (Source: Commission Against Corruption in Macao SAR, \u0022What\u0027s New - Detected Cases,\u0022 April 7, 2007.)    In June 2012, the Deputy Head of Hong Kong SAR, China\u0027s Independent Commission Against Corruption stated in a presentation that with regard to Mr. Ao\u0027s case, \u0022During the course of the asset tracing exercise we discovered that substantial funds had been sent to the United Kingdom and used to purchase a property.  This disclosed an offence of money laundering in Hong Kong and therefore we invoked Mutual Legal Assistance between Hong Kong and the UK as a means of freezing any potential sale of this property.  Eventually the property was sold under a court order and the funds are now banked in the UK awaiting repatriation to Macao.\u0022 (Source: Daniel M C Li,  Deputy Commissioner and Head of Operations, Independent Commission Against Corruption, Hong Kong Special Administrative Region, \u0022Asset Recovery: Is Law Enforcement doing enough?, \u0022  The 4th IAACA Seminar, Dalian, People\u2019s Republic of China, 25 \u2013 28 June 2012.)","Disposition of Criminal Case(s)":"According to statements by the Commission Against Corruption in Macao SAR, Mr. Ao was tried and convicted by the Macao Court of Final Appeal in two separate trials that ended in January 2008 and April 2009, respectively.  (Sources: Commission Against Corruption in Macao SAR, \u0022What\u0027s New - Detected Cases,\u0022 June 4, 2008 and \u0022What\u0027s New - Detected Cases,\u0022 April 22, 2009.)","Jurisdiction of Origin: Investigative Agency":"Commission Against Corruption of Macao SAR, China","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Macao Public Prosecutions Office","Jurisdiction of Origin: Courts Involved":"Court of First Instance","Jurisdiction of Asset Recovery: Investigative Agency":"Unspecified","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unspecified","Jurisdiction of Asset Recovery: Courts Involved":"Unspecified","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Assets_Macau_Daily_Times_Nov_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macao_Anti-Corruption_Commission_Feb_5_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Anti-Corruption_Commission_Detected_Case_Apr_4_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_News_Second_Trial_Feb_13_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ao_HK_Explain_Assets_Macau_Daily_Nov_29_2007_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Assets_Macau_Daily_Times_Nov_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macao_Anti-Corruption_Commission_Feb_5_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Anti-Corruption_Commission_Detected_Case_Apr_4_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_News_Second_Trial_Feb_13_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ao-UK_Speech_Daniel%20Li_IAACA_June_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Assets_Macau_Daily_Times_Nov_29_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macao_Anti-Corruption_Commission_Feb_5_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_Anti-Corruption_Commission_Detected_Case_Apr_4_2007.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Ao_Macau_News_Second_Trial_Feb_13_2009.pdf\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Ao%20Man%20Long_UK_Asset%20Return_Govt_Statement_Nov3%202015.pdf","Sources ":"Government Information Bureau of Macao SAR,  \u0022Most of the Illicit Assets Abroad in the Case of Ao Man Long Successfully Recovered,\u0022 November 3, 2015, at http:\/\/www.gcs.gov.mo\/showNews.php?PageLang=E\u0026DataUcn=93976;\nStatements by Commission Against Corruption in Macao SAR, particularly statement of April 4, 2007 which stated that of the over 790 million patacas in assets located, \u0022Until December 2006...the cash and bonds in Britain and other coutnries were equivalent to 275 million patacas,\u0022  accessed at its official website at http:\/\/www.ccac.org.mo\/en\/; Daniel M C Li,  Deputy Commissioner and Head of Operations, Independent Commission Against Corruption, Hong Kong Special Administrative Region, \u0022Asset Recovery: Is Law Enforcement doing enough?, \u0022  The 4th IAACA Seminar, Dalian, People\u2019s Republic of China, 25 \u2013 28 June 2012, accessed at http:\/\/www.iaaca.org\/Documents\/Presentation\/TheFourthIAACASeminar\/201207...  International Centre for Asset Recovery, Ao Man Long Case Study, UK Recovery, at http:\/\/www.assetrecovery.org\/kc\/node\/53b75da0-0d64-11de-a72f-27bb2e50913... \u0022Former Macau\u0027s secretary of transport and public works Ao Man Long to face second trial next week,\u0022 Macau News, February 13, 2009, accessed at http:\/\/www.macaunews.com.mo\/index.php?option=com_content\u0026task=view\u0026id=30... Poyi (Natalie) Cheung, \u0022CCAC: Ao couldn\u2019t explain his 850 million pataca assets,\u0022 Macau Daily Times, November 29, 2007, accessed at http:\/\/poyileung.wordpress.com\/2007\/11\/29\/ccac-ao-couldnt-explain-his-85...).\n"},{"Case ID":"ARW-17","Case Title (Name of Public Official or Entity Allegedly Involved)":"Arafat \u0022koko\u0022 Rahman (Singapore)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Bangladesh","Position of Public Official(s) (yrs in office)":"Son of Prime Minister Khaleda Zia (1991-1996, 2001-2006)","Jurisdiction of Asset Recovery":"Singapore","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2008","Asset Recovery End":"2013","UNCAC Offenses Implicated":"Art.16, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"United Nations Convention against Corruption","Contributing Factors in Asset Recovery":"Criminal conviction in Bangladesh, US foreign bribery case settlement with Siemens and subsequent non-conviction based asset forfeiture action against proceeds located in Singapore; also, as noted by the law firm Edwards Wildman, \u0022We understand that Mr Rahman\u2019s conviction appears to have been partially based on the offence of illicit enrichment, the usual method of enforcement through the mutual legal assistance procedure was not available in Singapore. Illicit enrichment is an offence in some countries where a public official gains a significant increase in his assets which he\/she cannot reasonably explain in relation to his\/her lawful income. This is a crime that is generally not considered punishable in many countries like the UK and Singapore, making enforcement of a confiscation order based on such an offence complicated. Further, Singapore does not have a (non-conviction based) civil forfeiture procedure. Despite these hurdles, Singapore was nevertheless able to return the funds in the Fairhill account by using a legal tool called the \u2018disposal inquiry\u2019 mechanism. It would be prudent to add that one suspects that this particular mechanism was only viable because of the specific facts of this case.\u0022 (Source:  Antonio Suarez-Martines, \u0022Civil forfeiture without borders: Bangladesh shows that where there\u2019s political will there\u2019s a way,\u0022 Edwards Wildman, September 9, 2013.) ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"No formal agreement but according to the Daily Star, the Chairman of the Anti-Corruption Commission stated that the returned assets would be used for anti-corruption initiatives. (Source:  Daily Star, \u0022S\u0027Pore returns Tk. 7.4 cr more,\u0022 August 28, 2013.)","Case Summary":"\n\tAccording to the Anti-Corruption Commission of Bangladesh, the U.S. and Bangladesh were engaged in joint efforts to recover Mr. Rahman\u0027s alleged bribery proceeds held in Singaporean bank accounts. \u00a0(Source: Anti-Corruption Commission of Bangladesh, \u0022US, Bangladesh joint effort to retrieve Coco \u0027bribes\u0027,\u0022 News Updates - Jan 2009.) \u00a0According to the Daily Star, between November 2012 through August 2013, Singapore returned $2,661,070 to Bangladesh in confiscated assets and accrued interest. \u00a0(Source: \u00a0Daily Star, \u0022S\u0027Pore returns Tk. 7.4 cr more,\u0022 August 28, 2013.)\n\n\t\u00a0\n\n\tA December 19, 2008 press report, the Anti-corruption Commission of Bangladesh had initiated an inquiry into alleged corruption proceeds held by Mr. Rahman in Singapore, and that Singapore had temporarily frozen S $2,061,093 and U.S. $261,477 in transactions by Mr. Rahman. \u00a0(Source: \u0022Singapore freezes Tk 11.6 cr of Koko: ACC begins probe,\u0022 Priyo.com, December 19, 2008.) \u00a0 The civil asset forfeiture complaint filed by the United States Government, in U.S. v. All Assets Held in the name of ZASZ Trading \u0026 Consulting Pte Ltd., had alleged that ZASZ is a Singapore company created at the direction of Mr. Rahman by Lim Siew Cheng of Henry Noon \u0026 Co Management Consultants firm, which also allegedly established Mr. Rahman\u0027s account at United Overseas Bank at the instruction of Mr. Rahman in 2004. \u00a0(Source: \u00a0U.S. v. All Assets Held in the Name of Zasz Trading and Consulting PTE Ltd., et. al, Case No. 1:09-cv-00021-JDB (D.D.C.), Amended Complaint for Forfeiture In Rem, Filed on August 21, 2009. \u00a0See also, case entry on asset recovery efforts by the United States.) \u00a0Singapore\u0027s Today Online reported that Mr. Lim Siew Cheng was fined on January 3, 2011 for his failure to inform authorities that the money he had been dealing with could have been obtained from criminal activity. (Source: Alkhatib, Shaffiq. \u00a0\u0022MD fined over suspect cash in bank accounts.\u0022 Today Online, Jan. 4, 2011, accessed at http:\/\/www.todayonline.com\/Print\/Singapore\/EDC110104-0000173\/MD-fined-ov....) \u00a0","Disposition of Criminal Case(s)":"According to the Press Trust of India, on June 23, 2011, Mr. Rahman was sentenced following his conviction in absentia on corruption charges. (Source: Press Trust of India, \u0022Former Bangladeshi premier Khaleda Zia\u0027s younger son jailed for bribery,\u0022 June 23, 2011.) According to the Daily Star, on April 27, 2011, Mr. Rahman\u0027s lawyers filed a petition to have his criminal case dismissed, pursuant to a February 9 ruling by the Bangladesh Supreme Court that acts committed before the passage of the Money Laundering Prevention Act of 2009 cannot be tried under it.  The article stated that the Anti-Corruption Commission of Bangladesh would take action after scrutinizing the Supreme Court\u0027s decision and the relevant laws.  (Source:  The Daily Star, \u0022Koko\u0027s lawyers for withdrawal of case,\u0022 April 28, 2011, accessed at http:\/\/www.thedailystar.net\/newDesign\/news-details.php?nid=183469.)  The trial had begun in Bangladesh in January 2011; he was being tried in absentia. (Source:  BDCAN, \u0022Trial of Arafat Rahman begins,\u0022 January 5, 2011).","Jurisdiction of Origin: Investigative Agency":"Anti-Corruption Commission of Bangladesh","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Anti-Corruption Commission of Bangladesh","Jurisdiction of Origin: Courts Involved":"Special Court","Jurisdiction of Asset Recovery: Investigative Agency":"Corruption Practices Investigation Bureau","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Amended_Complaint_Aug_21_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Default_Order_Apr_7_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Govt_Default_Memo_Exhibit_Feb_10_2010.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Dhaka_Asks_Gaea_News_Feb_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Singapore_Freeze_ICAR_Priyo_Dec_19_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Singapore_Intermediary_Today_Jan_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Trial_Begins_BDCAN_Jan_5_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Bangladesh_Sentenced_NDTV_Jun_23_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Rahman_Returns_3_Tranches_Daily_Star_Aug_28_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Amended_Complaint_Aug_21_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Default_Order_Apr_7_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Govt_Default_Memo_Exhibit_Feb_10_2010.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Dhaka_Asks_Gaea_News_Feb_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Singapore_Freeze_ICAR_Priyo_Dec_19_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Singapore_Intermediary_Today_Jan_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Trial_Begins_BDCAN_Jan_5_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Bangladesh_Sentenced_NDTV_Jun_23_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Rahman_US_Asset_Return_Edwards_Wildman_Blog_Sep_9_2013.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Amended_Complaint_Aug_21_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Default_Order_Apr_7_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Govt_Default_Memo_Exhibit_Feb_10_2010.zip, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Dhaka_Asks_Gaea_News_Feb_2_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Singapore_Freeze_ICAR_Priyo_Dec_19_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Singapore_Intermediary_Today_Jan_4_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Trial_Begins_BDCAN_Jan_5_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Bangladesh_Sentenced_NDTV_Jun_23_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Rahman_Bangladesh_Sentenced_NDTV_Jun_23_2011.pdf","Sources ":"\n\tAntonio Suarez-Martines, \u0022Civil forfeiture without borders: Bangladesh shows that where there\u2019s political will there\u2019s a way,\u0022 Edwards Wildman, September 9, 2013, at http:\/\/www.anticorruptionlaw.com\/blog.aspx?entry=5033; Daily Star, \u0022S\u0027Pore returns Tk. 7.4 cr more,\u0022 August 28, 2013, at http:\/\/www.thedailystar.net\/beta2\/news\/spore-returns-tk-7-4cr-more\/; \u0022Singapore freezes Tk 11.6 cr of Koko: ACC begins probe,\u0022 Priyo.com, December 19, 2008, as posted on www.assetrecovery.org\/kc\/node\/144dedf6-2b46-11de-900c-81c63910293a.2; Gaea News, \u0022Dhaka asks U.S. for money siphoned off by Zia\u0027s son,\u0022 February 2, 2009, as posted on www.assetrecovery.org\/kc\/node\/ba567240-2030-11de-a9b1-0d536ac86161.6; BDCAN, \u0022Trial of Arafat Rahman begins,\u0022 January 5, 2011, accessed at http:\/\/www.bdcan.ca\/banglanews\/news.details.php?news=1430; \n\n\t\u00a0\n\n\tU.S. v. All Assets Held in the Name of Zasz Trading and Consulting PTE Ltd., et. al, Case No. 1:09-cv-00021-JDB (D.D.C.), Amended Complaint for Forfeiture In Rem, filed August 21, 2009 and Memorandum Opinion and Order of Default Judgment and Judgment of Forfeiture, filed April 7, 2010 and Government Motion for Default Judgment and Exhibit 2, filed on February 19, 2010. \u00a0See also, Alkhatib, Shaffiq. \u00a0\u0022MD fined over suspect cash in bank accounts.\u0022 Today Online, Jan. 4, 2011, accessed at http:\/\/www.todayonline.com\/Print\/Singapore\/EDC110104-0000173\/MD-fined-ov... Press Trust of India, \u0022Former Bangladeshi premier Khaleda Zia\u0027s younger son jailed for bribery,\u0022 June 23, 2011, accessed at http:\/\/www.ndtv.com\/article\/world\/former-bangladeshi-premier-khaleda-zia...\n\n\t\u00a0\n"},{"Case ID":"ARW-18","Case Title (Name of Public Official or Entity Allegedly Involved)":"Arafat \u0022Koko\u0022 Rahman (United States)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Bangladesh","Position of Public Official(s) (yrs in office)":"Son of Prime Minister Khaleda Zia (in office, 1991-1996, 2001-2006)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Efforts, Location of Recovery Effort","Asset Recovery Start":"2008","Asset Recovery End":"2013","UNCAC Offenses Implicated":"Art.16, Art.18, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"Criminal conviction in Bangladesh, US foreign bribery case settlement with Siemens and subsequent non-conviction based asset forfeiture action against proceeds located in Singapore; also, as noted by the law firm Edwards Wildman, \u0022We understand that Mr Rahman\u2019s conviction appears to have been partially based on the offence of illicit enrichment, the usual method of enforcement through the mutual legal assistance procedure was not available in Singapore. Illicit enrichment is an offence in some countries where a public official gains a significant increase in his assets which he\/she cannot reasonably explain in relation to his\/her lawful income. This is a crime that is generally not considered punishable in many countries like the UK and Singapore, making enforcement of a confiscation order based on such an offence complicated. Further, Singapore does not have a (non-conviction based) civil forfeiture procedure. Despite these hurdles, Singapore was nevertheless able to return the funds in the Fairhill account by using a legal tool called the \u2018disposal inquiry\u2019 mechanism. It would be prudent to add that one suspects that this particular mechanism was only viable because of the specific facts of this case.\u0022 (Source:  Antonio Suarez-Martines, \u0022Civil forfeiture without borders: Bangladesh shows that where there\u2019s political will there\u2019s a way,\u0022 Edwards Wildman, September 9, 2013.) ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"No formal agreement but according to the Daily Star, the Chairman of the Anti-Corruption Commission stated that the returned assets would be used for anti-corruption initiatives. (Source:  Daily Star, \u0022S\u0027Pore returns Tk. 7.4 cr more,\u0022 August 28, 2013.)","Case Summary":"\n\tAccording to the Anti-Corruption Commission of Bangladesh, the U.S. and Bangladesh were engaged in joint efforts to recover Mr. Rahman\u0027s bribery proceeds held in Singaporean bank accounts. \u00a0(Source: Anti-Corruption Commission of Bangladesh, \u0022US, Bangladesh joint effort to retrieve Coco \u0027bribes\u0027,\u0022 News Updates - Jan 2009.) \u00a0According to the Daily Star, between November 2012 through August 2013, Singapore returned $2,661,070 to Bangladesh in confiscated assets and accrued interest. \u00a0(Source: \u00a0Daily Star, \u0022S\u0027Pore returns Tk. 7.4 cr more,\u0022 August 28, 2013.)\n\n\t\u00a0\n\n\tIn January 2009, the US Department of Justice had filed a civil asset forfeiture complaint against assets held in three Singapore bank accounts that the Department of Justice had alleged were bribery proceeds in violation of the Foreign Corrupt Practices Act. (Source: U.S. v. All Assets Held in the Name of Zasz Trading and Consulting PTE Ltd., et. al, Case No. 1:09-cv-00021-JDB (D.D.C.), Amended Complaint for Forfeiture In Rem, filed August 21, 2009.) \u00a0 On April 7, 2010, the U.S. District Court for the District of Columbia granted a Default Judgment and Judgment of Forfeiture against the following: (1) all assets held in the name of ZASZ Trading and Consulting Pte Ltd., account number 352-015-540-4 (formerly 1093101397) held at the United Overseas Bank, Singapore and any properties traceable thereto; (2) up to and including $762,000 plus interest of the assets held in the name of Zulfikar Ali, account number 0174053746 at Standard Chartered Bank, Singapore and any property traceable thereto; and (3) up to and including $226,249 plus interest of the assets held in the name of Fazel Selim, account number 0174001770 at Standard Chartered Bank, Singapore and any property traceable thereto. (Source: U.S. v. All Assets Held in the Name of Zasz Trading and Consulting PTE Ltd., et. al, Case No. 1:09-cv-00021-JDB (D.D.C.), Memorandum Opinion and Order of Default Judgment and Judgment of Forfeiture, filed April 7, 2010.) \u00a0","Disposition of Criminal Case(s)":"According to the Press Trust of India, on June 23, 2011, Mr. Rahman was sentenced following his conviction in absentia on corruption charges. (Source: Press Trust of India, \u0022Former Bangladeshi premier Khaleda Zia\u0027s younger son jailed for bribery,\u0022 June 23, 2011.)  According to the Daily Star, on April 27, 2011, Mr. Rahman\u0027s lawyers filed a petition to have his criminal case dismissed, pursuant to a February 9 ruling by the Bangladesh Supreme Court that acts committed before the passage of the Money Laundering Prevention Act of 2009 cannot be tried under it.  The  article stated that the Anti-Corruption Commission of Bangladesh would take action after scrutinizing the Supreme Court\u0027s decision and the relevant laws.  (Source:  The Daily Star, \u0022Koko\u0027s lawyers for withdrawal of case,\u0022 April 28, 2011, accessed at http:\/\/www.thedailystar.net\/newDesign\/news-details.php?nid=183469.)  The trial had begun in Bangladesh in January 2011; he was being tried in absentia. (Source:  BDCAN, \u0022Trial of Arafat Rahman begins,\u0022 January 5, 2011).","Jurisdiction of Origin: Investigative Agency":"Anti-Corruption Commission of Bangladesh","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Anti-Corruption Commission of Bangladesh","Jurisdiction of Origin: Courts Involved":"Special Court","Jurisdiction of Asset Recovery: Investigative Agency":"Federal Bureau of Investigation, Washington Field Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Department of Justice, Criminal Division, Asset Forfeiture and Money Laundering Section; Assistance by Criminal Division\u0027s Office of International Affairs","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the District of Columbia","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Attorneys_File_Withdrawal_Daily_Star_Apr_28_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Amended_Complaint_Aug_21_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Default_Order_Apr_7_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_US_Justice_Dept_FCPA_Appendix_C.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Trial_Begins_BDCAN_Jan_5_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Bangladesh_Sentenced_NDTV_Jun_23_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Rahman_Returns_3_Tranches_Daily_Star_Aug_28_2013_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Attorneys_File_Withdrawal_Daily_Star_Apr_28_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Amended_Complaint_Aug_21_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Default_Order_Apr_7_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_US_Justice_Dept_FCPA_Appendix_C.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Trial_Begins_BDCAN_Jan_5_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Bangladesh_Sentenced_NDTV_Jun_23_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Rahman_US_Asset_Return_Edwards_Wildman_Blog_Sep_9_2013_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Attorneys_File_Withdrawal_Daily_Star_Apr_28_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Amended_Complaint_Aug_21_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_DDC_Default_Order_Apr_7_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_US_Justice_Dept_FCPA_Appendix_C.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Trial_Begins_BDCAN_Jan_5_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Rahman_Bangladesh_Sentenced_NDTV_Jun_23_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Rahman_Bangladesh_Sentenced_NDTV_Jun_23_2011_0.pdf","Sources ":"\n\tU.S. v. All Assets Held in the Name of Zasz Trading and Consulting PTE Ltd., et. al, Case No. 1:09-cv-00021-JDB (D.D.C.), Amended Complaint for Forfeiture In Rem, filed August 21, 2009 \u00a0Memorandum Opinion and Order of Default Judgment and Judgment of Forfeiture, filed April 7, 2010; \u00a0U.S. Department of Justice\u0027s Report to the United States Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf. \u00a0\n\n\t\u00a0\n\n\tAntonio Suarez-Martines, \u0022Civil forfeiture without borders: Bangladesh shows that where there\u2019s political will there\u2019s a way,\u0022 Edwards Wildman, September 9, 2013, at http:\/\/www.anticorruptionlaw.com\/blog.aspx?entry=503; Daily Star, \u0022S\u0027Pore returns Tk. 7.4 cr more,\u0022 August 28, 2013, at http:\/\/www.thedailystar.net\/beta2\/news\/spore-returns-tk-7-4cr-more\n\n\tSee also, The Daily Star, \u0022Koko\u0027s lawyers for withdrawal of case,\u0022 April 28, 2011, accessed at http:\/\/www.thedailystar.net\/newDesign\/news-details.php?nid=183469; \u00a0BDCAN, \u0022Trial of Arafat Rahman begins,\u0022 January 5, 2011, accessed at http:\/\/www.bdcan.ca\/banglanews\/news.details.php?news=1430; Press Trust of India, \u0022Former Bangladeshi premier Khaleda Zia\u0027s younger son jailed for bribery,\u0022 June 23, 2011, accessed at http:\/\/www.ndtv.com\/article\/world\/former-bangladeshi-premier-khaleda-zia...\n\n\t\u00a0\n"},{"Case ID":"ARW-19","Case Title (Name of Public Official or Entity Allegedly Involved)":"Arnoldo Aleman","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Nicaragua","Position of Public Official(s) (yrs in office)":"President (1997-2002)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2002","Asset Recovery End":"2008","UNCAC Offenses Implicated":"Art.17, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation ","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"U.S.:  The establishment by the Immigration and Customs Enforcement of the first Politically Exposed Persons (PEPS) Task Force located in Miami, Florida. The PEPS Task Force was established in conjunction with ICE\u0027s international division, the U.S. Attorney\u0027s Office and the U.S. Department of State. The Task Force\u0027s goal is to identify, locate, and seize assets of corrupt politically exposed persons involved in the theft of embezzled government funds. An example that highlights the success of this Task Force is the conviction in Nicaragua of the former Nicaraguan President Arnoldo Aleman. ICE investigators worked with their Nicaraguan counterparts to discover and seize assets located in the United States belonging to Mr. Aleman valued in excess of $5 million dollars. Cooperation by U.S. and Nicaragua. (Source: Statement of Marcy M. Forman, Deputy Assistant Director, Financial Investigations, Immigration and Customs Enforcement, Department of Homeland Security, before House Government Reform Committee Subcommittee on Criminal Justice, Drug Policy and Human Resources, \u0022Terrorist Financing and Money Laundering Investigations: Who Investigates and How Effective Are They?,\u0022 May 11, 2004.","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Unknown","Agreement for Returned Assets - Description":"Unknown","Case Summary":"According to the U.S. Government website, America.gov, \u0022In 2004, U.S. authorities forfeited and transferred approximately $2.7 million of the former president\u0027s assets to the government of Nicaragua.\u0022  A 2005 U.S. Department of State report added that the funds were to be used for educational programs, with $100,000 going to support anti-corruption efforts of Nicaraguan Prosecutor General\u0027s Office. (Source: U.S. Department of State, Bureau of International Narcotics and Law Enforcement Affairs, International Narcotics Control Strategy Report, March 2005, accessed at http:\/\/www.state.gov\/p\/inl\/rls\/nrcrpt\/2005\/vol2\/html\/42382.htm).  Mr. Aleman had used fradulent shell companies and investment accounts to conceal his illicit proceeds. Assets identified and seized by the Immigration and Customs Enforcement, Miami Foreign Corrupt Investigations Group included seven certificates of deposit valued at $700,000, proceeds of the sale of a helicopter worth $671,000, a cabana at the Key Biscayne Ocean Club valued at $300,000, an investment account in Coral Gables, Fla., valued at $204,099, and a $150,000 deposit for the purchase of a Key Biscayne, Fla., condominium.  (Please note that according to the May 11, 2004 testimony of Ms. Marcy M. Forman, Deputy Assistant Director, Financial Investigations Division of the U.S. Immigration and Customs Enforcement: \u0022ICE investigators worked with their Nicaraguan counterparts to discover and seize assets located in the United States belonging to Aleman valued in excess of $5 million dollars.\u0022 Testimony before the House Committee on Government Reform, Subcommittee on Criminal Justice, Drug Policy and Human Resources.)","Disposition of Criminal Case(s)":"According to the University of Pittsburgh School of Law, Jurist Legal Research and News, in January 2009, the Nicaraguan Supreme Court overturned Mr. Aleman\u0027s 2003 conviction on money laundering and embezzlement charges. (Source: Andrew Gilmore, \u0022Nicaragua high court overturns corruption conviction of ex-president,\u0022 Jurist Legal Research and News, January 19, 2009, accessed at http:\/\/jurist.org\/paperchase\/2009\/01\/nicaragua-high-court-overturns.php.)","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General\u0027s Office, Nicaragua","Jurisdiction of Origin: Courts Involved":"Supreme Court","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Immigration and Customs Enforcement, Politically Exposed Persons Task Force","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney\u0027s Office for the Southern District of Florida","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of Florida","Documents":"","Sources ":"U.S. v. Proceeds of Certificates of Deposit Number 1271734730, et al, Case No. 03-20526-CIV-MORENO\/GARBER (S.D.Fla.), Amended Complaint for Forfeiture filed March 17, 2003; U.S.C.A. Mandate filed on October 7, 2008; Final Judgment filed October 9, 2008; \nCase description at http:\/\/www.america.gov\/anti-corruption.html; \nSee also, official website of the Prosecutor General of Nicaragua at www.pgr.gob.ni - follow links to Museo Digital de la Corrupcion and \u0022Hallazgos documentales de Actos Irregulares o Corruptos\u0022 for official documents and supporting documents on underlying cases. (Last accessed December 1, 2010).  \nU.S. Department of State, Bureau of International Narcotics and Law Enforcement Affairs, International Narcotics Control Strategy Report, March 2005, accessed at http:\/\/www.state.gov\/p\/inl\/rls\/nrcrpt\/2005\/vol2\/html\/42382.htm;\nAndrew Gilmore, \u0022Nicaragua high court overturns corruption conviction of ex-president,\u0022 Jurist Legal Research and News, January 19, 2009, accessed at http:\/\/jurist.org\/paperchase\/2009\/01\/nicaragua-high-court-overturns.php.\n"},{"Case ID":"ARW-20","Case Title (Name of Public Official or Entity Allegedly Involved)":"Augusto Pinochet","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Chile","Position of Public Official(s) (yrs in office)":"President (1973-1990); Commander-in-Chief of Chilean Army (1990-1998); \u0022Senator for life\u0022  (1998 to 2006)","Jurisdiction of Asset Recovery":"Spain","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort","Asset Recovery Start":"1979","Asset Recovery End":"2005","UNCAC Offenses Implicated":"Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"In 1998, Judge Garzon of Spain ordered a worldwide freeze on Mr. Pinochet\u0027s assets and ordered Riggs Bank to pay $8 million to a foundation established to assist victims of the Pinochet regime, to settle the Spanish case for violating  the 1998 court order (Source: United States Senate Permanent Subcommittee on Investigations, Money Laundering and Foreign Corruption: Enforcement and Effectiveness of the Patriot Act, Supplemental Staff Report on the U.S. Accounts Used by Augusto Pinochet (March 16, 2005), at footnote 5).  According to the Washington Post (February 26, 2005), Riggs Bank paid $8 million and its owners Joe and Robert Albritton paid  $1 million, for a total of $9 million.","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$8,000,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to an attorney familiar with the case, the civil society organization Consejo de Defensa del Estado brought two claims, in Spain and in the U.S., represented by an American attorney based in Miami.  The civil action in Spain was based on the claim that had Riggs Bank complied with Anti-Money Laundering regulations, Chile could have recovered its stolen assets much sooner.  (Source: Researcher telephone interview, November 2010).  In 1998, Judge Garzon of Spain ordered a worldwide freeze on Mr. Pinochet\u0027s assets and ordered Riggs Bank to pay $8 million to a foundation established to assist victims of the Pinochet regime, to settle the Spanish case for violating  the 1998 court order (Source: United States Senate Permanent Subcommittee on Investigations, Money Laundering and Foreign Corruption: Enforcement and Effectiveness of the Patriot Act, Supplemental Staff Report on the U.S. Accounts Used by Augusto Pinochet (March 16, 2005), at footnote 5).  According to the Washington Post (February 26, 2005), Riggs Bank paid $8 million and its owners Joe and Robert Albritton paid  $1 million, for a total of $9 million.  After deducting $1 million (mostly for legal expenses), $8 million was reported to have been given to the Salvador Allende Foundation in Santiago, Chile. (Source: Terrence O\u0027Hara, \u0022Allbrittons, Riggs to Pay Victims of Pinochet,\u0022 Washington Post, February 26, 2005).","Disposition of Criminal Case(s)":"A number of criminal proceedings had been instituted against Mr. Pinochet by the Chilean courts and by Spain\u0027s Fifth Central Magistrate of the National Court.  (Source: Regina v. Bartle and the Commissioner of Police for the Metropolis and Others Ex Parte Pinochet (on appeal from a Divisional Court of the Queen\u0027s Bench Division), Opinions of the Lords of Appeal, November 25, 1998.)","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Abogado Procuradora Fiscal - Santiago","Jurisdiction of Origin: Courts Involved":"Court of Appeals, Santiago","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Asset Recovery: Courts Involved":"Fifth Central Magistrate of the National Court","Documents":"","Sources ":"United States Senate Permanent Subcommittee on Investigations, Money Laundering and Foreign Corruption: Enforcement and Effectiveness of the Patriot Act, Supplemental Staff Report on the U.S. Accounts Used by Augusto Pinochet (March 16, 2005), accessed at http:\/\/levin.senate.gov\/newsroom\/supporting\/2005\/pinochetreport.pdf; \nTerrence O\u0027Hara, \u0022Allbrittons, Riggs to Pay Victims of Pinochet,\u0022 Washington Post, February 26, 2005.  \nSalvador Allende Foundation website: http:\/\/www.fundacionsalvadorallende.cl\/; \nRegina v. Bartle and the Commissioner of Police for the Metropolis and Others Ex Parte Pinochet (on appeal from a Divisional Court of the Queen\u0027s Bench Division), Opinions of the Lords of Appeal, November 25, 1998, accessed at http:\/\/www.publications.parliament.uk\/pa\/ld199899\/ldjudgmt\/jd981125\/pino....\n"},{"Case ID":"ARW-21","Case Title (Name of Public Official or Entity Allegedly Involved)":"Augusto Pinochet","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Chile","Position of Public Official(s) (yrs in office)":"President (1973-1990); Commander-in-Chief of Chilean Army (1990-1998); \u0022Senator for life\u0022  (1998 to 2006)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2000","Asset Recovery End":"2004","UNCAC Offenses Implicated":"Art.19, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"According to the March 2005 report by the U.S. Senate Permanent Subcommittee on Investigations on U.S. accounts used by Mr. Pinochet and his family and associates to conceal their illicit proceeds, at the order of Chilean Judge Sergio Munoz, Pinochet lawyer Oscar Aitken Lavanchy transferred $6.8 million from U.S. accounts (about $5.5 million from G.L.P. accounts; about $1.3 million from Trasker accounts) to a bank in Chile; on August 13, 2004, the bank deposited the funds into an account under control of the Santiago Court of Appeals.  (Source:  U.S. Senate Permanent Subcommittee on Investigations, Supplemental Staff Report on U.S. Accounts Used by Augusto Pinochet (March 16, 2005), at 56 and 62). ","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to the March 2005 report by the U.S. Senate Permanent Subcommittee on Investigations on U.S. accounts used by Mr. Pinochet and his family and associates to conceal their illicit proceeds, at the order of Chilean Judge Sergio Munoz, Pinochet lawyer Oscar Aitken Lavanchy transferred $6.8 million from U.S. accounts (about $5.5 million from G.L.P. accounts; about $1.3 million from Trasker accounts) to a bank in Chile; on August 13, 2004, the bank deposited the funds into an account under control of the Santiago Court of Appeals.  (Source:  U.S. Senate Permanent Subcommittee on Investigations, Supplemental Staff Report on U.S. Accounts Used by Augusto Pinochet (March 16, 2005), at 56 and 62).","Disposition of Criminal Case(s)":"A number of criminal proceedings had been instituted against Mr. Pinochet by the Chilean courts and by Spain\u0027s Fifth Central Magistrate of the National Court.  (Source: Regina v. Bartle and the Commissioner of Police for the Metropolis and Others Ex Parte Pinochet (on appeal from a Divisional Court of the Queen\u0027s Bench Division), Opinions of the Lords of Appeal, November 25, 1998.)","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Abogado Procuradora Fiscal, Santiago","Jurisdiction of Origin: Courts Involved":"Court of Appeals, Santiago","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Senate Permanent Subcommittee on Investigations","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"NA","Jurisdiction of Asset Recovery: Courts Involved":"NA","Documents":"","Sources ":"United States Senate Permanent Subcommittee on Investigations, Money Laundering and Foreign Corruption: Enforcement and Effectiveness of the Patriot Act, Supplemental Staff Report on the U.S. Accounts Used by Augusto Pinochet (March 16, 2005), accessed at http:\/\/levin.senate.gov\/newsroom\/supporting\/2005\/pinochetreport.pdf; \nRegina v. Bartle and the Commissioner of Police for the Metropolis and Others Ex Parte Pinochet (on appeal from a Divisional Court of the Queen\u0027s Bench Division), Opinions of the Lords of Appeal, November 25, 1998, accessed at http:\/\/www.publications.parliament.uk\/pa\/ld199899\/ldjudgmt\/jd981125\/pino....\n"},{"Case ID":"ARW-22","Case Title (Name of Public Official or Entity Allegedly Involved)":"BAE Systems \/ Tanzania Radar Defence System Case","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"","Position of Public Official(s) (yrs in office)":"Unknown","Jurisdiction of Asset Recovery":"United Kingdom","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2010","Asset Recovery End":"2012","UNCAC Offenses Implicated":"Art.16","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution; Criminal Restitution","Intl.Cooperation: MLAT\/Letter of Request?":"Other","Basis for Intl Cooperation":"Memorandum of Understanding","Contributing Factors in Asset Recovery":"Settlement agreement by the Serious Fraud\u00a0Office and BAE included provision on ex gratia payment to Tanzania; Memorandum of Understanding by Serious Fraud Office, the Government of Tanzania, BAE Systems and the Department for International Development (DFID)\u00a0\u00a0(Source: UK Serious Fraud Office Press Release, \u0022BAE Systems will pay towards educating children in Tanzania after signing an agreement brokered by the Serious Fraud Office,\u0022 March 15, 2012.)","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Final Judgment (No Appeal)","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Yes","Agreement for Returned Assets - Description":"\u0022The Serious Fraud Office, the Government of Tanzania, BAE Systems and the Department for International Development (DFID) have now signed a Memorandum of Understanding enabling the payment of \u00a329.5 million plus accrued interest to be paid by BAE Systems for educational projects in Tanzania.\u0022 The funds will be used for the purchase of textbooks and other school supplies and\u00a0equipment.\u00a0(Source: UK Serious Fraud Office, \u0022BAE Systems will pay towards educating children in Tanzania after signing an agreement brokered by the Serious Fraud Office,\u0022 March 15, 2012.)\u00a0","Case Summary":"As part of the February 2010 settlement agreement by the Serious Fraud Office (SFO) and BAE Systems Plc, BAE agreed to pay GBP 30 million in ex gratia payment for the benefit of the people of Tanzania in a manner to be agreed between the SFO and the Company, less any financial orders imposed by the Court.  In December 2010, the Southwark Crown Court approved the settlement, and fined the company GBP 500,000 and ordered it to pay GBP 225,000 in costs to the Serious Fraud Office. (Sources: R v. BAE Systems PLC, Case No. S2010565, Southwark Crown Court, December 21, 2010; Serious Fraud Office Press Release, \u0022BAE fined in Tanzania defense contract case,\u0022 December 21, 2010.)\u00a0 The company had agreed to pay the legal costs separate from the GBP 30 million settlement amount.\u00a0 In March 2012, the SFO announced that a newly agreed upon Memorandum of Understanding will enable the\u00a0GBP 29.5 million plus accrued interest [amount unspecified] to be spent towards education projects in Tanzania.\u00a0 (Source: UK Serious Fraud Office Press Release, \u0022BAE Systems will pay towards educating children in Tanzania after signing an agreement brokered by the Serious Fraud Office,\u0022 March 15, 2012.)\u00a0\u00a0 For greater discussion of the case, see UK Parliament, House of Commons,\u00a0The International Development Committee, \u0022Financial Crime\u00a0and Development, Eleventh Report of Session 2010\u201312,\u0022 Volume I (30 November 2011) and Transparency International UK,\u00a0\u0022Deterring and Punishing Corporate Bribery:\u00a0 An Evaluation of UK Corporate Plea\u00a0Agreements and Civil\u00a0Recovery in Overseas\u00a0Bribery Cases,\u0022\u00a0(June 2012)","Disposition of Criminal Case(s)":"According to a press release by the UK Serious Fraud Office, in December 2010, the Southwark Crown Court approved the February 2010 settlement agreement by the Serious Fraud Office (SFO) and BAE Systems Plc in which the company agreed to plead guilty to one count of breaching its duty to keep accounting records contrary to section 221 of the Companies Act 1985.  (Source: Serious Fraud Office Press Release, \u0022BAE fined in Tanzania defense contract case,\u0022 December 21, 2010.)","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Unknown","Jurisdiction of Origin: Courts Involved":"Unknown","Jurisdiction of Asset Recovery: Investigative Agency":"Serious Fraud Office","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Crown Prosecution Service","Jurisdiction of Asset Recovery: Courts Involved":"Southwark Crown Court","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_Charge.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_Prosecution_Opening_Nov_22_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_Sentencing_Remarks_Dec_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_Settlement_Agreement_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_SFO_PR_DEC_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_SFO_PR_Feb_5_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_UK_DFID_Memorandum_to_Parliament_Apr_27_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/BAE_SFO_Press_Release_Mar_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_Charge.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_Prosecution_Opening_Nov_22_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_Sentencing_Remarks_Dec_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_Settlement_Agreement_Feb_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_SFO_PR_DEC_21_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_SFO_PR_Feb_5_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/BAE_Tanzania_UK_DFID_Memorandum_to_Parliament_Apr_27_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/UK_Parliament_Finan_Crimes_Hearing_Report_Nov_2011.pdf","Sources ":"R v. BAE Systems PLC, Case No. S2010565, Southwark Crown Court Sentencing Remarks of December 21, 2010 (http:\/\/www.judiciary.gov.uk\/media\/judgments\/2010\/r-v-bae-systems-plc);\nProsecution Note for Opening; Settlement Agreement and Plea; and the Charge, all provided in links within the United Kingdom Serious Fraud Office Press Release, \u0022BAE fined in Tanzania defence contract case,\u0022 December 21, 2010, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-20...); \nUK Serious Fraud Office Press Release, \u0022BAE Systems plc,\u0022 February 5, 2010, posted at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-20... \nUK Serious Fraud Office Press Release, \u0022BAE Systems will pay towards educating children in Tanzania after signing an agreement brokered by the Serious Fraud Office,\u0022 March 15, 2012,\u00a0accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-20... \nUK Parliament, House of Commons, The International Development Committee, \u0022Financial Crime and Development, Eleventh Report of Session 2010\u201312,\u0022 Volume I (30 November 2011), accessed at http:\/\/www.publications.parliament.uk\/pa\/cm201012\/cmselect\/cmintdev\/847\/...\nTransparency International UK, \u0022Deterring and Punishing Corporate Bribery:\u00a0 An Evaluation of UK Corporate Plea Agreements and Civil Recovery in Overseas Bribery Cases,\u0022 (June 2012), accessed at http:\/\/www.transparency.org.uk\/our-work\/publications\/243-policy-paper-se...\n"},{"Case ID":"ARW-27","Case Title (Name of Public Official or Entity Allegedly Involved)":"Bruce Rappaport","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Antigua and Barbuda","Position of Public Official(s) (yrs in office)":"Former Ambassador for Antigua and Barbuda to Israel and Russia (Rappaport, dates of position not specified but it was in 1990 when he was appointed to negotiate the debt repayment terms)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"1996","Asset Recovery End":"2009","UNCAC Offenses Implicated":"Art.18","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Private Civil Action ","Intl.Cooperation: MLAT\/Letter of Request?":"No","Basis for Intl Cooperation":"NA","Contributing Factors in Asset Recovery":"In his July 2009 announcement of the Government of Antigua and Barbuda\u0027s settlement agreement and payment received from Rappaport, the Attorney General and Minister of Legal Affairs, Hon. Justin Simon QC stated, \u0022Shortly after this Administration took office, I informed you by way of a Press Statement that the government had commissioned a financial forensic investigation and had secured the services of Mr. Robert Lindquist who had himself led like-investigations in Trinidad and Tobago where over Seven Million U.S. Dollars of illegal payments to public officials had been recovered, and that he was instrumental in the arrests and prosecutions of persons involved in the Piarco International Airport scandal in Trinidad.\u0022  (Mr. Simon\u0027s statement is posted at http:\/\/www.ab.gov.ag\/gov_v4\/article_details.php?id=68\u0026category=38).\r\n","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$12,000,000","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"NA","Case Summary":"According to a statement by the Attorney General of Antigua and Barbuda that was published on the official website of the Government of Antigua and Barbuda, Mr. Rappaport agreed to pay the government $12 million in settlement. In 2006, the Attorney General of Antigua Barbuda had obtained an injunction from the High Court of Antigua to freeze the Antigua account of Mr. Rappaport\u0027s Miami-based IHI Debt Settlement Associates, LLC. and Miami accounts of Mr. Rappaport\u0027s companies. (Source: Press Release by the Government of Antigua Barbuda, \u0022Government of Antigua Barbuda Recoups U.S. $12 million dollars in case against former government officials and others,\u0022 posted on July 10, 2009, at http:\/\/www.ab.gov.ag\/gov_v4\/article_details.php?id=68\u0026category=38, and Statement by Hon. Justin L. Simon QC, Attorney General and Minister of Legal Affairs, \u0022On the filing of Lawsuits against members of the former Government,\u0022 March 1, 2006, posted at http:\/\/www.ab.gov.ag\/gov_v2\/government\/pressreleases\/pressreleases2006\/p....)","Disposition of Criminal Case(s)":"No known criminal proceedings; Mr. Rappaport passed away in January 2010. (Source: Juliet Benjamin, \u0022Rappaport Dies,\u0022 Antigua Observer, January 9, 2010, accessed at http:\/\/www.antiguaobserver.com\/?p=20689.)","Jurisdiction of Origin: Investigative Agency":"Attorney General and Minister of Legal Affairs","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General and Minister of Legal Affairs","Jurisdiction of Origin: Courts Involved":"NA","Jurisdiction of Asset Recovery: Investigative Agency":"NA","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Astigarraga David (Attorney Edward H. Davis, Jr.)","Jurisdiction of Asset Recovery: Courts Involved":"Miami-Dade County Circuit, Florida, United States","Documents":"","Sources ":"Press Release by the Government of Antigua and Barbuda, \u0022Government of Antigua Barbuda Recoups US $12 million dollars in case against former government officials and others,\u0022 Posted On: July 10, 2009, at  http:\/\/www.ab.gov.ag\/gov_v4\/article_details.php?id=68\u0026category=38, and Statement by Hon. Justin L. Simon QC, Attorney General and Minister of Legal Affairs, \u0022On the Filing of Lawsuits against Members of the Former Government,\u0022 March 1, 2006, posted at  http:\/\/www.ab.gov.ag\/gov_v2\/government\/pressreleases\/pressreleases2006\/p... \nAntigua and Barbuda v. Bruce Rappaport, et al, Case No. 06-03560 CA 25 (Eleventh Judicial Circuit Court in and for Miami-Dade County, Florida), Second Amended Complaint filed on October 10, 2007; Plaintiff\u0027s Notice of Dropping Certain Parties, dated February 20, 2009.  \nSee also, Juliet Benjamin, \u0022Rappaport Dies,\u0022 Antigua Observer, January 9, 2010, accessed at  http:\/\/www.antiguaobserver.com\/?p=20689.\n"},{"Case ID":"ARW-29","Case Title (Name of Public Official or Entity Allegedly Involved)":"Carlos F. Garcia \/ Ian Carl and Juan Paulo Depakakibo Garcia (Northern California Case)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"Former Comptroller of the Philippine Armed Forces (Carlos Garcia, 1990-2004), Sons (Ian Carl and Juan Paulo Depakakibo)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2003","Asset Recovery End":"2011","UNCAC Offenses Implicated":"Art.15, Art.17, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Criminal Prosecution and Forfeiture","Intl.Cooperation: MLAT\/Letter of Request?":"MLAT","Basis for Intl Cooperation":"Unspecified","Contributing Factors in Asset Recovery":"Ian Carl and Juan Paulo Depakakibo were apprehended pursuant to a routine search at the airport as they tried to enter the U.S. with the illegal bulk cash.  (Source:  U.S. v. Ian Carl Depakakibo and Juan Paulo Depakakibo, Case No. 08-cr-00888-MHP (N.D. Cal.)","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Judgment by Court of First Instance","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"N\/A","Case Summary":"One-hundred thousand dollars in U.S. currency had been seized from Ian Carl and Juan Paulo Depakakibo when they tried to enter the U.S. with the cash.  In January 2011, the U.S. District Court for the District of Northern California forfeited the confiscated funds to the U.S. Government. The brothers had agreed, as part of their plea, to forfeit the $100,000 seized from them at the time of their arrest on December 19, 2003.  (Source:  U.S. v. Ian Carl Depakakibo and Juan Paulo Depakakibo, Case No. 08-cr-00888-MHP (N.D. Cal.), Final Order of Forfeiture, filed January 7, 2011); U.S. Immigration and Customs Service Press Release, \u0022Sons of former Philippine military comptroller charged with bulk cash smuggling,\u0022 February 25, 2009.)  They and their father, mother and a third brother have been charged in the Philippines with the crime of Plunder, for allegedly illegally amassing $9 million (303.27 million Philippine Pesos) while their father, General Carlos F. Garcia, had been the Comptroller of the Philippine Armed Forces. (Source:  Philippines Complaint and Arrest Warrant in the Plunder case, included as Annex A in extradition complaint filed on March 4, 2009, In the Matter of Extradition of Clarita Depakakibo Garcia, Case No. 2:09-mc-50231 (E.D. Mich.)","Disposition of Criminal Case(s)":"According to a September 9, 2010 press release by the U.S. Department of Justice, former Major General Garcia \u0022recently was found guilty in the Philippines of perjury for a false declaration of his assets and liabilities in 2000.\u0022 (Source: U.S. Department of Justice Press Release, \u0022Sons of Former Philippine General Plead Guilty to Bulk Cash Smuggling,\u0022 September 9, 2010.) His Plunder case was ongoing as of July 2013. (Source: Philippines Office of solicitor General, TRO - Garcia) According to the April 5, 2005 Information against former Mr. Garcia, his wife Clarita Garcia and their sons Ian Carl, Juan Paulo and Timothy Mark D. Garcia, the Philippines Ombudsman\u0027s Office has charged them with committing the crime of Plunder. (Source: In the Matter of Extradition of Clarita Depakakibo Garcia, Case No. 2:09-mc-50231 (E.D. Mich.), Annex A to Extradition compaint filed on March 4, 2009). In November 2010, Ian Carl and Juan Paulo Depakakibo were sentenced to time served by U.S. District Court for the Northern District of California, subsequent to their guilty plea on bulk cash smuggling charge. (Source: U.S. v. Ian Carl Depakakibo and Juan Paulo Depakakibo, Case No. 08-cr-00888-MHP (N.D. Cal.), Judgment in a Criminal Case, filed on December 1, 2010.)","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Ombudsman, Office of the Special Prosecutor","Jurisdiction of Origin: Courts Involved":"Sandiganbayan, Supreme Court (Third Division)","Jurisdiction of Asset Recovery: Investigative Agency":"U.S. Customs and Border Protection, San Francisco International Airport","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Northern District of California","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Northern District of California","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_Forfeiture_Motion_Oct_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_Forfeiture_Order_Nov_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_ICE_PR_Feb_25_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_Indictment_Dec_9_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_Judgment_Dec_1_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Complaint_Arrest_Warrant_Extradition_Complaint_Mar_9_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_US_NDCAL_Guilty_Pleas_Justice_Dept_Press_Release_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Depakakibo_Northern_California_Final_Order_Forfeiture_Jan_7_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Garcia_NDCAL_Forfeiture_Order_Nov_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_Forfeiture_Motion_Oct_20_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_Forfeiture_Order_Nov_2_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_ICE_PR_Feb_25_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_Indictment_Dec_9_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_NDCAL_Judgment_Dec_1_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Complaint_Arrest_Warrant_Extradition_Complaint_Mar_9_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_US_NDCAL_Guilty_Pleas_Justice_Dept_Press_Release_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Depakakibo_Northern_California_Final_Order_Forfeiture_Jan_7_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Garcia_NDCAL_Forfeiture_Order_Jan_2011.pdf","Sources ":"U.S. v. Ian Carl Depakakibo and Juan Paulo Depakakibo, Case No. 08-cr-00888-MHP (N.D. Cal.), Indictment filed on December 9, 2008; Order Granting Motion for Preliminary Order of Forfeiture, filed on November 2, 2010; Judgment in a Criminal Case, filed on December 1, 2010; and Final Order of Forfeiture filed January 7, 2011. See also, U.S. Immigration and Customs Service Press Release, \u0022Sons of former Philippine military comptroller charged with bulk cash smuggling,\u0022 February 25, 2009, accessed at http:\/\/www.ice.gov\/news\/releases\/0902\/090225sanfrancisco.htm; U.S. Department of Justice Press Release, \u0022Sons of Former Philippine General Plead Guilty to Bulk Cash Smuggling,\u0022 September 9, 2010, accessed at http:\/\/www.justice.gov\/usao\/can\/press\/2010\/2010_09_09_garcias.guiltyplea.... Philippines Complaint and Arrest Warrant in the Plunder case, included as Annex A in extradition complaint filed on March 4, 2009, In the Matter of Extradition of Clarita Depakakibo Garcia, Case No. 2:09-mc-50231 (E.D. Mich.)\n"},{"Case ID":"ARW-31","Case Title (Name of Public Official or Entity Allegedly Involved)":"Carlos Garcia \/ Clarita Garcia \/ Timothy Mark D. Garcia (New York Condominium)","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"Philippines","Position of Public Official(s) (yrs in office)":"Former Comptroller of the Philippine Armed Forces (Carlos Garcia,1990-2004), Wife (Clarita Garcia), Son (Timothy Mark)","Jurisdiction of Asset Recovery":"United States","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"2015","UNCAC Offenses Implicated":"Art.15, Art.17, Art.20, Art.23","Money laundering Implicated":"Yes","Legal Basis for Asset Recovery":"Non-Conviction Based Confiscation","Intl.Cooperation: MLAT\/Letter of Request?":"","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"","Status of Asset Recovery ":"Completed","Stage in Asset Recovery Chain":"Assets Returned to Victim or Requesting Jurisdiction","Assets Frozen (USD)":"","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"$1,384,940.28","Agreement for Returned Assets":"No","Agreement for Returned Assets - Description":"","Case Summary":"Related to the General Carlos Garcia corruption cases in the Philippines, the U.S. filed criminal and civil actions against members of the Garcia family and their US assets.\u00a0 The actions include 2004 civil forfeiture proceedings in New York against an apartment that was allegedly purchased with corrupt proceeds, and 2009 extradition proceedings against Clarita Garcia (wife) and a third son Timothy Mark Garcia (who is not involved in the Northern California bulk cash smuggling case against Ian Carl and Juan Paulo D. Garcia).\u00a0 (Sources: U.S. v. All Right, Title and Interest in Real Property and Apputenance Located at Trump Park Avenue Condominium, Unit 6A, Case No. 1:04-cv-08918-RJH (S.D.N.Y.), Complaint filed November 10, 2004; In Re Clarita Depakakibo Garcia, Case No. 2:09-mc-50231-GCS (E.D. Mich.), Extradition Complaint filed March 4, 2009; unable to obtain copies of the extradition complaint against son Timothy and copy of a March 16, 2009 criminal complaint that were reported to have been filed against him in U.S. District Court for the Southern District of New York, as noted by\u00a0 Joseph G. Lariosa,\u00223rd son of Gen. Garcia now also detained in U.S.,\u0022 GMANews.TV posted at\u00a0 http:\/\/www.gmanews.tv\/story\/153224\/3rd-son-of-Gen-Garcia-now-also-detained-in-U.S.).\u00a0 On May 20, 2011, the US Government wrote to the court stating that the agreement with the Garcias for the forfeiture of the condominium had been stalled as it was contingent on the Philippine government\u0027s formal withdrawl of extradition requests of former general Garcia\u0027s sons and wife from the U.S.\u00a0 (Source: US v. All Right, Title and Interest in Real Property and Apputenance Located at Trump Park Avenue Condominium, Unit 6A, Case No. 1:04-cv-08918-RJH (S.D.N.Y.), Endorsed Letter to the Court by US Government dated May 20, 2011 and filed June 2, 2011.)\u00a0 In November 26, 2012, the US was granted a default judgment against the condominium.\u00a0 (Source: US v. All Right, Title and Interest in Real Property and Appurtenance Located at Trump Park Avenue Condominium, Unit 6A, Case No. 1:04-cv-08918-RJH (S.D.N.Y.), Default Judgment, November 26, 2012).\nAccording to a statement by the US Embassy Manila, on June 3, 2015, \u0022U.S. Ambassador Philip S. Goldberg presented Ombudsman Conchita Carpio-Morales with a check in the amount of U.S. $1,384,940.28 payable to the Republic of the Philippines. The check represents \u201cill-gotten\u201d gains acquired by former AFP Comptroller General Carlos F. Garcia.\u00a0 [\u00a0 ]\u00a0 Philippine and U.S. investigators worked closely together to determine that General Garcia laundered a substantial portion of his criminal proceeds through the United States.\u00a0 In particular, investigators with the U.S. Department of Homeland Security traced the criminal proceeds to two Citibank accounts in New York and a condominium in Trump Tower in New York.\u00a0 The U.S. Attorney\u0027s Office for the Southern District of New York then initiated civil forfeiture proceedings against those assets and eventually obtained default judgments of forfeiture.\u00a0 The net proceeds resulting from the sale of the condominium and the funds from the two Citibank accounts were returned to the Philippines by the United States today.\u0022\u00a0 (Source: US Embassy Manila, \u0022U.S. Helps Philippines Recover \u0027Ill-Gotten Gains\u0027\u201d, June 3, 2015, at http:\/\/manila.usembassy.gov\/press-photo-releases-2015\/us-helps-philippines-recover-ill-gotten-gains.html.)\n\u00a0","Disposition of Criminal Case(s)":"According to a June 3, 2015 statement by the Ombudsman of the Philippines, \u0022the Office of the Ombudsman filed criminal cases of perjury, money laundering and plunder against [Carlos] Garcia who eventually was convicted of perjury by the Sandiganbayan.\u00a0 In the last two criminal cases, Garcia pleaded to the lesser offenses of Indirect Bribery and Facilitating Money Laundering, which plea bargaining is the subject of review by the Supreme Court.\u00a0 Meanwhile, forfeiture proceedings are pending with the Sandiganbayan.\u0022\u00a0 (Source:\u00a0 Office of the Ombudsman, \u0022US turns over $1.38M proceeds of Garcia\u2019s forfeited assets,\u0022 June 3,2015.)\nAccording to the April 5, 2005 Information against former Mr. Garcia, his wife Clarita Garcia and their sons Ian Carl, Juan Paulo and Timothy Mark D. Garcia, the Philippines Ombudsman\u0027s Office had charged them with committing the crime of Plunder.\u00a0 (Source:\u00a0 In the Matter of Extradition of Clarita Depakakibo Garcia, Case No. 2:09-mc-50231 (E.D. Mich.), Annex A to Extradition compaint filed on March 4, 2009).\u00a0 In November 2010, Ian Carl and Juan Paulo Depakakibo were sentenced to time served by U.S. District Court for the Northern District of California, subsequent to their guilty plea on bulk cash smuggling charge.\u00a0\u00a0 (Source: U.S. v. Ian Carl Depakakibo and Juan Paulo Depakakibo, Case No. 08-cr-00888-MHP (N.D. Cal.), Judgment in a Criminal Case, filed on December 1, 2010.)\n\u00a0","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Office of the Ombudsman, Office of the Special Prosecutor","Jurisdiction of Origin: Courts Involved":"Sandiganbayan, Supreme Court (Third Division)","Jurisdiction of Asset Recovery: Investigative Agency":"Department of Homeland Security","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"U.S. Attorney for the Southern District of New York; U.S. Attorney for the Eastern District of Michigan","Jurisdiction of Asset Recovery: Courts Involved":"U.S. District Court for the Southern District of New York; U.S. District Court for the Eastern District of Michigan","Documents":"http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_GMANEWS_Apr_10_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Complaint_Arrest_Warrant_Extradition_Complaint_Mar_9_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Sct_Oct_12_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_US_NDCAL_Guilty_Pleas_Justice_Dept_Press_Release_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_SDNY_USG_Letter_Status_Forfeiture_May_20_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Garcia_SDNY_Condo_Default_Judgment_Nov_26_2012.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_GMANEWS_Apr_10_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Complaint_Arrest_Warrant_Extradition_Complaint_Mar_9_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Sct_Oct_12_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_US_NDCAL_Guilty_Pleas_Justice_Dept_Press_Release_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_SDNY_USG_Letter_Status_Forfeiture_May_20_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Garcia_SDNY_USG_Letter_Status_Forfeiture_May_20_2011.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_GMANEWS_Apr_10_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Complaint_Arrest_Warrant_Extradition_Complaint_Mar_9_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Sct_Oct_12_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_US_NDCAL_Guilty_Pleas_Justice_Dept_Press_Release_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_SDNY_USG_Letter_Status_Forfeiture_May_20_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Gacria_US_SDNY_Asset%20Return_USEmbassy%20Manila%20Press_Jun3_2015_0.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_GMANEWS_Apr_10_2008.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Complaint_Arrest_Warrant_Extradition_Complaint_Mar_9_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_Phil_Sct_Oct_12_2009.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_US_NDCAL_Guilty_Pleas_Justice_Dept_Press_Release_Sep_9_2010.pdf, http:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/documents\/arw\/Garcia_SDNY_USG_Letter_Status_Forfeiture_May_20_2011\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/Garcia_US%20Asset%20Return_Phil%20Ombudsman_statement_Jun3_2015_0.pdf","Sources ":"U.S. v. All Right, Title and Interest in Real Property and Apputenance Located at Trump Park Avenue Condominium, Unit 6A, Case No. 1:04-cv-08918-RJH (S.D.N.Y.), Complaint filed November 10, 2004 and Endorsed Letter to the Court by US Government dated May 20, 2011 and filed June 2, 2011 and Default Judgment filed November 26, 2012; In Re Clarita Depakakibo Garcia, Case No. 2:09-mc-50231-GCS (E.D. Mich.), extradition case filed March 4, 2009; unable to obtain copies of the extradition complaint against son Timothy and copy of a March 16, 2009 criminal complaint that were reported to have been filed against him in U.S. District Court for the Southern District of New York, noted by Joseph G. Lariosa,\u00223rd son of Gen. Garcia now also detained in U.S.,\u0022 GMANews.TV posted at\u00a0 http:\/\/www.gmanews.tv\/story\/153224\/3rd-son-of-Gen-Garcia-now-also-detained-in-U.S.); U.S. Department of Justice Press Release, \u0022Sons of Former Philippine General Plead Guilty to Bulk Cash Smuggling,\u0022 September 9, 2010, accessed at http:\/\/www.justice.gov\/usao\/can\/press\/2010\/2010_09_09_garcias.guiltyplea.press.html;\nUS Embassy Manila, \u0022U.S. Helps Philippines Recover \u0027Ill-Gotten Gains\u0027\u201d, June 3, 2015, at http:\/\/manila.usembassy.gov\/press-photo-releases-2015\/us-helps-philippines-recover-ill-gotten-gains.html; Office of the Ombudsman, \u0022US turns over $1.38M proceeds of Garcia\u2019s forfeited assets,\u0022 June 3,2015, at http:\/\/www.ombudsman.gov.ph\/index.php?home=1\u0026pressId=NjU3\n\u00a0\n"},{"Case ID":"ARW-32","Case Title (Name of Public Official or Entity Allegedly Involved)":"Carlos Perla","Jurisdiction of Origin of Public Official or Entity Allegedly Involved":"El Salvador","Position of Public Official(s) (yrs in office)":"Former head of the Salvadoran water authority, ANDA (Administracion Nacional de Acueductos y Alcantarillados) (1994-2002)","Jurisdiction of Asset Recovery":"Panama","Jurisdiction of Asset Description":"Undertaking Recovery Effort, Location of Recovery Effort, Asset Location \/ Alleged Asset Location","Asset Recovery Start":"2004","Asset Recovery End":"Ongoing","UNCAC Offenses Implicated":"Art.15, Art.17","Money laundering Implicated":"No","Legal Basis for Asset Recovery":"Actions Initiated by Foreign Jurisdiction","Intl.Cooperation: MLAT\/Letter of Request?":"Unknown","Basis for Intl Cooperation":"Unknown","Contributing Factors in Asset Recovery":"Ongoing Case","Status of Asset Recovery ":"Ongoing","Stage in Asset Recovery Chain":"Investigation\/Asset Tracing\/Asset Restraint","Assets Frozen (USD)":"$2,200,000 (Secondary Source)","Assets Adjudicated, Not Yet Returned (USD)":"","Assets Returned (USD)":"","Agreement for Returned Assets":"Ongoing","Agreement for Returned Assets - Description":"N\/A","Case Summary":"According to a November 4, 2010 article by elsalvador.com, El Salvador was seeking to have returned the $2.2 million frozen in the Panamanian bank accounts of Carlos Perla, the former head of the Salvadoran water authority, ANDA (Administracion Nacional de Acueductos y Alcantarillados).  El Salvador had made the request to have the funds frozen in 2004.  (Source: elsalvador.com, \u0022FGR busca recupar dinero de Carlos Perla,\u0022 November 4, 2010, posted at http:\/\/www.elsalvador.com\/mwedh\/nota\/nota_completa.asp?idCat=6358\u0026idArt=....)  In 2006, the U.S. Department of State had written in a report to Congress that \u0022[i]n El Salvador, the new Court of Accounts (Corte de Cuentas) conducted regular audits of public officials and employees with a view to preventing and sanctioning acts of corruption. As a result, El Salvador\u0027s attorney general has started numerous corruption-related prosecutions. The highest profile case is that of Carlos Perla, ex-president of the Salvadoran Water Authority (ANDA), who was accused of misappropriating $31 million during his tenure.\u0022 (Source: U.S. Department of State, Bureau of International Narcotics and Law Enforcement Affairs,\u0022Sixth Annual Report to Congress on the Inter-American Convention Against Corruption,\u0022 April 1, 2006.)","Disposition of Criminal Case(s)":"According to La Prensa, in July 2007 in El Salvador, Mr. Perla was sentenced to fifteen years\u0027 imprisonment, following his conviction on embezzlement charges. (Source:  Suchit Chavez and Jessica Avalos, \u0022Carlos Perla y Mario Orellana. candidatos a quedar en libertad,\u0022 La Prensa Grafica, February 10, 2011, accessed at http:\/\/www.laprensagrafica.com\/el-salvador\/judicial\/170762-carlos-perla-....)","Jurisdiction of Origin: Investigative Agency":"Unknown","Jurisdiction of Origin: Prosecuting Authority\/Civil Attorney(s)":"Attorney General","Jurisdiction of Origin: Courts Involved":"Court of Accounts (Corte de Cuentas) [secondary source]","Jurisdiction of Asset Recovery: Investigative Agency":"Unknown","Jurisdiction of Asset Recovery: Prosecuting Authority\/Civil Attorney(s)":"Prosecutor General","Jurisdiction of Asset Recovery: Courts Involved":"Unknown","Documents":"","Sources ":"elsalvador.com, \u0022FGR busca recupar dinero de Carlos Perla,\u0022 November 4, 2010, posted at http:\/\/www.elsalvador.com\/mwedh\/nota\/nota_completa.asp?idCat=6358\u0026idArt=... \nSuchit Chavez and Jessica Avalos, \u0022Carlos Perla y Mario Orellana. candidatos a quedar en libertad,\u0022 La Prensa Grafica, February 10, 2011, accessed at http:\/\/www.laprensagrafica.com\/el-salvador\/judicial\/170762-carlos-perla-... \nU.S. Department of State, Bureau of International Narcotics and Law Enforcement Affairs,\u0022Sixth Annual Report to Congress on the Inter-American Convention Against Corruption,\u0022 April 1, 2006, accessed at http:\/\/www.state.gov\/p\/inl\/rls\/rpt\/67758.htm.\n"}],"settlements":[{"Case ID":"ST-536","Case Cluster ":"","Jurisdiction of Settlement":"","Jurisdiction of Settlement \/ Enforcement Agency":"","Jurisdiction of Foreign Public Official(s) ":"","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"","Other Jurisdictions of Settlement":"","Settlement with Individual or Legal Person?":"","Type of Settlement":"","Legal Form of Settlement":"","Monetary Sanctions  (Types)":"","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"","OECD Anti-Bribery Convention Articles Implicated":"","Offenses - Alleged":"","Offenses - Settled":"","Public Procurement Contract \/ SOE Involved?":"","Summary":"","Sources ":"","Documents":""},{"Case ID":"ST-447","Case Cluster ":"Eli Lilly \u0026 Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Brazil, China, Poland, Russia","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"12\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$29,398,734 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$13,955,196 ","Civil Prejudgment Interest (US$) ":"$6,743,538 ","Civil Fine \/ Penalty (US$)":"$8,700,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials; falsification of books and records; internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, in December 2012, Eli Lilly \u0026 Co. consented to the entry of a Cease and Desist Order in relation to alleged improper payments by its subsidiaries to foreign government officials to win millions of dollars of business in Russia, Brazil, China, and Poland. \u0022The SEC alleges that the Indianapolis-based pharmaceutical company\u2019s subsidiary in Russia used offshore \u201cmarketing agreements\u201d to pay millions of dollars to third parties chosen by government customers or distributors, despite knowing little or nothing about the third parties beyond their offshore address and bank account information. These offshore entities rarely provided any services and in some instances were used to funnel money to government officials in order to obtain business for the subsidiary. Transactions with offshore or government-affiliated entities did not receive specialized or closer review for possible FCPA violations. Paperwork was accepted at face value and little was done to assess whether the terms or circumstances surrounding a transaction suggested the possibility of foreign bribery.\r\n \r\n The SEC alleges that when the company did become aware of possible FCPA violations in Russia, Lilly did not curtail the subsidiary\u2019s use of the marketing agreements for more than five years. Lilly subsidiaries in Brazil, China, and Poland also made improper payments to government officials or third-party entities associated with government officials. [ ]\r\n \r\n Lilly agreed to pay disgorgement of $13,955,196, prejudgment interest of $6,743,538, and a penalty of $8.7 million for a total payment of $29,398,734. Without admitting or denying the allegations, Lilly consented to the entry of a final judgment permanently enjoining the company from violating the anti-bribery, books and records, and internal controls provisions of the FCPA. Lilly also agreed to comply with certain undertakings including the retention of an independent consultant to review and make recommendations about its foreign corruption policies and procedures. The settlement is subject to court approval.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Eli Lilly and Company with FCPA Violations,\u0022 December 20, 2012.)","Sources ":"US v. Eli Lilly and Company, Case No. 12-cv-02045 (DDC), Complaint filed December 20, 2012; SEC Press Release, \u0022SEC Charges Eli Lilly and Company with FCPA Violations,\u0022 December 20, 2012, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171487116","Documents":""},{"Case ID":"ST-448","Case Cluster ":"FLIR Systems","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"4\/8","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, civil Penalty","Total Monetary Sanctions (US$)":"$9,504,584 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$7,534,000 ","Civil Prejudgment Interest (US$) ":"$970,584 ","Civil Fine \/ Penalty (US$)":"$1,000,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, FLIR Systems, Inc. is an Oregon-based corporation founded in 1978 which develops infrared technology for use in thermal imaging and other sensing products and systems, night vision, and camera systems for government and commercial customers. \r\n \r\n\u0022According to the SEC\u2019s order instituting a settled administrative proceeding against FLIR, the company had few internal controls over gifts and travel out of its foreign sales offices. Two employees in its Dubai office provided expensive watches to government officials with the Saudi Arabia Ministry of Interior in 2009, and they arranged for the company to pay for a 20-night excursion by Saudi officials that included stops in Casablanca, Paris, Dubai, Beirut, and New York City. The value of the gifts and the extent and nature of the travel were falsely recorded in FLIR\u2019s books and records as legitimate business expenses, and the company\u2019s internal controls failed to catch the improper payments despite documentation suggesting that extravagant gifts and travel were being provided. \r\n \r\n The SEC\u2019s order finds that from 2008 to 2010, FLIR paid approximately $40,000 for additional travel by Saudi government officials, including multiple New Year\u2019s Eve trips to Dubai with airfare, hotel, and expensive dinners and drinks. FLIR also accepted cursory invoices from a FLIR company partner without any supporting documentation to pay extended travel of Egyptian officials in mid-2011.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Oregon-Based Defense Contractor With FCPA Violations,\u0022 April 8, 2015.)","Sources ":"US Securities and Exchange Commission Administrative Proceeding File No, 3-16478, In the Matter of Flir Systems Inc., April 8, 2015, at https:\/\/www.sec.gov\/litigation\/admin\/2015\/34-74673.pdf; SEC Press Release, \u0022SEC Charges Oregon-Based Defense Contractor With FCPA Violations,\u0022 April 8, 2015, at https:\/\/www.sec.gov\/news\/pressrelease\/2015-62.html","Documents":""},{"Case ID":"ST-449","Case Cluster ":"FLIR Systems","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"11\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$50,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$50,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022FLIR is headquartered in Oregon and produces thermal imaging, night vision, and infrared cameras and sensor systems. According to the SEC\u2019s order instituting a settled administrative proceeding, FLIR entered into a multi-million dollar contract to provide thermal binoculars to the Saudi government in November 2008. Timms and Ramahi were the primary sales employees responsible for the contract, and also were involved in negotiations to sell FLIR\u2019s security cameras to the same government officials. At the time, Timms was the head of FLIR\u2019s Middle East office in Dubai and Ramahi reported to him. \r\n \r\n The SEC\u2019s order finds that Timms and Ramahi traveled to Saudi Arabia in March 2009 and provided five officials with expensive luxury watches during meetings to discuss several business opportunities. Timms and Ramahi believed these officials were important to sales of both the binoculars and the security cameras. A few months later, they arranged for key officials, including two who received watches, to embark on what Timms referred to as a \u201cworld tour\u201d of personal travel before and after they visited FLIR\u2019s Boston facilities for a factory equipment inspection that was a key condition to fulfillment of the contract. The officials traveled for 20 nights with stops in Casablanca, Paris, Dubai, Beirut, and New York City. There was no business purpose for the stops outside of Boston, and the airfare and hotel accommodations were paid for by FLIR. Prior to providing the gifts and travel to the Saudi Arabian officials, Ramahi and Timms each had taken FCPA training at the company that specifically identified luxury watches and side trips as prohibited gifts.\r\n \r\n According to the SEC\u2019s order, when FLIR\u2019s finance department flagged the expense reimbursement request for the watches during an unrelated review of expenses in the Dubai office and questioned the $7,000 cost, Timms and Ramahi obtained a second, fabricated invoice showing a cost of 7,000 Saudi Riyal (approximately $1,900 in U.S. dollars) instead of the true cost of $7,000 in U.S. dollars. They directed FLIR\u2019s local third-party agent to provide false information to the company to back up their story that the original submission was merely a mistake. Ramahi and Timms also falsely claimed that FLIR\u2019s payment for the world tour had been a billing mistake by FLIR\u2019s travel agent, and again used false documentation and FLIR\u2019s third-party agent to bolster their cover-up efforts.\u0022 (Source: US SEC Press Release, \u0022SEC Sanctions Two Former Defense Contractor Employees for FCPA Violations,\u0022 November 17, 2014.)","Sources ":"US Securities and Exchange Commission Administrative Proceedings File No. 3-16281, In the Matter of\r\n Stephen Timms and Yasser Ramahi, November 17, 2014, at https:\/\/www.sec.gov\/litigation\/admin\/2014\/34-73616.pdf;\r\n \r\n SEC Press Release, \u0022SEC Sanctions Two Former Defense Contractor Employees for FCPA Violations,\u0022 November 17, 2014, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370543472839.","Documents":""},{"Case ID":"ST-450","Case Cluster ":"FLIR Systems","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"11\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$20,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$20,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022FLIR is headquartered in Oregon and produces thermal imaging, night vision, and infrared cameras and sensor systems. According to the SEC\u2019s order instituting a settled administrative proceeding, FLIR entered into a multi-million dollar contract to provide thermal binoculars to the Saudi government in November 2008. Timms and Ramahi were the primary sales employees responsible for the contract, and also were involved in negotiations to sell FLIR\u2019s security cameras to the same government officials. At the time, Timms was the head of FLIR\u2019s Middle East office in Dubai and Ramahi reported to him. \r\n \r\n The SEC\u2019s order finds that Timms and Ramahi traveled to Saudi Arabia in March 2009 and provided five officials with expensive luxury watches during meetings to discuss several business opportunities. Timms and Ramahi believed these officials were important to sales of both the binoculars and the security cameras. A few months later, they arranged for key officials, including two who received watches, to embark on what Timms referred to as a \u201cworld tour\u201d of personal travel before and after they visited FLIR\u2019s Boston facilities for a factory equipment inspection that was a key condition to fulfillment of the contract. The officials traveled for 20 nights with stops in Casablanca, Paris, Dubai, Beirut, and New York City. There was no business purpose for the stops outside of Boston, and the airfare and hotel accommodations were paid for by FLIR. Prior to providing the gifts and travel to the Saudi Arabian officials, Ramahi and Timms each had taken FCPA training at the company that specifically identified luxury watches and side trips as prohibited gifts.\r\n \r\n According to the SEC\u2019s order, when FLIR\u2019s finance department flagged the expense reimbursement request for the watches during an unrelated review of expenses in the Dubai office and questioned the $7,000 cost, Timms and Ramahi obtained a second, fabricated invoice showing a cost of 7,000 Saudi Riyal (approximately $1,900 in U.S. dollars) instead of the true cost of $7,000 in U.S. dollars. They directed FLIR\u2019s local third-party agent to provide false information to the company to back up their story that the original submission was merely a mistake. Ramahi and Timms also falsely claimed that FLIR\u2019s payment for the world tour had been a billing mistake by FLIR\u2019s travel agent, and again used false documentation and FLIR\u2019s third-party agent to bolster their cover-up efforts.\u0022 (Source: US SEC Press Release, \u0022SEC Sanctions Two Former Defense Contractor Employees for FCPA Violations,\u0022 November 17, 2014.)","Sources ":"US Securities and Exchange Commission Administrative Proceedings File No. 3-16281, In the Matter of\r\n Stephen Timms and Yasser Ramahi, November 17, 2014, at https:\/\/www.sec.gov\/litigation\/admin\/2014\/34-73616.pdf;\r\n \r\n SEC Press Release, \u0022SEC Sanctions Two Former Defense Contractor Employees for FCPA Violations,\u0022 November 17, 2014, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370543472839.","Documents":""},{"Case ID":"ST-451","Case Cluster ":"Frederic Cilins","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Guinea","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"7\/25","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Penalty, Criminal Forfeiture","Total Monetary Sanctions (US$)":"$95,000 ","Criminal Fine\/Penalty (US$) ":"$75,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$20,000 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Obstruction of Justice in FCPA investigation","Offenses - Settled":"Obstruction of Justice in FCPA investigation","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, In July 2014, Frederic Cilins was sentenced in the Southern District of New York to 24 months in prison for obstructing a federal criminal investigation into alleged bribes to obtain mining concessions in the Republic of Guinea: \u0022Cilins offered to bribe a witness in an FCPA investigation to stop the witness from talking to the FBI,\u201d said Assistant Attorney General Caldwell. \u201cToday\u2019s sentence holds Cilins accountable for his effort to undermine the integrity of our justice system, and sends a message that those who interfere with federal investigations will be prosecuted and sent to prison.\u201d\r\n \r\n \u201cFrederic Cilins went to great lengths to thwart a Manhattan federal grand jury\u2019s investigation into an alleged bribery scheme in the Republic of Guinea,\u201d said U.S. Attorney Bharara. \u201cIn an effort to prevent the federal authorities from learning the truth, Cilins paid a witness for her silence and to destroy key documents. Today, Cilins learned that no one can manipulate justice.\u201d\r\n \r\n \u201cCilins obstructed the efforts of the FBI during the course of this investigation,\u201d said Director in Charge Venizelos. \u201cHis guilty plea and sentence demonstrate our shared commitment with the department\u2019s Criminal Division and U.S. Attorney\u2019s Office to hold accountable those who seek to interfere with the administration of justice. This case should be a reminder to all those who try to circumvent the efforts of a law enforcement investigation: the original crime and the cover-up both lend themselves to prosecution.\u201d\r\n \r\n According to court documents, Cilins obstructed an ongoing federal investigation concerning potential violations of the Foreign Corrupt Practices Act (FCPA) and other crimes. Federal law enforcement was investigating whether a particular mining company with which Cilins was affiliated paid bribes to officials of a former governmental regime in the Republic of Guinea to obtain and retain valuable mining concessions in the Republic of Guinea\u2019s Simandou region. During monitored and recorded phone calls and face-to-face meetings, Cilins agreed to pay substantial sums of money to induce a witness to the alleged bribery scheme to leave the United States to avoid questioning by the FBI, as well as to give documents to Cilins for destruction that had been requested by the FBI as part of the investigation. Cilins also sought to induce the witness to sign an affidavit containing false statements regarding matters under investigation by the grand jury. That witness was the former wife of a now-deceased Guinean government official who held an office in Guinea that allowed him to influence the award of mining concessions.\u0022 (Source: US Department of Justice Press Release, \u0022French Citizen Sentenced for Obstructing a Criminal Investigation into Alleged Bribes Paid to Win Mining Rights in Guinea,\u0022 July 25, 2014.)","Sources ":"US v. Frederic Cilins, Case No. 13-cr-315 (SDNY), Superseding Indictment filed February 18, 2014, plea Agreement of March 7, 2014 and other court documents, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-frederic-cilins-court-docket-number-13-cr-00315-whp; \r\n \r\n US Department of Justice Press Release, \u0022French Citizen Sentenced for Obstructing a Criminal Investigation into Alleged Bribes Paid to Win Mining Rights in Guinea,\u0022 July 25, 2014, at https:\/\/www.justice.gov\/opa\/pr\/french-citizen-sentenced-obstructing-criminal-investigation-alleged-bribes-paid-win-mining.","Documents":""},{"Case ID":"ST-452","Case Cluster ":"Goodyear Tire \u0026 Rubber Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Angola, Kenya","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"2\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$16,228,065 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$14,122,525 ","Civil Prejudgment Interest (US$) ":"$2,105,540 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, Goodyear Tire \u0026 Rubber Company \u0022failed to prevent or detect more than $3.2 million in bribes during a four-year period due to inadequate FCPA compliance controls at its subsidiaries in sub-Saharan Africa. Bribes were generally paid in cash to employees of private companies or government-owned entities as well as other local authorities such as police or city council officials. The improper payments were falsely recorded as legitimate business expenses in the books and records of the subsidiaries, which were consolidated into Goodyear\u2019s books and records. [ ] \r\n \r\n The SEC\u2019s order finds that Goodyear\u2019s subsidiary in Kenya bribed employees of the Kenya Ports Authority, Armed Forces Canteen Organization, Nzoia Sugar Company, Kenyan Air Force, Ministry of Roads, Ministry of State for Defense, East African Portland Cement Co., and Telkom Kenya Ltd. Goodyear\u2019s subsidiary in Angola bribed employees of the Catoca Diamond Mine, which is owned by a consortium of mining interests including Angola\u2019s national mining company Endiama E.P. and Russian mining company ALROSA. Others bribed in Angola worked at UNICARGAS, Engevia Construction and Public Works, Electric Company of Luanda, National Service of Alfadega, and Sonangol.\u0022 (Source: SEC Press Release, \u0022SEC Charges Goodyear With FCPA Violations,\u0022 February 24, 2015, at https:\/\/www.sec.gov\/news\/pressrelease\/2015-38.html.)","Sources ":"US Securities and Exchange Commission Administrative Proceeding File No. 3-16400, February 24, 2015 at https:\/\/www.sec.gov\/litigation\/admin\/2015\/34-74356.pdf\r\n \r\n SEC Press Release, \u0022SEC Charges Goodyear With FCPA Violations,\u0022 february 24, 2015, at https:\/\/www.sec.gov\/news\/pressrelease\/2015-38.html.)","Documents":""},{"Case ID":"ST-453","Case Cluster ":"Griffiths Energy International","Jurisdiction of Settlement":"Canada","Jurisdiction of Settlement \/ Enforcement Agency":"Crown Prosecution Service","Jurisdiction of Foreign Public Official(s) ":"Chad","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"1\/25","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine; Victims Fund Surcharge","Total Monetary Sanctions (US$)":"$10,340,283 ","Criminal Fine\/Penalty (US$) ":"$8,991,550 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$1,348,733 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$1,348,733 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials, Abuse of Office","Offenses - Settled":"Bribery of Foreign Officials, Abuse of Office","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to an announcement by the Griffiths Energy company, \u0022Griffiths Energy International Inc. (\u0022Griffiths Energy\u0022 or \u0022the Company\u0022) announced today that it reached a settlement and resolution with respect to a previously disclosed charge under section 3(1)(b) of Canada\u0027s Corruption of Foreign Public Officials Act (\u0022CFPOA\u0022).\r\n \r\n As previously disclosed, the matter involved certain contracts entered into by the prior management and Board of Directors of Griffiths Energy during the period between August 30, 2009 and February 9, 2011. Prior management entered into consulting contracts (the \u0022Contracts\u0022) with two entities owned and controlled by a foreign public official and his spouse. At a court hearing on Tuesday the Company entered a guilty plea to the charge before the Court of Queen\u0027s Bench in Calgary, Alberta and agreed to pay a total fine of C$10.35 million. Today the Court accepted the settlement.\r\n \r\n \u0022Griffiths Energy regrets the actions of the prior management and Board. When we discovered the contracts we blew the whistle and cooperated with the authorities because this is how Griffiths Energy\u0027s current management and board conduct business,\u0022 said Gary Guidry, President and Chief Executive Officer. \u0022The negotiated resolution addresses the interests of all stakeholders. Now that the matter is closed, Griffiths Energy can focus all of its attention on oil exploration, development and production in Chad.\u0022\r\n \r\n In November 2011, as previously announced, Griffiths Energy voluntarily disclosed to the appropriate authorities that it had commenced an internal investigation into the Contracts. The exhaustive investigation, supervised by a special committee of independent directors of the Board and conducted by external legal counsel, was concluded in May 2012. At that time Griffiths Energy voluntarily shared the results with appropriate authorities and worked with them to conclude the matter today.\r\n \r\n The Company affirms that no influence was actually obtained as a result of providing the benefits to the foreign public official, and that the award of its Production Sharing Contracts was not in any way connected to the improper promises and benefits indirectly provided to the foreign public official. These proceedings have no impact on the security and veracity of the Company\u0027s significant license area in Chad and the case is now closed.\r\n \r\n Griffiths Energy\u0027s conduct since the discovery of these contracts, and the proactive and responsible steps taken by the current management and Board to immediately self-disclose these issues to law enforcement, were described at length by counsel and were considered by the Court to be significant factors in agreeing to the resolution that was jointly recommended by counsel to the Company and the Crown. The Court also took favourable notice that Griffiths Energy was prepared to self-disclose even though Canada had not yet established policies or protocols governing such voluntary disclosures, and Griffiths Energy received no tangible concessions from the authorities when it self-reported.\u0022 (Source: \u0022Griffiths Energy International Announces Settlement,\u0022 Canada News Wire, January 25, 2013, at http:\/\/www.newswire.ca\/news-releases\/griffiths-energy-international-announces-settlement-511886831.html)","Sources ":"R v. Griffiths Energy International Inc., Court of Queen\u0027s Bench of Alberta, Amended Agreed Statement of Facts, January 4, 2013, at http:\/\/www.millerchevalier.com\/portalresource\/Spring2013_GriffithsAmendedStatmentofFacts; \u0022Griffiths Energy International Announces Settlement,\u0022 Canada News Wire, January 25, 2013, at http:\/\/www.newswire.ca\/news-releases\/griffiths-energy-international-announces-settlement-511886831.html); Paul Michael Blyschak and John W. Boscariol, McCarthy Tetrault, \u0022A Closer Look at the Griffiths Energy Case: Lessons and Insights on Canadian Anti-Corruption Enforcement,\u0022 February 14, 2013, at http:\/\/www.mccarthy.ca\/article_detail.aspx?id=6176","Documents":""},{"Case ID":"ST-454","Case Cluster ":"Hewelett-Packard","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"4\/9","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$2,527,750 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$2,527,750 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"Falsification of Books and Records; Internal Controls Violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, three subsidiaries of the Hewlett-Packard company reached settlements with the agency in 2014. \u0022In Mexico, according to the non-prosecution agreement, HP Mexico falsified corporate books and records and circumvented HP internal controls in connection with contracts to sell hardware, software, and licenses to Mexico\u2019s state-owned petroleum company, Petroleos Mexicanos (Pemex). To secure the contracts, HP Mexico understood that it had to retain a certain third-party consultant with close ties to senior executives of Pemex. HP agreed to pay a $1.41 million \u201ccommission\u201d to the consultant and hid the payments by inserting into the deal structure another third party, which had been approved by HP as a channel partner. HP Mexico made the commission payment to the channel partner, which in turn forwarded the payments to the consultant. Shortly thereafter, the consultant paid one of the Pemex officials approximately $125,000.\u0022 (Source: DOJ Press Release, \u0022Hewlett-Packard Russia Agrees to Plead Guilty to Foreign Bribery,\u0022 April 9, 2014.)","Sources ":"US Department of Justice Nonprosecution Agreement, Re: Hewlett-Packard Mexico, S. de R.L. de C.V. and DOJ Press Release, \u0022Hewlett-Packard Russia Agrees to Plead Guilty to Foreign Bribery,\u0022 both April 9, 2014, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-hewlett-packard-mexico-s-de-rl-de-cv-2014","Documents":""},{"Case ID":"ST-455","Case Cluster ":"Hewlett-Packard","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Mexico, Poland, Russia","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"4\/9","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$31,472,250 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$26,472,250 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$5,000,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022From approximately 2003 to 2010 (the \u201crelevant period\u201d), HP Co.\u2019s indirect, wholly-owned subsidiaries in Russia, Mexico and Poland, by and through their employees, agents and intermediaries, made unlawful payments to various foreign government officials to obtain business. These payments were also falsely recorded in the subsidiaries\u2019 books and records and, ultimately, in HP Co.\u2019s books and records. In Russia, HP Co.\u2019s subsidiary (\u201cHP  Russia\u201d) made payments through HP Russia\u2019s agents to a Russian government official to retain a multi-million dollar contract with the federal prosecutor\u2019s office. The payments were made through shell companies engaged by the agents to perform purported services under the contract. In Poland, certain agents or employees of HP Co.\u2019s Polish subsidiary (\u201cHP Poland\u201d) provided gifts and cash bribes to a Polish government official to obtain contracts with Poland\u2019s national police agency. In Mexico, HP Co.\u2019s Mexican subsidiary (\u201cHP Mexico\u201d) made improper payments to a third party in connection with a sale of software to Mexico\u2019s state-owned petroleum agency. HP Co. and its consolidated subsidiaries (collectively, \u201cHP\u201d) earned approximately $29 million in illicit profits as a result of this improper conduct. \r\n \r\n 2. The payments and improper gifts to government officials made directly or through intermediaries were falsely recorded in the relevant HP subsidiaries\u2019 books and records as legitimate consulting and service contracts, commissions, or travel expenses. In fact, the true purpose of the payments and gifts was to make improper payments to foreign government officials to obtain lucrative government contracts for HP. During the relevant period, HP lacked sufficient internal controls to detect and prevent the improper payments and gifts made by executives and representatives of certain of its foreign subsidiaries.\u0022 As part of the company\u0027s consent to entry of a cease and desist order, it agreed to \u0022pay disgorgement of $29,000,000 and prejudgment interest of $5,000,000 to the United States Treasury. $2,527,750 of Respondent\u2019s disgorgement obligation will be satisfied by Respondent\u2019s payment of $2,527,750 in forfeiture as part of HP Mexico\u2019s resolution with the United States Department of Justice.\u0022 (Source: US Securities and Exchange Commission Administrative Proceeding In the Matter of Hewlett -Packard Company, File No. 3-15832, April 9, 2014)","Sources ":"US Securities and Exchange Commission, \r\n \r\n \u0022SEC Charges Hewlett-Packard With FCPA Violations,\u0022 April 9, 2014, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370541453075","Documents":""},{"Case ID":"ST-456","Case Cluster ":"Hewlett-Packard","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Poland","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"4\/9","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$15,450,224 ","Criminal Fine\/Penalty (US$) ":"$15,450,224 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"Falsification of Books and Records; Internal Controls Violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, three subsidiaries of the Hewlett-Packard company reached settlements with the agency in 2014. Pursuant to a Deferred Prosecution agreement, a criminal information alleging violations of books and records and internal controls provisions of the FCPA was filed against Hewlett-Packard Polska, SP Z.O.O. (HP Poland). According to the Information, HP Poland was charged with violating the accounting provision misconduct during 2006-2010, namely cash bribery payments to a Polish official in order to obtain contracts with the Polish National Police Agency, part of the Polish Ministry of the Interior and Administration. (Source: US v. Hewlett-Packard Polska, SP Z.O.O., Case No. 14-cr-202 (NDCA), Information and Deferred Prosecution Agreement filed April 9, 2014, and US Department of Justice Press Release, \u0022HewlettPackard Russia Agrees to Plead Guilty to Foreign Bribery,\u0022 April 9, 2014.)","Sources ":"US v. Hewlett Packard Polska, SP Z.O.O., Case No. 14-cr-202 (NDCA), Information and Deferred Prosecution Agreement filed April 9, 2014, and US Department of Justice Press Release, \u0022HewlettPackard Russia Agrees to Plead Guilty to Foreign Bribery,\u0022 April 9, 2014, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-hewlett-packard-polska-sp-z-oocourt-docket-number-cr-14-202-ejd.","Documents":""},{"Case ID":"ST-457","Case Cluster ":"Hewlett-Packard","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Russia","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"4\/9","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$58,772,250 ","Criminal Fine\/Penalty (US$) ":"$58,772,250 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, the Russian subsidiary of the Hewlett-Packard company pleaded guilty to violation of FCPA charges: \u0022According to curt documents, in 1999, the Russian government announced a project to automate the computer and telecommunications infrastructure of its Office of the Prosecutor General of the Russian Federation (GPO). Not only was that project itself worth more than $100 million, but HP Russia viewed it as the \u201cgolden key\u201d that could unlock the door to another $100 to $150 million dollars in business with Russian government agencies. To secure a contract for the first phase of project, ultimately valued at more than \u20ac 35 million, HP Russia executives and other employees structured the deal to create a secret slush fund totaling several million dollars, at least part of which was intended for bribes to Russian government officials.\r\n \r\n As admitted in a statement of facts, HP Russia created excess profit margins for the slush fund through an elaborate buyback\r\n deal structure, whereby (1) HP sold the computer hardware and other technology products called for under the contract to a Russian channel partner, (2) HP bought the same products back from an intermediary company at a nearly \u20ac8 million markup and paid the intermediary an additional \u20ac4.2 million for purported services, and (3) HP sold the same products to the GPO at the increased price. The payments to the intermediary were then largely transferred through a cascading series of shell companies \u2013 some of which were directly associated with government officials \u2013 registered in the United States, United Kingdom, British Virgin Islands and Belize. Much of these payments from the intermediary were laundered through offshore bank accounts in Switzerland, Lithuania, Latvia and Austria. Portions of the funds were spent on travel, cars, jewelry, clothing, expensive watches, swimming pool technology, furniture, household appliances and other luxury goods. To keep track of these corrupt payments, the conspirators inside HP Russia kept two sets of books: secret spreadsheets that detailed the categories of recipients of the corrupt funds and sanitized versions that hid the corrupt payments from others outside of HP Russia. They also entered into offthebooks side agreements. As one example, an HP Russia executive executed a letter agreement to pay \u20ac2.8 million in purported \u201ccommission\u201d fees to a U.K.registered shell company, which was linked to a director of the Russian government agency responsible for managing the GPO project. HP Russia never disclosed the existence of the agreement to internal or external auditors or management outside of HP Russia and conducted no due diligence of the shell company.\u0022 (Source: US Department of Justice Press Release, \u0022HewlettPackard Russia Agrees to Plead Guilty to Foreign Bribery,\u0022 April 4, 2014.)","Sources ":"US v. ZAO Hewlett-Packard A.O., Case No. 14-cr-201 (NDCA), Information and Plea Agreement filed April 9, 2014, and US Department of Justice Press Release, \u0022HewlettPackard Russia Agrees to Plead Guilty to Foreign Bribery,\u0022 April 9, 2014, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-zao-hewlett-packard-aocourt-docket-number-cr-14-201-dlj","Documents":""},{"Case ID":"ST-458","Case Cluster ":"Hitachi Ltd.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"South Africa","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"9\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$19,000,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$19,000,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records, Internal Controls Violation","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, in September 2015, the agency \u0022charged Tokyo-based conglomerate Hitachi, Ltd. with violating the Foreign Corrupt Practices Act (FCPA) when it inaccurately recorded improper payments to South Africa\u2019s ruling political party in connection with contracts to build two multi-billion dollar power plants. Hitachi has agreed to pay $19 million to settle the SEC charges.\r\n \r\n The SEC alleges that Hitachi sold a 25-percent stake in a South African subsidiary to a company serving as a front for the African National Congress (ANC). This arrangement gave the front company and the ANC the ability to share in the profits from any power station contracts that Hitachi secured. Hitachi was ultimately awarded two contracts to build power stations in South Africa and paid the ANC\u2019s front company approximately $5 million in \u201cdividends\u201d based on profits derived from the contracts. Through a separate, undisclosed arrangement, Hitachi paid the front company an additional $1 million in \u201csuccess fees\u201d that were inaccurately booked as consulting fees without appropriate documentation. [ ] \r\n \r\n Hitachi was aware that Chancellor House Holdings (Pty) Ltd. was a funding vehicle for the ANC during the bidding process. \r\n Hitachi nevertheless continued to partner with Chancellor and encourage the company to use its political influence to help obtain government contracts from Eskom Holdings SOC Ltd., a public utility owned and operated by the South African government.\r\n \r\n Hitachi paid \u201csuccess fees\u201d to Chancellor for its exertion of influence during the Eskom tender process pursuant to a separate, unsigned side-arrangement.\u0022 (Source: SEC Press Release, \u0022SEC Charges Hitachi With FCPA Violations,\u0022 September 28, 2015.)","Sources ":"US Securities and Exchange Commission v. Hitachi Ltd., Case No. 1:15-cv-1573 (DDC), Complaint filed September 28, 2015, at https:\/\/www.sec.gov\/litigation\/complaints\/2015\/comp-pr2015-212.pdf;\r\n \r\n SEC Press Release, \u0022SEC Charges Hitachi With FCPA Violations,\u0022 September 28, 2015, at https:\/\/www.sec.gov\/news\/pressrelease\/2015-212.html","Documents":""},{"Case ID":"ST-459","Case Cluster ":"IAP Worldwide Services Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Kuwait","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"6\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022A Florida defense and government contracting company, IAP Worldwide Services Inc. (IAP), entered into a nonprosecution agreement and agreed to pay a $7.1 million penalty to resolve the government\u2019s investigation into whether the company conspired to bribe Kuwaiti officials in order to secure a government contract. [James M. Rama, a] former vice president of IAP also pleaded guilty today to conspiracy to violate the Foreign Corrupt Practices Act (FCPA) for his involvement in the bribery scheme. [ ] In 2004, Kuwait\u2019s Ministry of the Interior (MOI) initiated the Kuwait Security Program (KSP), a project that was intended to provide nationwide surveillance capabilities for several Kuwaiti government agencies primarily through the use of closed circuit television. The project was divided into two phases: a planning and feasibility period called \u201cPhase I\u201d and an installation period called \u201cPhase II.\u201d The MOI was responsible for overseeing the KSP, including selecting contractors to facilitate its implementation. Revenues from the Phase II contract were expected to be substantially greater than from Phase I.\r\n \r\n According to admissions made in connection with both the nonprosecution agreement and Rama\u2019s plea agreement, IAP and Rama schemed to ensure that IAP worked as the consultant for Phase I so that it could tailor the requirements for the Phase II contracts to IAP\u2019s strengths, which would give the company an advantage in the Phase II bidding. To that end, both IAP and Rama admitted that in February 2006, executives and senior employees of IAP, including Rama, set up a shell company called \u201cRamaco\u201d to bid on Phase I, in part to conceal IAP\u2019s role in crafting the Phase II requirements and its conflict of interest in connection with securing the Phase II contract.\r\n \r\n Ultimately, Ramaco secured the Phase I contract for approximately $4 million. According to admissions made in connection with both agreements, the Rama and IAP agreed that half of that amount would be diverted to a consultant who would pay bribes to Kuwaiti government officials to assist IAP in obtaining and retaining the Phase I contract and to obtain the Phase II contract. IAP and Rama admitted that they disguised the payments by transferring funds Ramaco received to an IAP bank account and then to the consultant through a series of accounts and intermediaries. According to the factual statements incorporated into both the nonprosecution agreement and Rama\u2019s plea agreement, between September 2006 and March 2008, IAP and its coconspirators paid the consultant approximately $1,783,688 understanding that some or all of the funds would be used to bribe Kuwaiti government officials.\u0022 (Source: DOJ Press Release, \u0022IAP Worldwide Services Inc. Resolves Foreign Corrupt Practices Act investigation,\u0022 June 16, 2015.)\r\n \r\n According to the Nonprosecution Agreement, the company agreed to pay the monetary penalty in the present value amount of $7,100,000 to the United States Treasury over a period of three years. (Source: Nonprosecution Agreement of June 15, 2015). Mr. Rama was sentenced to four months\u0027 imprisonment and no monetary sanctions were imposed, given his financial and personal circumstances and that it was his first offense. (Source: US v. Rama, Case No. 15-cr-143(EDVA), Judgment October 15, 2015 and Position of the United States with respect Sentencing, filed October 2, 2015.)","Sources ":"Nonprosecution Agreement by IAP Worldwide Services Inc. and DOJ Press Release, \u0022IAP Worldwide Services Inc. Resolves Foreign Corrupt Practices Act investigation,\u0022 June 16, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/iap; US v. James M. Rama, Case No. 15-cr-143 (EDVA), Information filed June 15, 2015, Plea Agreement and Statement of Facts, at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/james-rama; Judgment October 15, 2015 and Position of the United States with respect Sentencing, filed October 2, 2015, both accessed via PACER.","Documents":""},{"Case ID":"ST-460","Case Cluster ":"IAP Worldwide Services Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Kuwait","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"6\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Ciminal Penalty","Total Monetary Sanctions (US$)":"$7,100,000 ","Criminal Fine\/Penalty (US$) ":"$7,100,000 ","Criminal Fine \/ Penalty (Explanation)":"$0 ","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"NA","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022A Florida defense and government contracting company, IAP Worldwide Services Inc. (IAP), entered into a nonprosecution agreement and agreed to pay a $7.1 million penalty to resolve the government\u2019s investigation into whether the company conspired to bribe Kuwaiti officials in order to secure a government contract. [James M. Rama, a] former vice president of IAP also pleaded guilty today to conspiracy to violate the Foreign Corrupt Practices Act (FCPA) for his involvement in the bribery scheme. [ ] In 2004, Kuwait\u2019s Ministry of the Interior (MOI) initiated the Kuwait Security Program (KSP), a project that was intended to provide nationwide surveillance capabilities for several Kuwaiti government agencies primarily through the use of closed circuit television. The project was divided into two phases: a planning and feasibility period called \u201cPhase I\u201d and an installation period called \u201cPhase II.\u201d The MOI was responsible for overseeing the KSP, including selecting contractors to facilitate its implementation. Revenues from the Phase II contract were expected to be substantially greater than from Phase I.\r\n \r\n According to admissions made in connection with both the nonprosecution agreement and Rama\u2019s plea agreement, IAP and Rama schemed to ensure that IAP worked as the consultant for Phase I so that it could tailor the requirements for the Phase II contracts to IAP\u2019s strengths, which would give the company an advantage in the Phase II bidding. To that end, both IAP and Rama admitted that in February 2006, executives and senior employees of IAP, including Rama, set up a shell company called \u201cRamaco\u201d to bid on Phase I, in part to conceal IAP\u2019s role in crafting the Phase II requirements and its conflict of interest in connection with securing the Phase II contract.\r\n \r\n Ultimately, Ramaco secured the Phase I contract for approximately $4 million. According to admissions made in connection with both agreements, the Rama and IAP agreed that half of that amount would be diverted to a consultant who would pay bribes to Kuwaiti government officials to assist IAP in obtaining and retaining the Phase I contract and to obtain the Phase II contract. IAP and Rama admitted that they disguised the payments by transferring funds Ramaco received to an IAP bank account and then to the consultant through a series of accounts and intermediaries. According to the factual statements incorporated into both the nonprosecution agreement and Rama\u2019s plea agreement, between September 2006 and March 2008, IAP and its coconspirators paid the consultant approximately $1,783,688 understanding that some or all of the funds would be used to bribe Kuwaiti government officials.\u0022 (Source: DOJ Press Release, \u0022IAP Worldwide Services Inc. Resolves Foreign Corrupt Practices Act investigation,\u0022 June 16, 2015.)\r\n \r\n According to the Nonprosecution Agreement, the company agreed to pay the monetary penalty in the present value amount of $7,100,000 to the United States Treasury over a period of three years. (Source: Nonprosecution Agreement of June 15, 2015).","Sources ":"Nonprosecution Agreement by IAP Worldwide Services Inc. and DOJ Press Release, \u0022IAP Worldwide Services Inc. Resolves Foreign Corrupt Practices Act investigation,\u0022 June 16, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/iap","Documents":""},{"Case ID":"ST-461","Case Cluster ":"Ignacio Cueto Plaza","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/4","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$75,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$75,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No","Summary":"According to the US Securities and Exchange Commission Administrative Summary, \u0022An SEC investigation found that Ignacio Cueto Plaza, who was serving as president and chief operating officer at the time, authorized a sham consulting agreement and the company wired $1.15 million in payments to the consultant\u2019s Virginia-based brokerage account. The unsigned agreement falsely stated that the consultant would undertake a study of existing air routes in Argentina. Cueto knew no such study would be performed and the consultant instead agreed to help settle the labor dispute, and Cueto also nderstood it was possible that the consultant would pass a portion of the payments along to union officials in Argentina. Cueto pproved the payments to get the unions to abandon their threats to enforce the single-function rule and to get them to accept a wage increase lower than the amount asked for in negotiations.\u0022 (Source: US SEC Administrative Summary, \u0022Airline Executive Settles FCPA Charges,\u0022 February 4, 2016.)","Sources ":"US SEC Administrative Proceeding File No. 3-17100, In the Matter of Ignacio Cueto Plaza, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77057.pdf; Summary, \u0022Airline Executive Settles FCPA Charges,\u0022 February 4, 2016, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77057-s.pdf.","Documents":""},{"Case ID":"ST-462","Case Cluster ":"Innospec","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Indonesia, Iraq","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"8\/4","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Legal Costs","Total Monetary Sanctions (US$)":"$16,818 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$16,818 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office, \u0022Four men were today sentenced for their roles in bribing state officials in Indonesia and Iraq, following a Serious Fraud Office investigation into Associated Octel Corporation (subsequently renamed Innospec).\r\n \r\n Dennis Kerrison, 69, of Chertsey, Surrey, was sentenced to 4 years in prison.\r\n Paul Jennings, 57, of Neston, Cheshire, was sentenced to 2 years in prison.\r\n Miltiades Papachristos, 51 of Thessaloniki, Greece, was sentenced to 18 months in prison.\r\n David Turner, 59, of Newmarket, Suffolk, was sentenced to a 16 month suspended sentence with 300\r\n hours unpaid work \r\n \r\n Mr Kerrison and Dr Papachristos were convicted of conspiracy to commit corruption in June 2014 in relation to Indonesia only. Mr Jennings pleaded guilty in June 2012 to two charges of conspiracy to commit corruption and in July 2012 to a further charge of conspiracy to commit corruption in relation to Indonesia and Iraq. Dr Turner pleaded guilty to three charges of conspiracy to commit corruption in January 2012 in relation to Indonesia and Iraq. [ ]\r\n \r\n Upon sentencing the defendants, HHJ Goymer said:\r\n \r\n \u201cCorruption in this company was endemic, institutionalised and ingrained\u2026 but despite being a separate legal entity it is not an automated machine\u037e decisions are made by human minds. [ ]\r\n \r\n Innospec itself pleaded guilty in March 2010 to bribing state officials in Indonesia and was fined $12.7 million in England with additional penalties being imposed in the USA. Dr Turner was also ordered to pay \u00a310,000 towards prosecution costs and Mr Jennings was ordered to pay \u00a35000 towards these costs. Dr Turner and Mr Jennings have already been subject to disgorgement pay \u00a35000 towards these costs. Dr Turner and Mr Jennings have already been subject to disgorgement of benefit by the US Securities and Exchange Commission. The matter of costs for Mr Kerrison and Dr Papachristos has been adjourned pending the hearing of confiscation proceedings against them.\u0022 (Source: UK Serious Fraud Office Press Reease, \u0022Four sentenced for role in Innospec corruption,\u0022 August 4, 2014.)","Sources ":"UK Serious Fraud Office Press Release, \u0022Four sentenced for role in Innospec corruption,\u0022 August 4, 2014, at https:\/\/www.sfo.gov.uk\/2014\/08\/04\/four-sentenced-role-innospec-corruption\/.","Documents":""},{"Case ID":"ST-463","Case Cluster ":"Innospec","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Indonesia, Iraq","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"8\/4","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Legal Costs","Total Monetary Sanctions (US$)":"$8,409 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$8,409 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office, \u0022Four men were today sentenced for their roles in bribing state officials in Indonesia and Iraq, following a Serious Fraud Office investigation into Associated Octel Corporation (subsequently renamed Innospec).\r\n \r\n Dennis Kerrison, 69, of Chertsey, Surrey, was sentenced to 4 years in prison.\r\n Paul Jennings, 57, of Neston, Cheshire, was sentenced to 2 years in prison.\r\n Miltiades Papachristos, 51 of Thessaloniki, Greece, was sentenced to 18 months in prison.\r\n David Turner, 59, of Newmarket, Suffolk, was sentenced to a 16 month suspended sentence with 300\r\n hours unpaid work \r\n \r\n Mr Kerrison and Dr Papachristos were convicted of conspiracy to commit corruption in June 2014 in relation to Indonesia only. Mr Jennings pleaded guilty in June 2012 to two charges of conspiracy to commit corruption and in July 2012 to a further charge of conspiracy to commit corruption in relation to Indonesia and Iraq. Dr Turner pleaded guilty to three charges of conspiracy to commit corruption in January 2012 in relation to Indonesia and Iraq. [ ]\r\n \r\n Upon sentencing the defendants, HHJ Goymer said:\r\n \r\n \u201cCorruption in this company was endemic, institutionalised and ingrained\u2026 but despite being a separate legal entity it is not an automated machine\u037e decisions are made by human minds. [ ]\r\n \r\n Innospec itself pleaded guilty in March 2010 to bribing state officials in Indonesia and was fined $12.7 million in England with additional penalties being imposed in the USA. Dr Turner was also ordered to pay \u00a310,000 towards prosecution costs and Mr Jennings was ordered to pay \u00a35000 towards these costs. Dr Turner and Mr Jennings have already been subject to disgorgement pay \u00a35000 towards these costs. Dr Turner and Mr Jennings have already been subject to disgorgement of benefit by the US Securities and Exchange Commission. The matter of costs for Mr Kerrison and Dr Papachristos has been adjourned pending the hearing of confiscation proceedings against them.\u0022 (Source: UK Serious Fraud Office Press Reease, \u0022Four sentenced for role in Innospec corruption,\u0022 August 4, 2014.)","Sources ":"UK Serious Fraud Office Press Release, \u0022Four sentenced for role in Innospec corruption,\u0022 August 4, 2014, at https:\/\/www.sfo.gov.uk\/2014\/08\/04\/four-sentenced-role-innospec-corruption\/.","Documents":""},{"Case ID":"ST-464","Case Cluster ":"JLT Specialty Limited","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Financial Conduct Authority","Jurisdiction of Foreign Public Official(s) ":"Cameroon, China, Ecuador, Egypt, Gabon, Nigeria, Sudan, Unspecified West African countries","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"12\/19","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Final Notice","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$3,063,080 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$3,063,080 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Lack of Bribery Controls","Offenses - Settled":"Lack of Bribery Controls","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Financial Conduct Authority\u0027s Final Notice, JLT Specialty Limited \u0022provides insurance broking, risk management and claims consulting services to a wide range of national and international corporate clients. \r\n \r\n 2.2. The Authority has found that JLTSL breached Principle 3 by failing to take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems and controls for countering the risks of bribery and corruption associated with making payments to overseas third parties that helped JLTSL win and retain business from overseas clients (\u201cOverseas Introducers\u201d) in that: \r\n (1) during the whole of the Relevant Period, JLTSL failed to conduct adequate due diligence before entering into a relationship with an Overseas Introducer. In particular JLTSL did not take adequate steps to assess whether the Overseas Introducer was connected with the clients it introduced and\/or any public officials; \r\n (2) during the whole of the Relevant Period, JLTSL failed adequately to assess the risk associated with each piece of new insurance business introduced by an Overseas Introducer, which meant that JLTSL could not ensure that it took sufficient steps to counter the risk of bribery and corruption prior to making payments to Overseas Introducers; and \r\n (3) during the period 7 June 2011 to 9 May 2012 (\u201cthe Alarm Bells Period\u201d), JLTSL failed adequately to implement its own anti-bribery and corruption policies, which resulted in the risk of JLTSL entering into higher risk relationships with Overseas Introducers without sufficient senior management oversight and approval. Moreover, JLTSL failed to carry out adequate checks, which would have enabled it to identify that its policies were not being implemented correctly. \r\n 2.3. The Authority has found no evidence to suggest that JLTSL has permitted any illicit payment or inducement to any Overseas Introducer during the Relevant Period, nor that JLT intended to permit any illicit payment or inducement to any Overseas Introducer during the Relevant Period.\u0022 (Source: UK FCA Final Notice, File Reference Number 310428, December 19, 2013.)","Sources ":"UK Financial Conduct Authority, Final Notice to JLT Specialty Limited, Firm Reference Number 310428, December 19, 2013.","Documents":""},{"Case ID":"ST-465","Case Cluster ":"Keyuan Petrochemicals, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"2\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$1,000,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$1,000,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations; Violation of Anti-Fraud and Reporting provisions","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No","Summary":"According to the US Securities and Exchange Commission, \u0022Keyuan Petrochemicals, Inc., a China-based issuer formed through a reverse merger in April 2010, with violations of the anti-fraud, reporting, books and records, and internal control provisions of the federal securities laws. The SEC further charged Aichun Li, Keyuan\u2019s former Chief Financial Officer, with aiding and abetting Keyuan\u2019s reporting and books and records violations and for failing to implement internal accounting controls. Keyuan and Li have agreed to settle the SEC\u2019s claims against them.\r\n \r\n According to the SEC\u2019s complaint, between May 2010 and January 2011, in what was its first year as a U.S. public company, Keyuan systematically failed to disclose in its SEC filings numerous material related party transactions, as required by U.S. Generally Accepted Accounting Principles (\u201cGAAP\u201d) and Commission rules and regulations. The related parties included the company\u2019s three founding and controlling shareholders, including its current Chief Executive Officer, entities controlled by or affiliated with these persons, and entities controlled by Keyuan\u2019s management or their family members. The related party transactions included sales of products, purchases of raw materials, loan guarantees, and short term financing.\r\n \r\n Keyuan also operated an off-balance sheet cash account that was kept off the company\u2019s books by the former Vice President of Accounting. The account was used to pay for various items, including cash bonuses for senior officers and reimbursements to the CEO for business expenses, including travel, entertainment, and rent for an apartment. The account was also used to fund gifts\u2014both cash and non-cash\u2014 for Chinese government officials. By failing to properly record these transactions on the company\u2019s books and records, the company misstated its reported balances in its financial statements filed with the Commission.\r\n \r\n The SEC further alleges that Keyuan\u2019s then-CFO Aichun Li, a resident of North Carolina, played a role in the company\u2019s failure to disclose the related party transactions. Li was hired to ensure the company\u2019s compliance with U.S. accounting and financial reporting regulations, and she received information and encountered red flags that should have indicated that the company was not properly identifying or disclosing related party transactions. Despite such knowledge, Li signed Keyuan\u2019s registration statements and quarterly reports that failed to disclose material related party transactions.\u0022 (Source: SEC Litigation Release, \u0022Securities and Exchange Commission v. Keyuan Petrochemicals, Inc. and Aichun Li, Civil Action No. 13-cv-263 (D.D.C.), February 28, 2013.)","Sources ":"US Securities and Exchange Commission v. Keyuan Petrochemicals, Inc. and Aichun Li, Civil Action No. 13-cv-263 (D.D.C.), Complaint filed on February 28, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-30.pdf; and Litigation Release at https:\/\/www.sec.gov\/litigation\/litreleases\/2013\/lr22627.htm","Documents":""},{"Case ID":"ST-466","Case Cluster ":"Keyuan Petrochemicals, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"2\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$25,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$25,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No","Summary":"According to the US Securities and Exchange Commission, \u0022Keyuan Petrochemicals, Inc., a China-based issuer formed through a reverse merger in April 2010, with violations of the anti-fraud, reporting, books and records, and internal control provisions of the federal securities laws. The SEC further charged Aichun Li, Keyuan\u2019s former Chief Financial Officer, with aiding and abetting Keyuan\u2019s reporting and books and records violations and for failing to implement internal accounting controls. Keyuan and Li have agreed to settle the SEC\u2019s claims against them.\r\n \r\n According to the SEC\u2019s complaint, between May 2010 and January 2011, in what was its first year as a U.S. public company, Keyuan systematically\r\n failed to disclose in its SEC filings numerous material related party transactions, as required by U.S. Generally Accepted Accounting Principles\r\n (\u201cGAAP\u201d) and Commission rules and regulations. The related parties included the company\u2019s three founding and controlling shareholders,\r\n including its current Chief Executive Officer, entities controlled by or affiliated with these persons, and entities controlled by Keyuan\u2019s management or their family members. The related party transactions included sales of products, purchases of raw materials, loan guarantees, and short term financing.\r\n \r\n Keyuan also operated an off-balance sheet cash account that was kept off the company\u2019s books by the former Vice President of Accounting. The\r\n account was used to pay for various items, including cash bonuses for senior officers and reimbursements to the CEO for business expenses,\r\n including travel, entertainment, and rent for an apartment. The account was also used to fund gifts\u2014both cash and non-cash\u2014 for Chinese\r\n government officials. By failing to properly record these transactions on the company\u2019s books and records, the company misstated its reported balances in its financial statements filed with the Commission.\r\n \r\n The SEC further alleges that Keyuan\u2019s then-CFO Aichun Li, a resident of North Carolina, played a role in the company\u2019s failure to disclose the related\r\n party transactions. Li was hired to ensure the company\u2019s compliance with U.S. accounting and financial reporting regulations, and she received\r\n information and encountered red flags that should have indicated that the company was not properly identifying or disclosing related party transactions. Despite such knowledge, Li signed Keyuan\u2019s registration statements and quarterly reports that failed to disclose material related party transactions.\u0022 (Source: SEC Litigation Release, \u0022Securities and Exchange Commission v. Keyuan Petrochemicals, Inc. and Aichun Li, Civil Action No. 13-cv-263 (D.D.C.), February 28, 2013.)","Sources ":"US Securities and Exchange Commission v. Keyuan Petrochemicals, Inc. and Aichun Li, Civil Action No. 13-cv-263 (D.D.C.), Complaint filed on February 28, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-30.pdf; and Litigation Release at https:\/\/www.sec.gov\/litigation\/litreleases\/2013\/lr22627.htm","Documents":""},{"Case ID":"ST-467","Case Cluster ":"Koninklijke Philips Electronics","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Poland","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"4\/5","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$4,515,178 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$3,120,597 ","Civil Prejudgment Interest (US$) ":"$1,394,581 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, from at least 1999 through 2007, employees of Philips\u2019s Polish subsidiary, Philips Polska sp. z o.o. (\u201cPhilips Poland\u201d) made improper payments to healthcare officials in Poland regarding public tenders proffered by Polish healthcare facilities to purchase medical equipment. According to the Cease and Desist Order, \u0022Since at least 1999, Philips has participated in public tenders to sell medical equipment to Polish healthcare facilities. From 1999 through 2007, in at least 30 transactions, employees of Philips Poland made improper payments to public officials of Polish healthcare facilities to increase the likelihood that public tenders for the sale of medical equipment would be awarded to Philips.\r\n \r\n 4. Representatives of Philips Poland entered into arrangements with officials of various Polish healthcare facilities whereby Philips submitted the technical specifications of its medical equipment to officials drafting the tenders who incorporated the specifications of Philips\u2019 equipment into the contracts. Incorporating the specifications of Philips\u2019 equipment in the tenders\u2019\r\n requirements greatly increased the likelihood that Philips would be awarded the bids.\r\n \r\n 5. Certain of the healthcare officials involved in the arrangements with Philips also decided whom to award the tenders, and when Philips was awarded the contracts, the officials were paid the improper payments by employees of Philips Poland.\r\n \r\n 6. The improper payments made by employees of Philips Poland to the Polish healthcare officials usually amounted to 3% to 8% of the contracts\u2019 net value. [ ]\r\n \r\n 7. At times, Philips Poland employees also kept a portion of the improper payments as a \u201ccommission.\u201d The Philips Poland employees involved in the improper payments often utilized a third party agent to assist with the improper arrangements and payments to Polish healthcare officials.\u0022 The SEC did not impose a civil penalty, in light of the company\u0027s cooperation in the investigation. (Source: Administrative Proceeding File No. 3-15265, In the Matter of Koninklijke Philips Electronics NV, April 5, 2013).","Sources ":"US SEC Administrative Proceeding File No. 3-15265, In the Matter of Koninklijke Philips Electronics NV, April 5, 2013, at https:\/\/www.sec.gov\/litigation\/admin\/2013\/34-69327.pdf;","Documents":""},{"Case ID":"ST-468","Case Cluster ":"Las Vegas Sands Corp.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China (including Macao SAR)","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"4\/7","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$9,000,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$9,000,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"Falsification of Books and Records, Internal Controls Violations","Public Procurement Contract \/ SOE Involved?":"No","Summary":"According to the US Securities and Exchange Commission, \u0022Las Vegas Sands Corp. has agreed to pay a $9 million penalty to settle charges that it violated the Foreign Corrupt Practices Act (FCPA) by failing to properly authorize or document millions of dollars in payments to a consultant facilitating business activities in China and Macao.\r\n \r\n An SEC investigation found that LVS kept inaccurate books and records and frequently lacked supporting documentation or proper approvals for more than $62 million in payments to a consultant in Asia. The consultant acted as an intermediary to obscure the company\u2019s role in certain business transactions such as the purchases of a basketball team and a building in China, where casino gambling isn\u2019t permitted. At one point, LVS could not account for more than $700,000 transferred to the consultant for team expenses, yet continued to transfer millions of dollars to him. A portion of the payments were improperly recorded in company books and records, such as money supposedly spent on artwork for the building when none was actually purchased. [ ] \r\n  \r\n According to the SEC\u2019s order instituting a settled administrative proceeding:\r\n \r\n LVS transferred $6 million to a consultant internally referred to as a \u201cbeard\u201d to buy a team to play in the Chinese Basketball Association, which did not permit gaming companies to own a team. The company transferred an additional $8 million to the consultant to cover the costs of operating the team without any documentation of those costs.\r\n \r\n LVS used the same consultant as a beard to purchase a building in Beijing from a Chinese state-owned-entity, ostensibly to develop a business center for U.S. companies seeking to do business in China. Despite concerns by some employees that the real estate purchase was solely for political purposes, approximately $43 million in payments were made to the consultant without research, analysis, or proper approval by any LVS employee authorized to approve the amounts paid. \r\n \r\n Approximately $900,000 paid to an entity controlled by the consultant was recorded in company books and records as \u201cproperty management fees\u201d when no property management services were actually performed. Approximately $1.4 million was recorded as \u201carts and crafts\u201d when the entity never actually obtained any artwork for the building.\r\n LVS failed to prevent employees from circumventing policies and procedures for purchases, reimbursements to outside counsel, and comps to customers. For example, one employee obtained a cash advance of $28,000 and a cash reimbursement of $86,000 without proper authorization. An outside counsel requested reimbursement of $25,000 for expenses incurred on a business trip but provided no documentation, and later admitted that he actually requested the funds for a friend. In its casinos in Macao, LVS employees did not track which customers received comps to ensure they weren\u2019t providing improper gifts to government officials.\u0022 (Source: SEC Press Release, \u0022Las Vegas Sands Paying Penalty for FCPA Violations,\u0022 April 7, 2016.)","Sources ":"US Securities and Exchange Commission, In the Matter of Las Vegas Sands Corp., Administrative Proceeding File No. 3-17204, April 7, 2016, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77555.pdf; Press Release, \u0022Las Vegas Sands Paying Penalty for FCPA Violations,\u0022 April 7, 2016, at https:\/\/www.sec.gov\/news\/pressrelease\/2016-64.html.","Documents":""},{"Case ID":"ST-469","Case Cluster ":"Layne Christensen Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Burkina Faso, Democratic Republic of Congo, Guinea, Mali, Tanzania","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"10\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$5,127,193 ","Criminal Fine\/Penalty (US$) ":"NA","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"NA","Criminal Restitution \/ Reparation (US$)":"NA","Criminal Legal \/ Procedural Costs (US$)":"NA","Civil Disgorgement of Profits (US$) ":"$3,893,472.42 ","Civil Prejudgment Interest (US$) ":"$858,720.68 ","Civil Fine \/ Penalty (US$)":"$375,000 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art. 16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign public officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs, Tax, Permits)","Summary":"According to the US Securities and Exchange Commission, Layne Christen Co, \u0022a global water management, construction, and drilling company headquartered in Texas was charged with violating the Foreign Corrupt Practices Act (FCPA) by making improper payments to foreign officials in several African countries in order to obtain beneficial treatment and reduce its tax liability. [ ] \n \n  According to the SEC\u2019s order instituting settled administrative proceedings, Layne\u2019s misconduct occurred from 2005 to 2010. In addition to favorable tax treatment, the improper payments helped the company obtain customs clearance, work permits, and relief from inspections by immigration and labor officials in various African countries. \n \n Among the findings in the SEC\u2019s order:\n \n Layne paid nearly $800,000 to foreign officials in Mali, Guinea, and the Democratic Republic of the Congo (DRC) to reduce its tax liability and avoid associated penalties for delinquent payment. The bribes enabled Layne to realize more than $3.2 million in improper tax savings. \n \n Layne made improper payments to customs officials in Burkina Faso and the DRC to avoid paying customs duties and obtain clearance to import and export its equipment. The bribes were falsely recorded as legal fees and commissions in the company\u2019s books and records.\n \n Layne paid more than $23,000 in cash to police, border patrol, immigration officials, and labor inspectors in Burkina Faso, Guinea, Tanzania, and the DRC to obtain border entry for its equipment and employees. The bribes also helped secure work permits for its expatriate employees and avoid penalties for non-compliance with local immigration and labor regulations.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Texas-Based Layne Christensen Company With FCPA Violations,\u0022 October 27, 2014.)","Sources ":"US SEC Administrative Proceeding File No. 3-16216, In the Matter of Layne Christensen, October 24, 2014, at\n https:\/\/www.sec.gov\/litigation\/admin\/2014\/34-73437.pdf; SEC Press Release, \u0022SEC Charges Texas-Based Layne Christensen Company With FCPA Violations,\u0022 October 27, 2014., at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370543291857","Documents":""},{"Case ID":"ST-470","Case Cluster ":"Maxwell Technologies, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"1\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$8,000,000 ","Criminal Fine\/Penalty (US$) ":"$8,000,000 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Books and Records violation","Offenses - Settled":"Bribery of Foreign Officials; Books and Records violation","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Maxwell Technologies Inc., a publicly-traded manufacturer of energy-storage and power-delivery products based in San Diego, has agreed to pay an $8 million criminal penalty to resolve charges related to the Foreign Corrupt Practices Act (FCPA) for bribing Chinese government officials to secure sales of Maxwell\u2019s products to state-owned manufacturers of electric-utility infrastructure in several Chinese provinces. [ ]\r\n \r\n The department filed a deferred prosecution agreement and a criminal information against Maxwell in U.S. District Court for the Southern District of California today. The two-count information charges Maxwell with one count of violating the FCPA\u2019s anti-bribery provisions and one count of violating the FCPA\u2019s books-and-records provisions.\r\n \r\n According to court documents, Maxwell\u2019s wholly-owned Swiss subsidiary, Maxwell S.A., engaged a Chinese agent to sell Maxwell\u2019s products in China. From at least July 2002 through May 2009, Maxwell S.A. paid more than $2.5 million to its Chinese agent to secure contracts with Chinese customers, including contracts for the sale of Maxwell\u2019s high-voltage capacitor products to state-owned manufacturers of electrical-utility infrastructure. The agent in turn used Maxwell S.A.\u2019s money to bribe officials at the state-owned entities in connection with the sales contracts. Maxwell S.A. paid its Chinese agent approximately $165,000 in 2002 and increased the payments to the agent to $1.1 million in 2008. In its books and records, Maxwell mischaracterized the bribes as sales-commission expenses. According to court documents, Maxwell\u2019s U.S. management discovered the bribery scheme in late 2002.\u0022 (Source: US Department of Justice Press Release, \u0022Maxwell Technologies Inc. Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $8 Million Criminal Penalty,\u0022 January 31, 2011.)","Sources ":"US v. Maxwell Technologies, Inc., Case No, 11-cr-329 (SDCA), Information and Deferred Prosecution Agreement filed January 31, 2011; Department of Justice Press Release, \u0022Maxwell Technologies Inc. Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $8 Million Criminal Penalty,\u0022 January 31, 2011, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-maxwell-technologies-inc-court-docket-number11-cr-329-jm","Documents":""},{"Case ID":"ST-471","Case Cluster ":"Mead Johnson Nutrition","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"7\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits; Prejudgment Interest; Civil Penalty","Total Monetary Sanctions (US$)":"$12,030,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$7,770,000 ","Civil Prejudgment Interest (US$) ":"$1,260,000 ","Civil Fine \/ Penalty (US$)":"$3,000,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, the \u0022Mead Johnson Nutrition Company has agreed to settle charges that its Chinese subsidiary made improper payments to health care professionals at government-owned hospitals to recommend the company\u2019s infant formula to patients who were new or expectant mothers. [  ] \r\n \r\n An SEC investigation found that employees funded the improper payments through \u0027distributor allowance\u0027 funds paid to third-party distributors who market, sell, and distribute the company\u2019s products in China. Although the funds contractually belonged to the distributors, employees exercised some control over how the money was spent and provided specific guidance to distributors on how to use the funds. Cash and other incentives were subsequently paid to health care professionals in China hospitals to recommend Mead Johnson Nutrition products and provide the company with contact information for patients who were new or expectant mothers so it could market its infant formula to them directly. The company did not accurately reflect in its books and records the more than $2 million in improper payments made during a five-year period.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Mead Johnson Nutrition With FCPA Violations,\u0022 July 28, 2015.)","Sources ":"US Securities and Exchange Commission Administrative Proceeding File No. 3-16704, In the Matter of Mead Johnson Nutrition, at https:\/\/www.sec.gov\/litigation\/admin\/2015\/34-75532.pdf;\r\n \r\n SEC Press Release, \u0022SEC Charges Mead Johnson Nutrition With FCPA Violations,\u0022 July 28, 2015, at https:\/\/www.sec.gov\/news\/pressrelease\/2015-154.html","Documents":""},{"Case ID":"ST-472","Case Cluster ":"Nordam Group","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"7\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,000,000 ","Criminal Fine\/Penalty (US$) ":"$2,000,000 ","Criminal Fine \/ Penalty (Explanation)":"$0 ","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022The NORDAM Group Inc., a provider of aircraft maintenance, repair and overhaul (MRO) services based in Tulsa, Okla., has entered into an agreement with the Department of Justice to pay a $2 million penalty to resolve violations of the Foreign Corrupt Practices Act (FCPA).[ ]\r\n \r\n According to the agreement, NORDAM, its subsidiaries and affiliates paid bribes to employees of airlines created, controlled and exclusively owned by the People\u2019s Republic of China in order to secure contracts to perform MRO services for those airlines. The bribes were paid both directly and indirectly to the airline employees. In an effort to disguise the bribes, three employees of NORDAM\u2019s affiliate entered into sales representation agreements with fictitious entities and then used the money paid by NORDAM to those entities to pay bribes to the airline employees.\u0022 (Source: US Department of Justice Press Release, \u0022The Nordam Group Inc. Resolves Foreign Corrupt Practices Act Violations and Agrees to Pay $2 Million Penalty,\u0022 July 17, 2012.)\r\n \r\n The Nonprosecution Agreement notes that the company had demonstrated that any fine exceeding $2 million would substantially jeopardize the company\u0027s continued viability. It also states that customer invoices were artificially inflacted to offset the bribes paid to those customers\u0027 employees (para 7) and that the company \u0022paid as high as $1.5 million in bribes to secure roughly $2.48 million in profits from state-owned and controlled customers in China.\u0022 (Source: US DOJ, In re: Nordam Group Inc., July 6, 2012.)","Sources ":"US Department of Justice Nonprosecution Agreement (July 6, 2012) and Press Release, \u0022The Nordam Group Inc. Resolves Foreign Corrupt Practices Act Violations and Agrees to Pay $2 Million Penalty,\u0022 July 17, 2012, both at https:\/\/www.justice.gov\/criminal-fraud\/case\/re-nordam-group-inc-2012.","Documents":""},{"Case ID":"ST-473","Case Cluster ":"Nordion (Canada) Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Russua","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"3\/3","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$375,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$375,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Licensing)","Summary":"According to the US Securities and Exchange Commission Administrative Proceeding release, \u0022From at least 2004 through 2011, Nordion, Inc. (\u201cNordion\u201d), a global health science company, violated the books and records and internal accounting controls provisions of the Foreign Corrupt Practices Act of 1977 (\u201cFCPA\u201d) in connection with payments made to a third party agent to obtain Russian government approval to distribute TheraSphere, Nordion\u2019s liver cancer treatment, in Russia. Nordion failed to record those payments in a manner that accurately and fairly reflected the transactions in its books and records. Nordion also failed to devise and maintain adequate internal accounting controls to provide sufficient reassurances that Nordion funds were used as authorized, that third-party agents were appropriately vetted, and that Nordion adequately trained its employees to conduct business in countries with significant corruption risks.\u0022 The Administrative Summary notes that the scheme failed and Nordion was unable to distribute TheraSphere in Russia and did not profit from the scheme. (Source: In re: Nordion (Canada) Inc., Administrative Proceeding File No. 3-17153, and Administrative Summary.)","Sources ":"US Securities and Exchange Commission, In re: Nordion (Canada) Inc., Administrative Proceeding File No. 3-17153, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77290.pdf; Administrative Summary, \u0022SEC Charges Engineer and Former Employer with Bribe Scheme in Russia,\u0022 March 3, 2016, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77288-s.pdf.","Documents":""},{"Case ID":"ST-474","Case Cluster ":"Nordion (Canada) Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Russia","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"3\/3","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits; Prejudgment Interest; Civil Penalty","Total Monetary Sanctions (US$)":"$178,950 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$100,000 ","Civil Prejudgment Interest (US$) ":"$12,950 ","Civil Fine \/ Penalty (US$)":"$66,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Licensing)","Summary":"According to the US Securities and Exchange Commission Administrative Proceeding release, \u0022From at least 2004 through 2011, Nordion, Inc. (\u201cNordion\u201d), a global health science company, violated the books and records and internal accounting controls provisions of the Foreign Corrupt Practices Act of 1977 (\u201cFCPA\u201d) in connection with payments made to a third party agent to obtain Russian government approval to distribute TheraSphere, Nordion\u2019s liver cancer treatment, in Russia. Nordion failed to record those payments in a manner that accurately and fairly reflected the transactions in its books and records. Nordion also failed to devise and maintain adequate internal accounting controls to provide sufficient reassurances that Nordion funds were used as authorized, that third-party agents were appropriately vetted, and that Nordion adequately trained its employees to conduct business in countries with significant corruption risks.\u0022 The Administrative Summary notes that the scheme failed and Nordion was unable to distribute TheraSphere in Russia and did not profit from the scheme. (Source: In re: Nordion (Canada) Inc., Administrative Proceeding File No. 3-17153, and Administrative Summary.) Mr. Gourevitch, former employee, arranged for the improper payments to a third party agent and provided false documentation to the company to conceal the payments. (Source: US SEC Administrative Summary, \u0022SEC Charges Engineer and Former Employer with Bribe Scheme in Russia,\u0022 March 3, 2016.)","Sources ":"US Securities and Exchange Commission, Administrative Summary, \u0022SEC Charges Engineer and Former Employer with Bribe Scheme in Russia,\u0022 March 3, 2016, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77288-s.pdf","Documents":""},{"Case ID":"ST-475","Case Cluster ":"Novartis AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"3\/26","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits; Prejudgment Interest; Civil Penalty","Total Monetary Sanctions (US$)":"$25,000,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$21,500,000 ","Civil Prejudgment Interest (US$) ":"$1,500,000 ","Civil Fine \/ Penalty (US$)":"$2,000,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Press Release, \u0022Novartis AG has agreed to pay $25 million to settle charges that it violated the Foreign Corrupt Practices Act (FCPA) when its China-based subsidiaries engaged in pay-to-prescribe schemes to increase sales.\r\n \r\n An SEC investigation found that employees of two China-based Novartis subsidiaries gave money, gifts, and other things of value to health care professionals, which led to several million dollars in sales of pharmaceutical products to China\u2019s state health institutions. The schemes, which lasted a period of years, involved certain complicit managers within Novartis\u2019 China based subsidiaries. Novartis failed to devise and maintain a sufficient system of internal\r\n accounting controls and lacked an effective anti-corruption compliance program to detect and prevent these schemes. As a result, the improper payments were not accurately reflected in Novartis\u2019 books and records.\u0022 (Source: US Securities and Exchange Commission, Litigation Release and In re: Novartis AG, Administrative Proceeding File No. 3-17177, March 23, 2016.)","Sources ":"US Securities and Exchange Commission, In re: Novartis AG, Administrative Proceeding File No. 3-17177, March 2, 2016, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77431.pdf; Litigation Release at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77431-s.pdf.","Documents":""},{"Case ID":"ST-476","Case Cluster ":"Olympus Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Central and South America","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"3\/1","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$28,000,000 ","Criminal Fine\/Penalty (US$) ":"$28,000,000 ","Criminal Fine \/ Penalty (Explanation)":"$0 ","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, as part of a larger enforcement action involving payment of kick-backs by the Olympus Corporation of America, its Miami based subsidiary Olympus Latin America \u0022was charged with FCPA violations in connection with improper payments to health officials in Central and South America, and OLA entered into a separate three year DPA. According to court documents, from 2006 until August 2011, OLA implemented a plan to increase medical equipment sales in Central and South America by providing payments to health care practitioners at government owned health care facilities. These payments included cash, money transfers, personal grants, personal travel and free or heavily discounted equipment. The primary method to deliver these illicit benefits was through \u201ctraining centers,\u201d nominally set up to educate and train doctors, but which OLA used to provide benefits to preselected practitioners. OLA and its conspirators paid nearly $3 million to practitioners to induce the purchase of Olympus products and recognized more than $7.5 million in profits as a result.\u0022 (Source: US Department of Justice Press Release, \u0022Medical Equipment Company Will Pay $646 Million for Making Illegal Payments to Doctors and Hospitals in United States and Latin America,\u0022 March 1, 2016.)","Sources ":"US Department of Justice Press Release, \u0022Medical Equipment Company Will Pay $646 Million for Making Illegal Payments to Doctors and Hospitals in United States and Latin America,\u0022 March 1, 2016, at https:\/\/www.justice.gov\/opa\/pr\/medical-equipment-company-will-pay-646-million-making-illegal-payments-doctors-and-hospitals","Documents":""},{"Case ID":"ST-477","Case Cluster ":"Oracle Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"India","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"8\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$2,000,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$2,000,000 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Press Release, the agency alleged that \u0022certain employees of the India subsidiary of the Redwood Shores, Calif.-based enterprise systems firm structured transactions with India\u0027s government on more than a dozen occasions in a way that enabled Oracle India\u0027s distributors to hold approximately $2.2 million of the proceeds in unauthorized side funds. Those Oracle India employees then directed the distributors to make payments out of these side funds to purported local vendors, several of which were merely storefronts that did not provide any services to Oracle. Oracle\u0027s subsidiary documented certain payments with fake invoices. [ ] \r\n \r\n According to the SEC\u0027s complaint filed in U.S. District Court for the Northern District of California, the misconduct at Oracle\u0027s India subsidiary - Oracle India Private Limited - occurred from 2005 to 2007. Oracle India sold software licenses and services to India\u0027s government through local distributors, and then had the distributors \u0022park\u0022 excess funds from the sales outside Oracle India\u0027s books and records.\r\n \r\n For example, according to the SEC\u0027s complaint, Oracle India secured a $3.9 million deal with India\u0027s Ministry of Information Technology and Communications in May 2006. As instructed by Oracle India\u0027s then-sales director, only $2.1 million was sent to Oracle to record as revenue on the transaction, and the distributor kept $151,000 for services rendered. Certain other Oracle India employees further instructed the distributor to park the remaining $1.7 million for \u0022marketing development purposes.\u0022 Two months later, one of those same Oracle India employees created and provided to the distributor eight invoices for payments to purported third-party vendors ranging from $110,000 to $396,000. In fact, none of these storefront-only third parties provided any services or were included on Oracle\u0027s approved vendor list. The third-party payments created the risk that the funds could be used for illicit purposes such as bribery or embezzlement.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Oracle Corporation With FCPA Violations Related to Secret Side Funds in India,\u0022 August 16, 2012.)","Sources ":"US Securities and Exchange Corporation v. Oracle Corporation, Case No. 12-cv-4310 (NDCA), Complaint filed August 16, 2012, at https:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-158.pdf;\r\n SEC Press Release, \u0022SEC Charges Oracle Corporation With FCPA Violations Related to Secret Side Funds in India,\u0022 August 16, 2012, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171483848","Documents":""},{"Case ID":"ST-478","Case Cluster ":"Orofix International","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"7\/5","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,220,000 ","Criminal Fine\/Penalty (US$) ":"$2,220,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations","Offenses - Settled":"Internal controls violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Deferred Prosecution Agreement with Orthofix, a Curacao incorporated medical devices company with corporate offices in Texas, the company agreed to be charged with one count internal controls violations. According to the SEC\u2019s complaint filed in U.S. District Court for the Eastern District of Texas, \u0022the bribes began in 2003 and continued until 2010. Initially, Promeca [S.A. de CV, the company\u0027s Mexico-based subsidiary] falsely recorded the bribes as cash advances and falsified its invoices to support the expenditures. Later, when the bribes got much larger, Promeca falsely recorded them as promotional and training costs. Because of the bribery scheme, Promeca\u2019s training and promotional expenses were significantly over budget. Orthofix did launch an inquiry into these expenses, but did very little to investigate or diminish the excessive spending. Later, upon discovery of the bribe payments through a Promeca executive, Orthofix immediately self-reported the matter to the SEC and implemented significant remedial measures. The company terminated the Promeca executives who orchestrated the bribery scheme.\u0022 (Sources: US v. Orthofix International, N.V., Case No. 12-cr-00150 (EDTX), Information filed July 10, 2012 and Deferred Prosecution Agreement and Statement of Facts; SEC Press Release, \u0022SEC Charges Orthofix International With FCPA Violations,\u0022 July 10, 2012.)\r\n \r\n According to the Complaint filed in the case by the SEC, \u0022 From 2003 to 2010, Orthofix\u2019s wholly-owned Mexican subsidiary, Promeca S.A. de C.V. (\u201cPromeca\u201d), repeatedly paid bribes totaling approximately 317,000 to Mexican officials in order to obtain and retain sales contracts from Instituto Mexicano del Seguro Social (\u201cIMSS\u201d), the Mexican government-owned healthcare and social services institution. Promeca employees referred to these payments as \u0027chocolates.\u0027\u201d (Source: US Securities and Exchange Commission v. Orthofix N.V., Case No. 12-cr-150 (EDTX), Complaint filed July 5, 2012, at https:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-133.pdf.)","Sources ":"US v. Orthofix International, N.V., Case No. 12-cr-150 (EDTX), Information filed July 10, 2012 and Deferred Prosecution Agreement and Statement of Facts, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-orthofix-international-nv-court-docket-number-412-cr-00150-ras; SEC Press Release, \u0022SEC Charges Orthofix International With FCPA Violations,\u0022 July 10, 2012, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171483164","Documents":""},{"Case ID":"ST-479","Case Cluster ":"Orofix International","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Mexico","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"7\/5","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits; Prejudgment Interest","Total Monetary Sanctions (US$)":"$5,225,701 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$4,983,644 ","Civil Prejudgment Interest (US$) ":"$242,057 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the SEC\u2019s complaint filed in U.S. District Court for the Eastern District of Texas, \u0022the bribes began in 2003 and continued until 2010. Initially, Promeca [S.A. de CV, the company mexico-based subsidiary] falsely recorded the bribes as cash advances and falsified its invoices to support the expenditures. Later, when the bribes got much larger, Promeca falsely recorded them as promotional and training costs. Because of the bribery scheme, Promeca\u2019s training and promotional expenses were significantly over budget. Orthofix did launch an inquiry into these expenses, but did very little to investigate or diminish the excessive spending. Later, upon discovery of the bribe payments through a Promeca executive, Orthofix immediately self-reported the matter to the SEC and implemented significant remedial measures. The company terminated the Promeca executives who orchestrated the bribery scheme.\u0022 (Sources: US SEC Press Release, \u0022SEC Charges Orthofix International With FCPA Violations,\u0022 July 10, 2012.)\r\n \r\n According to the Complaint filed in the case by the SEC, \u0022 From 2003 to 2010, Orthofix\u2019s wholly-owned Mexican subsidiary, Promeca S.A. de C.V. (\u201cPromeca\u201d), repeatedly paid bribes totaling approximately 317,000 to Mexican officials in order to obtain and retain sales contracts from Instituto Mexicano del Seguro Social (\u201cIMSS\u201d), the Mexican government-owned\r\n healthcare and social services institution. Promeca employees referred to these payments as \u0027chocolates.\u0027\u201d (Source: US Securities and Exchange Commission v. Orthofix N.V., Case No. 4:12-cv-419 (ED Tex), Complaint filed July 5, 2012, at https:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-133.pdf.)","Sources ":"US Securities and Exchange Commission v. Orthofix N.V., Case No. 4:12-cv-419 (ED Tex), Complaint filed July 5, 2012, at https:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-133.pdf;\r\n \r\n SEC Press Release, \u0022SEC Charges Orthofix International With FCPA Violations,\u0022 July 10, 2012, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171483164","Documents":""},{"Case ID":"ST-480","Case Cluster ":"PBSJ Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Qatar","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"1\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Disgorgement of Profit, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$3,407,875 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$2,892,504 ","Civil Prejudgment Interest (US$) ":"$140,371 ","Civil Fine \/ Penalty (US$)":"$375,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, falsification of books and records; internal controls violations","Offenses - Settled":"Bribery of foreign officials, falsification of books and records; internal controls violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, the agency agreed to a deferred prosecution agreement (DPA) with The PBSJ Corporation and issued a Cease and Desist Order against the company\u0027s former President Walid Hatoum. PBSJ is now known as The Atkins North America Holdings Corporation and no longer offers public stock in the U.S.\r\n \r\n According to the SEC, its \u0022investigation found that Walid Hatoum, who has agreed to settle the SEC\u2019s charges, offered to funnel funds to a local company owned and controlled by a foreign official in order to secure two multi-million Qatari government contracts for PBSJ in 2009. The foreign official subsequently provided Hatoum and PBSJ\u2019s international subsidiary with access to confidential sealed-bid and pricing information that enabled the PBSJ subsidiary to tender winning bids for a hotel resort development project in Morocco and a light rail transit project in Qatar. [ ] \r\n  \r\n According to the SEC\u2019s order instituting a settled administrative proceeding against Hatoum, he also offered employment to a second foreign official in return for assistance as the bribery scheme began to unravel and PBSJ lost the hotel resort contract. Even though the bribes themselves were not consummated before the scheme was uncovered by the company, PBSJ earned approximately $2.9 million in illicit profits because it continued work on the light rail project until a replacement company could be found.\u0022 (US SEC Press Release, \u0022SEC Charges Former Executive at Tampa-Based Engineering Firm With FCPA Violations,\u0022 January 22, 2015.)","Sources ":"US Securities and Exchange Commission v. PBSJ, Deferred Prosecution Agreement, at https:\/\/www.sec.gov\/news\/press\/2015\/2015-13-dpa.pdf;\r\n \r\n SEC Press Release, \u0022SEC Charges Former Executive at Tampa-Based Engineering Firm With FCPA Violations,\u0022 January 22, 2015","Documents":""},{"Case ID":"ST-481","Case Cluster ":"PBSJ Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Qatar (and Morocco project)","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"1\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$50,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$50,000 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, the agency agreed to a deferred prosecution agreement (DPA) with The PBSJ Corporation and issued a Cease and Desist Order against the company\u0027s former President Walid Hatoum. PBSJ is now known as The Atkins North America Holdings Corporation and no longer offers public stock in the U.S.\r\n \r\n According to the SEC, its \u0022investigation found that Walid Hatoum, who has agreed to settle the SEC\u2019s charges, offered to funnel funds to a local company owned and controlled by a foreign official in order to secure two multi-million Qatari government contracts for PBSJ in 2009. The foreign official subsequently provided Hatoum and PBSJ\u2019s international subsidiary with access to confidential sealed-bid and pricing information that enabled the PBSJ subsidiary to tender winning bids for a hotel resort development project in Morocco and a light rail transit project in Qatar. [ ] \r\n  \r\n According to the SEC\u2019s order instituting a settled administrative proceeding against Hatoum, he also offered employment to a second foreign official in return for assistance as the bribery scheme began to unravel and PBSJ lost the hotel resort contract. Even though the bribes themselves were not consummated before the scheme was uncovered by the company, PBSJ earned approximately $2.9 million in illicit profits because it continued work on the light rail project until a replacement company could be found.\u0022 (US SEC Press Release, \u0022SEC Charges Former Executive at Tampa-Based Engineering Firm With FCPA Violations,\u0022 January 22, 2015.)","Sources ":"US Securities and Exchange Commission Administrative Proceeding, File No. 3-16351, In the Matter of Walid Hatoum, January 22, 2015, at https:\/\/www.sec.gov\/litigation\/admin\/2015\/34-74112.pdf; US Securities and Exchange Commission v. PBSJ, Deferred Prosecution Agreement, at https:\/\/www.sec.gov\/news\/press\/2015\/2015-13-dpa.pdf; SEC Press Release, \u0022SEC Charges Former Executive at Tampa-Based Engineering Firm With FCPA Violations,\u0022 January 22, 2015.","Documents":""},{"Case ID":"ST-482","Case Cluster ":"Petro Tiger","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Colombia","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"9\/25","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$30,000 ","Criminal Fine\/Penalty (US$) ":"$30,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials and Wire Fraud","Offenses - Settled":"Conspiracy to Bribe Foreign Officials and Wire Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Two former chief executive officers of PetroTiger Ltd. \u2013 a British Virgin Islands oil and gas company with operations in Colombia and offices in New Jersey \u2013 have been charged for their alleged participation in a scheme to pay bribes to foreign government officials in violation of the Foreign Corrupt Practices Act (FCPA), to defraud PetroTiger, and to launder proceeds of those crimes. In addition, PetroTiger\u2019s former general counsel pleaded guilty to bribery and fraud charges in connection with the same scheme. [ ] \r\n \r\n According to the charges, former co-CEOs of PetroTiger Joseph Sigelman, 42, formerly of Miami and the Philippines, and Knut Hammarskjold, 42, of Greenville, S.C.; former general counsel Gregory Weisman, 42, of Moorestown, N.J., and others allegedly paid bribes to an official in Colombia in exchange for the official\u2019s assistance in securing approval for an oil services contract worth roughly $39 million. [ ] \r\n \r\n Weisman pleaded guilty on Nov. 8, 2013, to a criminal information charging one count of conspiracy to violate the FCPA and to commit wire fraud. [ ] \r\n \r\n The charges allege the defendants made three separate payments from PetroTiger\u2019s bank account in the United States to the official\u2019s bank account in Colombia to secure approval from Colombia\u2019s state-owned and state-controlled oil company for a lucrative oil services contract in the country. According to the charges, to conceal the bribes, the defendants first attempted to make the payments to a bank account in the name of the foreign official\u2019s wife, for purported consulting services she did not perform. The charges allege that Sigelman and Hammarskjold provided Weisman invoices including her bank account information. The defendants made the payments directly to the official\u2019s bank account when attempts to transfer the money to his wife\u2019s account failed.\r\n \r\n In addition, court documents allege that the defendants attempted to secure kickback payments at the expense of PetroTiger\u2019s board members. According to the criminal charges, the defendants were negotiating an acquisition of another company on behalf of PetroTiger, including on behalf of several members of PetroTiger\u2019s board of directors who were helping to fund the acquisition. In exchange for negotiating a higher purchase price for the acquisition, two of the owners of the target company agreed to kick back to the defendants a portion of the increased purchase price. According to the charges, to conceal the kickback payments, the defendants had the payments deposited into Sigelman\u2019s bank account in the Philippines, created a \u201cside letter\u201d to falsely justify the payments, and used the code name \u0027Manila Split\u0027 to refer to the payments amongst themselves.\u0022 (Source: US Department of Justice Press Release, \u0022Foreign Bribery Charges Unsealed Against Former Chief Executive Officers of Oil Services Company,\u0022 January 6, 2014.) In September 2015, Mr. Weisman was ordered to pay $30,000 criminal fine and two years\u0027 probation. (Source: US v. Weisman, Case No. 13-cr-730 (D. NJ), Judgment filed September 14, 2015.)","Sources ":"US v. Weisman, Case No. 13-cr-730 (D. NJ), Plea Agreement filed September 25, 2013 and other court documents and Department of Justice Press Release, \u0022Foreign Bribery Charges Unsealed Against Former Chief Executive Officers of Oil Services Company,\u0022 January 6, 2014, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-gregory-weisman-court-docket-number-13-cr-00730-jei;\r\n \r\n Judgment filed September 14, 2015, accessed via PACER.","Documents":""},{"Case ID":"ST-483","Case Cluster ":"Petro Tiger","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Colombia","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"6\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Restitution","Total Monetary Sanctions (US$)":"$339,015 ","Criminal Fine\/Penalty (US$) ":"$100,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$239,015.45 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Wire Fraud","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, in 2015, the \u0022former co-chief executive officer (CEO) of PetroTiger Ltd. \u2013 a British Virgin Islands oil and gas company with operations in Colombia and formerly with an office in New Jersey \u2013 pleaded guilty today to conspiring to pay bribes to a foreign government official in violation of the Foreign Corrupt Practices Act (FCPA). [ ] \r\n \r\n At his plea hearing, Sigelman admitted to conspiring with co-CEO Knut Hammarskjold, PetroTiger\u2019s former general counsel Gregory Weisman, and others to make illegal payments of $333,500 to David Duran, an employee of the Colombian national oil company, Ecopetrol. Sigelman admitted to making the payments in exchange for Duran\u2019s assistance in securing a $45 million oil services contract for PetroTiger. \r\n \r\n Sigelman is the third former PetroTiger executive to plead guilty in the case. On Nov. 8, 2013, Weisman pleaded guilty to conspiracy to violate the FCPA and to commit wire fraud. On Feb. 18, 2014, Hammarskjold pleaded guilty to conspiracy to violate the FCPA and to commit wire fraud.\r\n \r\n The case was brought to the attention of the department through a voluntary disclosure by PetroTiger, which fully cooperated with the department\u2019s investigation. Based on PetroTiger\u2019s voluntary disclosure, cooperation, and remediation, among other factors, the department declined to prosecute PetroTiger.\u0022 (Source: US DOJ Press Release, \u0022Former Chief Executive Officer of Oil Services Company Pleads Guilty to Foreign Bribery Charge,\u0022 June 5, 2015.)","Sources ":"US v. Sigelman, Case No. 14-cv-263 (D. NJ), Plea Agreement filed June 15, 2015 and DOJ Press Release, \u0022Former Chief Executive Officer of Oil Services Company Pleads Guilty to Foreign Bribery Charge,\u0022 June 5, 2015, at https:\/\/www.justice.gov\/opa\/pr\/former-chief-executive-officer-oil-services-company-pleads-guilty-foreign-bribery-charge; other related court documents at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-joseph-sigelman-court-docket-number-14-cr-00263-jei; Amended Judgment filed June 23, 2015 accessed at Pacer.","Documents":""},{"Case ID":"ST-484","Case Cluster ":"Petro Tiger","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Colombia","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"9\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Restitution","Total Monetary Sanctions (US$)":"$121,592.93 ","Criminal Fine\/Penalty (US$) ":"$15,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$106,592.93 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Defraud US, Wire Fraud, Conspiracy to Commit Wire Fraud, Mail Fraud (Attempt and Conspiracy, Violation of Foreign Securities Exchanges, Conspriacy to Defraud US, Conspiracy to Commit ML","Offenses - Settled":"Conspiracy to Defraud US","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Mr. Knut Hammarskjold, the former chief executive officer of PetroTiger Ltd., a British Virgin Islands oil and gas company with operations in Colombia and offices in New Jersey, pleaded guilty for his role in a scheme to pay bribes to foreign government officials and to defraud PetroTiger: \u0022According to the charges, [Mr. Hammarskjold and his co-defendants] allegedly paid bribes to an official in Colombia in exchange for the official\u2019s assistance in securing approval for an oil services contract worth roughly $39 million. To conceal the bribes, the defendants allegedly first attempted to make the payments to a bank account in the name of the foreign official\u2019s wife, for purported consulting services she did not perform. The charges allege that Sigelman and Hammarskjold provided Weisman invoices including her bank account information. The defendants made the payments directly to the official\u2019s bank account when attempts to transfer the money to his wife\u2019s account failed.\r\n \r\n In addition, court documents allege that the defendants attempted to secure kickback payments at the expense of several of PetroTiger\u2019s board members. According to the criminal charges, the defendants were negotiating an acquisition of another company on behalf of PetroTiger, including on behalf of several members of PetroTiger\u2019s board of directors who were helping to fund the acquisition. In exchange for negotiating a higher purchase price for the acquisition, two of the owners of the target company agreed to kick back to the defendants a portion of the increased purchase price. According to the charges, to conceal the kickback payments, the defendants had the payments deposited into Sigelman\u2019s bank account in the Philippines, created a \u201cside letter\u201d to falsely justify the payments, and used the code name \u201cManila Split\u201d to refer to the payments amongst themselves.\u0022 (Source: US DOJ Press Release, \u0022Former Chief Executive Officer of Oil Services Company Pleads Guilty to Foreign Bribery Charges,\u0022 February 18, 2014.) Mr. Hammarskjold was ordered to pay $15,000 in criminal fine and $106,592.23 in restitution to Petro Tiger Ltd. (Source: US v. Hammarskjold, Case No. 14-cr-65 (D. NJ), Judgment filed September 14, 2015.)","Sources ":"US v. Hammarskjold, Case No. 14-cr-65 (D. NJ), Judgment filed September 14, 2015, accessed via Pacer; other court documents and related press releases including DOJ Press Release, \u0022Former Chief Executive Officer of Oil Services Company Pleads Guilty to Foreign Bribery Charges,\u0022 February 18, 2014, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-knut-hammarskjold-court-docket-number-14-cr-00065-jei","Documents":""},{"Case ID":"ST-485","Case Cluster ":"Pfizer H.C. P. Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Bulgaria, Croatia, Kazakhstan, Russia","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"8\/7","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$15,000,000 ","Criminal Fine\/Penalty (US$) ":"$15,000,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Pfizer H.C.P. Corporation, an indirect wholly owned subsidiary of Pfizer Inc., has agreed to pay a $15 million penalty to resolve an investigation of Foreign Corrupt Practices Act (FCPA) violations. [ ] In a related matter, Pfizer Inc. and Wyeth LLC reached settlements today with the Securities and Exchange Commission (SEC) under which Pfizer Inc. agreed to pay more than $26.3 million in disgorgement of profits, including pre-judgment interest, to resolve concerns involving the conduct of its subsidiaries. Wyeth, which had been acquired by Pfizer Inc. in 2009, agreed to pay $18.8 million in disgorgement of profits, including pre-judgment interest, to resolve concerns involving the conduct of Wyeth subsidiaries.\r\n \r\n As part of the resolution, the department today filed a two-count criminal information charging Pfizer H.C.P. with conspiracy and violations of the FCPA in connection with improper payments made to government officials, including publicly-employed regulators and health care professionals in Bulgaria, Croatia, Kazakhstan and Russia. The department and Pfizer H.C.P. agreed to resolve the investigation by entering into a deferred prosecution agreement. [ ] \r\n  \r\n According to court documents, Pfizer H.C.P. made a broad range of improper payments to numerous government officials in Bulgaria, Croatia, Kazakhstan and Russia \u2013 including hospital administrators, members of regulatory and purchasing committees and other health care professionals \u2013 and sought to improperly influence government decisions in these countries regarding the approval and registration of Pfizer Inc. products, the award of pharmaceutical tenders and the level of sales of Pfizer Inc. products. According to court documents, Pfizer H.C.P. used numerous mechanisms to improperly influence government officials, including sham consulting contracts, an exclusive distributorship and improper travel and cash payments. \r\n \r\n Pfizer H.C.P. admitted that between 1997 and 2006, it paid more than $2 million of bribes to government officials in Bulgaria, Croatia, Kazakhstan and Russia. Pfizer H.C.P. also admitted that it made more than $7 million in profits as a result of the bribes.\u0022 (Source: US Department of Justice Press Release, \u0022Pfizer H.C.P. Corp. Agrees to Pay $15 Million Penalty to Resolve Foreign Bribery Investigation,\u0022 August 7, 2012.)","Sources ":"US v. Pfizer H.C.P. Corporation, Case No. 12-cr-169 (DDC), Information and Deferred Prosecution Agreement filed August 7, 2012; Department of Justice Press Release, \u0022Pfizer H.C.P. Corp. Agrees to Pay $15 Million Penalty to Resolve Foreign Bribery Investigation,\u0022 August 7, 2012, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-pfizer-hcp-corporation-court-docket-number-12-cr-169.","Documents":""},{"Case ID":"ST-486","Case Cluster ":"Pfizer H.C. P. Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Bulgaria, China, Croatia, Czech Republic, Italy, Kazakhstan, Russia, Serbia","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"8\/7","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit; Prejudgment interest; Civil Penalty","Total Monetary Sanctions (US$)":"$37,753,248 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$17,217,831 ","Civil Prejudgment Interest (US$) ":"$1,658,793 ","Civil Fine \/ Penalty (US$)":"$18,876,624 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records; Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, the agency alleged that \u0022employees and agents of Pfizer\u2019s subsidiaries in Bulgaria, China, Croatia, Czech Republic, Italy, Kazakhstan, Russia, and Serbia made improper payments to foreign officials to obtain regulatory and formulary approvals, sales, and increased prescriptions for the company\u2019s pharmaceutical products. They tried to conceal the bribery by improperly recording the transactions in accounting records as legitimate expenses for promotional activities, marketing, training, travel and entertainment, clinical trials, freight, conferences, and advertising.\r\n \r\n The SEC separately charged another pharmaceutical company that Pfizer acquired a few years ago \u2013 Wyeth LLC \u2013 with its own FCPA violations. Pfizer and Wyeth agreed to separate settlements in which they will pay more than $45 million combined to settle their respective charges. In a parallel action, the Department of Justice announced that Pfizer H.C.P. Corporation agreed to pay a $15 million penalty to resolve its investigation of FCPA violations. [ ] \r\n  \r\n According to the SEC\u2019s complaint against Pfizer filed in U.S. District Court for the District of Columbia, the misconduct dates back as far as 2001. Employees of Pfizer\u2019s subsidiaries authorized and made cash payments and provided other incentives to bribe government doctors to utilize Pfizer products. In China, for example, Pfizer employees invited \u201chigh-prescribing doctors\u201d in the Chinese government to club-like meetings that included extensive recreational and entertainment activities to reward doctors\u2019 past product sales or prescriptions. Pfizer China also created various \u201cpoint programs\u201d under which government doctors could accumulate points based on the number of Pfizer prescriptions they wrote. The points were redeemed for various gifts ranging from medical books to cell phones, tea sets, and reading glasses. In Croatia, Pfizer employees created a \u201cbonus program\u201d for Croatian doctors who were employed in senior positions in Croatian government health care institutions. Once a doctor agreed to use Pfizer products, a percentage of the value purchased by a doctor\u2019s institution would be funneled back to the doctor in the form of cash, international travel, or free products.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Pfizer with FCPA Violations,\u0022 August 7, 2012.)","Sources ":"US SEC v. Pfizer, Case No. 12-cv-1303 (DDC), Complaint at https:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-152-pfizer.pdf;\r\n \r\n US SEC v. Wyeth, Case No. 12-cv-1304 (DDC), Complaint at https:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-152-wyeth.pdf;\r\n \r\n SEC Press Release, \u0022SEC Charges Pfizer with FCPA Violations,\u0022 August 7, 2012, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171483696","Documents":""},{"Case ID":"ST-487","Case Cluster ":"Pfizer H.C. P. Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, Indonesia, Pakistan, Saudi Arabia","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"8\/7","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit; Prejudgment Interest","Total Monetary Sanctions (US$)":"$18,876,624 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$17,217,831 ","Civil Prejudgment Interest (US$) ":"$1,658,793 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records; Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, the agency alleged that \u0022employees and agents of Pfizer\u2019s subsidiaries in Bulgaria, China, Croatia, Czech Republic, Italy, Kazakhstan, Russia, and Serbia made improper payments to foreign officials to obtain regulatory and formulary approvals, sales, and increased prescriptions for the company\u2019s pharmaceutical products. They tried to conceal the bribery by improperly recording the transactions in accounting records as legitimate expenses for promotional activities, marketing, training, travel and entertainment, clinical trials, freight, conferences, and advertising.\r\n \r\n The SEC separately charged another pharmaceutical company that Pfizer acquired a few years ago \u2013 Wyeth LLC \u2013 with its own FCPA violations. Pfizer and Wyeth agreed to separate settlements in which they will pay more than $45 million combined to settle their respective charges. In a parallel action, the Department of Justice announced that Pfizer H.C.P. Corporation agreed to pay a $15 million penalty to resolve its investigation of FCPA violations. [ ] \r\n  \r\n According to the SEC\u2019s complaint against Pfizer filed in U.S. District Court for the District of Columbia, the misconduct dates back as far as 2001. Employees of Pfizer\u2019s subsidiaries authorized and made cash payments and provided other incentives to bribe government doctors to utilize Pfizer products. In China, for example, Pfizer employees invited \u201chigh-prescribing doctors\u201d in the Chinese government to club-like meetings that included extensive recreational and entertainment activities to reward doctors\u2019 past product sales or prescriptions. Pfizer China also created various \u201cpoint programs\u201d under which government doctors could accumulate points based on the number of Pfizer prescriptions they wrote. The points were redeemed for various gifts ranging from medical books to cell phones, tea sets, and reading glasses. In Croatia, Pfizer employees created a \u201cbonus program\u201d for Croatian doctors who were employed in senior positions in Croatian government health care institutions. Once a doctor agreed to use Pfizer products, a percentage of the value purchased by a doctor\u2019s institution would be funneled back to the doctor in the form of cash, international travel, or free products.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Pfizer with FCPA Violations,\u0022 August 7, 2012.)","Sources ":"US SEC v. Pfizer, Case No. 12-cv-1303 (DDC), Complaint at https:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-152-pfizer.pdf;\r\n \r\n US SEC v. Wyeth, Case No. 12-cv-1304 (DDC), Complaint at https:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-152-wyeth.pdf;\r\n \r\n SEC Press Release, \u0022SEC Charges Pfizer with FCPA Violations,\u0022 August 7, 2012, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171483696","Documents":""},{"Case ID":"ST-488","Case Cluster ":"PTC Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profit; Prejudgment Interest","Total Monetary Sanctions (US$)":"$13,622,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$11,858,000 ","Civil Prejudgment Interest (US$) ":"$1,764,000 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of books and records; Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the SEC Press Release, PTC Inc., a Needham, Massachusetts based technology company, consented to the Cease and Desist Order. According to the SEC, \u0022From at least 2006 into 2011, two wholly-owned PTC subsidiaries (collectively, \u201cPTC-China\u201d) provided improper payments totaling nearly $1.5 million to government officials (\u201cChinese government officials\u201d or \u201cofficials\u201d) who were employed by Chinese state owned entities (\u201cSOEs\u201d) that were PTC customers. These payments were made to obtain or retain business from the SOEs. Specifically, PTC-China provided non-business travel, primarily sightseeing and tourist activities, as well as improper gifts and entertainment, to the Chinese government officials. PTC earned approximately $11.85 million in profits from sales contracts with SOEs whose officials received the improper payments.\r\n 2. PTC-China made these improper payments in two primary ways: 1) by providing at least $1,179,912 to third party agents, disguised as commission payments or sub-contracting fees, which were then used to pay for non-business related foreign travel for Chinese government officials; and 2) by allowing its sales staff to provide Chinese government officials with gifts and excessive entertainment of over $274,313. The payments were recorded as legitimate commissions and business expenses in PTC-China\u2019s books and records, when in fact they were improper payments designed to benefit the Chinese government officials. PTC-China\u2019s books and records were consolidated into PTC\u2019s books and records, thereby causing PTC\u2019s books and records to be inaccurate. PTC failed to devise and maintain an adequate system of internal accounting controls sufficient to prevent and detect these improper payments that occurred over several years.\u0022 (Source: US Securities and Exchange Commission, In the Matter of PTC Inc., Administrative Proceeding File No. 3-17118, February 16, 2016, Summary.)","Sources ":"US Securities and Exchange Commission, In the Matter of PTC Inc., Administrative Proceeding File No. 3-17118, February 16, 2016, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77145.pdf; Press Release, \u0022SEC: Tech Company Bribed Chinese Officials,\u0022 February 16, 2016, at https:\/\/www.sec.gov\/news\/pressrelease\/2016-29.html.","Documents":""},{"Case ID":"ST-489","Case Cluster ":"PTC Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$14,540,000 ","Criminal Fine\/Penalty (US$) ":"$14,540,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"The US Department of Justice Press Release stated, \u0022According to admissions made in the resolution documents, Parametric Technology (Shanghai) Software\r\n Company Ltd. and Parametric Technology (Hong Kong) Ltd. (collectively, PTC China), through local business partners, arranged and paid for employees of various Chinese state owned enterprises to travel to the United States, ostensibly for training at PTC Inc.\u2019s headquarters in Massachusetts, but primarily for recreational travel to other parts of the United States, including New York, Los Angeles, Las Vegas and Hawaii. PTC China paid a total of more than $1 million through its business partners to fund these trips, while during the same time period, PTC China entered into more than $13 million in contracts with the Chinese stateowned\r\n entities. Company employees typically accompanied the Chinese officials on these trips. PTC China admitted that the cost of these recreational trips was routinely hidden within the price of PTC China\u2019s software sales to the Chinese state owned entities whose employees went on the trips.\u0022 (Source: US Department of Justice, \u0022PTC Inc. Subsidiaries Agree to Pay More Than $14 Million to Resolve Foreign Bribery Charges,\u0022 February 16, 2016.)","Sources ":"US Department of Justice, \u0022PTC Inc. Subsidiaries Agree to Pay More Than $14 Million to Resolve Foreign Bribery Charges,\u0022 February 16, 2016.","Documents":""},{"Case ID":"ST-490","Case Cluster ":"PTC Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Falsification of books and records; internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"See related entry, US Securities and Exchange Commission Cease and Desist Order issued against PTC Inc. The SEC announced that the Deferred Prosecution Agreement with Mr. Yuan was the first \u0022with an individual in an FCPA case. DPAs facilitate and reward cooperation in SEC investigations by foregoing an enforcement action against an individual who agrees to cooperate fully and truthfully throughout the period of deferred prosecution. FCPA charges will be deferred for three years against Yu Kai Yuan, a former employee at one of PTC\u2019s Chinese subsidiaries, as a result of significant cooperation he has provided during the SEC\u2019s investigation.\u0022 (Source: US Securities and Exchange Commission Press Release, \u0022SEC: Tech Company Bribed Chinese Officials,\u0022 February 16, 2016; See also, SEC-Yu Kai Yuan Deferred Prosecution Agreement, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77145-dpa.pdf","Sources ":"SEC-Yu Kai Yuan Deferred Prosecution Agreement, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77145-dpa.pdf; US Securities and Exchange Commission Press Release, \u0022SEC: Tech Company Bribed Chinese Officials,\u0022 February 16, 2016, at https:\/\/www.sec.gov\/news\/pressrelease\/2016-29.html.","Documents":""},{"Case ID":"ST-491","Case Cluster ":"Qualcomm Incorporated","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"3\/1","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$7,500,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$7,500,000 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of books and records; Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Securities and Exchange Commission Press Release related to the US telecommunications company, \u0022Qualcomm Incorporated has agreed to pay $7.5 million to settle charges that it violated the Foreign Corrupt Practices Act (FCPA) by hiring relatives of Chinese government officials deciding whether to select the company\u2019s mobile technology products amid increasing competition in the international telecommunications market.\r\n An SEC investigation found that Qualcomm also provided gifts, travel, and entertainment to try to influence officials at government-owned telecom companies in China. With insufficient internal controls to detect improper payments, Qualcomm misrepresented in its books and records that the things of value provided to foreign officials were legitimate business expenses. [ ] The SEC\u2019s order finds that Qualcomm violated the anti-bribery, internal controls, and books-and-records provisions of the Securities Exchange Act of 1934. Without admitting or denying the findings, Qualcomm agreed to pay the $7.5 million penalty and self-report to the SEC for the next two years with annual reports and certifications of its FCPA compliance. \u0022 (Source: US SEC Press Release, \u0022SEC: Qualcomm Hired Relatives of Chinese Officials to Obtain Business,\u0022 March 1, 2016, at http:\/\/www.sec.gov\/news\/pressrelease\/2016-36.html)","Sources ":"US SEC Press Release, \u0022SEC: Qualcomm Hired Relatives of Chinese Officials to Obtain Business,\u0022 March 1, 2016, at http:\/\/www.sec.gov\/news\/pressrelease\/2016-36.html","Documents":""},{"Case ID":"ST-492","Case Cluster ":"Ralph Lauren Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"4\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Penalty","Total Monetary Sanctions (US$)":"$882,000 ","Criminal Fine\/Penalty (US$) ":"$882,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Department of Justice, \u0022Ralph Lauren Corporation (RLC), a New York based apparel company, has agreed to pay an $882,000 penalty to resolve allegations that it violated the Foreign Corrupt Practices Act (FCPA) by bribing government officials in Argentina to obtain improper customs clearance of merchandise, announced Mythili Raman, the Acting Assistant Attorney General for the Criminal Division, and Loretta E. Lynch, the United States Attorney for the\r\n Eastern District of New York.\r\n \r\n According to the agreement, the manager of RLC\u2019s subsidiary in Argentina bribed customs officials in Argentina over the span of five years to improperly obtain paperwork necessary for goods to clear customs\u037e permit clearance of items without the necessary paperwork and\/or the clearance of prohibited items\u037e and on occasion, to avoid inspection entirely. RLC\u2019s employee disguised the payments by funneling them through a customs clearance agency, which created fake invoices to justify the improper payments. During these five years, RLC did not have an anticorruption program and did not provide any anticorruption training or oversight with respect to its subsidiary in Argentina.\u0022 (Source: US DOJ Press Release, \u0022Ralph Lauren Corporation Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $882,000 Monetary Penalty,\u0022 April 22, 2013.)","Sources ":"US Department of Justice Press Release, \u0022Ralph Lauren Corporation Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $882,000 Monetary Penalty,\u0022 April 22, 2013 and Nonprosecution Agreement and Statement of Facts, at https:\/\/www.justice.gov\/sites\/default\/files\/criminal-fraud\/legacy\/2013\/04\/23\/Ralph-Lauren.-NPA-Executed.pdf.","Documents":""},{"Case ID":"ST-493","Case Cluster ":"Ralph Lauren Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"4\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Disgorgement of Profits; Prejudgment Interest","Total Monetary Sanctions (US$)":"$734,845.79 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$593,000 ","Civil Prejudgment Interest (US$) ":"$141,845.79 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"Bribery of Foreign Officials; Falsification of Books and Records; Internal Controls Violations","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission, the agency entered into its firt Nonprosecution Agreement (NPA) in an FCPA action: \u0022Ralph Lauren Corporation\u0027s Argentine subsidiary paid bribes to government and customs officials to improperly secure the importation of Ralph Lauren Corporation\u0027s products in Argentina. The purpose of the bribes, paid through its customs broker, was to obtain entry of Ralph Lauren Corporation\u0027s products into the country without necessary paperwork, avoid inspection of prohibited products, and avoid inspection by customs officials. The bribe payments and gifts to Argentine officials totaled $593,000 during a four-year period.\r\n \r\n Under the NPA, Ralph Lauren Corporation agreed to pay $593,000 in disgorgement and $141,845.79 in prejudgment interest.\u0022 The misconduct took place between approximately 2004 through 2009. (Source: US SEC Press Release, \u0022SEC Announces Non-Prosecution Agreement With Ralph Lauren Corporation Involving FCPA Misconduct,\u0022 April 22, 2013.)","Sources ":"US Securities and Exchange Commission Nonprosecution Agreement with Ralph Lauren Corporation, at https:\/\/www.sec.gov\/news\/press\/2013\/2013-65-npa.pdf;\r\n Press Release, \u0022SEC Announces Non-Prosecution Agreement With Ralph Lauren Corporation Involving FCPA Misconduct,\u0022 April 22, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171514780","Documents":""},{"Case ID":"ST-494","Case Cluster ":"Rheinmetall AG","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Bremen Public Prosecution Office","Jurisdiction of Foreign Public Official(s) ":"Greece","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"12\/8","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Section 30 Administrative Act (OWiG)","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$45,531,981 ","Criminal Fine\/Penalty (US$) ":"$368,481 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$45,163,500 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Foreign Bribery","Offenses - Settled":"Breach of Trust","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Bremen Public Prosecution, the Rheinmetall AG accepted a settlement on behalf of its subsidiary, Rheinmetall Defence Electronics GmbH (RDE). According to the Prosecution\u0027s press release, in the framework of the sale of air defense systems (type ASRAD) to Greece, RDE was deemed responsible for not having taken the necessary measures to impede undue payments to Greek public officials. The press release noted that proceedings against RDE\u0027s predecessor company, STN Atlas GmbH and related individuals were ongoing. (Source: Staatsanwaltschaft Bremen, P r e s s e m i t t e i l u n g 13 \/ 2014, \u0022Staatsanwaltschaft verh\u00e4ngt Geldbu\u00dfe in H\u00f6he von \u00fcber 37 Millionen Euro gegen die Rheinmetall Defence Electro-nics GmbH,\u0022 December 11, 2014.)","Sources ":"Staatsanwaltschaft Bremen, P r e s s e m i t t e i l u n g 13 \/ 2014, \u0022Staatsanwaltschaft verh\u00e4ngt Geldbu\u00dfe in H\u00f6he von \u00fcber 37 Millionen Euro gegen die Rheinmetall Defence Electronics GmbH,\u0022 December 11, 2014 and Pr e s s e m i t t e i l u n g 3 \/ 2014, \u0022Ermittlungsma\u00dfnahmen in den Verfahren gegen Verantwortliche von Rheinmetall Defence Elektronics GmbH und von Atlas Elektronik GmbH,\u0022 April 14, 2014, both accessible at http:\/\/www.staatsanwaltschaft.bremen.de\/sixcms\/detail.php?gsid=bremen120.c.12313.de.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Nr.%203%202014.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Nr.%2013.pdf"},{"Case ID":"ST-495","Case Cluster ":"Rino International Corp.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"5\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Not specified","Summary":"According to the US Securities and Exchange Commission, RINO, a holding company for subsidiaries that manufacture, install, and service equipment for the Chinese steel industry, became a China-based U.S. issuer through a reverse merger in October 2007. According to the SEC\u2019s complaint, [Cheif Executive Officer David] Zou, a Chinese national living in China, and [Chairman of the Board] Qiu, a Chinese national living in California, diverted some of the proceeds from an offering of securities by RINO in December 2009. Zou and Qiu are alleged to have used the proceeds to purchase a $3.5 million family home for personal use. RINO, Zou, and Qiu initially failed to disclose this diversion, and conflicting information was provided to RINO\u2019s outside auditor about the expenditure. Zou and Qiu also used offering proceeds to pay for automobiles as well as designer clothing and accessories without recording them as personal expenses or otherwise disclosing them in RINO\u2019s public filings.\r\n \r\n The Commission further alleges that RINO\u2019s SEC filings contained materially false and misleading statements and omissions concerning RINO\u2019s revenue and operations between 2008 and 2010. According to the complaint, RINO maintained two conflicting sets of financial records \u2013 one set of books for filings in China and another set of books for filings in the U.S. The Chinese books reflected sales of approximately $31 million from the first quarter of 2008 through the first three quarters of 2010. But the U.S. books that formed the basis for RINO\u2019s SEC filings contained false contracts and portrayed sales revenues of approximately $491 million during that same time period \u2013 more than 15 times greater than the revenues recorded in the Chinese books. The complaint alleges that Zou and Qiu knew or were reckless in not knowing that the U.S. books were supported by false contracts and, nonetheless, signed and certified RINO\u2019s public filings containing false and misleading statements and omissions about RINO\u2019s revenue and operations.\u0022 (Source: SEC Litigation Release, \u0022SEC Charges RINO, Its CEO, and Its Chairman of the Board with Scheme to Overstate Revenues and Divert Money for Personal Use,\u0022 May 15, 2013.)","Sources ":"US Securities and Exchange Commission v. Rino International, Dejun David Zhou, and Jianping Qiu, Case No, 13-cv-711, SEC Litigation Release, \u0022SEC Charges RINO, Its CEO, and Its Chairman of the Board with Scheme to Overstate Revenues and Divert Money for Personal Use,\u0022 May 15, 2013, at https:\/\/www.sec.gov\/litigation\/litreleases\/2013\/lr22699.htm.","Documents":""},{"Case ID":"ST-496","Case Cluster ":"Rino International Corp.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"5\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Civil Penalty","Total Monetary Sanctions (US$)":"$1,850,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,750,000 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$100,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records; Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Not specified","Summary":"According to the US Securities and Exchange Commission, RINO, a holding company for subsidiaries that manufacture, install, and service equipment for the Chinese steel industry, became a China-based U.S. issuer through a reverse merger in October 2007. According to the SEC\u2019s complaint, [Cheif Executive Officer David] Zou, a Chinese national living in China, and [Chairman of the Board] Qiu, a Chinese national living in California, diverted some of the proceeds from an offering of securities by RINO in December 2009. Zou and Qiu are alleged to have used the proceeds to purchase a $3.5 million family home for personal use. RINO, Zou, and Qiu initially failed to disclose this diversion, and conflicting information was provided to RINO\u2019s outside auditor about the expenditure. Zou and Qiu also used offering proceeds to pay for automobiles as well as designer clothing and accessories without recording them as personal expenses or otherwise disclosing them in RINO\u2019s public filings.\r\n \r\n The Commission further alleges that RINO\u2019s SEC filings contained materially false and misleading statements and omissions concerning RINO\u2019s revenue and operations between 2008 and 2010. According to the complaint, RINO maintained two conflicting sets of financial records \u2013 one set of books for filings in China and another set of books for filings in the U.S. The Chinese books reflected sales of approximately $31 million from the first quarter of 2008 through the first three quarters of 2010. But the U.S. books that formed the basis for RINO\u2019s SEC filings contained false contracts and portrayed sales revenues of approximately $491 million during that same time period \u2013 more than 15 times greater than the revenues recorded in the Chinese books. The complaint alleges that Zou and Qiu knew or were reckless in not knowing that the U.S. books were supported by false contracts and, nonetheless, signed and certified RINO\u2019s public filings containing false and misleading statements and omissions about RINO\u2019s revenue and operations.\u0022 (Source: SEC Litigation Release, \u0022SEC Charges RINO, Its CEO, and Its Chairman of the Board with Scheme to Overstate Revenues and Divert Money for Personal Use,\u0022 May 15, 2013.)","Sources ":"US Securities and Exchange Commission v. Rino International, Dejun David Zhou, and Jianping Qiu, Case No, 13-cv-711, SEC Litigation Release, \u0022SEC Charges RINO, Its CEO, and Its Chairman of the Board with Scheme to Overstate Revenues and Divert Money for Personal Use,\u0022 May 15, 2013, at https:\/\/www.sec.gov\/litigation\/litreleases\/2013\/lr22699.htm.","Documents":""},{"Case ID":"ST-497","Case Cluster ":"Rino International Corp.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"5\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Civil Penalty","Total Monetary Sanctions (US$)":"$1,900,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,750,000 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$150,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Not specified","Summary":"According to the US Securities and Exchange Commission, RINO, a holding company for subsidiaries that manufacture, install, and service equipment for the Chinese steel industry, became a China-based U.S. issuer through a reverse merger in October 2007. According to the SEC\u2019s complaint, [Cheif Executive Officer David] Zou, a Chinese national living in China, and [Chairman of the Board] Qiu, a Chinese national living in California, diverted some of the proceeds from an offering of securities by RINO in December 2009. Zou and Qiu are alleged to have used the proceeds to purchase a $3.5 million family home for personal use. RINO, Zou, and Qiu initially failed to disclose this diversion, and conflicting information was provided to RINO\u2019s outside auditor about the expenditure. Zou and Qiu also used offering proceeds to pay for automobiles as well as designer clothing and accessories without recording them as personal expenses or otherwise disclosing them in RINO\u2019s public filings.\r\n \r\n The Commission further alleges that RINO\u2019s SEC filings contained materially false and misleading statements and omissions concerning RINO\u2019s revenue and operations between 2008 and 2010. According to the complaint, RINO maintained two conflicting sets of financial records \u2013 one set of books for filings in China and another set of books for filings in the U.S. The Chinese books reflected sales of approximately $31 million from the first quarter of 2008 through the first three quarters of 2010. But the U.S. books that formed the basis for RINO\u2019s SEC filings contained false contracts and portrayed sales revenues of approximately $491 million during that same time period \u2013 more than 15 times greater than the revenues recorded in the Chinese books. The complaint alleges that Zou and Qiu knew or were reckless in not knowing that the U.S. books were supported by false contracts and, nonetheless, signed and certified RINO\u2019s public filings containing false and misleading statements and omissions about RINO\u2019s revenue and operations.\u0022 (Source: SEC Litigation Release, \u0022SEC Charges RINO, Its CEO, and Its Chairman of the Board with Scheme to Overstate Revenues and Divert Money for Personal Use,\u0022 May 15, 2013.)","Sources ":"US Securities and Exchange Commission v. Rino International, Dejun David Zhou, and Jianping Qiu, Case No, 13-cv-711, SEC Litigation Release, \u0022SEC Charges RINO, Its CEO, and Its Chairman of the Board with Scheme to Overstate Revenues and Divert Money for Personal Use,\u0022 May 15, 2013, at https:\/\/www.sec.gov\/litigation\/litreleases\/2013\/lr22699.htm.","Documents":""},{"Case ID":"ST-498","Case Cluster ":"SAP SE","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Panama","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/1","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits; Prejudgment Interest","Total Monetary Sanctions (US$)":"$3,888,896 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$3,700,000 ","Civil Prejudgment Interest (US$) ":"$188,896 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, the software manufacturer company \u0022SAP\u2019s deficient internal controls allowed a former SAP executive to pay $145,000 in bribes to a senior Panamanian government official and offer bribes to two others in exchange for lucrative sales contracts. The SEC charged the SAP executive, Vicente E. Garcia, in a separate enforcement action last year that included a parallel criminal action. Garcia has been sentenced to 22 months in prison.\r\n \r\nAccording to the SEC\u2019s order instituting a settled administrative proceeding:\r\n \r\n SAP is headquartered in Germany and executes most of its sales through a network of worldwide corporate partners, including a partner in Panama.\r\n \r\n The bribery scheme involved providing large discounts of up to 82 percent to SAP\u2019s Panamanian partner, who used the excessive discounts to create a slush fund out of which to pay bribes to Panamanian officials on Garcia\u2019s behalf so SAP could sell software.\r\n \r\n SAP had no requirements for heightened anti-corruption scrutiny for such large discounts.\r\n \r\n SAP falsely recorded the slush fund as legitimate discounts on the books of SAP\u2019s Mexican subsidiary, and the figures were subsequently consolidated into SAP\u2019s financial statements.\r\n \r\n SAP failed to devise and maintain a sufficient system of internal accounting controls to provide reasonable assurances that the discounts were recorded in accordance with U.S. Generally Accepted Accounting Principles.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Software Company With FCPA Violations,\u0022 February 1, 2016.)","Sources ":"US SEC Press Release, \u0022SEC Charges Software Company With FCPA Violations,\u0022 February 1, 2016, at https:\/\/www.sec.gov\/news\/pressrelease\/2016-17.html","Documents":""},{"Case ID":"ST-499","Case Cluster ":"SAP SE","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Panama","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"8\/12","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"$0 ","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022Vicente Eduardo Garcia, 65, of Miami, was sentenced to 22 months in prison by U.S. District Judge Charles R. Breyer of the Northern District of California. On Aug. 12, 2015, Garcia pleaded guilty to one count of conspiracy to violate the Foreign Corrupt Practices Act (FCPA). On July 15, 2015, Garcia and the U.S. Securities and Exchange Commission (SEC) entered into a settlement of the parallel SEC investigation in which Garcia agreed, among other things, to pay disgorgement of $85,965 plus prejudgment interest. For this reason, the United States did not request, and the court did not order, forfeiture in the criminal action.\r\n \r\n In his plea, Garcia admitted that in late 2009, to secure for SAP a multimillion-dollar contract to provide a Panamanian state agency with a technology upgrade package, Garcia conspired with others to bribe two Panamanian government officials directly and a third official through an agent. Garcia admitted that the conspirators used sham contracts and false invoices to disguise the true nature of the bribes and that he believed paying such bribes was necessary to secure the initial and any future Panamanian government contracts. Panamanian officials awarded the $14.5 million contract, which included $2.1 million in SAP software licenses, to SAP\u2019s partner as well as subsequent contracts that also included the provision of SAP products. Garcia personally received over $85,000 in kickbacks for arranging the bribes.\u0022 (Source: US DOJ Press Release, \u0022Former Executive Sentenced for Conspiracy to Bribe Panamanian Officials,\u0022 December 16, 2015.)","Sources ":"US DOJ Press Release, \u0022Former Executive Sentenced for Conspiracy to Bribe Panamanian Officials,\u0022 December 16, 2015, at https:\/\/www.justice.gov\/opa\/pr\/former-executive-sentenced-conspiracy-bribe-panamanian-officials","Documents":""},{"Case ID":"ST-500","Case Cluster ":"SAP SE","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Panama","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"8\/12","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profit; Prejudgment interest","Total Monetary Sanctions (US$)":"$92,395 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$85,965 ","Civil Prejudgment Interest (US$) ":"$6,430 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, the agency\u0027s \u0022investigation found that Vicente E. Garcia, the former vice president of global and strategic accounts for SAP SE, orchestrated a scheme to pay $145,000 in bribes to one government official and promised to pay two others in order to obtain four contracts to sell SAP software to the Panamanian government. He essentially caused SAP, which is headquartered in Germany and executes most of its sales through a network of worldwide corporate partners, to sell software to a partner in Panama at discounts of up to 82 percent. The excessive discounts enabled the partner to create a slush fund from its excessive earnings on the other end of the sales and tap that money to pay the bribes to Panamanian government officials so SAP could sell the software. Garcia, who lives in Miami, also received kickbacks from the slush fund into his bank account.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Former Software Executive With FCPA Violations,\u0022 August 12, 2015.) Mr. Garcia was ordered to pay \u0022disgorgement of $85,965, representing the kickback Garcia received in connection with the bribery scheme, and prejudgment interest of $6,430 to the Securities and Exchange Commission for transfer to the general fund of the United States Treasury subject to Exchange Act Section 21F(g)(3).\u0022 (Source: US SEC Administrative Proceeding File No. 3-16750, In the Matter of Vicente E. Garcia, August 12, 2015.)","Sources ":"US Securities and Exchange Commission, Administrative Proceeding File No. 3-16750, In the Matter of Vicente E. Garcia, August 12, 2015., at https:\/\/www.sec.gov\/litigation\/admin\/2015\/34-75684.pdf;\r\n \r\n US SEC Press Release, \u0022SEC Charges Former Software Executive With FCPA Violations,\u0022 August 12, 2015, at https:\/\/www.sec.gov\/news\/pressrelease\/2015-165.html","Documents":""},{"Case ID":"ST-501","Case Cluster ":"SBM Offshore NV","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Openbaar Ministrie (Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Angola, Brazil, Equatorial Guinea","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"11\/12","Other Jurisdictions of Settlement":"Brazil","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Out of Court Settlement","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$240,000,000 ","Criminal Fine\/Penalty (US$) ":"$40,000,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$200,000,000 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art.1, Art. 2","Offenses - Alleged":"Bribery of Foreign Public Officials","Offenses - Settled":"Bribery of Foreign Public Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Openbaar Ministrie press release, \u0022SBM Offshore has accepted an offer from the Dutch Public Prosecutor\u0027s Service (Openbaar Ministerie) to enter into an out-of-court settlement. The settlement consists of a payment by SBM Offshore to the Openbaar Ministerie of US$ 240,000,000 in total. This amount consists of a US$ 40,000,000 fine and US$ 200,000,000 disgorgement (ontneming van wederrechtelijk verkregen voordeel). This settlement relates to improper payments to sales agents and foreign government officials in Equatorial Guinea, Angola and Brazil in the period from 2007 through 2011 as identified by the Openbaar Ministerie and the Dutch Fiscal Intelligence and Investigation Service (Fiscale Inlichtingenen Opsporingsdienst\u037e FIOD). According to the Openbaar Ministerie\u0027s those payments\r\n constitute the indictable offences of bribery in the public and the private sector as well as forgery (valsheid in geschrifte).(Source: Openbaar Ministrie press release, \u0022SBM Offshore N.V. settles bribery case for US$240,000,000,\u0022 November 12, 2014 at https:\/\/www.om.nl\/vaste-onderdelen\/zoeken\/@87201\/sbm-offshore-settles\/).","Sources ":"Openbaar Ministrie press release, \u0022SBM Offshore N.V. settles bribery case for US$240,000,000,\u0022 November 12, 2014 at https:\/\/www.om.nl\/vaste-onderdelen\/zoeken\/@87201\/sbm-offshore-settles\/","Documents":""},{"Case ID":"ST-502","Case Cluster ":"SBM Offshore NV","Jurisdiction of Settlement":"Brazil","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Netherlands (SBM Offshore NV)","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"4\/4","Other Jurisdictions of Settlement":"Brazil","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"out-of-court settlement, on a no admission of guilt basis","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$68,662.50 ","Criminal Fine\/Penalty (US$) ":"$68,662.50 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$68,662.50 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Prosecution by affected jurisdiction","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Foreign Bribery","Offenses - Settled":"Foreign Bribery","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to press statements by SBM Offshore, the company\u0027s CEO and Member of the Supervisory Board agreed to an out of court settlement on a non admission of guilt basis for bribes allegedly paid to officials of the majority Brazilian government owned Petrobras. The settlement agreement was approved by a judge. (Sources: SBM Offshore Press Releases, \u0022Confirmation of the Settlement Regarding Allegations Against CEO and Member of the Supervisory Board,\u0022 April 6, 2016 and \u0022Settlement Regarding Accusations against CEO and Member of the Supervisory Board,\u0022 January 25, 2016.) According to SBM Offshore\u0027s 2015 Full-Year Earnings report, the company had set aside $245 million for a possible settlement with the Brazilian authorities. (Source: SBM Offshore 2015 Full-Year Earnings Report, \u0022Compliance,\u0022 Ferbuary 10, 2016.)","Sources ":"SBM Offshore Full Year 2015 Earnings, \u0022Compliance,\u0022 February 10, 2016 at http:\/\/www.sbmoffshore.com\/?press-release=sbm-offshore-2015-full-year-earnings; SBM Offshore Press Releases, \u0022Confirmation of the Settlement Regarding Allegations Against CEO and Member of the Supervisory Board,\u0022 April 6, 2016, at http:\/\/www.sbmoffshore.com\/?press-release=confirmation-settlement-regarding-allegations-ceo-member-supervisory-board, and \u0022Settlement Regarding Accusations against CEO and Member of the Supervisory Board,\u0022 January 25, 2016, at \r\n  http:\/\/www.sbmoffshore.com\/?press-release=settlement-regarding-accusations-ceo-member-supervisory-board \r\n \r\n  but no official information is provided in the Controladoria-Geral da Uniao (General Attorney Office) web page. http:\/\/www.cgu.gov.br\/assuntos\/responsabilizacao-de-empresas","Documents":""},{"Case ID":"ST-503","Case Cluster ":"SBM Offshore NV","Jurisdiction of Settlement":"Brazil","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Netherlands (SBM Offshore NV)","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"4\/4","Other Jurisdictions of Settlement":"Brazil","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"out-of-court settlement, on a no admission of guilt basis","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$68,662.50 ","Criminal Fine\/Penalty (US$) ":"$68,662.50 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$68,662.50 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Prosecution by affected jurisdiction","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Foreign Bribery","Offenses - Settled":"Foreign Bribery","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to press statements by SBM Offshore, the company\u0027s CEO and Member of the Supervisory Board agreed to an out of court settlement on a non admission of guilt basis for bribes allegedly paid to officials of the majority Brazilian government owned Petrobras. The settlement agreement was approved by a judge. (Sources: SBM Offshore Press Releases, \u0022Confirmation of the Settlement Regarding Allegations Against CEO and Member of the Supervisory Board,\u0022 April 6, 2016 and \u0022Settlement Regarding Accusations against CEO and Member of the Supervisory Board,\u0022 January 25, 2016.) According to SBM Offshore\u0027s 2015 Full-Year Earnings report, the company had set aside $245 million for a possible settlement with the Brazilian authorities. (Source: SBM Offshore 2015 Full-Year Earnings Report, \u0022Compliance,\u0022 Ferbuary 10, 2016.)","Sources ":"SBM Offshore Full Year 2015 Earnings, \u0022Compliance,\u0022 February 10, 2016 at http:\/\/www.sbmoffshore.com\/?press-release=sbm-offshore-2015-full-year-earnings; SBM Offshore Press Releases, \u0022Confirmation of the Settlement Regarding Allegations Against CEO and Member of the Supervisory Board,\u0022 April 6, 2016, at http:\/\/www.sbmoffshore.com\/?press-release=confirmation-settlement-regarding-allegations-ceo-member-supervisory-board, and \u0022Settlement Regarding Accusations against CEO and Member of the Supervisory Board,\u0022 January 25, 2016, at \r\n  http:\/\/www.sbmoffshore.com\/?press-release=settlement-regarding-accusations-ceo-member-supervisory-board \r\n \r\n  but no official information is provided in the Controladoria-Geral da Uniao (General Attorney Office) web page. http:\/\/www.cgu.gov.br\/assuntos\/responsabilizacao-de-empresas","Documents":""},{"Case ID":"ST-504","Case Cluster ":"SciClone Pharmaceuticals Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/4","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profit; Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$12,826,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$9,426,000 ","Civil Prejudgment Interest (US$) ":"$900,000 ","Civil Fine \/ Penalty (US$)":"$2,500,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022From at least 2007 to 2012, employees of SciClone subsidiaries, who acted as agents of SciClone in conducting business in China, gave money, gifts and other things of value to foreign officials, including healthcare professionals (\u201cHCPs\u201d) who were employed by state-owned hospitals in China, in order to obtain sales of SciClone pharmaceutical products. Various means were employed, and these schemes were known to and condoned by various managers within SciClone\u2019s China-based corporate structure. The related transactions were falsely recorded in SciClone\u2019s books and records as legitimate business expenses, such as sponsorships, travel and entertainment, conferences, honoraria, and promotion expenses. During this period, SciClone also failed to devise and maintain a sufficient system of internal accounting controls and lacked an effective anti-corruption compliance program.","Sources ":"US Securities and Exchange Commission, In the Matter of Sciclone Pharmaceuticals Inc, Administrative Proceeding File No. 3-17101, february 4, 2016, at https:\/\/www.sec.gov\/litigation\/admin\/2016\/34-77058.pdf.","Documents":""},{"Case ID":"ST-505","Case Cluster ":"Securency Intl Pty Ltd.","Jurisdiction of Settlement":"Australia","Jurisdiction of Settlement \/ Enforcement Agency":"Commonwealth Director of Public Prosecutions","Jurisdiction of Foreign Public Official(s) ":"Malaysia","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"8\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"False Accounting","Offenses - Settled":"False Accounting","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Sentencing in R v. Ellery, David John Ellery pleaded guilty to one charge of false accounting,\r\n contrary to s 83(1)(a) of the Crimes Act 1958 (Vic). \u0022The offence occurred between 28 June and 19 July 2006. At the time, [Mr. Ellery was] the chief financial officer, and a company secretary, of Securency International Pty Ltd\r\n (\u201cSecurency\u201d).\r\n 3 Securency is an Australian company, which is jointly owned by the Reserve Bank of Australia and a British company, Innovia Films BVBA. Securency manufactures and supplies a range of unique substances used in banknotes and security documents.\r\n Its polymer substrate product is used by various people, including another Reserve Bank subsidiary, Note Printing Australia Limited (\u201cNote Printing\u201d), in the printing\r\n of banknotes.\r\n 4 In 1999 and 2000, Note Printing and Securency each negotiated and entered into separate agreements with a Malaysian man, Abdul Kayum Syed Ahmad (\u201cKayum\u201d),\r\n and\/or his company, Aksavest Sdn Bhd, appointing them as their agent in Malaysia.\r\n The agency agreements provided that the agent was to be remunerated in the form of success-based commissions, based on the contracts which the agent obtained for the relevant company. The agent was to bear the cost of any expenses incurred in order to obtain contracts.\r\n 5 In December 2003, Note Printing entered into a contract to supply Bank Negara Malaysia with 160 million 5 ringgit polymer banknotes. Securency was not a party to the banknote contract. Note Printing used Securency\u2019s polymer substrate in manufacturing the banknotes, and the contract price of $15.2 million included a price for that substrate. Note Printing paid Kayum substantial commission payments, in respect of the 2003 contract.\r\n 6 The Commonwealth Director of Public Prosecutions has brought charges against Securency, Note Printing, and various former officers of the two companies, alleging\r\n that they conspired with each other and with Kayum, between October 2001 and December 2003, to offer bribes to officials in the Malaysian bank, in order to obtain the business of supplying 5 ringgit polymer banknotes. The DPP alleges that the bribes were to be paid from the commission payable to Kayum.\r\n 7 The DPP does not allege that [Mr. Ellery was] a participant in the alleged Malaysian conspiracy, or that [he was] involved in it when, in mid-2006, [he] committed the false accounting offence to which [he has] pleaded guilty.\u0022 (Source: R v. Ellery [2012] VSC 349, Sentencing.)","Sources ":"R v. Ellery [2012] VSC 349, Sentencing at http:\/\/www.austlii.edu.au\/cgi-bin\/sign.cgi\/au\/cases\/vic\/VSC\/2012\/349;\r\n \r\nAustralia Federal Police Media Release, \u0022Foreign bribery charges laid in Australia,\u0022 July 1, 2011, at http:\/\/www.afp.gov.au\/media-centre\/news\/afp\/2011\/july\/foreign-bribery-charges-laid-in-australia.aspx; \u0022Further charges laid in foreign bribery investigation,\u0022 August 10, 2011, at http:\/\/www.afp.gov.au\/media-centre\/news\/afp\/2011\/august\/further-charges-laid-in-foreign-bribery-investigation; \r\n Robert Wyld, \u0022An Update From Australia \u2013 Securency\r\n Banknote Printing Bribery Scandal\r\n Secures First Conviction And Sentence\r\n And Pressure Increases On Australia\u2019s\r\n Central Bank,\u0022 FCPA Professor, August 30, 2012, at http:\/\/fcpaprofessor.com\/an-update-from-australia-securency-banknote-printing-bribery-scandal-secures-first-conviction-and-sentence-and-pressure-increases-on-australias-central-bank\/;\r\n \r\n Sentencing document","Documents":""},{"Case ID":"ST-506","Case Cluster ":"Siemens","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"2\/3","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$8,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$8,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022On December 13, 2011, the Commission filed a Civil Action charging Bock, Signer, Truppel and four other senior executives of Siemens and its regional company in Argentina with violations of the anti-bribery, books and records, and internal controls provisions of the FCPA. The Commission alleged that between 2001 and 2007, the defendants paid bribes to senior government officials in Argentina to retain a $1 billion contract (\u201cthe DNI contract\u201d) to produce national identity cards for Argentine citizens. The officials included two Argentine presidents and cabinet ministers in two presidential administrations.\r\n \r\n The Commission\u2019s complaint alleged that Bock and Signer, both senior Siemens managers based in Germany, took various actions to revive the DNI contract after it was cancelled by government officials in Argentina, and made sure that the bribery connected to the contract went undetected. Truppel, a former CFO of Siemens Argentina with close ties to government officials, assisted their efforts. The Commission\u2019s complaint also alleged that Uriel Sharef, a member of Siemens Managing Board, or \u201cVorstand,\u201d and the most senior officer charged in connection with the scheme, met with payment intermediaries in the U.S. and agreed to pay bribes to Argentine officials while enlisting subordinates to conceal payments and circumvent Siemens\u2019 internal accounting controls. [ ]\r\n \r\n The Commission previously announced that on April 16, 2013, a final judgment was entered by the Court against Uriel Sharef, a former officer and board member of Siemens, for his role in the long standing bribery scheme. The final judgment, to which Sharef consented without admitting or denying the allegations in the Commission\u2019s complaint, enjoined him from violating the anti-bribery and related books and records and internal controls provisions of the FCPA, and ordered him to pay a $275,000 civil penalty. Bernd Regendantz settled with the Commission when the complaint was filed, and allegations against Herbert Steffen and Carlos Sergi were dismissed.\u0022 (Source: US Securities and Exchange Commission Press Release, \u0022SEC Concludes Its Case Against Former Siemens Executives Charged with Bribery in Argentina, Obtaining Judgments over $1.8 Million,\u0022 February 10, 2014.)","Sources ":"US Securities and Exchange Commission Press Release, \u0022SEC Concludes Its Case Against Former Siemens Executives Charged with Bribery in Argentina, Obtaining Judgments over $1.8 Million,\u0022 February 10, 2014, at https:\/\/www.sec.gov\/litigation\/litreleases\/2014\/lr22923.htm","Documents":""},{"Case ID":"ST-507","Case Cluster ":"Siemens","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"2\/4","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$524,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$524,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022On December 13, 2011, the Commission filed a Civil Action charging Bock, Signer, Truppel and four other senior executives of Siemens and its regional company in Argentina with violations of the anti-bribery, books and records, and internal controls provisions of the FCPA. The Commission alleged that between 2001 and 2007, the defendants paid bribes to senior government officials in Argentina to retain a $1 billion contract (\u201cthe DNI contract\u201d) to produce national identity cards for Argentine citizens. The officials included two Argentine presidents and cabinet ministers in two presidential administrations.\r\n \r\n The Commission\u2019s complaint alleged that Bock and Signer, both senior Siemens managers based in Germany, took various actions to revive the DNI contract after it was cancelled by government officials in Argentina, and made sure that the bribery connected to the contract went undetected. Truppel, a former CFO of Siemens Argentina with close ties to government officials, assisted their efforts. The Commission\u2019s complaint also alleged that Uriel Sharef, a member of Siemens Managing Board, or \u201cVorstand,\u201d and the most senior officer charged in connection with the scheme, met with payment intermediaries in the U.S. and agreed to pay bribes to Argentine officials while enlisting subordinates to conceal payments and circumvent Siemens\u2019 internal accounting controls. [ ]\r\n \r\n The Commission previously announced that on April 16, 2013, a final judgment was entered by the Court against Uriel Sharef, a former officer and board member of Siemens, for his role in the long standing bribery scheme. The final judgment, to which Sharef consented without admitting or denying the allegations in the Commission\u2019s complaint, enjoined him from violating the anti-bribery and related books and records and internal controls provisions of the FCPA, and ordered him to pay a $275,000 civil penalty. Bernd Regendantz settled with the Commission when the complaint was filed, and allegations against Herbert Steffen and Carlos Sergi were dismissed.\u0022 (Source: US Securities and Exchange Commission Press Release, \u0022SEC Concludes Its Case Against Former Siemens Executives Charged with Bribery in Argentina, Obtaining Judgments over $1.8 Million,\u0022 February 10, 2014.)","Sources ":"US Securities and Exchange Commission Press Release, \u0022SEC Concludes Its Case Against Former Siemens Executives Charged with Bribery in Argentina, Obtaining Judgments over $1.8 Million,\u0022 February 10, 2014, at https:\/\/www.sec.gov\/litigation\/litreleases\/2014\/lr22923.htm","Documents":""},{"Case ID":"ST-508","Case Cluster ":"Siemens","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"2\/4","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$937,957 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$316,452 ","Civil Prejudgment Interest (US$) ":"$97,505 ","Civil Fine \/ Penalty (US$)":"$524,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022On December 13, 2011, the Commission filed a Civil Action charging Bock, Signer, Truppel and four other senior executives of Siemens and its regional company in Argentina with violations of the anti-bribery, books and records, and internal controls provisions of the FCPA. The Commission alleged that between 2001 and 2007, the defendants paid bribes to senior government officials in Argentina to retain a $1 billion contract (\u201cthe DNI contract\u201d) to produce national identity cards for Argentine citizens. The officials included two Argentine presidents and cabinet ministers in two presidential administrations.\r\n \r\n The Commission\u2019s complaint alleged that Bock and Signer, both senior Siemens managers based in Germany, took various actions to revive the DNI contract after it was cancelled by government officials in Argentina, and made sure that the bribery connected to the contract went undetected. Truppel, a former CFO of Siemens Argentina with close ties to government officials, assisted their efforts. The Commission\u2019s complaint also alleged that Uriel Sharef, a member of Siemens Managing Board, or \u201cVorstand,\u201d and the most senior officer charged in connection with the scheme, met with payment intermediaries in the U.S. and agreed to pay bribes to Argentine officials while enlisting subordinates to conceal payments and circumvent Siemens\u2019 internal accounting controls. [ ]\r\n \r\n The Commission previously announced that on April 16, 2013, a final judgment was entered by the Court against Uriel Sharef, a former officer and board member of Siemens, for his role in the long standing bribery scheme. The final judgment, to which Sharef consented without admitting or denying the allegations in the Commission\u2019s complaint, enjoined him from violating the anti-bribery and related books and records and internal controls provisions of the FCPA, and ordered him to pay a $275,000 civil penalty. Bernd Regendantz settled with the Commission when the complaint was filed, and allegations against Herbert Steffen and Carlos Sergi were dismissed.\u0022 (Source: US Securities and Exchange Commission Press Release, \u0022SEC Concludes Its Case Against Former Siemens Executives Charged with Bribery in Argentina, Obtaining Judgments over $1.8 Million,\u0022 February 10, 2014.)","Sources ":"US Securities and Exchange Commission Press Release, \u0022SEC Concludes Its Case Against Former Siemens Executives Charged with Bribery in Argentina, Obtaining Judgments over $1.8 Million,\u0022 February 10, 2014, at https:\/\/www.sec.gov\/litigation\/litreleases\/2014\/lr22923.htm","Documents":""},{"Case ID":"ST-509","Case Cluster ":"Siemens","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"4\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$275,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$275,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, Uriel Sharef, a former officer and board member of Siemens Aktiengesellschaft (Siemens) settled with the agency in 2013. \u0022The settlement resolves the Commission\u0027s civil action against Sharef for his role in Siemens\u0027 decade-long bribery scheme to retain a $1 billion government contract to produce national identity cards for Argentine citizens. The final judgment, to which Sharef consented, enjoins him from violating the anti-bribery and related internal controls provisions of the FCPA and orders him to pay a $275,000 civil penalty, the second highest penalty assessed against an individual in an FCPA case.\r\n \r\n On December 13, 2011, the Commission filed a civil action against Uriel Sharef and six other defendants, alleging that between 2001 and 2007, Sharef, along with other Siemens executives, paid bribes to senior government officials in Argentina in connection with a government contract to provide national identity cards to all Argentine citizens. The officials included two Argentine presidents and cabinet ministers in two presidential administrations. During this period, Sharef was a member of Siemens Managing Board, or \u201cVorstand,\u201d and was the most senior officer charged in connection with the scheme. Sharef met with payment intermediaries in the United States and agreed to pay $27 million in bribes to Argentine officials. Sharef also enlisted subordinates to conceal the payments by circumventing Siemens\u0027 internal accounting controls.\r\n \r\n According to the SEC\u0027s complaint, approximately $31.3 million of the $100 million in bribes paid were made after March 12, 2001, when Siemens became a U.S. issuer subject to U.S. securities laws. As a result of the bribe payments it made, Siemens received an arbitration award in 2007 against the government of Argentina of more than $217 million plus interest for the contract. In August 2009, after settling bribery charges with the U.S. and Germany, Siemens waived the arbitration award.\u0022 (Source: US Securities and Exchange Commission Litigation Release, \u0022Former Siemens Executive Uriel Sharef Settles Bribery Charges,\u0022 April 16, 2013.)","Sources ":"US Securities and Exchange Commission Litigation Release, \u0022Former Siemens Executive Uriel Sharef Settles Bribery Charges,\u0022 April 16, 2013, at https:\/\/www.sec.gov\/litigation\/litreleases\/2013\/lr22676.htm","Documents":""},{"Case ID":"ST-510","Case Cluster ":"Siemens Industrial Turbomachinery","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Russia","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"11\/12","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Summary Punishment Order","Monetary Sanctions  (Types)":"Criminal Compensation; Criminal Reparations","Total Monetary Sanctions (US$)":"$10,863,765 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$10,728,061 ","Criminal Restitution \/ Reparation (US$)":"$135,704 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$135,704 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"in the form of a donation to the International Committee of the Red Cross (ICRC).","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art, 2, Art. 8","Offenses - Alleged":"Inadequate enforcement of compliance regulations","Offenses - Settled":"Inadequate enforcement of compliance regulations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Media Release issued by the Swiss Office of the Attorney General, \u0022The Office of the Attorney General of Switzerland (OAG) has concluded a criminal investigation into the Swedish company Siemens Industrial Turbomachinery (SIT). The investigation was closed after SIT admitted inadequate enforcement of compliance regulations in relation to Yamal gas pipeline projects and paid CHF 125,000 in reparation. SIT also paid US$ 10.6 million in compensation for unlawfully obtained profits.\r\n \r\nThe OAG investigated the circumstances behind contracts awarded to the Swedish company, acquired by Siemens in 2003, for the supply of gas turbines during the construction of the pipeline, which runs from the gas fields on the Russian Yamal peninsula to Western Europe. In the course of project, initiated by Russia\u0027s largest natural gas production company, bribes were paid to senior executives of the Russian state-owned company. SIT made the unlawful payments between 2004 and 2006 via bank accounts held by the end recipients in Switzerland. This was the connecting factor that gave rise to the OAG\u0027s investigation.\r\n \r\n The SIT accepts that it did not take all the required and reasonable organisational steps to prevent bribes being paid to foreign public officials in connection with projects to build compressor stations and to supply gas turbines for the Yamal pipeline network. In particular, it admitted basic failures in checking consultancy agreements. The company is therefore guilty of organisational offences under Art. 102 of the Swiss Criminal Code (SCC). SIT has paid reparation of CHF 125,000 in the form of a donation to the International Committee of the Red Cross (ICRC).\r\n \r\n As a consequence, the OAG closed the investigation into SIT based on Art. 53 SCC and at the same time ordered the forfeiture of unlawfully obtained assets. The profits obtained unlawfully from the projects concerned amount to US$ 10.6 million. The OAG ordered SIT to pay a corresponding sum in compensation to the State (Art. 71 para. 1 SCC). The compensation has now been paid.\u0022 (Source: \u0022Bribery relating to the construction of Yamal Pipeline: Siemens subsidiary pays reparation,\u0022 November 12, 2013,)","Sources ":"Swiss Office of the Attorney General Media Release, \u0022Bribery relating to the construction of Yamal Pipeline: Siemens subsidiary pays reparation,\u0022 November 12, 2013, at https:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026print_style=yes\u0026msg-id=50913","Documents":""},{"Case ID":"ST-511","Case Cluster ":"Smith \u0026 Wesson","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia, Pakistan, Others","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"7\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profit; Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$2,034,892 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$107,852 ","Civil Prejudgment Interest (US$) ":"$21,040 ","Civil Fine \/ Penalty (US$)":"$1,906,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, the agency\u0027s \u0022order instituting a settled administrative proceeding, the Springfield, Mass. based firearms manufacturer sought to break into new markets overseas starting in 2007 and continuing into early 2010. During that period, Smith \u0026 Wesson\u2019s international sales staff engaged in a pervasive effort to attract new business by offering, authorizing, or making illegal payments or providing gifts meant for government officials in Pakistan, Indonesia, and other foreign countries. [ ]\r\n \r\n According to the SEC\u2019s order, Smith \u0026 Wesson retained a third party agent in Pakistan in 2008 to help the company obtain a deal to sell firearms to a Pakistani police department. Smith \u0026 Wesson officials authorized the agent to provide more than $11,000 worth of guns to Pakistani police officials as gifts, and then make additional cash payments. Smith \u0026 Wesson ultimately won a contract to sell 548 pistols to the Pakistani police for a profit of $107,852.\r\n \r\n The SEC\u2019s order finds that Smith \u0026 Wesson employees made or authorized improper payments related to multiple other pending or contemplated international sales contracts. For example, in 2009, Smith \u0026 Wesson attempted to win a contract to sell firearms to an Indonesian police department by making improper payments to its third party agent in Indonesia. The agent indicated he would provide a portion of that money to Indonesian officials under the guise of legitimate firearm lab testing costs. He said Indonesian police officials expected to be paid additional amounts above the actual cost of testing the guns. Smith \u0026 Wesson officials authorized and made the inflated payment, but a deal was never consummated.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Smith \u0026 Wesson with FCPA Violations,\u0022 July 28, 2014.)","Sources ":"US Securities and Exchange Commission, In the Matter of Smith \u0026 Wesson Holding Corporation, Administrative Proceeding File No. 3-15986, July 28, 2016, at https:\/\/www.sec.gov\/litigation\/admin\/2014\/34-72678.pdf; Press Release, \u0022SEC Charges Smith \u0026 Wesson with FCPA Violations,\u0022 July 28, 2014, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370542384677;","Documents":""},{"Case ID":"ST-512","Case Cluster ":"SNC-Lavalin","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Federal Prosecutor General","Jurisdiction of Foreign Public Official(s) ":"Bangladesh","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"8\/5","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture, Criminal Restitution","Total Monetary Sanctions (US$)":"$40,300,000 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$27,000,000 ","Criminal Restitution \/ Reparation (US$)":"$13,300,000 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$13,300,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Return to SNC Lavalin (Partie Plaignante)","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of foreign officials; Money laundering; Fraud; Mismanagement","Offenses - Settled":"Bribery of foreign officials; Money laundering; Fraud; Mismanagement","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Wall Street Journal and other secondary sources, the Swiss Federal Cirminal Court approved the plea agreement by Mr. Riad Ben Aissa, which included forfeiture of CHF 40 milion forfeited of which CHF 13 million was provided to SNC-Lavalin, which was permitted to file claim as a victim. (Source: James V. Grimaldi and Margaret T. Coker, \u0022Canadian Firm Recoups Cash in Bribery Probe,\u0022 December 11, 2014; Greg McArthur, \u0022Swiss court grants SNC special status in fraud case against former executive,\u0022 May 22, 2013.)","Sources ":"Acte d\u0027accusation en procedure simplifiee, Riad Ben Aissa, August 5, 2014, at http:\/\/nawaat.org\/portail\/wp-content\/uploads\/Acte_Accusation_riadh_Ben_Aissa_ALSTOM.pdf; James V. Grimaldi and Margaret T. Coker, \u0022Canadian Firm Recoups Cash in Bribery Probe,\u0022 December 11, 2014, at http:\/\/www.wsj.com\/articles\/canadian-firm-recoups-cash-in-bribery-case-1418343614; Greg McArthur, \u0022Swiss court grants SNC special status in fraud case against former executive,\u0022 May 22, 2013, at http:\/\/www.theglobeandmail.com\/report-on-business\/swiss-court-grants-snc-special-status-in-fraud-case-against-former-executive\/article12053350\/; Brian Hutchinson, \u0022Inside the \u0027clandestine world\u0027 of SNC-Lavalin\u0027s fallen star Riadh Ben Aissa,\u0022 March 18, 2015, at http:\/\/business.financialpost.com\/legal-post\/inside-the-clandestine-world-of-snc-lavalins-fallen-star-riadh-ben-aissa","Documents":""},{"Case ID":"ST-513","Case Cluster ":"SNC-Lavalin Inc.","Jurisdiction of Settlement":"World Bank","Jurisdiction of Settlement \/ Enforcement Agency":"Integrity","Jurisdiction of Foreign Public Official(s) ":"Bangladesh","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"4\/17","Other Jurisdictions of Settlement":"Switzerland (Ben Aissa)","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Negotiated Resolution Agreement","Monetary Sanctions  (Types)":"None specified","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"Ten years debarment of SNC-Lavalin Inc. and over 100 related entities","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Violation of World Bank Procurement Guidelines","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Violation of World Bank Procurement Guidelines","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the World Bank, SNC-Lavalin Inc. and \u0022over 100 affiliates - [were debarred] for a period of 10 years following the company\u2019s misconduct in relation to the Padma Multipurpose Bridge Project in Bangladesh, as well as misconduct under another Bank-financed project. SNC-Lavalin Inc. is a subsidiary of SNC-Lavalin Group, a Canadian company, and represents more than 60% of its business. \r\n \r\nThe debarment is part of a Negotiated Resolution Agreement between the World Bank and SNC-Lavalin Group following a World Bank investigation into allegations of bribery schemes involving SNC-Lavalin Inc. and officials in Bangladesh.\r\n \r\n While the investigation was ongoing, the World Bank\u2019s Integrity Vice Presidency also learned of misconduct by SNC-Lavalin Inc. in relation to the World Bank-financed Rural Electrification and Transmission project in Cambodia. [ ]\r\n \r\n SNC-Lavalin\u2019s misconduct involved a conspiracy to pay bribes and misrepresentations when bidding for Bank-financed contracts in violation of the World Bank\u2019s procurement guidelines. Under the Agreement, the SNC-Lavalin Group and its affiliates commit to cooperating with the World Bank\u2019s Integrity Vice Presidency and continuing to improve their internal compliance program. The debarment of SNC-Lavalin Inc. qualifies for cross-debarment by other MDBs under the Agreement of Mutual Recognition of Debarments that was signed on April 9, 2010.\u0022 (Source: World Bank, \u0022World Bank Debars SNC-Lavalin Inc. and its Affiliates for 10 years,\u0022 April 17, 2013.)","Sources ":"World Bank, \u0022World Bank Debars SNC-Lavalin Inc. and its Affiliates for 10 years,\u0022 April 17, 2013, at http:\/\/www.worldbank.org\/en\/news\/press-release\/2013\/04\/17\/world-bank-debars-snc-lavalin-inc-and-its-affiliates-for-ten-years","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/SNC-Lavalin%20Inc%20debarment_WB%20Press%20Release.pdf"},{"Case ID":"ST-514","Case Cluster ":"Standard Bank","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Tanzania","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"11\/30","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Compensation (to Tanzania), Disgorgement of Profits, Financial Penalty, Legal Costs","Total Monetary Sanctions (US$)":"$32,742,222.58 ","Criminal Fine\/Penalty (US$) ":"$16,800,000 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$8,400,000 ","Criminal Restitution \/ Reparation (US$)":"$7,046,197 ","Criminal Legal \/ Procedural Costs (US$)":"$496,026 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$7,046,197 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Compensation to Tanzania (US$6 million and $1 million in interest)","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Failure to Prevent Bribery","Offenses - Settled":"Failure to Prevent Bribery","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Crown Court Judgment, \u0022the Government of Tanzania wished to raise funds by way of a sovereign note private placement. Stanbic Bank Tanzania Ltd (\u201cStanbic\u201d), which is a subsidiary of Standard Bank Group Ltd (a publicly owned company registered in South Africa), was not licensed to deal with non-local foreign investors in the debt capital market and so Stanbic involved Standard Bank, another subsidiary of the same group that was licensed, and together they sought to obtain instructions to raise the funds. Negotiations did not progress until Stanbic entered into an agreement with a Tanzanian company called Enterprise Growth Market Advisors Limited (\u201cEGMA\u201d). \r\n \r\n 7. Two of the three directors and shareholders of EGMA were the Commissioner of the Tanzania Revenue Authority (and, thus, a member of the Government of Tanzania) and the former Chief Executive Officer of Tanzanian Capital Markets and Securities Authority (\u201cCMSA\u201d). EGMA\u2019s fee was agreed at 1% of the funds raised and in order to meet the cost of that agreement, the fee for the placement was increased from 1.4% to 2.4%. In the event, although the potential for corrupt practices to affect this type of business were well known, Standard Bank, which did not have adequate measures in place to guard against such risks, relied on Stanbic to conduct appropriate due diligence in relation to EGMA; Standard Bank made no enquiry about EGMA or its role. \r\n \r\n 8. The mandate to raise the funds was placed with Standard Bank and Stanbic and US $600 million was raised but there is no evidence that EGMA provided any services in relation to the transaction. Meanwhile, EGMA had opened a bank account with Stanbic and its fee of US $6 million was paid (as agreed) via Stanbic into the account. Very shortly thereafter the vast majority of the sum had been withdrawn in cash. The withdrawals excited the concern of staff at Stanbic who referred the matter to the head office of Standard Bank Group Ltd; Standard Bank were alerted and very quickly thereafter, a law firm was appointed to investigate the matter and, within three weeks of the first report, both the Serious and Organised Crime Agency and the SFO were informed.\u0022 The Judgment also makes note of Standard Bank\u0027s settlement with the US Securities and Exchange Commission. (Source: Judgment in Between : SERIOUS FRAUD OFFICE Applicant - and - STANDARD BANK PLC (Now known as ICBC Standard Bank plc), Case No: U20150854, Crown Court (Queen\u0027s Bench Division), November 30, 2015.)","Sources ":"Judgment in Between SERIOUS FRAUD OFFICE Applicant - and - STANDARD BANK PLC (Now known as ICBC Standard Bank plc), Case No: U20150854, Crown Court (Queen\u0027s Bench Division), November 30, 2015, at https:\/\/www.judiciary.gov.uk\/wp-content\/uploads\/2015\/11\/sfo-v-standard-bank_Final_1.pdf; UK Serious Fraud Office Press Release, \u0022SFO agrees first UK DPA with Standard Bank,\u0022 November 30, 2015, which includes links to the Deferred Prosecution Agreement, Statement of Facts and Judgments at https:\/\/www.sfo.gov.uk\/2015\/11\/30\/sfo-agrees-first-uk-dpa-with-standard-bank\/","Documents":""},{"Case ID":"ST-515","Case Cluster ":"Standard Bank","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Tanzania","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"11\/30","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits; Civil Penalty","Total Monetary Sanctions (US$)":"$4,200,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"See Note - other civil monetary sanctions","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$4,200,000 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"Standard Bank was ordered to pay disgorgement of $8.4 million; this amount was deemed satisfied by the payment of $4.2 million in penalty to the US and $4.2 million in penalty to the UK.","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Negligent Securities Fraud","Offenses - Settled":"Negligent Securities Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, Standard Bank Plc was charged \u0022with failing to disclose certain payments in connection with debt issued by the Government of Tanzania in 2013. The London-based bank acted as a lead manager for the offering and failed to disclose payments made by an affiliate to a Tanzanian firm that received a portion of the proceeds of the $600 million offering but performed no substantive role in the transaction.\r\n \r\n Standard Bank, now ICBC Standard Bank Plc, agreed to settle the SEC\u2019s charges by paying a $4.2 million penalty and admitting the facts underlying the SEC\u2019s charges that were admitted in a related settlement with the United Kingdom\u2019s Serious Fraud Office (SFO). As part of that coordinated global settlement, the SFO also announced a settlement today in an action it brought against Standard in the U.K. for Standard\u2019s violations of Section 7 of the U.K.\u2019s Bribery Act of 2010. The Bribery Act of 2010 is similar to the Unites States\u2019 Foreign Corrupt Practices Act (FCPA). The SEC would not have jurisdiction to bring charges under the FCPA because Standard was not an \u201cissuer\u201d as defined by that Act. Standard will pay a total of approximately $36.9 million in monetary relief in the SEC and U.K. actions. \r\n \r\n [Accordng to the SEC\u0027s Cease and Desist] order,] the offering documents and statements to potential investors in the sovereign debt offering were materially misleading because they failed to disclose that Standard\u2019s affiliate, Stanbic Bank Tanzania Limited, would pay $6 million of the proceeds to Enterprise Growth Markets Advisors Limited (EGMA), a private Tanzanian firm. The order found Standard did not seek to understand EGMA\u2019s role in the transaction despite red flags that the $6 million payment was intended to induce the Government of Tanzania to select Standard and Stanbic as managers for the offering. One of EGMA\u2019s directors was a representative of the Government of Tanzania and the offering was not finalized until Standard and Stanbic committed to pay EGMA one percent of the proceeds of the offering. Standard and Stanbic split 1.4 percent of the proceeds, with each receiving $4.2 million for their participation in the transaction. [ ] \r\n \r\n The SEC\u2019s order requires Standard to cease and desist from committing or causing any violations and any future violations of Section 17(a)(2) of the Securities Act of 1933 that prohibits obtaining money by any materially untrue statement or omission, and to pay a $4.2 million civil penalty. The order also requires Standard to pay disgorgement of $8.4 million, which the Commission has deemed satisfied by a payment of equal amount in the U.K. matter.\u0022 (Source: US SEC Press Release, \u0022Standard Bank to Pay $4.2 Million to Settle SEC Charges Bank Agrees to $36.9 Million Global Settlement with the SEC and the U.K.\u2019s Serious Fraud Office,\u0022 November 30, 2015.)","Sources ":"US Securities and Exchange Commission, In the Matter of Standard Bank, Plc, Administrative Proceedings File No. 3-16973, at https:\/\/www.sec.gov\/litigation\/admin\/2015\/33-9981.pdf; SEC Press Release, \u0022Standard Bank to Pay $4.2 Million to Settle SEC Charges Bank Agrees to $36.9 Million Global Settlement with the SEC and the U.K.\u2019s Serious Fraud Office,\u0022 November 30, 2015, at https:\/\/www.sec.gov\/news\/pressrelease\/2015-268.html","Documents":""},{"Case ID":"ST-516","Case Cluster ":"Stryker Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina, Greece, Mexico, Poland, Romania","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"10\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profit; Prejudgment interest, Civil Penalty","Total Monetary Sanctions (US$)":"$13,283,523 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$7,502,635 ","Civil Prejudgment Interest (US$) ":"$2,280,888 ","Civil Fine \/ Penalty (US$)":"$3,500,000 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, Stryker is a Michigan corporation with its principal executive offices in Kalamazoo, Michigan. Stryker manufactures and distributes medical devices and products in more than 100 countries around the world. The Company \u0022made approximately $2.2 million in unlawful payments to various government employees including public health care professionals (collectively, the \u201cforeign officials\u201d) in Mexico, Poland, Romania, Argentina, and Greece. Stryker incorrectly described these expenses in the company\u2019s books and records as legitimate consulting and service contracts, travel expenses, charitable donations, or commissions, when in fact the payments were improperly made by Stryker to obtain or retain business. Stryker earned approximately $7.5 million in illicit profits as a result of these payments.\u0022 (Source: US Securities and Exchange Commission, In the Matter of Stryker Corporation, Administrative Proceeding File No. 3-15587, October 24, 2013.)","Sources ":"US Securities and Exchange Commission, In the Matter of Stryker Corporation, Administrative Proceeding File No. 3-15587, October 24, 2013, at https:\/\/www.sec.gov\/litigation\/admin\/2013\/34-70751.pdf","Documents":""},{"Case ID":"ST-517","Case Cluster ":"Subramanian Krishnan","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Unspecified (misconduct by Asia Pacific regional office)","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"9\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$60,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$60,000 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Internal Controls Violations","Offenses - Settled":"Internal Controls Violations","Public Procurement Contract \/ SOE Involved?":"No","Summary":"According to the US Securities and Exchange Commission, \u0022On September 28, 2012, the Securities and Exchange Commission filed a partially-settled civil injunctive action in the U.S. District Court for the District of Minnesota against Subramanian Krishnan (Krishnan). In its complaint, the Commission alleges that Krishnan, the former Chief Financial Officer (CFO) of Digi International, Inc. (Digi), engaged in conduct which resulted in the filing of inaccurate reports and accompanying certifications in Digi\u2019s annual quarterly reports from March 2005 through May 2010.\r\n \r\n Krishnan engaged in a course of conduct, as a result of which corporate funds were used to pay for unauthorized travel and entertainment\r\n expenses. Krishnan authorized such expenses for Digi employees, caused the Company to file inaccurate reports, failed to enforce Digi\u2019s internal controls, demonstrated a lack of management integrity, failed to act to reveal inaccurate reports, and wrongly certified that he evaluated the effectiveness of Digi\u2019s internal controls and disclosed they were effective.\u0022 (Source: SEC Litigation Release, \u0022SEC Charges Former CFO with Evading Internal Controls to Pay for Unauthorized Travel and Entertainment,\u0022 September 28, 2012.)","Sources ":"US SEC v. Subramanian Krishnan, Case No. 12-cv-2495 (D. Minn), Complaint filed September 28, 2012 and FInal Judgment of July 5, 2013, accessed via Pacer; SEC Litigation Release, \u0022SEC Charges Former CFO with Evading Internal Controls to Pay for Unauthorized Travel and Entertainment,\u0022 September 28, 2012, at https:\/\/www.sec.gov\/litigation\/litreleases\/2012\/lr22500.htm","Documents":""},{"Case ID":"ST-518","Case Cluster ":"Sweett Group","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"United Arab Emirates","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/19","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation, Legal Costs","Total Monetary Sanctions (US$)":"$3,358,610 ","Criminal Fine\/Penalty (US$) ":"$2,004,130 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$1,218,440 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$136,040 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Failure to Prevent Bribery","Offenses - Settled":"Failure to Prevent Bribery","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office, in February 2016, construction and professional services company \u0022Sweett Group PLC was sentenced and ordered to pay \u00a32.25 million as a result of a conviction arising from a Serious Fraud Office investigation into its activities in the United Arab Emirates.\r\n \r\nThe company pleaded guilty in December 2015 to a charge of failing to prevent an act of bribery intended to secure and retain a contract with Al Ain Ahlia Insurance Company (AAAI), contrary to Section 7(1)(b) of the Bribery Act 2010.\r\n \r\n The relevant conduct occurred between 1 December 2012 and 1 December 2015. [ ]\r\n \r\n His Honour Judge Beddoe described the offence as a system failure and said that the offending was patently committed over a period of time.\r\n \r\n Referring to Section 7 of the Bribery Act 2010 and to Sweett\u2019s ignorance of its subsidiary\u2019s actions , HHJ Bedoe said:\r\n \r\n The whole point of section 7 is to impose a duty on those running such companies throughout the world properly to supervise them. Rogue elements can only operate in this way \u2013 and operate for so long \u2013 because of a failure properly to supervise what they are doing and the way they are doing it.\r\n \r\n The SFO\u2019s investigation into Sweett Group PLC, which commenced on 14 July 2014, uncovered that its subsidiary company, Cyril Sweett International Limited had made corrupt payments to Khaled Al Badie, the Vice Chairman of the Board and Chairman of the Real Estate and Investment Committee of AAAI to secure the award of a contract with AAAI for the building of the Rotana Hotel in Abu Dhabi.\r\n \r\n The amount is broken down as \u00a31.4m in fine, \u00a3851,152.23 in confiscation. Additionally, \u00a395,031.97 in costs were awarded to the SFO.\r\n \r\n The judge ordered the confiscation order to be paid within three months. Half of the fine is to be paid by 19 February 2017 and the other half by 19 February 2018.\r\n \r\n The SFO\u2019s investigation into individuals continues.\u0022 (Source: UK Serious Fraud Office, \u0022Sweett Group PLC sentenced and ordered to pay \u00a32.25 million after Bribery Act conviction,\u0022 February 19, 2016.)","Sources ":"US Serious Fraud Office Press Release, \u0022Sweett Group PLC sentenced and ordered to pay [GBP] 2.25million after Bribery Act conviction,\u0022 February 19, 2016, at\r\n https:\/\/www.sfo.gov.uk\/2016\/02\/19\/sweett-group-plc-sentenced-and-ordered-to-pay-2-3-million-after-bribery-act-conviction\/","Documents":""},{"Case ID":"ST-519","Case Cluster ":"Tenam Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Russia","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"12\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$2,126,622.36 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$2,126,622.36 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy - Money Laundering; Conspiracy to Interfere with Interstate Commerce by Extortion","Offenses - Settled":"Conspiracy - Money Laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022A former Russian official residing in Maryland was sentenced [on December 15, 2015] to 48 months in prison for conspiracy to commit money laundering in connection with his role in arranging more than $2 million in corrupt payments to influence the awarding of contracts with a Russian state-owned nuclear energy corporation. [ ] \r\n  \r\nVadim Mikerin [ ] was also ordered to forfeit $2,126,622.36. [ ] \r\n \r\n According to court documents, Mikerin was the director of the Pan American Department of JSC Techsnabexport (TENEX), a subsidiary of Russia\u2019s State Atomic Energy Corporation and the sole supplier and exporter of Russian Federation uranium and uranium enrichment services to nuclear power companies worldwide, and the president of TENAM Corporation, a wholly owned subsidiary and the official representative of TENEX. Court documents show that between 2004 and October 2014, conspirators agreed to make corrupt payments to influence Mikerin and to secure improper business advantages for U.S. companies that did\r\n business with TENEX, in violation of the Foreign Corrupt Practices Act (FCPA). Mikerin admitted that he conspired with Daren Condrey, Boris Rubizhevsky and others to transmit approximately $2,126,622 from Maryland and elsewhere in the United States to offshore shell company bank accounts located in Cyprus, Latvia and Switzerland with the intent to promote the FCPA violations. Mikerin further admitted that the conspirators used consulting agreements and code words to disguise the corrupt payments.\u0022 \r\n \r\n Two other defendants in the case also pleaded guilty. Daren Condrey pleaded guilty on June 17, 2015, to conspiring to violate the Foreign Corrupt Practices Act (FCPA) and conspiring to commit wire fraud. Boris Rubizhevsky pleaded guilty on June 15,\r\n 2015, to conspiracy to commit money laundering. As of April 18, 2016, Mr. Condrey and Mr. Rubizhevsky appear to be awaiting sentencing. (Source: US v. Condrey, Case No. 15-cr-336 and US v. Rubizhevsky, Case No. 15-cr-332 (D. Md.), Court Docket Reports as of April 18, 2016, accessed via Pacer.)","Sources ":"US v. Mikherin, Case No. 14-cr-529 (D. Md.), Superseding Information, Plea Agreement and Department of Justice press Release, \u0022Former Russian Nuclear Energy Official Sentenced to 48 Months in Prison for Money Laundering Conspiracy Involving Foreign Corrupt Practices Act Violations,\u0022 December 15, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/vadim-mikerin; Court documents related to US v. Rubizhevsky at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/boris-rubizhevsky; US v. Condrey, at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/daren-condrey","Documents":""},{"Case ID":"ST-520","Case Cluster ":"Torvald Klaveness","Jurisdiction of Settlement":"Norway","Jurisdiction of Settlement \/ Enforcement Agency":"OKOKRIM","Jurisdiction of Foreign Public Official(s) ":"Bahrain","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"5\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Penalty Notice","Monetary Sanctions  (Types)":"Criminal Fine and Confiscation","Total Monetary Sanctions (US$)":"$5,401,300 ","Criminal Fine\/Penalty (US$) ":"$3,375,810 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$2,025,490 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a press statement issued by OKOKRIM, in the period July 2003-March 2004, Caburnes Chartering AS (parent company Torvald Klaveness) paid bribes to senior officials in connection with freight shipping agreements with Aluminum Bahrain BSC (ALBA), a majority state owned entity. (Source: OKOKRIM, \u0022Millionforelegg for bestikkelser,\u0022 last updated May 15, 2014.). See related entry, Alcoa settlements with the US Department of Justice and the Securities and Exchange Commission.","Sources ":"OKOKRIM, \u0022Millionforelegg for bestikkelser,\u0022 last updated May 15, 2014, at http:\/\/www.okokrim.no\/wwww-9k5f5x;\r\n \r\nOKOKRIM Annual Report 2014, at http:\/\/www.okokrim.no\/www\/okokrim\/resource.nsf\/files\/2545112408-okokrim_annualreport_2014\/$FILE\/okokrim_annualreport_2014.pdf","Documents":""},{"Case ID":"ST-521","Case Cluster ":"Total S.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iran","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"5\/29","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$245,200,000 ","Criminal Fine\/Penalty (US$) ":"$245,200,000 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials; Falsifcation of Books and Records; Internal Controls Violations","Offenses - Settled":"Conspiracy to Bribe Foreign Officials; Falsifcation of Books and Records; Internal Controls Violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, in 2013 Total SA agreed to a deferred prosecution agreement which stated in part, \u0022in 1995 Total sought to re-enter the Iranian oil and gas market by attempting to obtain a contract with the National Iranian Oil Company (NIOC) to develop the Sirri A and E oil and gas fields. In May 1995, Total entered into negotiations with an Iranian official who served as the Chairman of an Iranian state-owned and state-controlled engineering company. Total subsequently entered into a purported consulting agreement pursuant to which Total would corruptly make payments to an intermediary designated by the Iranian official to secure NIOC signing a development agreement with Total for the Sirri A and E project, which NIOC did in July 1995. Over the next two-and-a- half years, Total paid approximately $16 million in bribes under the purported consulting agreement. \r\n \r\n In 1997, Total sought to negotiate a contract with NIOC to develop a portion of the South Pars gas field, the world\u2019s largest gas field. At the direction of the Iranian official, Total and a second intermediary entered into another purported consulting agreement that called for Total to make large payments to the intermediary. In September 1997, Total executed a contract with NIOC that granted it a 40 percent interest in developing phases two and three of the South Pars gas field. Over the next seven years, Total made unlawful payments of approximately $44 million pursuant to the second purported consulting agreement. In sum, between 1995 and 2004, at the direction of the Iranian official, Total corruptly made approximately $60 million in bribe payments under the agreements for the purpose of inducing the Iranian official to use his influence in connection with Total\u2019s efforts to obtain and retain lucrative oil rights in the Sirri A and E and South Pars oil and gas fields. Total mischaracterized the unlawful payments as \u201cbusiness development expenses\u201d when they were, in fact, bribes designed to corruptly influence a foreign official. Further, Total failed to implement effective internal accounting controls, permitting the consulting agreements\u2019 true nature and true participants to be concealed and thereby failing to maintain accountability for assets.\u0022 (Source: US DOJ Press Release, \u0022French Oil and Gas Company, TOTAL, S.A., charged in the United States and France in connection with an international bribery scheme,\u0022 May 29, 2013.)","Sources ":"US v. Total SA, Case No. 1:13-cr-239 (EDVA), Information and Deferred Prosecution Agreement filed May 29, 2013 and DOJ Press Release, \u0022French Oil and Gas Company, TOTAL, S.A., charged in the United States and France in connection with an international bribery scheme,\u0022 May 29, 2013, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-total-sa-court-docket-number-113-cr-239.","Documents":""},{"Case ID":"ST-522","Case Cluster ":"Total S.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iran","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"5\/29","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profit","Total Monetary Sanctions (US$)":"$153,000,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$153,000,000 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, in 2013, the agency \u0022charged France-based oil and gas company Total S.A. with violating the Foreign Corrupt Practices Act (FCPA) by paying $60 million in bribes to intermediaries of an Iranian government official who then exercised his influence to help the company obtain valuable contracts to develop significant oil and gas fields in Iran.\r\n \r\n The SEC alleges that Total made more than $150 million in profits through the bribery scheme. Total attempted to cover up the true nature of the illegal payments by entering into sham consulting agreements with intermediaries of the Iranian official and mischaracterizing the bribes in its books and records as legitimate \u201cbusiness development expenses\u201d related to the consulting agreements. Total had inadequate systems to properly review the consulting agreements and lacked sufficient internal controls to comply with federal laws prohibiting bribery. [ ] \r\n \r\n Total negotiated a development contract in 1995 with the National Iranian Oil Company (NIOC) for the country\u2019s Sirri A and E oil and gas fields. Prior to executing the contract, Total held a meeting with the Iranian official and agreed to enter into a purported consulting agreement with an intermediary he designated. They agreed that Total would make payments to the intermediary under the guise of a consulting agreement when the real purpose was to induce the Iranian official to use his influence to help obtain NIOC\u2019s approval of the development agreement. After the contract was executed, Total corruptly made the bribery payments that resulted in NIOC allowing Total to develop the Sirri A and E oil and gas fields and make more than $150 million in profits.\u0022 (Source: SEC Press Release, \u0022SEC Charges Total S.A. for Illegal Payments to Iranian Official,\u0022 May 29, 2013.)","Sources ":"US Securities and Exchange Commission, In the Matter of Total S.A., Administrative Proceeding File No. 3-15338, at https:\/\/www.sec.gov\/litigation\/admin\/2013\/34-69654.pdf;\r\n \r\n SEC Press Release, \u0022SEC Charges Total S.A. for Illegal Payments to Iranian Official,\u0022 May 29, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171575006","Documents":""},{"Case ID":"ST-523","Case Cluster ":"Tyco International Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"9\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosection Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$13,680,000 ","Criminal Fine\/Penalty (US$) ":"$13,680,000 ","Criminal Fine \/ Penalty (Explanation)":"which includes $2.1 million fine imposed on its subsidiary Tyco Valve and Controls Middle East","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records","Offenses - Settled":"Falsification of Books and Records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, in 2012, Tyco International Ltd, a company based in Switzerland that manufactures and sells products related to security, fire protection and energy agreed to pay a $13.68 million penalty for falsifying books and records in connection with payments by its subsidiaries to government officials in various countries in order to obtain and retain business. [ ]  \r\n \r\nTyco Valves \u0026 Controls Middle East Inc. (TVC ME) \u2013 an indirect, wholly owned subsidiary of Tyco that sold and marketed valves and other industrial equipment throughout the Middle East for the oil, gas, petrochemical, commercial construction, water treatment and desalination industries \u2013 pleaded guilty [on September 24, 2012] for conspiring to violate the anti\u00adbribery provisions of the FCPA. According to the criminal information to which TVC ME pleaded guilty, the company paid bribes to officials employed by Saudi Aramco, an oil and gas company controlled and managed by the government of the Kingdom of Saudi Arabia, in order to obtain contracts with Saudi Aramco.\u0022 (Source: US Department of Justice Press Release, \u0022Subsidiary of Tyco International Ltd. Pleads Guilty, Is Sentenced for Conspiracy to Violate Foreign Corrupt Practices Act,\u0022 September 24, 2012.)","Sources ":"US Department of Justice, In re: Tyco International Ltd., Non-Proseccution Agreement, September 20, 2012 and Press Release, \u0022Subsidiary of Tyco International Ltd. Pleads Guilty, Is Sentenced for Conspiracy to Violate Foreign Corrupt Practices Act,\u0022 September 24, 2012, at https:\/\/www.justice.gov\/criminal-fraud\/case\/re-tyco-international-ltd-2012.","Documents":""},{"Case ID":"ST-524","Case Cluster ":"Tyco International Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Turkey","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"9\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$13,131,509 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$10,564,992 ","Civil Prejudgment Interest (US$) ":"$2,566,517 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials; Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, in 2012 the agency \u0022charged Tyco International Ltd. with violating the Foreign Corrupt Practices Act (FCPA) when subsidiaries arranged illicit payments to foreign officials in more than a dozen countries.\r\n \r\n The SEC alleges that subsidiaries of the Swiss-based global manufacturer perpetuated schemes that typically involved payments of fake \u201ccommissions\u201d or the use of third-party agents to funnel money improperly to obtain lucrative contracts. Overall, Tyco reaped illicit benefits amounting to more than $10.5 million as a result of the paid to win business.\r\n \r\n Tyco, whose securities are publicly traded in the U.S., agreed to pay more than $26 million to settle the SEC\u2019s charges and resolve a criminal matter announced today by the U.S. Department of Justice. [ ] \r\n \r\n The SEC alleges that Tyco subsidiaries operated 12 different illicit payment schemes around the world starting before 2006 and continuing until 2009. The most profitable scheme occurred in Germany, where agents of a Tyco subsidiary paid third parties to secure contracts or avoid penalties or fines in several countries. These payments were falsely recorded as \u201ccommissions\u201d in Tyco\u2019s books and records when they were in fact bribes to pay off government customers. Tyco\u2019s benefit as a result of these illicit payments was more than $4.6 million.\r\n \r\n According to the SEC\u2019s complaint, Tyco\u2019s subsidiary in China signed a contract with the Chinese Ministry of Public Security for $770,000 but reportedly paid approximately $3,700 to the \u201csite project team\u201d of a state-owned corporation to be able to obtain the contract. This amount was improperly recorded as a commission. Tyco\u2019s subsidiary in France recorded payments to individuals from 2005 to 2009 for \u201cbusiness introduction services.\u201d However, one of the individuals receiving payments was a security officer at a government-owned mining company in Mauritania, and many of the earlier payments were deposited in the official\u2019s personal bank account in France. In Thailand, Tyco\u2019s subsidiary had a contract to install a CCTV system in the Thai Parliament House in 2006, and paid more than $50,000 to a Thai entity that acted as a consultant. The invoice for the payment refers to \u201crenovation work,\u201d but Tyco is unable to ascertain what, if any, work was actually done.\r\n \r\n The SEC alleges that another scheme occurred in Turkey, where Tyco\u2019s subsidiary retained a New York City-based sales agent who made illicit payments involving the sale of microwave equipment in September 2006 to an entity controlled by the Turkish government. Employees at Tyco\u2019s subsidiary were well aware that the agent was paying foreign government customers to obtain orders. One internal e-mail stated, \u201cHell, everyone knows you have to bribe somebody to do business in Turkey. Nevertheless, I\u2019ll play it dumb if [the sales agent] should call.\u201d The benefit obtained by Tyco as a result of the September 2006 deal was $44,513.\u0022 (Source: US Securities and Exchange Commission, Litigation Release No. 22491, \u0022SEC Charges TYCO with Making Illicit Payments to Foreign Officials,\u0022 September 24, 2012.)","Sources ":"Securities and Exchange Commission v. Tyco International Ltd, 1:12-cv-01583 (D.D.C.), Complaint filed Sept. 24, 2012), at\r\n https:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-196.pdf; US Securities and Exchange Commission, Litigation Release No. 22491 \/ September 24, 2012, \u0022SEC Charges TYCO with Making Illicit Payments to Foreign Officials,\u0022 at https:\/\/www.sec.gov\/litigation\/litreleases\/2012\/lr22491.htm","Documents":""},{"Case ID":"ST-525","Case Cluster ":"Tyco International Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"9\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"Tyco Valve and Controls Middle East was fined $2.1 million but this amount was included in its parent company\u0027s fine","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, in 2012, Tyco International Ltd, a company based in Switzerland that manufactures and sells products related to security, fire protection and energy agreed to pay a $13.68 million penalty for \u0022falsifying books and records in connection with payments by its subsidiaries to government officials in various countries in order to obtain and retain business. [ ]  \r\n \r\n Tyco Valves \u0026 Controls Middle East Inc. (TVC ME) \u2013 an indirect, wholly owned subsidiary of Tyco that sold and marketed valves and other industrial equipment throughout the Middle East for the oil, gas, petrochemical, commercial construction, water treatment and desalination industries \u2013 pleaded guilty [on September 24, 2012] for conspiring to violate the anti\u00adbribery provisions of the FCPA. According to the criminal information to which TVC ME pleaded guilty, the company paid bribes to officials employed by Saudi Aramco, an oil and gas company controlled and managed by the government of the Kingdom of Saudi Arabia, in order to obtain contracts with Saudi Aramco.\u0022 (Source: US Department of Justice Press Release, \u0022Subsidiary of Tyco International Ltd. Pleads Guilty, Is Sentenced for Conspiracy to Violate Foreign Corrupt Practices Act,\u0022 September 24, 2012.)","Sources ":"US Department of Justice, In re: Tyco International Ltd., Nonproseccution Agreement, September 20, 2012 and Press Release, \u0022Subsidiary of Tyco International Ltd. Pleads Guilty, Is Sentenced for Conspiracy to Violate Foreign Corrupt Practices Act,\u0022 September 24, 2012, at https:\/\/www.justice.gov\/criminal-fraud\/case\/re-tyco-international-ltd-2012; \r\n \r\nUS v. Tyco Valves and Controls Middle East, Case No. 1:12-cr-00418-(EDVA), Information, Plea Agreement and Judgment at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-tyco-valves-and-controls-middle-east-inc-court-docket-number-112,","Documents":""},{"Case ID":"ST-526","Case Cluster ":"VimpelCom Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Uzbekistan","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/18","Other Jurisdictions of Settlement":"Netherlands","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine; Criminal Forfeiture","Total Monetary Sanctions (US$)":"$230,326,398 ","Criminal Fine\/Penalty (US$) ":"$190,326,398.40 ","Criminal Fine \/ Penalty (Explanation)":"Please see case summary for explanation.","Criminal Forfeiture \/ Confiscation (US$)":"$40,000,000 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"No (License)","Summary":"According to the US Department of Justice, \u0022Amsterdam-based VimpelCom Limited, the world\u2019s sixth largest telecommunications company and an issuer of publicly traded securities in the United States, and its wholly owned Uzbek subsidiary, Unitel LLC, entered into resolutions with the Department of Justice today in which they admitted to a conspiracy to make more than $114 million in bribery payments to a government official in Uzbekistan between 2006 and 2012 to enable them to enter and continue operating in the Uzbek telecommunications market. [ ] According to the companies\u2019 admissions, VimpelCom and Unitel, through various executives and employees, paid bribes to an Uzbek government official, who was a close relative of a high ranking government official and had influence over the Uzbek governmental body that regulated the telecom industry. The companies structured and concealed the bribes through various payments to a shell company that certain VimpelCom and Unitel management knew was beneficially owned by the foreign official. The bribes were paid on multiple\r\n occasions between approximately 2006 and 2012 so that VimpelCom could enter the Uzbek market and Unitel could gain valuable telecom assets and continue operating in Uzbekistan. VimpelCom and Unitel contemplated additional bribes in 2013, but those bribes were not completed before VimpelCom opened an internal investigation.\r\n In addition, VimpelCom admitted that it falsified its books and records and attempted to conceal and disguise the bribery scheme by classifying payments as equity transactions, consulting and repudiation agreements and reseller transactions. VimpelCom also failed to implement and enforce adequate internal accounting controls, which allowed the bribe payments to occur without detection or remediation. Moreover, when the board of directors sought an FCPA legal opinion assessing corruption risks involved in the transactions, certain VimpelCom management withheld crucial information from outside counsel performing the review that restricted the scope of FCPA opinions, rendering them worthless. Rather than implement and enforce a strong anticorruption ethic, certain VimpelCom executives sought ways to give the company plausible deniability of illegality while knowingly proceeding with corrupt business transactions.\u0022 (Source: US Department of Justice Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million\u037e United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016.) According to the Deferred Prosecution Agreement, the company agrees to pay $460,326,398.40, $40,000 of which will be paid as forfeiture; the amount was to be offset by sanctions paid to The Prosecution Service of the Netherlands, up to $230,326,398.40. As to the forfeited funds, the company \u0022acknowledges that at least $40,000,000 was proceeds of transactions in violation of the anti-bribery provisions of the FCPA.\u0022 (VimpelCom Deferred Prosecution Agreement, paras 8 and 9.)","Sources ":"US v. VimpelCom and US v. Unitel, Case No. 16-cr-17 (SDNY), Information filed in both on February 18, 2016, Vimpelcom Deferred Prosecution Agreement and Statement of Facts filed February 22, 2016 and Unitel Plea Agreement filed February 22, 2016, at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/vimpelcom;\r\n US Department of Justice Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million\u037e United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/NCB_First%20Global%20Accts_Notice%20Verified%20Claim%20by%20Uzbekistan_01252016.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Vimpelcom_CivilAssetForfeiture%20Complaint_Feb2016.pdf"},{"Case ID":"ST-527","Case Cluster ":"VimpelCom Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Uzbekistan","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/18","Other Jurisdictions of Settlement":"Netherlands","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement","Total Monetary Sanctions (US$)":"$167,500,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$167,500,000 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, falsification of books and records; internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (License)","Summary":"According to the US Securities and Exchange Commission Complaint, \u0022VimpeiCom Ltd (\u0022VimpelCom\u0022) is a corporation organized under the laws of Bermuda. VimpelCom was headquartered in Moscow, Russia until 2010, when it moved its headquarters to Amsterdam, the Netherlands. VimpelCom issues and maintains a class of publicly traded securities registered pursuant to Section 12(b) ofthe Securities Exchange Act of 1934, which are now traded on the NASDAQ, and were traded on the New York Stock Exchange prior to September 2013.\u0022 (Source: US v. VimpelCom Ltd., Complaint filed in Southern District of New York, at http:\/\/www.sec.gov\/litigation\/complaints\/2016\/comp-pr2016-34.pdf.)\r\n \r\n According to the SEC press release announcing the settlement with Vimpelcom, \u0022The SEC alleges that VimpelCom offered and paid bribes to an Uzbek government official related to the President of Uzbekistan as the company entered the Uzbek telecommunications market and sought government-issued licenses, frequencies, channels, and number blocks. At least $114 million in bribe payments were funneled through an entity affiliated with the Uzbek official, and approximately a half-million dollars in bribes were disguised as charitable donations made to charities directly affiliated with the Uzbek official. [ ] \r\n \r\n \u0027VimpelCom made massive revenues in Uzbekistan by paying over $100 million to an official with significant influence over top leaders of the Uzbek government,\u0027 said Andrew J. Ceresney, Director of the SEC Enforcement Division. \u0027These old-fashioned bribes, hidden through sham contracts and charitable contributions, left the company\u2019s books and records riddled with inaccuracies.\u0027 [ ] \r\n  \r\n The SEC\u2019s complaint was filed in U.S. District Court for the Southern District of New York. VimpelCom consented to the entry of a court order ordering the company to pay disgorgement and retain an independent monitor, and permanently enjoining the company from future violations of Sections 30A, 13(b)(2)(A), and 13(b)(2)(B) of the Securities Exchange Act of 1934. [ ] \r\n \r\n The SEC appreciates the significant assistance of the Department of Justice\u2019s Criminal Division, Fraud and Asset Forfeiture Money Laundering Sections as well as the following agencies: Internal Revenue Service, Department of Homeland Security, Public Prosecution Service of the Netherlands (Openbaar Ministrie), National Authority for Investigation and Prosecution of Economic and Environmental Crime in Norway (\u00d8KOKRIM), Swedish Prosecution Authority, Office of the Attorney General in Switzerland, and Corruption Prevention and Combating Bureau in Latvia. Other valuable assistance was provided by the British Virgin Islands Financial Services Commission, Caymans Islands Monetary Authority, Bermuda Monetary Authority, and Central Bank of Ireland, Estonia Financial Supervisory Authority (Finantsinspektioon), Comisi\u00f3n Nacional del Mercado de Valores (Spain), Latvian Financial and Capital Market Commission, UAE Securities and Commodities Authority, Banking Commission of the Marshall Islands, and Gibraltar Financial Services Commission.\u0022 The company was ordered by the SEC to pay $375 million in disgorgement, with $167.5 million to be paid to the Dutch authorities and $40 million in settlement with the US Department of Justice. (Sources: Securities and Exchange Commission Press Release, \u0022VimpelCom to Pay $795 Million in Global Settlement for FCPA Violations,\u0022 February 18, 2016; US v. VimpleCom, Case No. 16-cv-2016 (SDNY), Final Judgment filed February 22, 2016.)","Sources ":"US Securities and Exchange Commission v. VimpelCom Ltd., Case No. 1:16-cv-1266 (SDNY), Complaint, at http:\/\/www.sec.gov\/litigation\/complaints\/2016\/comp-pr2016-34.pdf and FInal Judgment filed February 22, 2016, accessed at Pacer; Securities and Exchange Commission Press Release, \u0022VimpelCom to Pay $795 Million in Global Settlement for FCPA Violations,\u0022 February 18, 2016, at http:\/\/www.sec.gov\/news\/pressrelease\/2016-34.html","Documents":""},{"Case ID":"ST-528","Case Cluster ":"VimpelCom Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Uzbekistan","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/22","Other Jurisdictions of Settlement":"Netherlands","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"See related case, VimpelCom Limited","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"No (License)","Summary":"According to the US Department of Justice, \u0022Amsterdam-based VimpelCom Limited, the world\u2019s sixth-largest telecommunications company and an issuer of publicly traded securities in the United States, and its wholly owned Uzbek subsidiary, Unitel LLC, entered into resolutions with the Department of Justice today in which they admitted to a conspiracy to make more than $114 million in bribery payments to a government official in Uzbekistan between 2006 and 2012 to enable them to enter and continue operating in the Uzbek telecommunications market.\r\n[ ] VimpelCom and Unitel, through various executives and employees, paid bribes to an Uzbek government official, who was a close relative of a high-ranking government official and had influence over the Uzbek governmental body that regulated the telecom industry. The companies structured and concealed the bribes through various payments to a shell company that certain VimpelCom and Unitel management knew was beneficially owned by the foreign official. The bribes were paid on multiple occasions between approximately 2006 and 2012 so that VimpelCom could enter the Uzbek market and Unitel could gain valuable telecom assets and continue operating in Uzbekistan. VimpelCom and Unitel contemplated additional bribes in 2013, but those bribes were not completed before VimpelCom opened an internal investigation.\u0022 (Source: DOJ Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million; United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016.) According to the Unitel Plea Agreement, given the complexities of the overall disposition and the interrelationship between VimpelCom and Unitel and the monetary sanctions imposed on VimpelCom by the US and Dutch authorities, it was agreed that no financial penalties would be imposed on Unitel. (Source: US v. Unitel LLC, Case No. 16-cr-1737 (SDNY), Plea Agreement filed February 22, 2016, at 8.)","Sources ":"US v. Unitel LLC, Case No. 16-cr-1737 (SDNY), Information filed February 18, 2016 and Plea Agreement filed February 22, 2016, at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/vimpelcom;\r\n \r\nDOJ Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million; United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016, at https:\/\/www.justice.gov\/opa\/pr\/vimpelcom-limited-and-unitel-llc-enter-global-foreign-bribery-resolution-more-795-million","Documents":""},{"Case ID":"ST-529","Case Cluster ":"VimpelCom Limited","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Openbaar Ministrie (Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Uzbekistan","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"2\/18","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Out of Court Settlement","Monetary Sanctions  (Types)":"Criminal Fine; Criminal Confiscation","Total Monetary Sanctions (US$)":"$397,500,000 ","Criminal Fine\/Penalty (US$) ":"$100,000,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$297,500,000 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, falsification of books and records; internal controls violations","Offenses - Settled":"Bribery of foreign officials, falsification of books and records; internal controls violations","Public Procurement Contract \/ SOE Involved?":"No (License)","Summary":"According to the Press Release issued by the Openbaar Ministrie (Public Prosecution Service, DPP), \u0022The criminal investigation was initiated in 2013. The Dutch criminal investigation was carried out by the FIOD under supervision of the National Prosecutor\u2019s Office for Serious Fraud, Environmental Crime and Asset Confiscation (\u201cFunctioneel Parket\u201d). During the investigation, Vimpelcom\u2019s head office in Amsterdam was searched in March 2014. Vimpelcom has initiated its own investigation into its activities in Uzbekistan. This investigation was conducted by internal investigators, by an American specialized law firm and by forensic accountants. Both the DPPS and the US authorities were regularly informed about the results of this internal investigation. [ ]\u0022 VipelCom was fined US$!00 million and subject to confiscation of illegally obtained proceeds totaling US$130 million; US$167.5 million was confiscated from its subsidiary Unitel. (Source: Openbaar Ministrie, Vimpelcom pays close to 400 million dollars to the Netherlands for bribery in Uzbekistan,\u0022 February 16, 2016. See also, Statement of Facts. Both at https:\/\/www.om.nl\/algemeen\/english\/@93227\/vimpelcom-pays-close\/) The US Department of Justice press release stated that \u0022Under the terms of its resolution with the SEC, VimpelCom agreed to a total of $375 million in disgorgement of profits and prejudgment interest, to be divided between the SEC and OM.\u0022 (Source: US DOJ Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million\u037e United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016.)","Sources ":"Openbaar Ministrie, Vimpelcom pays close to 400 million dollars to the Netherlands for bribery in Uzbekistan,\u0022 February 16, 2016. See also, Statement of Facts (link to downloadable PDF), at https:\/\/www.om.nl\/algemeen\/english\/@93227\/vimpelcom-pays-close\/; US DOJ Press Release, \u0022VimpelCom Limited and Unitel LLC Enter into Global Foreign Bribery Resolution of More Than $795 Million\u037e United States Seeks $850 Million Forfeiture in Corrupt Proceeds of Bribery Scheme,\u0022 February 18, 2016","Documents":""},{"Case ID":"ST-530","Case Cluster ":"Weatherford International Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food); Unspecified Africa and Middle East countries","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"11\/26","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$87,178,256 ","Criminal Fine\/Penalty (US$) ":"$87,178,256 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations","Offenses - Settled":"Internal controls violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Weatherford Services Limited (Weatherford Services), a subsidiary of Weatherford International, today agreed to plead guilty to violating the anti-bribery provisions of the FCPA. As part of a coordinated FCPA resolution, the department today also filed a criminal information in U.S. District Court for the Southern District of Texas charging Weatherford International with one count of violating the internal controls provisions of the FCPA. To resolve the charge, Weatherford International has agreed to pay an $87.2 million criminal penalty as part of a deferred prosecution agreement with the department. [ ] \r\n  \r\n In a separate matter, Weatherford International and four of its subsidiaries today agreed to pay a combined $100 million to resolve a criminal and administrative export controls investigation conducted by the U.S. Attorney\u2019s Office for the Southern District of Texas, the Department of Commerce\u2019s Bureau of Industry and Security, and the Department of the Treasury\u2019s Office of Foreign Assets Control. As part of the resolution of that investigation, Weatherford International has agreed to enter into a deferred prosecution agreement for a term of two years and two of its subsidiaries have agreed to plead guilty to export controls charges. [ ] \r\n  \r\n The combined investigations resulted in the conviction of three Weatherford subsidiaries, the entry by Weatherford International into two deferred prosecution agreements and a civil settlement, and the payment of a total of $252,690,606 in penalties and fines. \r\n \r\n FCPA Violations\r\n \r\n According to court documents filed by the department, prior to 2008, Weatherford International knowingly failed to establish an effective system of internal accounting controls designed to detect and prevent corruption, including FCPA violations. The company failed to implement these internal controls despite operating in an industry with a substantial corruption risk profile and despite growing its global footprint in large part by purchasing existing companies, often themselves in countries with high corruption risks. As a result, a permissive and uncontrolled environment existed within which employees of certain of Weatherford International\u2019s wholly owned subsidiaries in Africa and the Middle East were able to engage in corrupt conduct over the course of many years, including both bribery of foreign officials and fraudulent misuse of the United Nations\u2019 Oil for Food Program.\r\n \r\n Court documents state that Weatherford Services employees established and operated a joint venture in Africa with two local entities controlled by foreign officials and their relatives from 2004 through at least 2008. The foreign officials selected the entities with which Weatherford Services would partner, and Weatherford Services and Weatherford International employees knew that the members of the local entities included foreign officials\u2019 relatives and associates. Notwithstanding the fact that the local entities did not contribute capital, expertise or labor to the joint venture, neither Weatherford Services nor Weatherford International investigated why the local entities were involved in the joint venture. The sole purpose of those local entities, in fact, was to serve as conduits through which Weatherford Services funneled hundreds of thousands of dollars in payments to the foreign officials controlling them. In exchange for the payments they received from Weatherford Services through the joint venture, the foreign officials awarded the joint venture lucrative contracts, gave Weatherford Services inside information about competitors\u2019 pricing, and took contracts away from Weatherford Services\u2019 competitors and awarded them to the joint venture.\r\n \r\n Additionally, Weatherford Services employees in Africa bribed a foreign official so that he would approve the renewal of an oil services contract, according to court documents. Weatherford Services funneled bribery payments to the foreign official through a freight forwarding agent it retained via a consultancy agreement in July 2006. Weatherford Services generated sham purchase orders for consulting services the freight forwarding agent never performed, and the freight forwarding agent, in turn, generated sham invoices for those same nonexistent services. When paid for those invoices, the freight forwarding agent passed at least some of those monies on to the foreign official with the authority to approve Weatherford Services\u2019 contract renewal. In exchange for these payments, the foreign official awarded the renewal contract to Weatherford Services in 2006.\r\n \r\n Further, according to court documents, in a third scheme in the Middle East, from 2005 through 2011, employees of Weatherford Oil Tools Middle East Limited (WOTME), another Weatherford International subsidiary, awarded improper \u201cvolume discounts\u201d to a distributor who supplied Weatherford International products to a government-owned national oil company, believing that those discounts were being used to create a slush fund with which to make bribe payments to decision-makers at the national oil company. Between 2005 and 2011, WOTME paid approximately $15 million in volume discounts to the distributor.\u0022(Source: US DOJ Press Release, \u0022Three Subsidiaries of Weatherford International Limited Agree to Plead Guilty to FCPA and Export Control Violations,\u0022 November 26, 2013.)","Sources ":"US v. Weatherford International Limited, Case No. 13-cr-733 (S.D. Tex), Information and Deferrred Prosecution Agreement filed November 26, 2013 and DOJ Press Release, \u0022Three Subsidiaries of Weatherford International Limited Agree to Plead Guilty to FCPA and Export Control Violations,\u0022 November 26, 2013, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-weatherford-international-ltd-court-docket-number-13-cr-733","Documents":""},{"Case ID":"ST-531","Case Cluster ":"Weatherford International Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Congo (Republic of), Iraq (UN Oil-for-Food), Angola, Algeria, Albania","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"11\/26","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$65,612,360.34 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$59,337,937 ","Civil Prejudgment Interest (US$) ":"$4,399,423.34 ","Civil Fine \/ Penalty (US$)":"1,875,000","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, falsification of books and records; internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes; No (Tax)","Summary":"According to the US Securities and Exchange Commission, Weatherford International, an oil services company\u0027s \u0022misconduct occurred from at least 2002 to 2011. In Angola, for example, Weatherford\u2019s legal department permitted its subsidiary to use an agent who insisted that an FCPA clause be omitted from the consultancy agreement. The company took no steps to determine whether the agent was paying bribes to foreign officials, and the agent used sham work orders and invoices to pay bribes that ensured the renewal of a lucrative oil services contract for Weatherford in Angola. The same agent made illicit payments to obtain commercial contracts for Weatherford in Congo. The company also allowed its subsidiary to enter into a joint venture agreement with companies whose beneficial owners included Angolan oil company officials and a relative of an Angolan Minister in order to win business. A Weatherford employee reported in a 2006 ethics questionnaire that Weatherford personnel were making payments to government officials in Angola and elsewhere, but the company failed to investigate. \r\n \r\n The SEC\u2019s complaint also alleges that Weatherford failed to perform due diligence on a distributor suggested by an official at a national oil company in the Middle East. From 2005 to 2011, Weatherford and its subsidiaries awarded more than $11.8 million in improper \u201cvolume discounts\u201d to the distributor \u2013 money intended for the creation of a slush fund to pay foreign officials. \r\n \r\n According to the SEC\u2019s complaint, the misconduct went beyond the use of agents or other third parties. Weatherford provided improper travel and entertainment to officials of a state-owned company in Algeria with no legitimate business purpose. For example, Weatherford paid for a 2006 FIFA World Cup trip by two of the officials, the July 2006 honeymoon of an official\u2019s daughter, and an October 2005 religious trip to Saudi Arabia by an official and his family that was improperly recorded as a donation in Weatherford\u2019s books and records. Weatherford\u2019s Middle East subsidiary also made more than $1.4 million in improper payments to obtain nine contracts under the Oil-for-Food program in 2002. Iraqi ministries demanded improper \u201cinland transportation fees\u201d in an effort to subvert the UN program. Weatherford\u2019s subsidiary complied with the Iraqi demands and paid more than $115,000 in fees despite invoices that included charges inconsistent with the actual deliveries. Weatherford obtained more than $7 million in profits from the misconduct.\r\n \r\n The SEC further alleges that managers at Weatherford\u2019s subsidiary in Italy flouted the lack of internal controls and misappropriated more than $200,000 in company funds, some of which was improperly paid to Albanian tax auditors. The managers misreported cash advances, diverted payments on previously paid invoices, misappropriated government rebate checks, and received reimbursement for such purchases as golf equipment and perfume that did not relate to business activities. \r\n \r\n According to the SEC\u2019s complaint, Weatherford employees created false accounting and inventory records from 2002 to 2007 to hide the illegal commercial sales to Cuba, Syria, Sudan, and Iran. During this time period, exporting or re-exporting goods or services from the U.S. to these sanctioned countries was prohibited. The falsified financial statements and books and records of Weatherford subsidiaries involved in the misconduct were consolidated into the financial statements of the parent company.\u0022 (Source: SEC Press Release, \u0022SEC Charges Weatherford International With FCPA Violations,\u0022 November 26, 2013.)\r\n \r\n According to the Judgment in the case, the company \u0022is liable for disgorgement of $90,984,844 representing profits gained as a result of the conduct alleged in the Complaint, together with prejUdgment interest thereon in the amount of $4,399,423.34 for a total of $95,384,267.34 (\u0022disgorgement obligation\u0022). A portion of the Defendant\u0027s disgorgement obligation in the amount of $31,646,907 shall be deemed satisfied by Defendant\u0027s entry into a written Deferred Prosecution Agreement (\u0022DPA\u0022) with the U.S.\r\n Attorney\u0027s Office for the Southern District of Texas, wherein Defendant agrees to make a payment in an amount greater than or equal to $31,646,907 within one year of the entry of the Final Judgment. In the event that Defendant\u0027s DP A requires a payment less than $31,646,907, the Defendant acknowledges that its disgorgement obligation will be credited up to the amount of the payment required by the DP A, with the remaining balance due and payable to the SEC within 14 days of payment pursuant to the DP A in the parallel criminal proceeding. Defendant is also liable for a civil penalty in the amount of$I,875,000 pursuant to Section 21(d)(3) of the Exchange Act [15 U.S.c. \u00a7 78u(d)(3)]. Defendant shall satisfy this obligation by paying $1,875,000 within 14 days after entry of this Final Judgment.\u0022 (US SEC v. Weatherford International Ltd., Case No. 13-cv-3500, Judgment filed December 19, 2013.)","Sources ":"US Securities and Exchange Commission v. Weatherford International Ltd., Case No. 13-cv-3500 (S.D. Tex.), Complaint filed November 26, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-252.pdf; Judgment accessed via Pacer; SEC Press Release, \u0022SEC Charges Weatherford International With FCPA Violations,\u0022 November 26, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370540415694","Documents":""},{"Case ID":"ST-532","Case Cluster ":"Weatherford International Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Angola","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"11\/26","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$420,000.00 ","Criminal Fine\/Penalty (US$) ":"$420,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0","Criminal Restitution \/ Reparation (US$)":" $0","Criminal Legal \/ Procedural Costs (US$)":"$0","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Weatherford Services Limited (Weatherford Services), a subsidiary of Weatherford International, today agreed to plead guilty to violating the anti-bribery provisions of the FCPA. [ ] Court documents state that Weatherford Services employees established and operated a joint venture in Africa with two local entities controlled by foreign officials and their relatives from 2004 through at least 2008. The foreign officials selected the entities with which Weatherford Services would partner, and Weatherford Services and Weatherford International employees knew that the members of the local entities included foreign officials\u2019 relatives and associates. Notwithstanding the fact that the local entities did not contribute capital, expertise or labor to the joint venture, neither Weatherford Services nor Weatherford International investigated why the local entities were involved in the joint venture. The sole purpose of those local entities, in fact, was to serve as conduits through which Weatherford Services funneled hundreds of thousands of dollars in payments to the foreign officials controlling them. In exchange for the payments they received from Weatherford Services through the joint venture, the foreign officials awarded the joint venture lucrative contracts, gave Weatherford Services inside information about competitors\u2019 pricing, and took contracts away from Weatherford Services\u2019 competitors and awarded them to the joint venture.\r\n \r\n Additionally, Weatherford Services employees in Africa bribed a foreign official so that he would approve the renewal of an oil services contract, according to court documents. Weatherford Services funneled bribery payments to the foreign official through a freight forwarding agent it retained via a consultancy agreement in July 2006. Weatherford Services generated sham purchase orders for consulting services the freight forwarding agent never performed, and the freight forwarding agent, in turn, generated sham invoices for those same nonexistent services. When paid for those invoices, the freight forwarding agent passed at least some of those monies on to the foreign official with the authority to approve Weatherford Services\u2019 contract renewal. In exchange for these payments, the foreign official awarded the renewal contract to Weatherford Services in 2006.\u0022 (Source: US DOJ Press Release, \u0022Three Subsidiaries of Weatherford International Limited Agree to Plead Guilty to FCPA and Export Control Violations,\u0022 November 26, 2013.) The Information and Plea Agreement filed in US v. Weatherford Services Limited identifies the African country as Angola. (Source: US v. Weatherford Services Limited, Case No. 13-cr-734 (S.D. Tex), Information and Plea Agreement filed November 26, 2013.)","Sources ":"US v. Weatherford Services Limited, Case No. 13-cr-734 (S.D. Tex), Information and Plea Agreement filed November 26, 2013 and DOJ Press Release, \u0022Three Subsidiaries of Weatherford International Limited Agree to Plead Guilty to FCPA and Export Control Violations,\u0022 November 26, 2013, at https:\/\/www.justice.gov\/opa\/pr\/three-subsidiaries-weatherford-international-limited-agree-plead-guilty-fcpa-and-export.","Documents":""},{"Case ID":"ST-533","Case Cluster ":"Yara International ASA","Jurisdiction of Settlement":"Nigeria, Norway","Jurisdiction of Settlement \/ Enforcement Agency":"OKOKRIM","Jurisdiction of Foreign Public Official(s) ":"India, Libya","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"1\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Penalty Notice","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$44,182,500 ","Criminal Fine\/Penalty (US$) ":"$44,182,500 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.17","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign public officials","Offenses - Settled":"Bribery of Foreign Public Officials","Public Procurement Contract \/ SOE Involved?":"Not specified","Summary":"According to the press release by Yara International, \u0022The Board of Yara International ASA has informed the Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime (\u00d8kokrim) that the company acknowledges guilt and accepts a corporate fine and confiscation totalling NOK 295 million. This relates to agreements dating back to 2007 and earlier.\r\n In April 2011 Yara International ASA launched an external investigation and concurrently notified \u00d8kokrim of possible irregularities. The main findings of the external investigation were published in June 2012. [ ] The fine of NOK 270 million is related to historical irregularities linked to the establishment of Lifeco (Libya), an unrealized project in India and Yara\u0027s activities in Switzerland. In addition \u00d8kokrim has imposed a confiscation of NOK 25 million related to earlier phosphate deliveries.\u0022 (Source: YARA International ASA Media Release, \u0022Yara accepts corporate penalty,\u0022 January 15, 2014.)","Sources ":"http:\/\/www.okokrim.no\/wwww-9fdaqu;\r\n \r\n YARA International ASA Media Release, \u0022Yara accepts corporate penalty,\u0022 January 15, 2014, at http:\/\/yara.com\/media\/press_releases\/1754700\/press_release\/201401\/yara-accepts-corporate-penalty\/; \r\n \r\n See also, The Nordic Page, \u0022The Biggest Corruption Trial in Norway Continues,\u0022 January 6, 2015, at http:\/\/www.tnp.no\/norway\/economy\/4769-biggest-corruption-trial-in-norway-continues-india-libya-yara-bribe;","Documents":""},{"Case ID":"ST-397","Case Cluster ":"Alcoa \/ Aluminum Bahrain (ALBA)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Bahrain","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"1\/9","Other Jurisdictions of Settlement":"United Kingdom (Bruce Hall only)","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$223,000,000 ","Criminal Fine\/Penalty (US$) ":"$209,000,000 ","Criminal Fine \/ Penalty (Explanation)":"Owing to \u0022undue burden\u0022 to the company, fine to be paid in five annual installments of $41,800,000; forfeiture to IRS","Criminal Forfeiture \/ Confiscation (US$)":"$14,000,000 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice press release announcing the plea agreement, \u0022Alcoa World Alumina has agreed to plead guilty in the Western District of Pennsylvania to one count of violating the antibribery provisions of the FCPA in connection with a 2004 corrupt transaction, to pay a criminal fine of $209 million, and to administratively forfeit $14 million. [ ] As admitted in the charging documents, in 2004, Alcoa World Alumina corruptly secured a long-term alumina supply agreement with Alba by agreeing to purportedly sell over 1.5 million metric tons of alumina to Alba [Aluminium Bahrain B.S.C.] through offshore shell companies owned by Consultant A. The sham distributorship permitted Consultant A to mark up the price of alumina by approximately $188 million from 2005 to 2009, the duration of the corrupt supply agreement. Court filings allege that Consultant A used the markup to pay tens of millions in corrupt kickbacks to Bahraini government officials, including senior members of Bahrain\u2019s Royal Family. To conceal the illicit payments, Consultant A and the government officials used various offshore bank accounts, including accounts held under aliases, at several major financial institutions around the world, including in Guernsey, Luxembourg, Liechtenstein and Switzerland.\u0022 (Source: US Department of Justice Press Release, \u0022Alcoa World Alumina Agrees to Plead Guilty to Foreign Bribery and Pay $223 Million in Fines and Forfeiture,\u0022 January 9, 2014.)","Sources ":"US v. Alcoa World Alumina LLC, Case No. 4-cr-7 (WDPA), Information, Plea Agreement and Judgment filed on January 9, 2014 and\r\n US Department of Justice Press Release, \u0022Alcoa World Alumina Agrees to Plead Guilty to Foreign Bribery and Pay $223 Million in Fines and Forfeiture,\u0022 January 9, 2014, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-alcoa-world-alumina-llc-court-docket-number-14-cr-00007-dwa","Documents":""},{"Case ID":"ST-398","Case Cluster ":"Alcoa \/ Aluminum Bahrain (ALBA)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Bahrain","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"1\/9","Other Jurisdictions of Settlement":"United Kingdom (Bruce Hall only)","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement","Total Monetary Sanctions (US$)":"$161,000,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$161,000,000 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Falsification of books and records; Internal controls violations,","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Press Release announcing the Cease and Desist Order issued against Alcoa Inc., \u0022An SEC investigation found that more than $110 million in corrupt payments were made to Bahraini officials with influence over contract negotiations between Alcoa and a major government-operated aluminum plant. Alcoa\u2019s subsidiaries used a London-based consultant with connections to Bahrain\u2019s royal family as an intermediary to negotiate with government officials and funnel the illicit payments to retain Alcoa\u2019s business as a supplier to the plant. Alcoa lacked sufficient internal controls to prevent and detect the bribes, which were improperly recorded in Alcoa\u2019s books and records as legitimate commissions or sales to a distributor. [ ] Alcoa will pay $175 million in disgorgement of ill-gotten gains, of which $14 million will be satisfied by the company\u2019s payment of forfeiture in the parallel criminal matter. Alcoa also will pay a criminal fine of $209 million.\u0022 (Source: US Securities and Exchange Press Release, \u0022SEC Charges Alcoa With FCPA Violations,\u0022 January 9, 2014.) Please note that the $14 million was administratively forfeited to the Internal Revenue Service; the disgorgement was to be paid in five annual installments. (Source: US Securities and Exchange Commission, In the Matter of Alcoa Inc. Cease and Desist Order, Administrative Proceeding File No. 3-15673, January 9, 2014)","Sources ":"US Securities and Exchange Cease and Desist Order in the Matter of Alcoa Inc. Administrative Proceeding File No. 3-15673, January 9, 2014 at http:\/\/www.sec.gov\/litigation\/admin\/2014\/34-71261.pdf; SEC Press Release, \u0022SEC Charges Alcoa With FCPA Violations,\u0022 January 9, 2014, at http:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370540596936","Documents":""},{"Case ID":"ST-399","Case Cluster ":"Alcoa \/ Aluminum Bahrain (ALBA)","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Bahrain","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"7\/22","Other Jurisdictions of Settlement":"United States (Alcoa only)","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Confiscation, criminal restitution, logal costs","Total Monetary Sanctions (US$)":"$7,168,324 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$6,143,560 ","Criminal Restitution \/ Reparation (US$)":"$853,970 ","Criminal Legal \/ Procedural Costs (US$)":"$170,794 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to corrupt; Corruption; Acquire and transfer criminal property","Offenses - Settled":"Conspiracy to corrupt","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office, \u0022Bruce Hall was today sentenced to 16 months in prison for conspiracy to corrupt, in relation to contracts\r\n Bruce Hall was today sentenced to 16 months in prison for conspiracy to corrupt, in relation to contracts for the supply of goods and services to a Bahraini company, Aluminium Bahrain B.S.C. (Alba). Mr Hall served as CEO of Alba, from September 2001 to June 2005.\r\n \r\n Judge Loraine Smith, who presided over the hearing, heard how Mr Hall received \u00a32.9 million in corrupt\r\n payments between 2002 and 2005, including 10,000 Bahraini dinars in cash from Sheikh Isa bin Ali Al\r\n Khalifa, a member of the Bahraini royal family and at the time Bahrain\u2019s minister of finance and Alba\u2019s\r\n chairman. The payments were made in exchange for Mr Hall agreeing to and allowing corrupt arrangements that Sheikh Isa had been involved in before Mr Hall\u2019s appointment as CEO to continue.\r\n As a result of these corrupt payments, Mr Hall will need to pay a confiscation order of \u00a33,070,106.03 in\r\n seven days or face serving an additional term of imprisonment of 10 years. Mr Hall must, in addition to\r\n the confiscation order, pay Alba compensation in the amount of \u00a3500,010 and pay \u00a3100,000 as a\r\n contribution to prosecution costs.\r\n [ ] As part of Mr Hall\u2019s mitigation he also agreed to divest himself of other corrupt payments he received\r\n during his time as the CEO of Alba. These payments were not part of the indictment as the SFO did not\r\n have the jurisdiction to prosecute for the conduct acknowledged by Mr Hall. In order to recover these\r\n payments received by Mr Hall, which amount to US$900,000, the Director of the SFO elected to launch\r\n proceedings under Part 5 of the Proceeds of Crime Act 2002 in the High Court. These proceedings were\r\n finalised at the High Court on 17 July 2014 but could not be made public until the start of the Mr Hall\u2019s\r\n sentencing hearing yesterday.\u0022 (Source: UK Serious Fraud Office Press Office, \u0022Bruce Hall sentenced to 16 months in prison,\u0022 July 22, 2014.)","Sources ":"UK Serious Fraud Office Press Office, \u0022Bruce Hall sentenced to 16 months in prison,\u0022 July 22, 2014, at https:\/\/www.sfo.gov.uk\/2014\/07\/22\/bruce-hall-sentenced-16-months-prison\/;\r\n \r\n See also, US Securities and Exchange Cease and Desist Order in the Matter of Alcoa Inc. Administrative Proceeding File No. 3-15673, January 9, 2014 at http:\/\/www.sec.gov\/litigation\/admin\/2014\/34-71261.pdf; SEC Press Release, \u0022SEC Charges Alcoa With FCPA Violations,\u0022 January 9, 2014, at http:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370540596936","Documents":""},{"Case ID":"ST-400","Case Cluster ":"Allianz SE","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"12\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profit, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$12,396,423 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$5,315,649 ","Civil Prejudgment Interest (US$) ":"$1,765,125 ","Civil Fine \/ Penalty (US$)":"$5,315,649 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records; Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Press Release announcing the Cease and Desist Order, \u0022These proceedings arise out of violations of the books and records and internal controls provisions of the Foreign Corrupt Practices Act (\u201cFCPA\u201d) by Allianz SE (\u201cAllianz\u201d or the \u201cCompany\u201d), through its Indonesian majority-owned subsidiary, PT Asuransi Allianz Utama (\u201cUtama\u201d). Between 2001 and 2008, Utama managers made improper payments to employees of state-owned entities in Indonesia in order to obtain and retain business. Allianz learned of the improper payments from two complaints made several years apart. The first complaint was submitted in 2005 alleging significant misconduct, including unsupported payments to agents. A subsequent audit of Utama\u2019s accounting records uncovered that managers at Utama were using \u201cspecial purpose accounts\u201d to make illicit payments, many to government officials, in order to secure business in Indonesia. Despite the audit, the conduct continued. The second complaint was lodged in 2009 to Allianz\u2019s external auditors and alleged that Allianz created illicit off-the-books accounts. In response, Allianz began an internal investigation. The Commission staff opened an investigation in April 2010 after receiving an anonymous complaint of possible FCPA violations. The investigation determined that from at least 2001 through December 2008, the Utama managers, with the assistance of others in the Indonesian office, made payments to employees of state-owned entities in Indonesia to procure or retain insurance contracts related to large government projects in Indonesia. As a result of improper payments of approximately $650,626 to agents and employees of state-owned entities and others, Allianz realized $5,315,649 in profits.\u0022 The SEC\u2019s order found that Allianz violated the books and records and internal controls provisions of the FCPA, specifically Sections 13(b)(2)(A) and 13(b)(2)(B) of the Securities Exchange Act of 1934. Without admitting or denying the findings, Allianz agreed to cease and desist from further violations and pay disgorgement of $5,315,649, prejudgment interest of $1,765,125, and a penalty of $5,315,649 for a total of $12,396,423. (Source: US Securities and Exchange Commission, In the Matter of Allianz SE, Inc. Cease and Desist Order, Administrative Proceeding File No. 3-15132, December 17, 2012.)","Sources ":"US Securities and Exchange Commission, In the Matter of Allianz SE, Inc. Cease and Desist Order, Administrative Proceeding File No. 3-15132, December 17, 2012, at http:\/\/www.sec.gov\/litigation\/admin\/2012\/34-68448.pdf; SEC Press Release, \u0022SEC Charges Germany-Based Allianz SE with FCPA Violations,\u0022 at http:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171486902","Documents":""},{"Case ID":"ST-401","Case Cluster ":"Alstom","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Egypt","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"11\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"Criminal Fine to be paid by Alstom S.A. (parent company)","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Alstom S.A., a French power and transportation company, was sentenced in November 2015 to pay a $772,290,000 fine to resolve criminal charges related to a widespread corruption scheme involving at least $75 million in secret bribes paid to government officials in countries around the world. According to the Department of Justice, Alstom and its subsidiaries - Alstom Prom, Alstom Power and Alstom T\u0026D - \u0022through various executives and employees, paid bribes to government officials and falsified books and records in connection with power, grid and transportation projects for state-owned entities around the world, including in Indonesia, Egypt, Saudi Arabia, the Bahamas and Taiwan. In Indonesia, for example, Alstom, Alstom Prom and Alstom Power paid bribes to government officials\u2014including a high-ranking member of the Indonesian Parliament and high-ranking members of Perusahaan Listrik Negara, the state-owned electricity company in Indonesia\u2014in exchange for assistance in securing several contracts to provide power related services valued at approximately $375 million. In total, Alstom paid more than $75 million to secure more than $4 billion in projects around the world, with a profit to the company of approximately $300 million.\r\n \r\n Alstom and its subsidiaries also attempted to conceal the bribery scheme by retaining consultants who purportedly provided consulting services on behalf of the companies, but who actually served as conduits for corrupt payments to the government officials. Internal Alstom documents refer to some of the consultants in code, including \u201cMr. Geneva,\u201d \u201cMr. Paris,\u201d \u201cLondon,\u201d \u201cQuiet Man\u201d and \u201cOld Friend.\u201d\r\n \r\n The sentence, which is the largest criminal fine ever imposed in an FCPA case, reflects a number of factors, including: Alstom\u2019s failure to voluntarily disclose the misconduct, even though it was aware of related misconduct at a U.S. subsidiary that previously resolved corruption charges with the department in connection with a power project in Italy\u037e Alstom\u2019s refusal to fully cooperate with the department\u2019s investigation for several years\u037e the breadth of the companies\u2019 misconduct, which spanned many years, occurred in countries around the globe and in several business lines, and involved sophisticated schemes to bribe high-level government officials\u037e Alstom\u2019s lack of an effective compliance and ethics program at the time of the conduct\u037e and Alstom\u2019s prior criminal misconduct, including conduct that led to resolutions with various other governments and the World Bank.\u0022 (Source: US Department of Justice Press Release, \u0022Alstom Sentenced to Pay $772 Million Criminal Fine to Resolve Foreign Bribery Charges,\u0022 November 1, 2015.)","Sources ":"US v. Alstom S.A., Case No. 14-cr-246 (D. Conn), Information and Plea Agreement filed December 22, 2014; US Department of Justice Press Release, \u0022Alstom Sentenced to Pay $772 Million Criminal Fine to Resolve Foreign Bribery Charges,\u0022 November 1, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-alstom-sa-et-al-court-docket-number-314-cr-00245-jba-314-cr","Documents":""},{"Case ID":"ST-402","Case Cluster ":"Alstom","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Bahamas; Egypt; Indonesia; Saudi Arabia","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"11\/13","Other Jurisdictions of Settlement":"Unknown (Bahamas: Criminal conviction following trial)","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Crimimal Fine","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"Criminal Fine to be paid by Alstom S.A. (parent company)","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Alstom S.A., a French power and transportation company, was sentenced in November 2015 to pay a $772,290,000 fine to resolve criminal charges related to a widespread corruption scheme involving at least $75 million in secret bribes paid to government officials in countries around the world.\r\n \r\nAccording to the Department of Justice, Alstom and its subsidiaries - Alstom Prom, Alstom Power and Alstom T\u0026D - \u0022through various executives and employees, paid bribes to government officials and falsified books and records in connection with power, grid and transportation projects for state-owned entities around the world, including in Indonesia, Egypt, Saudi Arabia, the Bahamas and Taiwan. In Indonesia, for example, Alstom, Alstom Prom and Alstom Power paid bribes to government officials\u2014including a high-ranking member of the Indonesian Parliament and high-ranking\r\n members of Perusahaan Listrik Negara, the stat-eowned electricity company in Indonesia\u2014in exchange for assistance in securing several contracts to provide power related services valued at approximately $375 million. In total, Alstom paid more than $75 million to secure more than $4 billion in\r\n projects around the world, with a profit to the company of approximately $300 million.\r\n \r\n Alstom and its subsidiaries also attempted to conceal the bribery scheme by retaining consultants who purportedly provided consulting services on behalf of the companies, but who actually served as conduits for corrupt payments to the government officials. Internal Alstom documents refer to some of the consultants in code, including \u201cMr. Geneva,\u201d \u201cMr. Paris,\u201d \u201cLondon,\u201d \u201cQuiet Man\u201d and \u201cOld Friend.\u201d\r\n \r\n The sentence, which is the largest criminal fine ever imposed in an FCPA case, reflects a number of factors, including: Alstom\u2019s failure to voluntarily disclose the misconduct, even though it was aware of related misconduct at a U.S. subsidiary that previously resolved corruption charges with the department in connection with a power project in Italy\u037e Alstom\u2019s refusal to fully cooperate with the department\u2019s investigation for several years\u037e the breadth of the companies\u2019 misconduct, which spanned many years, occurred in countries around the globe and in several business lines, and involved sophisticated schemes to bribe high-level government officials\u037e Alstom\u2019s lack of an effective compliance and ethics program at the time of the conduct\u037e and Alstom\u2019s prior criminal misconduct, including conduct that led to resolutions with various other governments and the World Bank.\u0022 (Source: US Department of Justice Press Release, \u0022Alstom Sentenced to Pay $772 Million Criminal Fine to Resolve Foreign Bribery Charges,\u0022 November 1, 2015.)\r\n \r\n According to secondary sources, in May 2016, a former board member of the Bahamas Electricity Company was convicted following trial of accepting bribes. (Source: Lamech Johnson, \u0022Update: Ramsey convicted of multiple charges in Bec bribe,\u0022 May 4, 2016, at http:\/\/www.tribune242.com\/news\/2016\/may\/04\/ramsey-guilty-most-charges-bec-bribe-case\/)","Sources ":"US v. Alstom S.A., Case No. 14-cr-246 (D. Conn), Information and Plea Agreement filed December 22, 2014; US Department of Justice Press Release, \u0022Alstom Sentenced to Pay $772 Million Criminal Fine to Resolve Foreign Bribery Charges,\u0022 November 1, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-alstom-sa-et-al-court-docket-number-314-cr-00245-jba-314-cr; See also, Office of the Attorney-General Statement in Response to Nassau Guardian Editorial, Thursday 28 May 2015, at http:\/\/www.bahamas.gov.bs\/wps\/portal\/public\/Agency%20News%20and%20Press%20Release\/Office%20of%20the%20Attorney-General%20Statement%20in%20Response%20to%20Nassau%20Guardian%20Editorial%20Thursday%2028%20May%202015\/!ut\/p\/b1\/vZfZsqJIEIafpR_AtqCKorhkF9lXkRtCRFERBBcQnn50ejqmz_TMcS66rboi4s_4Kv_KTGCaTONpUq-6fbG67k_16vh8TnAKVdt0RURMghEHNCqwNEl2oArZh2D5EID_WDz4Fg9Uk-cf8SoDMNBCx-AddkbbOj1dTOPZkhWyi9bLspcmPmEW9VLko8mhvYB5azUbpGhXEjR3YdNpmA10yOV9tassWB2AFxF1rO0NZ5TDjnMyDnRlMO_PMjpVzU3H3WHOpSJs0mrAZbxbonCX8pfChjt73vPbXNTCdp1qE4kPPJdB2q25H6roGAWgn2epmJi5dRB5LfbtTHMb_jBTZFmZFHEgoqLHF0NwgTJJ2sWcZ-KV2K9nldFGzbY2EVv6pqGNoys3JL1eM5m9ceTEkqphE8al49UYBSE9NrezGQUdZ8FJ7kwKZVme_vL0E9M-85RiXsQj8PFOQRQKQJuZukREAsGMfRH_AHzg23TwrAmRwnrIAB3hf8b_LPhfNfWf8ehV_GKafGrR04E_BZ-V7avCTT53Ab0S4O8C1Uam_BQwRHnmwRgO5igigKk1O1Wb6fIhY384SRCBhwzwnk-5gFjUNJjGAKX-YWi0sRy9A7jbZknApdyPlBRCU5I8KyxpK1cs_2BDSqZ0yzBBwLr9ZfRsK8-cPPJCgZcUXWaVfwI_HtwH6HcDVcYmD6_ZwOEZGqg29W4gfKulqmOD357hh6JB7q-_w_k02WfV135dfQVfCYcphiWIIxggRNhpdFhiTnrOeM3aNuFV3Rw2YxTu-0LYFbpCudUOlWGHw1kJWa70jnh9KMc0KR40Z_RGyBdxVatdcKNOyhwKNHUi4rJvpV5WB0Zc-K4QkpLenqKmSBYnNcapwkzsUAzyWdnmQh7CUA-hcsuybN2Z1bnJTklz0MSUhRqlcV44nOCyLC5ZrjgZonWzLKG7Wx8xA-_nXrrmhXTJVTzReMQO_JcvnzeJjtifDB49zQo8K5DmBhgjJwiM2AqPhp_7lPkwnAoBHUhh7wc6fTUE078G3w1mi2XqvuhKg3kvUNfxu4HwzUARvBtIvxv47qLx0bsz_PV9-GHQsYhDDI1ZmgBIQZp7Djpwfw46SY4cxMxW5v3CCsMuL-e3aq5o_gKXO3ZDz_WC5bk5OyHCxJ7wu2pThOKqBdZ6jaWyHwBDubSm0wMvUpdMy7EmbpWtpK6Da2l5mL_g1IY8ie1F3cNtISuDx6ar0U2ze0NYT41WTY8htPXgfBxgLfjXWpwnXrgeuQ7c8smEakSrfz3IqH8z0DLP2uMtwEOqpAwfwIebihN8M5AGQWRacjM3QTGYckFZlvPdwHXtg82rQfZmoD7D7wbC3w7UafgAGtCwiEjROng3kP7lwA9dhwDEiBAW0xRNEwQe3xddyAnBxexlZ9Tj-n7JEtHVK-QVx_tp37czwHer-7xTy8rKYAmDVHh0hyDXwcFk23ttYTlJpb3RhN7xyNTHzQ0m6xwqIXMwcG-25UwHg1JER3_lmQqyXHlGk3LZnbymvqa3-IzDPL7vYrNw2_OqituNyMYb5xo-fkVz_nBbqYGw3JidLPHbYacMPgdhZ5-MZdH38jEsLub61jYlnzjZEAu1a_G7jb6PTDMQeS-_7E2Zc4Pkdul7w6Lum1ZnFvbSPF7XaIYkergtb_2WuxJ5vCa9OrRRvD_WrsLcVyzbymq4XdyRO5yV8XSimQlcLbItdz6OOI0sYOm-Qb5Mmyrs9McysCd7s54if29YdT9t8qPgOUf-ADdQn-4!\/dl4\/d5\/L2dBISEvZ0FBIS9nQSEh\/; Lamech Johnson, \u0022Update: Ramsey convicted of multiple charges in Bec bribe,\u0022 May 4, 2016, at http:\/\/www.tribune242.com\/news\/2016\/may\/04\/ramsey-guilty-most-charges-bec-bribe-case\/","Documents":""},{"Case ID":"ST-403","Case Cluster ":"Alstom","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Egypt, Indonesia, Saudi Arabia","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"11\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"Criminal Fine to be paid by Alstom S.A. (parent company)","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Alstom S.A., a French power and transportation company, was sentenced in November 2015 to pay a $772,290,000 fine to resolve criminal charges related to a widespread corruption scheme involving at least $75 million in secret bribes paid to government officials in countries around the world.\r\n \r\n According to the Department of Justice, Alstom and its subsidiaries - Alstom Prom, Alstom Power and Alstom T\u0026D - \u0022through various executives and employees, paid bribes to government officials and falsified books and records in connection with power, grid and transportation projects for state-owned entities around the world, including in Indonesia, Egypt, Saudi Arabia, the Bahamas and Taiwan. In Indonesia, for example, Alstom, Alstom Prom and Alstom Power paid bribes to government officials\u2014including a high-ranking member of the Indonesian Parliament and high-ranking\r\n members of Perusahaan Listrik Negara, the stat-eowned electricity company in Indonesia\u2014in exchange for assistance in securing several contracts to provide power related services valued at approximately $375 million. In total, Alstom paid more than $75 million to secure more than $4 billion in\r\n projects around the world, with a profit to the company of approximately $300 million.\r\n \r\n Alstom and its subsidiaries also attempted to conceal the bribery scheme by retaining consultants who purportedly provided consulting services on behalf of the companies, but who actually served as conduits for corrupt payments to the government officials. Internal Alstom documents refer to some of the consultants in code, including \u201cMr. Geneva,\u201d \u201cMr. Paris,\u201d \u201cLondon,\u201d \u201cQuiet Man\u201d and \u201cOld Friend.\u201d\r\n \r\n The sentence, which is the largest criminal fine ever imposed in an FCPA case, reflects a number of factors, including: Alstom\u2019s failure to voluntarily disclose the misconduct, even though it was aware of related misconduct at a U.S. subsidiary that previously resolved corruption charges with the department in connection with a power project in Italy\u037e Alstom\u2019s refusal to fully cooperate with the department\u2019s investigation for several years\u037e the breadth of the companies\u2019 misconduct, which spanned many years, occurred in countries around the globe and in several business lines, and involved sophisticated schemes to bribe high-level government officials\u037e Alstom\u2019s lack of an effective compliance and ethics program at the time of the conduct\u037e and Alstom\u2019s prior criminal misconduct, including conduct that led to resolutions with various other governments and the World Bank.\u0022 (Source: US Department of Justice Press Release, \u0022Alstom Sentenced to Pay $772 Million Criminal Fine to Resolve Foreign Bribery Charges,\u0022 November 1, 2015.)","Sources ":"US v. Alstom S.A., Case No. 14-cr-246 (D. Conn), Information and Plea Agreement filed December 22, 2014; US Department of Justice Press Release, \u0022Alstom Sentenced to Pay $772 Million Criminal Fine to Resolve Foreign Bribery Charges,\u0022 November 1, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-alstom-sa-et-al-court-docket-number-314-cr-00245-jba-314-cr","Documents":""},{"Case ID":"ST-404","Case Cluster ":"Alstom","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Bahamas; Egypt; Indonesia; Saudi Arabia; Taiwan, China","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"11\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$772,290,000 ","Criminal Fine\/Penalty (US$) ":"$772,290,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records; Internal controls violations","Offenses - Settled":"Falsification of books and records; Internal controls violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Alstom S.A., a French power and transportation company, was sentenced in November 2015 to pay a $772,290,000 fine to resolve criminal charges related to a widespread corruption scheme involving at least $75 million in secret bribes paid to government officials in countries around the world.\r\n \r\n According to the Department of Justice, Alstom and its subsidiaries - Alstom Prom, Alstom Power and Alstom T\u0026D - \u0022through various executives and employees, paid bribes to government officials and falsified books and records in connection with power, grid and transportation projects for state-owned entities around the world, including in Indonesia, Egypt, Saudi Arabia, the Bahamas and Taiwan. In Indonesia, for example, Alstom, Alstom Prom and Alstom Power paid bribes to government officials\u2014including a high-ranking member of the Indonesian Parliament and high-ranking\r\n members of Perusahaan Listrik Negara, the stat-eowned electricity company in Indonesia\u2014in exchange for assistance in securing several contracts to provide power related services valued at approximately $375 million. In total, Alstom paid more than $75 million to secure more than $4 billion in\r\n projects around the world, with a profit to the company of approximately $300 million.\r\n \r\n Alstom and its subsidiaries also attempted to conceal the bribery scheme by retaining consultants who purportedly provided consulting services on behalf of the companies, but who actually served as conduits for corrupt payments to the government officials. Internal Alstom documents refer to some of the consultants in code, including \u201cMr. Geneva,\u201d \u201cMr. Paris,\u201d \u201cLondon,\u201d \u201cQuiet Man\u201d and \u201cOld Friend.\u201d\r\n \r\n The sentence, which is the largest criminal fine ever imposed in an FCPA case, reflects a number of factors, including: Alstom\u2019s failure to voluntarily disclose the misconduct, even though it was aware of related misconduct at a U.S. subsidiary that previously resolved corruption charges with the department in connection with a power project in Italy\u037e Alstom\u2019s refusal to fully cooperate with the department\u2019s investigation for several years\u037e the breadth of the companies\u2019 misconduct, which spanned many years, occurred in countries around the globe and in several business lines, and involved sophisticated schemes to bribe high-level government officials\u037e Alstom\u2019s lack of an effective compliance and ethics program at the time of the conduct\u037e and Alstom\u2019s prior criminal misconduct, including conduct that led to resolutions with various other governments and the World Bank.\u0022 (Source: US Department of Justice Press Release, \u0022Alstom Sentenced to Pay $772 Million Criminal Fine to Resolve Foreign Bribery Charges,\u0022 November 1, 2015.)","Sources ":"US v. Alstom S.A., Case No. 14-cr-246 (D. Conn), Information and Plea Agreement filed December 22, 2014; US Department of Justice Press Release, \u0022Alstom Sentenced to Pay $772 Million Criminal Fine to Resolve Foreign Bribery Charges,\u0022 November 1, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-alstom-sa-et-al-court-docket-number-314-cr-00245-jba-314-cr","Documents":""},{"Case ID":"ST-405","Case Cluster ":"Alstom S.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Indonesia","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"5\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$88,000,000 ","Criminal Fine\/Penalty (US$) ":"$88,000,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials; Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials; Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Marubeni Corporation, a Japanese trading company involved in the handling of products and provision of services in a broad range of sectors around the world, including power generation pleaded guilty in 2014 to \u0022one count of conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA) and seven counts of violating the FCPA. The company signed a plea agreement in which it admitted its criminal conduct, agreed to maintain and implement an enhanced global anti-corruption compliance program and to cooperate with the department\u2019s ongoing investigation, and agreed to pay an $88 million fine, which the court accepted in imposing the sentence. The plea agreement cites Marubeni\u2019s refusal to cooperate with the department\u2019s investigation when given the opportunity to do so, its lack of an effective compliance and ethics program at the time of the offense, and its failure to timely remediate as several of the factors considered by the department in determining the resolution.\r\n \r\n According to the court filings, Marubeni and its employees, together with others, paid bribes to officials in Indonesia \u2013 including a high-ranking member of the Indonesian Parliament and high-ranking members of Perusahaan Listrik Negara (PLN), the state-owned and state-controlled electricity company in Indonesia \u2013 in exchange for assistance in securing a $118 million contract, known as the Tarahan project, for the company and its consortium partner to provide power-related services for the citizens of Indonesia. To conceal the bribes, Marubeni and its consortium partner retained two consultants purportedly to provide legitimate consulting services on behalf of the power company and its subsidiaries in connection with the Tarahan project. The primary purpose for hiring the consultants, however, was to use the consultants to pay bribes to Indonesian officials.\r\n \r\n Also according to court filings, the first consultant retained by Marubeni and its co-conspirators received hundreds of thousands of dollars in his U.S. bank account to be used to bribe the member of Parliament. The consultant then allegedly transferred the bribe money to a bank account in Indonesia for the benefit of the official. E-mails between the co-conspirators discuss in detail the use of the first consultant to funnel bribes to the member of Parliament and the influence that the member of Parliament could exert over the Tarahan project.\r\n \r\n As admitted in court documents, in the fall of 2003, Marubeni and its co-conspirators determined that the first consultant was not effectively bribing key officials at PLN. As a result, Marubeni and its consortium partner decided to reduce the first consultant\u2019s commission from three percent of the total contract value to one percent, and pay the remaining two percent to a second consultant who could more effectively bribe officials at PLN. In an e-mail between two employees of Marubeni\u2019s consortium partner, they discussed a meeting between Marubeni, an executive from the consortium partner, and the first consultant, stating that the consultant \u201ccommitted to convince [the member of Parliament] that \u2018one\u2019 [percent] is enough.\u201d Marubeni and its co-conspirators were successful in securing the Tarahan project and subsequently made payments to the consultants for the purpose of bribing the Indonesian officials.\r\n \r\n Frederic Pierucci, a current executive at Marubeni\u2019s consortium partner, pleaded guilty on July 29, 2013, to one count of conspiring to violate the FCPA and one count of violating the FCPA. David Rothschild, a former vice president of regional sales at the consortium partner, pleaded guilty on Nov. 2, 2012 to one count of conspiracy to violate the FCPA. Lawrence Hoskins, a former senior vice president for the Asia region for the consortium partner, and William Pomponi, a former vice president of regional sales at the consortium partner, were charged in a second superseding indictment on July 30, 2013.\u0022 (Source: US DOJ Press Release, \u0022Marubeni Corporation Sentenced for Foreign Bribery Violations,\u0022 May 15, 2014.)","Sources ":"US v. Marubeni Corporation, Case No. 14-cr-52 (D. Conn), Information and Plea Agreement filed March 19, 2014, and DOJ Press Release, \u0022Marubeni Corporation Sentenced for Foreign Bribery Violations,\u0022 May 15, 2014, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-marubeni-corporation-court-docket-number-14-cr-00052-jba.","Documents":""},{"Case ID":"ST-406","Case Cluster ":"Archer Daniels Midland Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Ukraine, Venezuela","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"12\/20","Other Jurisdictions of Settlement":"Germany","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$0.00 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"As part of the Non-Prosecution Agreement, ADM agreed to pay $9,450,000 in criminal fine, from which any amounts ordered against ACTI Ukraine would be deducted.","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"No (VAT Fraud - Ukraine)","Summary":"According to the US Department of Justice, \u0022Alfred C. Toepfer International Ukraine Ltd. (ACTI Ukraine), a subsidiary of ADM, pleaded guilty in the Central District of Illinois to one count of conspiracy to violate the anti-bribery provisions of the FCPA and agreed to pay $17.8 million in criminal fines. The Department of Justice also entered into a non-prosecution agreement (NPA) with ADM in connection with the company\u2019s failure to implement an adequate system of internal financial controls to address the making of improper payments both in Ukraine and by an ADM joint venture in Venezuela. [ ] \r\n \r\n According to the charges, from 2002 to 2008, ACTI Ukraine, a trader and seller of commodities based in the Ukraine, together with Alfred C. Toepfer International G.m.b.H. (ACTI Hamburg), another subsidiary of ADM, paid third-party vendors to pass on bribes to Ukrainian government officials to obtain VAT refunds. The charges allege that, in total, ACTI Ukraine and ACTI Hamburg paid roughly $22 million to two vendors, nearly all of which was to be passed on to Ukrainian government officials to obtain over $100 million in VAT refunds, resulting in a benefit to ACTI Ukraine and ACTI Hamburg of roughly $41 million.\r\n \r\n According to the NPA with ADM, a number of concerns were expressed to ADM executives, including an e-mail calling into question potentially illegal \u201cdonations\u201d by ACTI Ukraine and ACTI Hamburg to recover the VAT refunds, yet nonetheless failed to implement sufficient anti-bribery compliance policies and procedures to prevent corrupt payments.\u0022 (Source: US DOJ Press Release, \u0022ADM Subsidiary Pleads Guilty to Conspiracy to Violate the Foreign Corrupt Practices Act,\u0022 December 20, 2013.)","Sources ":"US DOJ Press Release, \u0022ADM Subsidiary Pleads Guilty to Conspiracy to Violate the Foreign Corrupt Practices Act,\u0022 December 20, 2013.","Documents":""},{"Case ID":"ST-407","Case Cluster ":"Archer Daniels Midland Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Ukraine","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"12\/20","Other Jurisdictions of Settlement":"Germany","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit, Prejudgment Interest","Total Monetary Sanctions (US$)":"$36,467,366 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$33,342,012 ","Civil Prejudgment Interest (US$) ":"$3,125,354 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records; Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (VAT Fraud)","Summary":"According to the US Securities and Exchange Commission Press Release, the agency \u0022today charged global food processor Archer-Daniels-Midland Company (ADM) for failing to prevent illicit payments made by foreign subsidiaries to Ukrainian government officials in violation of the Foreign Corrupt Practices Act (FCPA).\r\n \r\n An SEC investigation found that ADM\u2019s subsidiaries in Germany and Ukraine paid $21 million in bribes through intermediaries to secure the release of value-added tax (VAT) refunds. The payments were then concealed by improperly recording the transactions in accounting records as insurance premiums and other purported business expenses. ADM had insufficient anti-bribery compliance controls and made approximately $33 million in illegal profits as a result of the bribery by its subsidiaries. [ ] \r\n \r\n According to the SEC\u2019s complaint filed in U.S. District Court for the Central District of Illinois, the bribery occurred from 2002 to 2008. Ukraine imposed a 20 percent VAT on goods purchased in its country. If the goods were exported, the exporter could apply for a refund of the VAT already paid to the government on those goods. However, at times the Ukrainian government delayed paying VAT refunds it owed or did not make any refund payments at all. On these occasions, the outstanding amount of VAT refunds owed to ADM\u2019s Ukraine affiliate reached as high as $46 million.\r\n \r\n The SEC alleges that in order to obtain the VAT refunds that the Ukraine government was withholding, ADM\u2019s subsidiaries in Germany and Ukraine devised several schemes to bribe Ukraine government officials to release the money. The bribes paid were generally 18 to 20 percent of the corresponding VAT refunds. For example, the subsidiaries artificially inflated commodities contracts with a Ukrainian shipping company to provide bribe payments to government officials. In another scheme, the subsidiaries created phony insurance contracts with an insurance company that included false premiums passed on to Ukraine government officials. The misconduct went unchecked by ADM for several years because of its deficient and decentralized system of FCPA oversight over subsidiaries in Germany and Ukraine.\u0022 (Source: US Securities and Exchange Commission, \u0022SEC Charges Archer-Daniels-Midland Company With FCPA Violations,\u0022 December 20, 2013.)","Sources ":"US v. Archer-Daniels Midland Company, Case No. 2:13-cv-2279 (CD. Ill), Complaint filed December 20, 2013; US Securities and Exchange Commission, \u0022SEC Charges Archer-Daniels-Midland Company With FCPA Violations,\u0022 December 20, 2013, at http:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370540535139","Documents":""},{"Case ID":"ST-408","Case Cluster ":"Archer Daniels Midland Company","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Ukraine","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unknown","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,338,387 ","Criminal Fine\/Penalty (US$) ":"$1,338,387 ","Criminal Fine \/ Penalty (Explanation)":"Noted in ACTI Hamburg Plea Agreement","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Na (VAT Fraud - Ukraine)","Summary":"According to the US Department of Justice, \u0022Alfred C. Toepfer International Ukraine Ltd. (ACTI Ukraine), a subsidiary of ADM, pleaded guilty in the Central District of Illinois to one count of conspiracy to violate the anti-bribery provisions of the FCPA and agreed to pay $17.8 million in criminal fines. The Department of Justice also entered into a non-prosecution agreement (NPA) with ADM in connection with the company\u2019s failure to implement an adequate system of internal financial controls to address the making of improper payments both in Ukraine and by an ADM joint venture in Venezuela. [ ] \r\n \r\n According to the charges, from 2002 to 2008, ACTI Ukraine, a trader and seller of commodities based in the Ukraine, together with Alfred C. Toepfer International G.m.b.H. (ACTI Hamburg), another subsidiary of ADM, paid third-party vendors to pass on bribes to Ukrainian government officials to obtain VAT refunds. The charges allege that, in total, ACTI Ukraine and ACTI Hamburg paid roughly $22 million to two vendors, nearly all of which was to be passed on to Ukrainian government officials to obtain over $100 million in VAT refunds, resulting in a benefit to ACTI Ukraine and ACTI Hamburg of roughly $41 million.\r\n \r\n According to the NPA with ADM, a number of concerns were expressed to ADM executives, including an e-mail calling into question potentially illegal \u201cdonations\u201d by ACTI Ukraine and ACTI Hamburg to recover the VAT refunds, yet nonetheless failed to implement sufficient anti-bribery compliance policies and procedures to prevent corrupt payments.\u0022 (Source: US DOJ Press Release, \u0022ADM Subsidiary Pleads Guilty to Conspiracy to Violate the Foreign Corrupt Practices Act,\u0022 December 20, 2013.)","Sources ":"US Department of Justice Press Release, \u0022ADM Subsidiary Pleads Guilty to Conspiracy to Violate the Foreign Corrupt Practices Act,\u0022 December 20, 2013, at https:\/\/www.justice.gov\/opa\/pr\/adm-subsidiary-pleads-guilty-conspiracy-violate-foreign-corrupt-practices-act and plea agreement","Documents":""},{"Case ID":"ST-409","Case Cluster ":"Archer Daniels Midland Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Ukraine","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"","Other Jurisdictions of Settlement":"Germany","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$17,800,000 ","Criminal Fine\/Penalty (US$) ":"$17,800,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"No (VAT Fraud - Ukraine)","Summary":"According to the US Department of Justice, \u0022Alfred C. Toepfer International Ukraine Ltd. (ACTI Ukraine), a subsidiary of ADM, pleaded guilty in the Central District of Illinois to one count of conspiracy to violate the anti-bribery provisions of the FCPA and agreed to pay $17.8 million in criminal fines. The Department of Justice also entered into a non-prosecution agreement (NPA) with ADM in connection with the company\u2019s failure to implement an adequate system of internal financial controls to address the making of improper payments both in Ukraine and by an ADM joint venture in Venezuela. [ ] \r\n \r\n According to the charges, from 2002 to 2008, ACTI Ukraine, a trader and seller of commodities based in the Ukraine, together with Alfred C. Toepfer International G.m.b.H. (ACTI Hamburg), another subsidiary of ADM, paid third-party vendors to pass on bribes to Ukrainian government officials to obtain VAT refunds. The charges allege that, in total, ACTI Ukraine and ACTI Hamburg paid roughly $22 million to two vendors, nearly all of which was to be passed on to Ukrainian government officials to obtain over $100 million in VAT refunds, resulting in a benefit to ACTI Ukraine and ACTI Hamburg of roughly $41 million.\r\n \r\n According to the NPA with ADM, a number of concerns were expressed to ADM executives, including an e-mail calling into question potentially illegal \u201cdonations\u201d by ACTI Ukraine and ACTI Hamburg to recover the VAT refunds, yet nonetheless failed to implement sufficient anti-bribery compliance policies and procedures to prevent corrupt payments.\u0022 (Source: US DOJ Press Release, \u0022ADM Subsidiary Pleads Guilty to Conspiracy to Violate the Foreign Corrupt Practices Act,\u0022 December 20, 2013.)","Sources ":"US v. Alfred C. Toepfer International (Ukraine) Ltd., Case No. 13-cr-20062 (CD. Ill), Information and Plea Agreement both filed December 20, 2013 at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-alfred-c-toepfer-international-ukraine-ltd-court-docket-number","Documents":""},{"Case ID":"ST-410","Case Cluster ":"Avon Products","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"12\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$67,648,000 ","Criminal Fine\/Penalty (US$) ":"$67,648,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"No (License)","Summary":"According to the US Department of Justice, referencing court documents filed in the case, \u0022from at least 2004 through 2008, Avon and Avon China conspired to falsify Avon\u2019s books and records by falsely describing the nature and purpose of certain Avon China transactions. \r\n \r\n Specifically, the companies sought to disguise over $8 million in gifts, cash and nonbusiness travel, meals and entertainment that Avon China executives and employees gave to government officials in China in order to obtain and retain business benefits for Avon China. Avon China attempted to disguise the payments and benefits through various means, including falsely describing the nature or purpose of, or participants associated with such expenses, and falsely recording payments to a third party intermediary as payments for legitimate consulting services.\r\n \r\n The companies also admitted that in late 2005 Avon learned that Avon China was routinely providing things of value to Chinese government officials and failing to properly document them. Instead of ensuring the practice was halted, fixing the false books and records, disciplining the culpable individuals, and implementing\r\n appropriate controls to address this problem, the companies took steps to conceal the conduct, despite knowing that Avon China\u2019s books and records, and ultimately Avon\u2019s books and records, would continue to be inaccurate.\u0022 (Source: US Department of Justice Press Release, Avon China Pleads Guilty to Violating the FCPA by Concealing More Than $8 Million in Gifts to Chinese Officials,\u0022 December 17, 2014.)","Sources ":"US v. Avon Products (China) Co. Ltd. Case No. 14-cr-828 (SDNY), Information and Plea Agreement, filed December 17, 2014; Department of Justice Press Release, Avon China Pleads Guilty to Violating the FCPA by Concealing More Than $8 Million in Gifts to Chinese Officials,\u0022 December 17, 2014, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-avon-products-china-co-ltd","Documents":""},{"Case ID":"ST-411","Case Cluster ":"Avon Products","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"12\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Accounting provisions of the FCPA","Offenses - Settled":"Accounting provisions of the FCPA","Public Procurement Contract \/ SOE Involved?":"No (License)","Summary":"According to the US Department of Justice, referencing court documents filed in the case, \u0022from at least 2004 through 2008, Avon and Avon China conspired to falsify Avon\u2019s books and records by falsely describing the nature and purpose of certain Avon China transactions. \r\n \r\n Specifically, the companies sought to disguise over $8 million in gifts, cash and nonbusiness travel, meals and entertainment that Avon China executives and employees gave to government officials in China in order to obtain and retain business benefits for Avon China. Avon China attempted to disguise the payments and benefits through various means, including falsely describing the nature or purpose of, or participants associated with such expenses, and falsely recording payments to a third party intermediary as payments for legitimate consulting services.\r\n \r\n The companies also admitted that in late 2005 Avon learned that Avon China was routinely providing things of value to Chinese government officials and failing to properly document them. Instead of ensuring the practice was halted, fixing the false books and records, disciplining the culpable individuals, and implementing\r\n appropriate controls to address this problem, the companies took steps to conceal the conduct, despite knowing that Avon China\u2019s books and records, and ultimately Avon\u2019s books and records, would continue to be inaccurate.\u0022 (Source: US Department of Justice Press Release, Avon China Pleads Guilty to Violating the FCPA by Concealing More Than $8 Million in Gifts to Chinese Officials,\u0022 December 17, 2014.)","Sources ":"US v. Avon Products (China) Co. Ltd. Case No. 14-cr-828 (SDNY), Information and Plea Agreement, filed December 17, 2014; Department of Justice Press Release, Avon China Pleads Guilty to Violating the FCPA by Concealing More Than $8 Million in Gifts to Chinese Officials,\u0022 December 17, 2014, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-avon-products-china-co-ltd","Documents":""},{"Case ID":"ST-412","Case Cluster ":"Avon Products","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"12\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit, Prejudgment Interest","Total Monetary Sanctions (US$)":"$67,365,013.13 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$52,850,000 ","Civil Prejudgment Interest (US$) ":"$14,515,013.13 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records; Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022The SEC alleges that Avon\u2019s subsidiary in China made $8 million worth of payments in cash, gifts, travel, and entertainment to gain access to Chinese officials implementing and overseeing direct selling regulations in China. Avon sought to be among the first allowed to test the regulations, and eventually received the first direct selling business license in China in March 2006. The improper payments also were made to avoid fines or negative news articles that could have impacted Avon\u2019s clean corporate image required to retain the license. Examples of improper payments alleged in the SEC\u2019s complaint include paid travel for Chinese government officials within China or to the U.S. or Europe as well as such gifts as Louis Vuitton merchandise, Gucci bags, Tiffany pens, and corporate box tickets to the China Open tennis tournament. [ ] \r\n  \r\n According to the SEC\u2019s complaint filed in U.S. District Court for the Southern District of New York, the improper payments occurred from 2004 to 2008. Avon management learned about potential FCPA problems at the subsidiary through an internal audit report in late 2005. Avon management consulted an outside law firm, directed that reforms be instituted at the subsidiary, and sent an internal audit team to follow up. Ultimately, however, no such reforms were instituted at the Chinese subsidiary. Avon finally began a full-blown internal investigation in 2008 after its CEO received a letter from a whistleblower.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Avon With FCPA Violations \/\r\n Avon Entities to Pay $135 Million to Settle SEC and Criminal Cases,\u0022 December 17, 2014.)","Sources ":"US SEC v. Avon Products, Inc., Case No. 14-cv-9956 (SDNY), Complaint filed December 17, 2014, at https:\/\/www.sec.gov\/litigation\/complaints\/2014\/comp-pr2014-285.pdf; SEC Press Release, \u0022SEC Charges Avon With FCPA Violations \/ Avon Entities to Pay $135 Million to Settle SEC and Criminal Cases,\u0022 December 17, 2014, at https:\/\/www.sec.gov\/news\/pressrelease\/2014-285.html","Documents":""},{"Case ID":"ST-413","Case Cluster ":"Bechtel \/ Power Generation Engineering and Services Company (PGESCo)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Egypt","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"3\/23","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$5,258,995 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$5,258,995 ","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Mail Fraud, Conspiracy to Commit Money Laundering, Interference with Administration of Internal Revenue (Tax) Laws in relation to an FCPA bribery scheme","Offenses - Settled":"Mail Fraud, Conspiracy to Commit Money Laundering, Interference with Administration of Internal Revenue (Tax) Laws in relation to an FCPA bribery scheme","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Asem Elgawhary [ ] pleaded guilty on Dec. 4, 2014, to mail fraud, conspiracy to commit money laundering, and obstruction and interference with the administration of the tax laws. In imposing sentence today [the Court] also ordered Elgawhary to forfeit $5.2 million.\r\n \r\n From 1996 to 2011, Elgawhary was assigned by Bechtel\u2014a U.S. corporation engaged in engineering, construction and project management\u2014to be the general manager at Power Generation Engineering and Services Company (PGESCo), a joint venture between Bechtel and Egypt\u2019s state-owned and state-controlled electricity company, known as EEHC. PGESCo assisted EEHC in identifying possible subcontractors, soliciting bids and awarding contracts to perform power projects for EEHC. According to his plea agreement, Elgawhary admitted to accepting a total of $5.2 million from three power companies, which they paid to secure a competitive and unfair advantage in the bidding process. One of the power companies, Alstom S.A., together with a Swiss subsidiary, pleaded guilty on Dec. 22, 2014, to violations of the Foreign Corrupt Practices Act (FCPA) in connection with a scheme to pay bribes to foreign officials, including Elgawhary, in various countries. \r\n \r\n As Elgawhary admitted in his plea agreement, he attempted to conceal the kickback scheme by routing the payments through various off-shore bank accounts, including Swiss bank accounts, under his control. Elgawhary also sent various documents and \u201cRepresentation Letters\u201d to Bechtel executives and members of the PGESCo Board of Directors, falsely certifying that he had no knowledge or suspicion of any fraud at PGESCo, and that there were no possible violations of law or regulations that should have been considered for disclosure in PGESCo\u2019s financial statements. Elgawhary also admitted that, in a further attempt to conceal the scheme, he made misrepresentations to counsel for Bechtel when he was interviewed in April 2011.\r\n \r\n Elgawhary further admitted to obstructing and interfering with tax laws by failing to report any of the kickback payments as income for the tax years 2008 through 2011 and providing false information about foreign bank accounts.\u0022 (Source: US Department of Justice Press Release, \u0022Former Bechtel Executive Sentenced to 42 Months in Prison and Ordered to Forfeit $5.2 Million in Connection with Kickback Scheme,\u0022 March 23, 2015.)","Sources ":"US v. Asem Elgawhary, Case No. 14-cr-68 (D. Md.), Criminal Complaint, filed (November 27, 2013), Indictment (February 20, 2014); Department of Justice Press Release, \u0022Former Bechtel Executive Sentenced to 42 Months in Prison and Ordered to Forfeit $5.2 Million in Connection with Kickback Scheme,\u0022 March 23, 2015, accessed at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-asem-m-elgawhary-court-docket-number-14-cr-00068-dkc; Consent Order of Forfeiture and Judgment, both filed March 23, 2015 accessed via PACER.","Documents":""},{"Case ID":"ST-414","Case Cluster ":"Berger Group Holdings Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"India, Indonesia, Kuwait, Vietnam","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"7\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$17,100,000 ","Criminal Fine\/Penalty (US$) ":"$17,100,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Louis Berger International, Inc. a New Jersey-based construction management company admitted to violations of the Foreign Corrupt Practices Act (FCPA) and agreed to pay a $17.1 million criminal penalty to resolve charges that it bribed foreign officials in India, Indonesia, Vietnam and Kuwait to secure government construction management contracts. Two of the company\u2019s former executives also pleaded guilty to conspiracy and FCPA charges in connection with the scheme. [ ] \r\n \r\n LBI entered into a deferred prosecution agreement (DPA) today and admitted its criminal conduct, including its conspiracy to violate the antibribery provisions of the FCPA. Pursuant to the DPA, LBI has agreed to pay a $17.1 million criminal penalty, to implement rigorous internal controls, to continue to cooperate fully with the department and to retain a compliance monitor for at least three years. \r\n \r\n Richard Hirsch [ ] and James McClung [ ], each pleaded guilty to one count of conspiracy to violate the FCPA and one substantive count of violating the FCPA. Hirsch previously served as the Senior Vice President responsible for the company\u2019s operations in Indonesia, Thailand, the Philippines and Vietnam. McClung previously served as the Senior Vice President responsible for the company\u2019s operations in India and, subsequent to Hirsch, in Vietnam. [As of April 18, 2016, the sentencing in Mr.Hirsch and Mr. McClung\u0027s cases had been set for May 12, 2016.]\r\n \r\n According to admissions in the DPA and statements in the charging documents, from 1998 through 2010, the company and its employees, including Hirsch and McClung, orchestrated $3.9 million in bribe payments to foreign officials in various countries in order to secure government contracts. To conceal the payments, the co-conspirators made payments under the guise of \u201ccommitment fees,\u201d \u201ccounterpart per diems,\u201d and other payments to third-party vendors. In reality, the payments were intended to fund bribes to foreign officials who had awarded contracts to LBI or who supervised LBI\u2019s work on contracts.\u0022 (Source:: US Department of Justice Press Release, \u0022Louis Berger International Resolves Foreign Bribery Charges,\u0022 July 17, 2015; US v. James McClung, Case No. 15-cr-00357 and US v. Richard Hirsch, Case No. 15-cr-00358 (D. NJ), Court Docket Report as of April 18, 2016.)","Sources ":"US v. Louis Berger international Inc., Case No. 15-mj-3624 (D. NJ), Criminal Complaint and Deferred prosecution Agreement filed July 7, 2015; Department of Justice Press Release, \u0022Louis Berger International Resolves Foreign Bribery Charges,\u0022 July 17, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/louis-berger-international; US v. Hirsch, Case No. 15-cr-00358 and US v. McClung, Case No. 15-cr-00357 (D. NJ), Court Docket Report as of April 18, 2016; and other related court documents at https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/james-mcclung and https:\/\/www.justice.gov\/criminal-fraud\/fcpa\/cases\/richard-hirsch","Documents":""},{"Case ID":"ST-415","Case Cluster ":"Besso Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Financial Conduct Authority","Jurisdiction of Foreign Public Official(s) ":"None specified","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"3\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Final Notice","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$524,261 ","Criminal Fine\/Penalty (US$) ":"NA","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"NA","Criminal Restitution \/ Reparation (US$)":"NA","Criminal Legal \/ Procedural Costs (US$)":"NA","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$524,261 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art. 16","OECD Anti-Bribery Convention Articles Implicated":"Art. 2, Art. 8","Offenses - Alleged":"Lack of Bribery Controls","Offenses - Settled":"Lack of Bribery Controls","Public Procurement Contract \/ SOE Involved?":"No","Summary":"According to the UK Financial Conduct Authority\u0027s Final Notice, \u00224.1. Besso is the broking subsidiary of Besso Insurance Group Limited. Besso is a medium-sized Lloyd\u2019s general insurance broker operating mainly in the commercial sector, specialising in marine, aviation, transport, property, casualty, international and liability insurance. Besso has been authorised by the Authority\n to carry out a number of regulated activities since 14 January 2005. This includes assisting in the administration and performance of contracts of insurance.\n 4.2. Insurance and reinsurance brokers such as Besso make payments to, and share commission with, Third Parties in a number of circumstances. For example, a broker may pay a co-broker who assists in the placement of insurance or reinsurance. In some cases, a broker may pay a broker who provides services (e.g., administrative and policy insurance services) in relation to the placement of\n insurance in countries where the principal broker does not have an office. In other cases, a broker may pay individuals or companies who have limited or no involvement in placement activities, but assist with client introductions and providing relevant market and other information.\n 4.3. Being a wholesale broker, Besso was heavily reliant upon Producing Brokers to bring business to it. The Producing Brokers would have the relationship with the insured and would handle all correspondence in relation to that insured. Besso would normally agree a split of commission between the Producing Broker and itself.\n 4.4. During the Relevant Period, Besso offered (and continues to offer) broking services for both insurance and reinsurance business across a wide range of industries and countries, which will have had a varying degree of perceived risk of bribery and corruption. In establishing and maintaining business relationships, Besso made use of, and paid commissions to, Third Parties (both overseas and in the UK). Accordingly, although it was not unusual or inappropriate for Besso to make payments to Third Parties, there was a risk, which was increased for higher risk industries and countries, that a proportion of the money paid to Third Parties might have been used by the Third Parties for inappropriate purposes. This could have included paying bribes to persons connected with the insured or public officials.\u0022 (Source: UK FCA FInal Notice, File Reference Number 309159, March 17, 2014.)","Sources ":"UK Financial Conduct Authority, Final Notice to Besso Limited, Firm Reference Number 309159, Maarch 17, 2014, at https:\/\/www.fca.org.uk\/your-fca\/documents\/final-notices\/2014\/besso-limited","Documents":""},{"Case ID":"ST-416","Case Cluster ":"BHP Billiton","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Burundi; other unnamed African and Asian countries","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"5\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$25,000,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$25,000,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, BHPB is a global resources company that is among the world\u2019s leading producers of major commodities, including iron ore, coal, oil and gas, copper, aluminum, manganese, uranium, nickel, and silver. \u0022This matter concerns BHPB\u2019s failure to devise and maintain sufficient internal controls over a global hospitality program that the company hosted in connection with its sponsorship of the 2008 Beijing Summer Olympic Games. BHPB invited approximately 176 government officials and employees of state-owned enterprises (collectively, \u201cgovernment officials\u201d) to attend the Olympics at BHPB\u2019s expense. The majority of these invitations were extended to government officials from countries in Africa and Asia that had well-known histories of corruption. The three to four day hospitality packages included event tickets, luxury hotel accommodations, meals, other hospitality, and, in many instances, offers of business-class airfare for government officials and their guests. BHPB informed its employees that \u201c[o]ne of the core objectives [of the Olympic sponsorship] is to maximize the commercial investment made in the Games through assisting [BHPB] to strengthen relationships with key local and global stakeholders, e.g.: Government Ministers, Suppliers and Customers,\u201d and that the hospitality program was \u201ca primary vehicle to ensure this goal is achieved.\u201d\r\n \r\n 2. BHPB recognized that inviting government officials to the Olympics created a heightened risk of violating anti-corruption laws and the company\u2019s own Guide to Business Conduct, but the internal controls it developed and relied upon in an effort to address this risk were insufficient. As a result, BHPB invited government officials who were directly involved in, or in a position to influence, pending contract negotiations, efforts to obtain access rights, regulatory actions, or business dealings affecting BHPB in multiple countries. In addition, BHPB\u2019s books and records, namely certain internal forms that employees prepared in order to invite a government official to the Olympics, did not, in reasonable detail, accurately and fairly reflect BHPB\u2019s pending\r\n negotiations or business dealings with the government official at the time of the invitation.\u0022 (Source: SEC Administrative Proceedings, File No. 3-16546, In the Matter of BHP Billiton Ltd. and BHP Billiton Plc, May 20, 2015.)","Sources ":"US Securities and Exchange Commission, Administrative Proceedings, File No. 3-16546, In the Matter of BHP Billiton Ltd. and BHP Billiton Plc, May 20, 2015, at https:\/\/www.sec.gov\/litigation\/admin\/2015\/34-74998.pdf","Documents":""},{"Case ID":"ST-417","Case Cluster ":"Bilfinger SE \/ Willbros","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"12\/9","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$32,000,000 ","Criminal Fine\/Penalty (US$) ":"$32,000,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe foreign officials","Offenses - Settled":"Conspiracy to Bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Bilfinger SE, an international engineering and services company based in Mannheim, Germany, has agreed to pay a $32 million penalty to resolve charges that it violated the Foreign Corrupt Practices Act (FCPA) by bribing government officials of the Federal Republic of Nigeria to obtain and retain contracts related to the Eastern Gas Gathering System (EGGS) project, which was valued at approximately $387 million. [ ] \r\n \r\n As part of the agreed resolution, the department today filed a three-count criminal information in U.S. District Court for the Southern District of Texas charging Bilfinger with violating and conspiring to violate the FCPA\u2019s anti-bribery provisions. [ ]\r\n \r\n According to court documents, from late 2003 through June 2005, Bilfinger conspired with Willbros Group Inc. and others to make corrupt payments totaling more than $6 million to Nigerian government officials to assist in obtaining and retaining contracts related to the EGGS project. Bilfinger and Willbros formed a joint venture to bid on the EGGS project and inflated the price of the joint venture\u2019s bid by 3 percent to cover the cost of paying bribes to Nigerian officials. As part of the conspiracy, Bilfinger employees bribed Nigerian officials with cash that Bilfinger employees sent from Germany to Nigeria. At another point in the conspiracy, when Willbros employees encountered difficulty obtaining enough money to make their share of the bribe payments, Bilfinger loaned them $1 million, with the express purpose of paying bribes to the Nigerian officials.\r\n \r\n Including today\u2019s action, the department has filed criminal charges in the Southern District of Texas against three institutions and four executives and consultants in connection with the EGGS bribery scheme:\r\n \r\n On Sept. 14, 2006, Jim Bob Brown, a former Willbros executive, pleaded guilty to one count of conspiracy to violate the FCPA in connection with his role in making corrupt payments to Nigerian government officials to obtain and retain the EGGS contract and in connection with his role in making corrupt payments in Ecuador. Brown was sentenced on Jan. 28, 2010, to serve 12 months and one day in prison, to be followed by two years of supervised release, and ordered to pay a $17,500 fine.\r\n \r\n On Nov. 5, 2007, Jason Steph, also a former Willbros executive, pleaded guilty to one count of conspiracy to violate the FCPA in connection with his role in making corrupt payments to Nigerian government officials to obtain and retain the EGGS contract. Steph was sentenced on Jan. 28, 2010, to serve 15 months in prison, to be followed by two years of supervised release, and ordered to pay a $2,000 fine.\r\n \r\n On May 14, 2008, Willbros Group Inc. and Willbros International Inc. entered into a deferred prosecution agreement and agreed to pay a $22 million criminal penalty in connection with the company\u2019s payment of bribes to government officials in Nigeria and Ecuador. On March 30, 2012, the government moved to dismiss the charges against Willbros on the grounds that Willbros had satisfied its obligations under the deferred prosecution agreement, and on April 2, 2012, the court granted the United States\u2019 motion.\r\n \r\n On Dec. 19, 2008, Kenneth Tillery, a former Willbros executive, was charged with conspiring to make and making bribe payments to Nigerian and Ecuadoran officials in connection with the EGGS project and pipeline projects in Ecuador and conspiring to launder the bribe payments. Tillery remains a fugitive. The charges against Tillery are merely accusations, and he is presumed innocent unless and until proven guilty.\r\n \r\n On Nov. 12, 2009, Paul Grayson Novak, a former Willbros consultant, pleaded guilty to one count of conspiracy to violate the FCPA and one substantive count of violating the FCPA in connection with his role in making corrupt payments to Nigerian government officials to obtain and retain the EGGS contract. Novak was sentenced on May 3, 2013, to serve 15 months in prison, to be followed by two years of supervised release, and ordered to pay a $1 million fine.\u0022 (Source: US Department of Justice Press Release, \u0022German Engineering Firm Bilfinger Resolves Foreign Corrupt Practices Act Charges and Agrees to Pay $32 Million Criminal Penalty,\u0022 December 11, 2013, at https:\/\/www.justice.gov\/opa\/pr\/german-engineering-firm-bilfinger-resolves-foreign-corrupt-practices-act-charges-and-agrees.)","Sources ":"US v. Bilfinger SE, Case No. 4:13-cr-745 (SD Tex.), Information and Deferred Prosecution Agreement filed December 9, 2013; USDOJ Press Release, \u0022German Engineering Firm Bilfinger Resolves Foreign Corrupt Practices Act Charges and Agrees to Pay $32 Million Criminal Penalty,\u0022 December 11, 2013, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-bilfinger-se-court-docket-number-413-cr-745","Documents":""},{"Case ID":"ST-418","Case Cluster ":"Bilfinger SE \/ Willbros","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"5\/8","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,000,000 ","Criminal Fine\/Penalty (US$) ":"$1,000,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to Bribe foreign officials; Assist in Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe foreign officials; Assist in Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Bilfinger SE, an international engineering and services company based in Mannheim, Germany, has agreed to pay a $32 million penalty to resolve charges that it violated the Foreign Corrupt Practices Act (FCPA) by bribing government officials of the Federal Republic of Nigeria to obtain and retain contracts related to the Eastern Gas Gathering System (EGGS) project, which was valued at approximately $387 million. [ ] \r\n \r\n As part of the agreed resolution, the department today filed a three-count criminal information in U.S. District Court for the Southern District of Texas charging Bilfinger with violating and conspiring to violate the FCPA\u2019s anti-bribery provisions. [ ]\r\n \r\n According to court documents, from late 2003 through June 2005, Bilfinger conspired with Willbros Group Inc. and others to make corrupt payments totaling more than $6 million to Nigerian government officials to assist in obtaining and retaining contracts related to the EGGS project. Bilfinger and Willbros formed a joint venture to bid on the EGGS project and inflated the price of the joint venture\u2019s bid by 3 percent to cover the cost of paying bribes to Nigerian officials. As part of the conspiracy, Bilfinger employees bribed Nigerian officials with cash that Bilfinger employees sent from Germany to Nigeria. At another point in the conspiracy, when Willbros employees encountered difficulty obtaining enough money to make their share of the bribe payments, Bilfinger loaned them $1 million, with the express purpose of paying bribes to the Nigerian officials.\r\n \r\n Including today\u2019s action, the department has filed criminal charges in the Southern District of Texas against three institutions and four executives and consultants in connection with the EGGS bribery scheme:\r\n \r\n On Sept. 14, 2006, Jim Bob Brown, a former Willbros executive, pleaded guilty to one count of conspiracy to violate the FCPA in connection with his role in making corrupt payments to Nigerian government officials to obtain and retain the EGGS contract and in connection with his role in making corrupt payments in Ecuador. Brown was sentenced on Jan. 28, 2010, to serve 12 months and one day in prison, to be followed by two years of supervised release, and ordered to pay a $17,500 fine.\r\n \r\n On Nov. 5, 2007, Jason Steph, also a former Willbros executive, pleaded guilty to one count of conspiracy to violate the FCPA in connection with his role in making corrupt payments to Nigerian government officials to obtain and retain the EGGS contract. Steph was sentenced on Jan. 28, 2010, to serve 15 months in prison, to be followed by two years of supervised release, and ordered to pay a $2,000 fine.\r\n \r\n On May 14, 2008, Willbros Group Inc. and Willbros International Inc. entered into a deferred prosecution agreement and agreed to pay a $22 million criminal penalty in connection with the company\u2019s payment of bribes to government officials in Nigeria and Ecuador. On March 30, 2012, the government moved to dismiss the charges against Willbros on the grounds that Willbros had satisfied its obligations under the deferred prosecution agreement, and on April 2, 2012, the court granted the United States\u2019 motion.\r\n \r\n On Dec. 19, 2008, Kenneth Tillery, a former Willbros executive, was charged with conspiring to make and making bribe payments to Nigerian and Ecuadoran officials in connection with the EGGS project and pipeline projects in Ecuador and conspiring to launder the bribe payments. Tillery remains a fugitive. The charges against Tillery are merely accusations, and he is presumed innocent unless and until proven guilty.\r\n \r\n On Nov. 12, 2009, Paul Grayson Novak, a former Willbros consultant, pleaded guilty to one count of conspiracy to violate the FCPA and one substantive count of violating the FCPA in connection with his role in making corrupt payments to Nigerian government officials to obtain and retain the EGGS contract. Novak was sentenced on May 3, 2013, to serve 15 months in prison, to be followed by two years of supervised release, and ordered to pay a $1 million fine.\u0022 (Source: US Department of Justice Press Release, \u0022German Engineering Firm Bilfinger Resolves Foreign Corrupt Practices Act Charges and Agrees to Pay $32 Million Criminal Penalty,\u0022 December 11, 2013, at https:\/\/www.justice.gov\/opa\/pr\/german-engineering-firm-bilfinger-resolves-foreign-corrupt-practices-act-charges-and-agrees.)","Sources ":"US v. Bilfinger SE, Case No. 4:13-cr-745 (SD Tex.), Information and Deferred Prosecution Agreement filed December 9, 2013; US Department of Justice Press Release, \u0022German Engineering Firm Bilfinger Resolves Foreign Corrupt Practices Act Charges and Agrees to Pay $32 Million Criminal Penalty,\u0022 December 11, 2013, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-bilfinger-se-court-docket-number-413-cr-745;\r\n \r\n US v. Paul Grayson Novak, Case No. 4:08-cr-22 (SD Tex.), Indictment filed November 11, 2009, Plea Agreement (November 12, 2009), Judgment (May 8, 2013), at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-paul-grayson-novak-2009-docket-no-408-cr-00022","Documents":""},{"Case ID":"ST-419","Case Cluster ":"Bio-Rad Laboratories","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Russia","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"11\/3","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$14,350,000 ","Criminal Fine\/Penalty (US$) ":"$14,350,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records; Internal Controls Violations","Offenses - Settled":"Falsification of Books and Records; Internal Controls Violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022California-based medical diagnostics and life sciences manufacturing and sales company, Bio-Rad Laboratories Inc. (BioRad), has agreed to pay a $14.35 million penalty to resolve allegations that it violated the Foreign Corrupt Practices Act (FCPA) by falsifying its books and records and failing to implement adequate internal controls in connection with sales it made in Russia. [ ] According to the company\u2019s admissions in the agreement, Bio-Rad SNC, a Bio-Rad subsidiary located in France, retained and paid intermediary companies commissions of 15-30 percent purportedly in exchange for various services in connection with certain governmental sales in Russia. The intermediary companies, however, did not perform these services. Several high-level managers at Bio-Rad, responsible for overseeing\r\n Bio-Rad\u2019s business in Russia, reviewed and approved the commission payments to the intermediary companies despite knowing that the intermediary companies were not performing such services. These managers knowingly caused the payments to be falsely recorded on Bio-Rad SNC\u2019s and, ultimately, Bio-Rad\u2019s books. Bio-Rad, through several of its managers, also failed to implement adequate controls, as well as adequate compliance systems, with regard to its Russian operations while knowing that the failure to implement such controls allowed the intermediary companies to be paid significantly above-market commissions for little or no services.\u0022 (Source: Department of Justice Press Release, \u0022Bio-Rad Laboratories Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $14.35 Million Penalty,\u0022 November 3, 2014.)","Sources ":"US Department of Justice Non-Prosecution Agreement in re: Bio-Rad Laboratories, Inc., November 3, 2014, at https:\/\/www.justice.gov\/sites\/default\/files\/criminal-fraud\/legacy\/2014\/11\/03\/Bio-Rad-NPA-110314.pdf; Department of Justice Press Release, \u0022Bio-Rad Laboratories Resolves Foreign Corrupt Practices Act\r\n Investigation and Agrees to Pay $14.35 Million Penalty,\u0022 November 3, 2014.","Documents":""},{"Case ID":"ST-420","Case Cluster ":"Bizjet","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico, Panama","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"11\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$15,000 ","Criminal Fine\/Penalty (US$) ":"$15,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials, Conspiracy to Launder Monetary Instruments, Money Laundering","Offenses - Settled":"Conspiracy; Bribery of Foreign Officials - Aid and Abet","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Bernd Kowalewski, the former President and CEO of BizJet, pleaded guilty \u0022to conspiracy to violate the Foreign Corrupt Practices Act (FCPA) and a substantive violation of the FCPA in connection with a scheme to pay bribes to officials in Mexico and Panama in exchange for those officials\u2019 assistance in securing contracts for BizJet to perform aircraft maintenance, repair and overhaul services.\u0022 (Source: US DOJ Press Release, \u0022Former Chief Executive Officer of Lufthansa Subsidiary BizJet Pleads Guilty to Foreign Bribery Charges,\u0022 July 24, 2014.)\r\n \r\n According to the US Department of Justice, \u0022BizJet paid bribes to officials employed by the Mexican Policia Federal Preventiva, the Mexican Coordinacion General de Transportes Aereos Presidenciales, the air fleet for the Gobierno del Estado de Sinaloa, the air fleet for the Gobierno del Estado de Sonora and the Republica de Panama Autoridad Aeronautica Civil. In many instances, BizJet paid the bribes directly to the foreign officials. In other instances, BizJet funneled the bribes through a shell company owned and operated by a BizJet sales manager. BizJet executives orchestrated, authorized and approved the unlawful payments.\u0022 (Source: US Department of Justice Press Release, \u0022Bizjet International Sales and Support Inc., Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $11.8 Million Criminal Penalty,\u0022 March 14, 2012.) According to the Statement of Facts agreed to by the company as part of its Deferred Prosecution Agreement, \u0022Shell Company A\u0022 was owned by BizJet\u0027s Sales Manager and operated out of his personal residence in Van Nuys, California (para 7); Shell Company A \u0022operated under the pretense\u0022 of supplying aircraft maintenance, repair and overhaul services but in fact was used in the conspiracy by BizJet executives and sales manager to make unlawful payments to foreign officials via its bank account in California. (para 18) (Source: US v. BizJet International Sales and Support, Inc., Case No. 4:12-cr-00061 (N.D. Okla.), Deferred Prosecution Agreement and Statement of Facts filed March 14, 2012.)","Sources ":"US v. Kowalewski, Case No. 12-cr-07 (N.D. Okla), Judgment filed on November 18, 2014 and Court Docket Report as of April 19, 2016;\r\n \r\n Department of Justice Press Release, \u0022Former Chief Executive Officer of Lufthansa Subsidiary BizJet Pleads Guilty to Foreign Bribery Charges,\u0022 July 24, 2014, at https:\/\/www.justice.gov\/opa\/pr\/former-chief-executive-officer-lufthansa-subsidiary-bizjet-pleads-guilty-foreign-bribery\r\n \r\n US v. BizJet International Sales and Support, Inc., Case No. 4:12-cr-00061 (N.D. Okla.), Deferred Prosecution Agreement and Statement of Facts filed March 14, 2012, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-bizjet-international-sales-and-support-inc-court-docket-number","Documents":""},{"Case ID":"ST-421","Case Cluster ":"Bizjet","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico, Panama","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"4\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$10,000 ","Criminal Fine\/Penalty (US$) ":"$10,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Mr. Uhl was Controller or Vice President of Bizjet International Sales and Support Inc., the U.S.-based subsidiary of Lufthansa Technik AG, which provides aircraft maintenance, repair and overhaul (MRO) services. \u0022BizJet paid bribes to officials employed by the Mexican Policia Federal Preventiva, the Mexican Coordinacion General de Transportes Aereos Presidenciales, the air fleet for the Gobierno del Estado de Sinaloa, the air fleet for the Gobierno del Estado de Sonora and the Republica de Panama Autoridad Aeronautica Civil. In many instances, BizJet paid the bribes directly to the foreign officials. In other instances, BizJet funneled the bribes through a shell company owned and operated by a BizJet sales manager. BizJet executives orchestrated, authorized and approved the unlawful payments.\u0022 (Source: US Department of Justice Press Release, \u0022Bizjet International Sales and Support Inc., Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $11.8 Million Criminal Penalty,\u0022 March 14, 2012.) According to the Statement of Facts agreed to by the company as part of its Deferred Prosecution Agreement, \u0022Shell Company A\u0022 was owned by BizJet\u0027s Sales Manager and operated out of his personal residence in Van Nuys, California (para 7); Shell Company A \u0022operated under the pretense\u0022 of supplying aircraft maintenance, repair and overhaul services but in fact was used in the conspiracy by BizJet executives and sales manager to make unlawful payments to foreign officials via its bank account in California. (para 18) (Source: US v. BizJet International Sales and Support, Inc., Case No. 4:12-cr-00061 (N.D. Okla.), Deferred Prosecution Agreement and Statement of Facts filed March 14, 2012.)","Sources ":"US v. Uhl, Case No. 11-cr-184 (N.D. Okla), Information, Plea Agreement and Judgment, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-neal-uhl-court-docket-number-11-cr-184-gkf;\r\n \r\n Department of Justice Press Release, \u0022Former Chief Executive Officer of Lufthansa Subsidiary BizJet Pleads Guilty to Foreign Bribery Charges,\u0022 July 24, 2014, at https:\/\/www.justice.gov\/opa\/pr\/former-chief-executive-officer-lufthansa-subsidiary-bizjet-pleads-guilty-foreign-bribery\r\n \r\n US v. BizJet International Sales and Support, Inc., Case No. 4:12-cr-00061 (N.D. Okla.), Deferred Prosecution Agreement and Statement of Facts filed March 14, 2012, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-bizjet-international-sales-and-support-inc-court-docket-number","Documents":""},{"Case ID":"ST-422","Case Cluster ":"Bizjet","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico, Panama","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"4\/3","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials; Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials; Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Mr. Uhl was Vice President of Sales and Marketing of Bizjet International Sales and Support Inc., the U.S.-based subsidiary of Lufthansa Technik AG, which provides aircraft maintenance, repair and overhaul (MRO) services. \u0022BizJet paid bribes to officials employed by the Mexican Policia Federal Preventiva, the Mexican Coordinacion General de Transportes Aereos Presidenciales, the air fleet for the Gobierno del Estado de Sinaloa, the air fleet for the Gobierno del Estado de Sonora and the Republica de Panama Autoridad Aeronautica Civil. In many instances, BizJet paid the bribes directly to the foreign officials. In other instances, BizJet funneled the bribes through a shell company owned and operated by a BizJet sales manager. BizJet executives orchestrated, authorized and approved the unlawful payments.\u0022 (Source: US Department of Justice Press Release, \u0022Bizjet International Sales and Support Inc., Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $11.8 Million Criminal Penalty,\u0022 March 14, 2012.) According to the Statement of Facts agreed to by the company as part of its Deferred Prosecution Agreement, \u0022Shell Company A\u0022 was owned by BizJet\u0027s Sales Manager and operated out of his personal residence in Van Nuys, California (para 7); Shell Company A \u0022operated under the pretense\u0022 of supplying aircraft maintenance, repair and overhaul services but in fact was used in the conspiracy by BizJet executives and sales manager to make unlawful payments to foreign officials via its bank account in California. (para 18) (Source: US v. BizJet International Sales and Support, Inc., Case No. 4:12-cr-00061 (N.D. Okla.), Deferred Prosecution Agreement and Statement of Facts filed March 14, 2012.)","Sources ":"US v. Dubois, Case No. 11-cr-183 (N.D. Okla), Information, Plea Agreement and Judgment, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-peter-dubois-court-docket-number-11-cr-183-gkf; DOJ Press Release, \u0022Four Former Executives of Lufthansa Subsidiary Bizjet Charged with Foreign Bribery,\u0022 April 5, 2013, at https:\/\/www.justice.gov\/opa\/pr\/four-former-executives-lufthansa-subsidiary-bizjet-charged-foreign-bribery.","Documents":""},{"Case ID":"ST-423","Case Cluster ":"BNY Mellon","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Unidentified Middle East nation","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"8\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment interest, Civil Fine","Total Monetary Sanctions (US$)":"$14,800,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$8,300,000 ","Civil Prejudgment Interest (US$) ":"$1,500,000 ","Civil Fine \/ Penalty (US$)":"$5,000,000 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, Bank of New York Mellon \u0022has agreed to pay $14.8 million to settle charges that it violated the Foreign Corrupt Practices Act (FCPA) by providing valuable student internships to family members of foreign government officials affiliated with a Middle Eastern sovereign wealth fund. An SEC investigation found that BNY Mellon did not evaluate or hire the family members through its existing, highly competitive internship programs that have stringent hiring standards and require a minimum grade point average and multiple interviews. The family members did not meet the rigorous criteria yet were hired with the knowledge and approval of senior BNY Mellon employees in order to corruptly influence foreign officials and win or retain contracts to manage and service the assets of the sovereign wealth fund. According to the SEC\u2019s order instituting a settled administrative proceeding, the sovereign wealth fund officials requested that BNY Mellon provide their family members with internships, and they made numerous follow-up requests about the status, timing, and other details of the internships for their relatives.\u0022 (Source: SEC Press Release, \u0022SEC Charges BNY Mellon With FCPA Violations,\u0022 August 18, 2015.)","Sources ":"US Securities and Exchange Commission, In the Matter of The Bank of New York Mellon Corporation, Administrative Proceeding File No. 3-16762, August 18, 2015, at https:\/\/www.sec.gov\/litigation\/admin\/2015\/34-75720.pdf; SEC Press Release, \u0022SEC Charges BNY Mellon With FCPA Violations,\u0022 August 18, 2015, at https:\/\/www.sec.gov\/news\/pressrelease\/2015-170.html.","Documents":""},{"Case ID":"ST-424","Case Cluster ":"Bonny Island Nigeria","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"4\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$11,760,000 ","Criminal Fine\/Penalty (US$) ":"$11,760,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art.1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Department of Justice, \u0022Parker Drilling Company, a publicly listed drilling-services company, headquartered in Houston, has agreed to pay an $11.76 million penalty to resolve charges related to the Foreign Corrupt Practices Act (FCPA) for authorizing payment to an intermediary, knowing that the payment would be used to corruptly influence the decisions of a Nigerian government panel reviewing Parker Drilling\u2019s adherence to Nigerian customs and tax laws. [ ] \r\n \r\n The investigation of Parker Drilling stemmed from the Justice Department\u2019s Panalpina-related investigations, which previously yielded criminal resolutions with Panalpina and five oil and gas service companies and subsidiaries and resulted in more than $156 million in criminal penalties. [ ] \r\n  \r\n According to court documents, in 2001 and 2002, Panalpina World Transport (Nigeria) Limited, working on Parker Drilling\u2019s behalf, avoided certain costs associated with complying with Nigeria\u2019s customs laws by fraudulently claiming that Parker Drilling\u2019s rigs had been exported and then re-imported into Nigeria. In late 2002, Nigeria formed a government commission, commonly called the Temporary Import (TI) Panel, to examine whether Nigeria\u2019s Customs Service had collected certain duties and tariffs that Nigeria was due. In December 2002, the TI Panel commenced proceedings against Parker Drilling. The TI Panel later determined that Parker Drilling had violated Nigeria\u2019s customs laws and assessed a $3.8 million fine against Parker Drilling.\r\n \r\n According to court documents, rather than pay the assessed fine, Parker Drilling contracted indirectly with an intermediary agent to resolve its customs issues. From January to May 2004, Parker Drilling transferred $1.25 million to the agent, who reported spending a portion of the money on various things including entertaining government officials. Emails in which the agent requested additional money from Parker Drilling referenced the agent\u2019s interactions with Nigeria\u2019s Ministry of Finance, State Security Service, and a delegation from the president\u2019s office. Two senior executives within Parker Drilling at the time reviewed and approved the agent\u2019s invoices, knowing that the invoices arbitrarily attributed portions of the money that Parker Drilling transferred to the agent to various fees and expenses. The agent succeeded in reducing Parker Drilling\u2019s TI Panel fines from $3.8 million to just $750,000.\u0022 (Source: DOJ Press Release, \u0022Parker Drilling Company Resolves FCPA Investigation and Agrees to Pay $11.76 Million Penalty,\u0022 April 16, 2013.)","Sources ":"US v. Parker Drilling Company, Case No. 13-cr-176 (EDVA), Information and Deferred Prosecution Agreement filed April 16, 2013 and DOJ Press Release, \u0022Parker Drilling Company Resolves FCPA Investigation and Agrees to Pay $11.76 Million Penalty,\u0022 April 16, 2013, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-parker-drilling-company-court-docket-number-13-cr-176","Documents":""},{"Case ID":"ST-425","Case Cluster ":"Bonny Island Nigeria","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"4\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment interest","Total Monetary Sanctions (US$)":"$4,090,818 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$3,050,000 ","Civil Prejudgment Interest (US$) ":"$1,040,818 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"SOE","Summary":"According to the US Securities and Exchange Commission, Parker Drilling Company, a worldwide drilling services and project management firm was charged in April 2013, \u0022with violating the Foreign Corrupt Practices Act (FCPA) by authorizing improper payments to a third-party intermediary retained to assist the company in resolving customs disputes.\r\n \r\n The SEC\u0027s complaint, filed in federal district court in Alexandria, Virginia, alleges that in 2004 Parker Drilling authorized payments to a Nigerian agent totaling $1.25 million. The company did so despite former senior executives knowing that the agent intended to use the funds to \u0022entertain\u0022 Nigerian officials involved in resolving Parker Drilling\u0027s ongoing customs problems. Following the Nigerian agent\u0027s work, the company received an unexplained $3,050,000 reduction of a previously assessed customs fine, and the company was permitted to nationalize and sell its Nigerian rigs.\u0022 (Source: SEC Litigation Release No. 22672 \/ April 16, 2013, \u0022SEC Charges Parker Drilling Company with Violating the Foreign Corrupt Practices Act.\u0022)","Sources ":"US Securities and Exchange Commission v. Parker Drilling Company, Civil Action No. 13-cv-461 (E.D. Va.), Complaint filed April 16, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp22672.pdf; SEC Litigation Release No. 22672 \/ April 16, 2013, \u0022SEC Charges Parker Drilling Company with Violating the Foreign Corrupt Practices Act,\u0022 at https:\/\/www.sec.gov\/litigation\/litreleases\/2013\/lr22672.htm.","Documents":""},{"Case ID":"ST-426","Case Cluster ":"Bristol-Myers Squibb","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"10\/5","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment interest, Civil Fine","Total Monetary Sanctions (US$)":"$14,650,000 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$11,400,000 ","Civil Prejudgment Interest (US$) ":"$500,000 ","Civil Fine \/ Penalty (US$)":"$2,750,000 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations and Recordkeeping","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission\u2019s \u0022order instituting settled administrative proceedings, Bristol-Myers Squibb lacked effective internal controls over interactions with health care providers at BMS China, its majority-owned joint venture. Between 2009 and 2014, BMS China sales representatives sought to secure and increase business by providing health care providers in China with cash, jewelry and other gifts, meals, travel, entertainment, and sponsorships for conferences and meetings. BMS China inaccurately recorded the spending as legitimate business expenses in its books and records, which were then consolidated into the books and records of Bristol-Myers Squibb. [ ] The SEC\u2019s order finds that Bristol-Myers Squibb violated the FCPA\u2019s internal controls and recordkeeping provisions. Without admitting or denying the findings, Bristol-Myers Squibb consented to the order and agreed to return $11.4 million of profits plus prejudgment interest of $500,000 and pay a civil penalty of $2.75 million. Bristol-Myers Squibb also agreed to report to the SEC for a two-year period on the status of its remediation and implementation of FCPA and anti-corruption compliance measures.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Bristol-Myers Squibb With FCPA Violations,\u0022 October 5, 2015.)","Sources ":"US SEC Press Release, \u0022SEC Charges Bristol-Myers Squibb With FCPA Violations,\u0022 October 5, 2015, at https:\/\/www.sec.gov\/news\/pressrelease\/2015-229.html","Documents":""},{"Case ID":"ST-427","Case Cluster ":"Brucker Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"12\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Cease and Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment interest, Civil Fine","Total Monetary Sanctions (US$)":"$2,399,969 ","Criminal Fine\/Penalty (US$) ":"NA","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"NA","Criminal Restitution \/ Reparation (US$)":"NA","Criminal Legal \/ Procedural Costs (US$)":"NA","Civil Disgorgement of Profits (US$) ":"$1,714,852 ","Civil Prejudgment Interest (US$) ":"$310,117 ","Civil Fine \/ Penalty (US$)":"$375,000 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"NA","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art. 16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations and Recordkeeping","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, Brucker Corporation, a Billerica, Mass.-based global manufacturer of scientific instruments was charged \u0022with violating the Foreign Corrupt Practices Act (FCPA) by providing non-business related travel and improper payments to various Chinese government officials in an effort to win business. \n \n An SEC investigation found that Bruker Corporation lacked sufficient internal controls to prevent and detect approximately $230,000 in improper payments out of its China-based offices that falsely recorded them in books and records as legitimate business and marketing expenses. The payments enabled Bruker to realize approximately $1.7 million in profits from sales contracts with state-owned entities in China whose officials received the improper payments. [ ] \n \n According to the SEC\u2019s order instituting a settled administrative proceeding, a Bruker office in China paid more than $111,000 to Chinese government officials under 12 suspicious collaboration agreements contingent on state-owned entities providing research on Bruker products or using Bruker products in demonstration laboratories. The collaboration agreements did not specify the work product that the state-owned entities had to provide in order to be paid, and no work product was actually provided to the Bruker office by the state-owned entities. Certain collaboration agreements were executed directly with a Chinese government official rather than the state-owned entity itself, and in some cases Bruker\u2019s office paid the official directly. \n \n According to the SEC\u2019s order, the other improper payments involved reimbursements to Chinese government officials for leisure travel to the United States, Czech Republic, Norway, Sweden, France, Germany, Switzerland, and Italy. These officials often were responsible for authorizing the purchase of Bruker products, and the leisure trips typically followed business-related travel for the officials funded by the company. For example, Bruker paid for the purported training expenses of a Chinese government official who signed the sales contract on behalf of a state-owned entity, but the payment actually was reimbursement for sightseeing, tour tickets, shopping, and other leisure activities in Frankfurt and Paris. Bruker also funded some trips for Chinese government officials that had no legitimate business component. For example, two Chinese government officials received paid travel to New York despite the lack of any Bruker facilities there, and also to Los Angeles where they engaged in sightseeing activities.\u0022 (Source: US SEC Press Release, \u0022SEC Charges Massachusetts-Based Scientific Instruments Manufacturer with FCPA Violations,\u0022 December 15, 2014.)","Sources ":"US SEC Press Release, \u0022SEC Charges Massachusetts-Based Scientific Instruments Manufacturer with FCPA Violations,\u0022 December 15, 2014, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370543708934; Administrative Proceeding File No.","Documents":""},{"Case ID":"ST-428","Case Cluster ":"Control Components, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Multiple","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"11\/9","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Plea Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$20,000.00 ","Criminal Fine\/Penalty (US$) ":"$20,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On July 22, 2009, Control Components, Inc. (CCI), a Rancho Santa Margarita, California-based company, was charged in a three count criminal information with violations of the FCPA and the Travel Act, stemming from a decade-long scheme to secure contracts in approximately 36 countries by paying bribes to officials and employees of various foreign state-owned companies as well as foreign and domestic private companies. Previously, two former executives of CCI, Mario Covino and Richard Morlok, were each charged with one count of conspiracy to bribe foreign officials in violation of the FCPA (on December 17, 2008 and January 7, 2009, respectively). On April 9, 2009, a grand jury in the Central District of California returned an indictment against six additional former CCI executives for their alleged roles in this bribery scheme. According to court documents, from 2003 through 2007, CCI, a manufacturer of service control valves for use in the nuclear, oil and gas, and power generation industries, made approximately 236 corrupt payments to officers and employees of foreign state-owned and private companies in more than 30 countries. Sales from these corrupt payments resulted in net profits to the company of approximately $46.5 million.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Control Componets, Inc. Case Summary, at 64-65.)","Sources ":"US v. Hong Rose Carson, Case No, 09-cr-77 (C.D. Cal), Judgment filed November 5, 2012","Documents":""},{"Case ID":"ST-429","Case Cluster ":"Control Components, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Multiple","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"11\/7","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Plea Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$20,000.00 ","Criminal Fine\/Penalty (US$) ":"$20,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On July 22, 2009, Control Components, Inc. (CCI), a Rancho Santa Margarita, California-based company, was charged in a three count criminal information with violations of the FCPA and the Travel Act, stemming from a decade-long scheme to secure contracts in approximately 36 countries by paying bribes to officials and employees of various foreign state-owned companies as well as foreign and domestic private companies. Previously, two former executives of CCI, Mario Covino and Richard Morlok, were each charged with one count of conspiracy to bribe foreign officials in violation of the FCPA (on December 17, 2008 and January 7, 2009, respectively). On April 9, 2009, a grand jury in the Central District of California returned an indictment against six additional former CCI executives for their alleged roles in this bribery scheme. According to court documents, from 2003 through 2007, CCI, a manufacturer of service control valves for use in the nuclear, oil and gas, and power generation industries, made approximately 236 corrupt payments to officers and employees of foreign state-owned and private companies in more than 30 countries. Sales from these corrupt payments resulted in net profits to the company of approximately $46.5 million.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Control Componets, Inc. Case Summary, at 64-65.)","Sources ":"US v. Stuart Carson, Case No, 09-cr-77 (C.D. Cal), Judgment filed November 7, 2012","Documents":""},{"Case ID":"ST-430","Case Cluster ":"Dallas Airmotive","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Argentina, Brazil, Peru","Year of Settlement":"2014","Month\/Day of Settlement (or Notes)":"12\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Penalty","Total Monetary Sanctions (US$)":"$14,000,000","Criminal Fine\/Penalty (US$) ":"$14,000,000 ","Criminal Fine \/ Penalty (Explanation)":"$0 ","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"Accordng to the US Department of Justice, \u0022Dallas Airmotive Inc., a provider of aircraft engine maintenance, repair and overhaul services based in Grapevine, Texas, has admitted to violations of the Foreign Corrupt Practices Act (FCPA) and agreed to pay a $14 million criminal penalty to resolve charges that it bribed Latin American government officials in order to secure lucrative government contracts. [ ] \r\n \r\n A criminal information, filed today in federal court in the Northern District of Texas as part of the deferred prosecution agreement, charges Dallas Airmotive with one count of conspiring to violate the FCPA and one count of violating the FCPA\u2019s antibribery provisions. According to Dallas Airmotive\u2019s detailed admissions in the statement of facts accompanying the deferred prosecution agreement, between 2008 and 2012, the company bribed officials of the Brazilian Air Force, the Peruvian Air Force, the Office of the Governor of the Brazilian State of Roraima, and the Office of the Governor of the San Juan Province in Argentina. Dallas Airmotive used various methods to convey the bribe payments, including by entering into agreements with front companies affiliated with foreign officials, making payments to third party representatives with the understanding that funds would be directed to foreign officials, and directly providing things of value, such as paid vacations, to foreign officials.\u0022 (Source: US DOJ Press Release, \u0022Dallas Airmotive Inc. Admits Foreign Corrupt Practices Act Violations and Agrees to Pay $14 Million Criminal Penalty,\u0022 December 10, 2014.)","Sources ":"US v. Airmotive, Inc., Case No. 14-cr-483 (NDTX), Information filed December 10, 2014; Deferred Prosecution and US DOJ Press Release, \u0022Dallas Airmotive Inc. Admits Foreign Corrupt Practices Act Violations and Agrees to Pay $14 Million Criminal Penalty,\u0022 December 10, 2014, all accessed at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-dallas-airmotive-2014-court-docket-no-3-14-cr-483-d.","Documents":""},{"Case ID":"ST-431","Case Cluster ":"Data Systems \u0026 Solutions LLC","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Lithuania","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"6\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Penalty","Total Monetary Sanctions (US$)":"$8,820,000.00 ","Criminal Fine\/Penalty (US$) ":"$8,820,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Data Systems \u0026 Solutions LLC (DS\u0026S), a company based in Reston, Va., that provides design, installation, maintenance and other services at nuclear and fossil fuel power plants, has agreed to pay an $8.82 million criminal penalty to resolve violations of the Foreign Corrupt Practices Act (FCPA) [ ] , \r\n \r\n The department filed a two-count criminal information today in the Eastern District of Virginia charging DS\u0026S with conspiring to violate, and violating, the FCPA\u2019s anti-bribery provisions.\r\n \r\n According to court documents, DS\u0026S paid bribes to officials employed by the Ignalina Nuclear Power Plant, a state-owned nuclear power plant in Lithuania, to secure contracts to perform services for the plant. To disguise the scheme, the bribes were funneled through several subcontractors located in the United States and abroad. The subcontractors, in turn, made repeated payments to high-level officials at Ignalina via check or wire transfer.\u0022 (Source: US DOJ Press Release, \u0022Data Systems \u0026 Solutions LLC Resolves Foreign Corrupt Practices Act Violations and Agrees to Pay $8.82 Million Criminal Penalty,\u0022 June 18, 2012.)","Sources ":"US v. Data Systems \u0026 Solutions LLC, Case No. 12-cr-262 (EDVA), Information and Deferred Prosecution Agreement filed June 18, 2012 and DOJ Press Release, \u0022Data Systems \u0026 Solutions LLC Resolves Foreign Corrupt Practices Act Violations and Agrees to Pay $8.82 Million Criminal Penalty,\u0022 June 18, 2012, accessed at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-data-systems-solutions-llc-court-docket-number-12-cr-262-lo.","Documents":""},{"Case ID":"ST-432","Case Cluster ":"Diebold Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China, Indonesia, Russia","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"10\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Penalty","Total Monetary Sanctions (US$)":"$25,920,000.00 ","Criminal Fine\/Penalty (US$) ":"$25,920,000.00 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials; Conspiracy Falsification of Books and Records","Offenses - Settled":"Conspiracy to Bribe Foreign Officials; Conspiracy Falsification of Books and Records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Diebold Inc. (Diebold), the Ohio-based provider of integrated self-service delivery and security systems, including automated teller machines (ATMs), has agreed to pay a $25.2 million penalty to resolve allegations that it violated the Foreign Corrupt Practices Act (FCPA) by bribing government officials in China and Indonesia and falsifying records in Russia in order to obtain and retain contracts to provide ATMs to state-owned and private banks in those countries. [ ] \r\n \r\n The department today filed in U.S. District Court for the Northern District of Ohio a criminal information and a deferred prosecution agreement. The two-count information charges Diebold with conspiring to violate the FCPA\u2019s anti-bribery and books and records provisions and violating the FCPA\u2019s books and records provisions. [ ] \r\n \r\n According to court documents, Diebold paid bribes and falsified documents in connection with the sale of ATMs to bank customers in China, Indonesia, and Russia. With respect to China and Indonesia, the court documents allege that from 2005 to 2010, in order to secure and retain business with bank customers, including state-owned and -controlled banks, Diebold repeatedly provided things of value, including payments, gifts, and non-business travel for employees of the banks, totaling approximately $1.75 million. Diebold attempted to disguise the payments and benefits through various means, including by making payments through third parties designated by the banks and by inaccurately recording leisure trips for bank employees as \u201ctraining.\u201d The court documents also allege that from 2005 to 2009, Diebold created and entered into false contracts with a distributor in Russia for services that the distributor was not performing. The distributor, in turn, used the money that Diebold paid to it, in part, to pay bribes to employees of Diebold\u2019s privately-owned bank customers in Russia in order to obtain and retain ATM-related contracts with those customers.\u0022 (Source: US DOJ Press Release, \u0022Diebold Incorporated Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $25.2 Million Criminal Penalty,\u0022 October 22, 2013.)","Sources ":"US v. Diebold Inc., Case No. 13-cr-464 (ND Ohio), Information and Deferred Prosecution Agreement both filed October 22, 2013; DOJ Press Release, \u0022Diebold Incorporated Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $25.2 Million Criminal Penalty,\u0022 October 22, 2013, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-diebold-inc-court-docket-number-13-cr-000464-so","Documents":""},{"Case ID":"ST-433","Case Cluster ":"Diebold Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, Indonesia, Russia","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"10\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$22,972,942.00 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$19,719,550 ","Civil Prejudgment Interest (US$) ":"$3,253,392 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, Diebold, the \u0022Ohio-based manufacturer of ATMs and bank security systems with violating the Foreign Corrupt Practices Act by bribing officials at government-owned banks with pleasure trips in order to illicitly win business.\r\n \r\n The SEC alleges that subsidiaries of Diebold Inc. in China and Indonesia spent approximately $1.8 million on travel, entertainment, and other improper gifts for senior officials with the ability to influence the banks\u2019 purchasing decisions. Government-owned bank officials in China and Indonesia were rewarded with free trips to popular tourist destinations in the U.S. and Europe, and Diebold\u2019s expenditures were falsely recorded in the company\u2019s books and records as legitimate training expenses. Diebold\u2019s subsidiary in China also provided dozens of government bank officials with annual cash gifts ranging from less than $100 to more than $600. The SEC further alleges that Diebold falsified books and records to hide approximately $1.2 million of bribes paid to employees at privately owned banks in Russia. [ ] \r\n \r\n According to the SEC\u2019s complaint filed in federal court in Washington D.C., Diebold\u2019s misconduct occurred from 2005 to 2010. Among the tourist destinations of U.S. trips were the Grand Canyon, Napa Valley, Disneyland, and Universal Studios as well as Las Vegas, New York City, Chicago, Washington D.C., and Hawaii. Officials also were treated to European vacations. For example, eight officials at a government-owned bank in China enjoyed a two-week trip at Diebold\u2019s expense that included stays in Paris, Brussels, Amsterdam, Cologne, Frankfurt, Munich, Salzburg, Vienna, Klagenfurt, Venice, Florence, and Rome. Destinations of leisure trips for other officials included Australia, New Zealand, and Bali. In total, Diebold spent approximately $1.6 million to bribe government-owned bank officials in China, and more than $147,000 to bribe officials at government banks in Indonesia. \r\n \r\n The SEC further alleges that from 2005 to 2008, Diebold\u2019s Russian subsidiary paid approximately $1.2 million in bribes in connection with the sale of ATMs to private banks in Russia. The bribes were funneled through a distributor in Russia using phony service contracts to hide and falsely record the payments as legitimate business expenses.\u0022 (Source: SEC Press Release, \u0022SEC Charges Diebold With FCPA Violations,\u0022 October 22, 2013.)","Sources ":"US Securities and Exchange Commission v. Diebold Inc., Case No. 1:13-cv-01609 (DDC), Complaint filed October 12, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-225.pdf; Final Judgment of November 5, 2013 accessed at PACER;\r\n \r\n SEC Press Release, \u0022SEC Charges Diebold With FCPA Violations,\u0022 October 22, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1370539977273","Documents":""},{"Case ID":"ST-434","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"4\/6","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$0.00 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials; Securities Fraud","Offenses - Settled":"Bribery of Foreign Officials; Securities Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022the global markets group at broker-dealer Direct Access Partners (DAP) executed fixed income trades for customers in foreign sovereign debt. DAP Global generated more than $66 million in revenue for DAP from transaction fees - in the form of markups and markdowns - on riskless principal trade executions in Venezuelan sovereign or state-sponsored bonds for Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES). A portion of this revenue was illicitly paid to BANDES Vice President of Finance, Mar\u00eda de los \u00c1ngeles Gonz\u00e1lez de Hernandez, who authorized the fraudulent trades. [ ] \r\n \r\n The SEC\u0027s complaint charges the following individuals for the roles in the kickback scheme:\r\n \r\n Tomas Alberto Clarke Bethancourt, who lives in Miami and is an executive vice president at DAP. Known as \u0022Tomas Clarke,\u0022 he was responsible for executing the fraudulent trades and maintaining spreadsheets tracking the illicit markups and markdowns on those trades.\r\n Iuri Rodolfo Bethancourt, who lives in Panama and received more than $20 million in fraudulent proceeds from DAP via his Panamanian shell company, which then paid Gonzalez a portion of this amount.\r\n Jose Alejandro Hurtado, who lives in Miami and served as the intermediary between DAP and Gonzalez. Hurtado was paid more than $6 million in kickbacks disguised as salary payments from DAP, and he remitted some of that money to Gonzalez.\r\n Haydee Leticia Pabon, who is Hurtado\u0027s wife and received approximately $8 million in markups or markdowns on BANDES trades that were funneled to her from DAP in the form of sham finders\u0027 fees. [ ]\r\n \r\n According to the SEC\u0027s complaint, the scheme began in October 2008 and continued until at least June 2010. BANDES was a new customer to DAP brought in by DAP Global executives through their connections to Hurtado. As a result of the kickbacks to Gonzalez, DAP obtained BANDES\u0027 lucrative trading business and provided Gonzalez with the incentive to enter into trades with DAP at considerable markups or markdowns without regard to the prices paid by BANDES. Gonzalez used her senior role at the Caracas-based bank to ensure that its bond trades would continue to be steered to DAP. As the scheme evolved over time, the traders deceived DAP\u0027s clearing brokers, executed internal wash trades, inter-positioned another broker-dealer in the trades to conceal their role in the transactions, and engaged in massive roundtrip trades to pad their revenue.\r\n \r\n For example, the SEC alleges that in January 2010, the traders and Gonzalez arranged for two fraudulent roundtrip trades with BANDES as both buyer and seller. These trades - which lacked any legitimate business purpose - caused BANDES to pay DAP more than $10 million in fees, a portion of which was diverted to Gonzalez for authorizing the blatantly fraudulent trades.\r\n \r\n The SEC further alleges that, giving rise to the adage of no honor among thieves, Clarke and Hurtado frequently falsified the size of DAP\u0027s fees in their reports to Gonzalez, which enabled the traders to retain a greater share of the fraudulent profits.\u0022 (Source: US SEC Press Release,\u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013.) \r\n \r\n In April 2014, Benito Chinea and Joseph DeMeneses were added to the SEC\u0027s complaint. In 2016, seven defendants in the case were ordered to forfeit $42,506,171, which was deemed satisfied by the criminal judgments imposed against them. (Source: US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank.\u0022)","Sources ":"US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank,\u0022 at https:\/\/www.sec.gov\/litigation\/litreleases\/2016\/lr23513.htm; \r\n \r\n US Securities and Exchange Commission v. Clarke Bethancourt, Bethancourt, Hurtado and Pabon, Case No. 13-cv-3074 (SDNY), Complaint filed May 7, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-84.pdf; SEC Press Release, \u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171514248","Documents":""},{"Case ID":"ST-435","Case Cluster ":"","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"4\/6","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$0.00 ","Criminal Fine\/Penalty (US$) ":"NA","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"NA","Criminal Restitution \/ Reparation (US$)":"NA","Criminal Legal \/ Procedural Costs (US$)":"NA","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"$0 ","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art. 16,  Art. 23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials; Securities Fraud","Offenses - Settled":"Bribery of Foreign Officials; Securities Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022the global markets group at broker-dealer Direct Access Partners (DAP) executed fixed income trades for customers in foreign sovereign debt. DAP Global generated more than $66 million in revenue for DAP from transaction fees - in the form of markups and markdowns - on riskless principal trade executions in Venezuelan sovereign or state-sponsored bonds for Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES). A portion of this revenue was illicitly paid to BANDES Vice President of Finance, Mar\u00eda de los \u00c1ngeles Gonz\u00e1lez de Hernandez, who authorized the fraudulent trades. [ ] \n \n The SEC\u0027s complaint charges the following individuals for the roles in the kickback scheme:\n \n Tomas Alberto Clarke Bethancourt, who lives in Miami and is an executive vice president at DAP. Known as \u0022Tomas Clarke,\u0022 he was responsible for executing the fraudulent trades and maintaining spreadsheets tracking the illicit markups and markdowns on those trades.\n Iuri Rodolfo Bethancourt, who lives in Panama and received more than $20 million in fraudulent proceeds from DAP via his Panamanian shell company, which then paid Gonzalez a portion of this amount.\n Jose Alejandro Hurtado, who lives in Miami and served as the intermediary between DAP and Gonzalez. Hurtado was paid more than $6 million in kickbacks disguised as salary payments from DAP, and he remitted some of that money to Gonzalez.\n Haydee Leticia Pabon, who is Hurtado\u0027s wife and received approximately $8 million in markups or markdowns on BANDES trades that were funneled to her from DAP in the form of sham finders\u0027 fees. [ ]\n \n According to the SEC\u0027s complaint, the scheme began in October 2008 and continued until at least June 2010. BANDES was a new customer to DAP brought in by DAP Global executives through their connections to Hurtado. As a result of the kickbacks to Gonzalez, DAP obtained BANDES\u0027 lucrative trading business and provided Gonzalez with the incentive to enter into trades with DAP at considerable markups or markdowns without regard to the prices paid by BANDES. Gonzalez used her senior role at the Caracas-based bank to ensure that its bond trades would continue to be steered to DAP. As the scheme evolved over time, the traders deceived DAP\u0027s clearing brokers, executed internal wash trades, inter-positioned another broker-dealer in the trades to conceal their role in the transactions, and engaged in massive roundtrip trades to pad their revenue.\n \n For example, the SEC alleges that in January 2010, the traders and Gonzalez arranged for two fraudulent roundtrip trades with BANDES as both buyer and seller. These trades - which lacked any legitimate business purpose - caused BANDES to pay DAP more than $10 million in fees, a portion of which was diverted to Gonzalez for authorizing the blatantly fraudulent trades.\n \n The SEC further alleges that, giving rise to the adage of no honor among thieves, Clarke and Hurtado frequently falsified the size of DAP\u0027s fees in their reports to Gonzalez, which enabled the traders to retain a greater share of the fraudulent profits.\u0022 (Source: US SEC Press Release,\u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013.) \n \n In April 2014, Benito Chinea and Joseph DeMeneses were added to the SEC\u0027s complaint. In 2016, seven defendants in the case were ordered to forfeit $42,506,171, which was deemed satisfied by the criminal judgments imposed against them. (Source: US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank.\u0022)","Sources ":"US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank,\u0022 at https:\/\/www.sec.gov\/litigation\/litreleases\/2016\/lr23513.htm; \n \n US Securities and Exchange Commission v. Clarke Bethancourt, Bethancourt, Hurtado and Pabon, Case No. 13-cv-3074 (SDNY), Complaint filed May 7, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-84.pdf; SEC Press Release, \u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171514248","Documents":""},{"Case ID":"ST-436","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"4\/6","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$0.00 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials; Securities Fraud","Offenses - Settled":"Bribery of Foreign Officials; Securities Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022the global markets group at broker-dealer Direct Access Partners (DAP) executed fixed income trades for customers in foreign sovereign debt. DAP Global generated more than $66 million in revenue for DAP from transaction fees - in the form of markups and markdowns - on riskless principal trade executions in Venezuelan sovereign or state-sponsored bonds for Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES). A portion of this revenue was illicitly paid to BANDES Vice President of Finance, Mar\u00eda de los \u00c1ngeles Gonz\u00e1lez de Hernandez, who authorized the fraudulent trades. [ ] \r\n \r\n The SEC\u0027s complaint charges the following individuals for the roles in the kickback scheme:\r\n \r\n Tomas Alberto Clarke Bethancourt, who lives in Miami and is an executive vice president at DAP. Known as \u0022Tomas Clarke,\u0022 he was responsible for executing the fraudulent trades and maintaining spreadsheets tracking the illicit markups and markdowns on those trades.\r\n Iuri Rodolfo Bethancourt, who lives in Panama and received more than $20 million in fraudulent proceeds from DAP via his Panamanian shell company, which then paid Gonzalez a portion of this amount.\r\n Jose Alejandro Hurtado, who lives in Miami and served as the intermediary between DAP and Gonzalez. Hurtado was paid more than $6 million in kickbacks disguised as salary payments from DAP, and he remitted some of that money to Gonzalez.\r\n Haydee Leticia Pabon, who is Hurtado\u0027s wife and received approximately $8 million in markups or markdowns on BANDES trades that were funneled to her from DAP in the form of sham finders\u0027 fees. [ ]\r\n \r\n According to the SEC\u0027s complaint, the scheme began in October 2008 and continued until at least June 2010. BANDES was a new customer to DAP brought in by DAP Global executives through their connections to Hurtado. As a result of the kickbacks to Gonzalez, DAP obtained BANDES\u0027 lucrative trading business and provided Gonzalez with the incentive to enter into trades with DAP at considerable markups or markdowns without regard to the prices paid by BANDES. Gonzalez used her senior role at the Caracas-based bank to ensure that its bond trades would continue to be steered to DAP. As the scheme evolved over time, the traders deceived DAP\u0027s clearing brokers, executed internal wash trades, inter-positioned another broker-dealer in the trades to conceal their role in the transactions, and engaged in massive roundtrip trades to pad their revenue.\r\n \r\n For example, the SEC alleges that in January 2010, the traders and Gonzalez arranged for two fraudulent roundtrip trades with BANDES as both buyer and seller. These trades - which lacked any legitimate business purpose - caused BANDES to pay DAP more than $10 million in fees, a portion of which was diverted to Gonzalez for authorizing the blatantly fraudulent trades.\r\n \r\n The SEC further alleges that, giving rise to the adage of no honor among thieves, Clarke and Hurtado frequently falsified the size of DAP\u0027s fees in their reports to Gonzalez, which enabled the traders to retain a greater share of the fraudulent profits.\u0022 (Source: US SEC Press Release,\u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013.) \r\n \r\n In April 2014, Benito Chinea and Joseph DeMeneses were added to the SEC\u0027s complaint. In 2016, seven defendants in the case were ordered to forfeit $42,506,171, which was deemed satisfied by the criminal judgments imposed against them. (Source: US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank.\u0022)","Sources ":"US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank,\u0022 at https:\/\/www.sec.gov\/litigation\/litreleases\/2016\/lr23513.htm; \r\n \r\n US Securities and Exchange Commission v. Clarke Bethancourt, Bethancourt, Hurtado and Pabon, Case No. 13-cv-3074 (SDNY), Complaint filed May 7, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-84.pdf; SEC Press Release, \u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171514248","Documents":""},{"Case ID":"ST-437","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"4\/6","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$0","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials; Securities Fraud","Offenses - Settled":"Bribery of Foreign Officials; Securities Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022the global markets group at broker-dealer Direct Access Partners (DAP) executed fixed income trades for customers in foreign sovereign debt. DAP Global generated more than $66 million in revenue for DAP from transaction fees - in the form of markups and markdowns - on riskless principal trade executions in Venezuelan sovereign or state-sponsored bonds for Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES). A portion of this revenue was illicitly paid to BANDES Vice President of Finance, Mar\u00eda de los \u00c1ngeles Gonz\u00e1lez de Hernandez, who authorized the fraudulent trades. [ ] \r\n \r\n The SEC\u0027s complaint charges the following individuals for the roles in the kickback scheme:\r\n \r\n Tomas Alberto Clarke Bethancourt, who lives in Miami and is an executive vice president at DAP. Known as \u0022Tomas Clarke,\u0022 he was responsible for executing the fraudulent trades and maintaining spreadsheets tracking the illicit markups and markdowns on those trades.\r\n Iuri Rodolfo Bethancourt, who lives in Panama and received more than $20 million in fraudulent proceeds from DAP via his Panamanian shell company, which then paid Gonzalez a portion of this amount.\r\n Jose Alejandro Hurtado, who lives in Miami and served as the intermediary between DAP and Gonzalez. Hurtado was paid more than $6 million in kickbacks disguised as salary payments from DAP, and he remitted some of that money to Gonzalez.\r\n Haydee Leticia Pabon, who is Hurtado\u0027s wife and received approximately $8 million in markups or markdowns on BANDES trades that were funneled to her from DAP in the form of sham finders\u0027 fees. [ ]\r\n \r\n According to the SEC\u0027s complaint, the scheme began in October 2008 and continued until at least June 2010. BANDES was a new customer to DAP brought in by DAP Global executives through their connections to Hurtado. As a result of the kickbacks to Gonzalez, DAP obtained BANDES\u0027 lucrative trading business and provided Gonzalez with the incentive to enter into trades with DAP at considerable markups or markdowns without regard to the prices paid by BANDES. Gonzalez used her senior role at the Caracas-based bank to ensure that its bond trades would continue to be steered to DAP. As the scheme evolved over time, the traders deceived DAP\u0027s clearing brokers, executed internal wash trades, inter-positioned another broker-dealer in the trades to conceal their role in the transactions, and engaged in massive roundtrip trades to pad their revenue.\r\n \r\n For example, the SEC alleges that in January 2010, the traders and Gonzalez arranged for two fraudulent roundtrip trades with BANDES as both buyer and seller. These trades - which lacked any legitimate business purpose - caused BANDES to pay DAP more than $10 million in fees, a portion of which was diverted to Gonzalez for authorizing the blatantly fraudulent trades.\r\n \r\n The SEC further alleges that, giving rise to the adage of no honor among thieves, Clarke and Hurtado frequently falsified the size of DAP\u0027s fees in their reports to Gonzalez, which enabled the traders to retain a greater share of the fraudulent profits.\u0022 (Source: US SEC Press Release,\u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013.) \r\n \r\n In April 2014, Benito Chinea and Joseph DeMeneses were added to the SEC\u0027s complaint. In 2016, seven defendants in the case were ordered to forfeit $42,506,171, which was deemed satisfied by the criminal judgments imposed against them. (Source: US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank.\u0022)","Sources ":"US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank,\u0022 at https:\/\/www.sec.gov\/litigation\/litreleases\/2016\/lr23513.htm; \r\n \r\n US Securities and Exchange Commission v. Clarke Bethancourt, Bethancourt, Hurtado and Pabon, Case No. 13-cv-3074 (SDNY), Complaint filed May 7, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-84.pdf; SEC Press Release, \u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171514248","Documents":""},{"Case ID":"ST-438","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"4\/6","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$0","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"$0 ","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials; Securities Fraud","Offenses - Settled":"Bribery of Foreign Officials; Securities Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022the global markets group at broker-dealer Direct Access Partners (DAP) executed fixed income trades for customers in foreign sovereign debt. DAP Global generated more than $66 million in revenue for DAP from transaction fees - in the form of markups and markdowns - on riskless principal trade executions in Venezuelan sovereign or state-sponsored bonds for Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES). A portion of this revenue was illicitly paid to BANDES Vice President of Finance, Mar\u00eda de los \u00c1ngeles Gonz\u00e1lez de Hernandez, who authorized the fraudulent trades. [ ] \r\n \r\n The SEC\u0027s complaint charges the following individuals for the roles in the kickback scheme:\r\n \r\n Tomas Alberto Clarke Bethancourt, who lives in Miami and is an executive vice president at DAP. Known as \u0022Tomas Clarke,\u0022 he was responsible for executing the fraudulent trades and maintaining spreadsheets tracking the illicit markups and markdowns on those trades.\r\n Iuri Rodolfo Bethancourt, who lives in Panama and received more than $20 million in fraudulent proceeds from DAP via his Panamanian shell company, which then paid Gonzalez a portion of this amount.\r\n Jose Alejandro Hurtado, who lives in Miami and served as the intermediary between DAP and Gonzalez. Hurtado was paid more than $6 million in kickbacks disguised as salary payments from DAP, and he remitted some of that money to Gonzalez.\r\n Haydee Leticia Pabon, who is Hurtado\u0027s wife and received approximately $8 million in markups or markdowns on BANDES trades that were funneled to her from DAP in the form of sham finders\u0027 fees. [ ]\r\n \r\n According to the SEC\u0027s complaint, the scheme began in October 2008 and continued until at least June 2010. BANDES was a new customer to DAP brought in by DAP Global executives through their connections to Hurtado. As a result of the kickbacks to Gonzalez, DAP obtained BANDES\u0027 lucrative trading business and provided Gonzalez with the incentive to enter into trades with DAP at considerable markups or markdowns without regard to the prices paid by BANDES. Gonzalez used her senior role at the Caracas-based bank to ensure that its bond trades would continue to be steered to DAP. As the scheme evolved over time, the traders deceived DAP\u0027s clearing brokers, executed internal wash trades, inter-positioned another broker-dealer in the trades to conceal their role in the transactions, and engaged in massive roundtrip trades to pad their revenue.\r\n \r\n For example, the SEC alleges that in January 2010, the traders and Gonzalez arranged for two fraudulent roundtrip trades with BANDES as both buyer and seller. These trades - which lacked any legitimate business purpose - caused BANDES to pay DAP more than $10 million in fees, a portion of which was diverted to Gonzalez for authorizing the blatantly fraudulent trades.\r\n \r\n The SEC further alleges that, giving rise to the adage of no honor among thieves, Clarke and Hurtado frequently falsified the size of DAP\u0027s fees in their reports to Gonzalez, which enabled the traders to retain a greater share of the fraudulent profits.\u0022 (Source: US SEC Press Release,\u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013.) \r\n \r\n In April 2014, Benito Chinea and Joseph DeMeneses were added to the SEC\u0027s complaint. In 2016, seven defendants in the case were ordered to forfeit $42,506,171, which was deemed satisfied by the criminal judgments imposed against them. (Source: US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank.\u0022)","Sources ":"US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank,\u0022 at https:\/\/www.sec.gov\/litigation\/litreleases\/2016\/lr23513.htm; \r\n \r\n US Securities and Exchange Commission v. Clarke Bethancourt, Bethancourt, Hurtado and Pabon, Case No. 13-cv-3074 (SDNY), Complaint filed May 7, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-84.pdf; SEC Press Release, \u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171514248","Documents":""},{"Case ID":"ST-439","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"4\/6","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$0","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials; Securities Fraud","Offenses - Settled":"Bribery of Foreign Officials; Securities Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022the global markets group at broker-dealer Direct Access Partners (DAP) executed fixed income trades for customers in foreign sovereign debt. DAP Global generated more than $66 million in revenue for DAP from transaction fees - in the form of markups and markdowns - on riskless principal trade executions in Venezuelan sovereign or state-sponsored bonds for Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES). A portion of this revenue was illicitly paid to BANDES Vice President of Finance, Mar\u00eda de los \u00c1ngeles Gonz\u00e1lez de Hernandez, who authorized the fraudulent trades. [ ] \r\n \r\n The SEC\u0027s complaint charges the following individuals for the roles in the kickback scheme:\r\n \r\n Tomas Alberto Clarke Bethancourt, who lives in Miami and is an executive vice president at DAP. Known as \u0022Tomas Clarke,\u0022 he was responsible for executing the fraudulent trades and maintaining spreadsheets tracking the illicit markups and markdowns on those trades.\r\n Iuri Rodolfo Bethancourt, who lives in Panama and received more than $20 million in fraudulent proceeds from DAP via his Panamanian shell company, which then paid Gonzalez a portion of this amount.\r\n Jose Alejandro Hurtado, who lives in Miami and served as the intermediary between DAP and Gonzalez. Hurtado was paid more than $6 million in kickbacks disguised as salary payments from DAP, and he remitted some of that money to Gonzalez.\r\n Haydee Leticia Pabon, who is Hurtado\u0027s wife and received approximately $8 million in markups or markdowns on BANDES trades that were funneled to her from DAP in the form of sham finders\u0027 fees. [ ]\r\n \r\n According to the SEC\u0027s complaint, the scheme began in October 2008 and continued until at least June 2010. BANDES was a new customer to DAP brought in by DAP Global executives through their connections to Hurtado. As a result of the kickbacks to Gonzalez, DAP obtained BANDES\u0027 lucrative trading business and provided Gonzalez with the incentive to enter into trades with DAP at considerable markups or markdowns without regard to the prices paid by BANDES. Gonzalez used her senior role at the Caracas-based bank to ensure that its bond trades would continue to be steered to DAP. As the scheme evolved over time, the traders deceived DAP\u0027s clearing brokers, executed internal wash trades, inter-positioned another broker-dealer in the trades to conceal their role in the transactions, and engaged in massive roundtrip trades to pad their revenue.\r\n \r\n For example, the SEC alleges that in January 2010, the traders and Gonzalez arranged for two fraudulent roundtrip trades with BANDES as both buyer and seller. These trades - which lacked any legitimate business purpose - caused BANDES to pay DAP more than $10 million in fees, a portion of which was diverted to Gonzalez for authorizing the blatantly fraudulent trades.\r\n \r\n The SEC further alleges that, giving rise to the adage of no honor among thieves, Clarke and Hurtado frequently falsified the size of DAP\u0027s fees in their reports to Gonzalez, which enabled the traders to retain a greater share of the fraudulent profits.\u0022 (Source: US SEC Press Release,\u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013.) \r\n \r\n In April 2014, Benito Chinea and Joseph DeMeneses were added to the SEC\u0027s complaint. In 2016, seven defendants in the case were ordered to forfeit $42,506,171, which was deemed satisfied by the criminal judgments imposed against them. (Source: US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank.\u0022)","Sources ":"US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank,\u0022 at https:\/\/www.sec.gov\/litigation\/litreleases\/2016\/lr23513.htm; \r\n \r\n US Securities and Exchange Commission v. Clarke Bethancourt, Bethancourt, Hurtado and Pabon, Case No. 13-cv-3074 (SDNY), Complaint filed May 7, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-84.pdf; SEC Press Release, \u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171514248","Documents":""},{"Case ID":"ST-440","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"11\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$8,347,849.00 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$8,347,849 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Violation of Travel Act; Money Laundering; Conspiring to violate the Travel Act and to commit money laundering","Offenses - Settled":"Violation of Travel Act; Money Laundering; Conspiring to violate the Travel Act and to commit money laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice press release of November 18, 2013, \u0022Maria De Los Angeles Gonzalez De Hernandez [ ] pleaded guilty [ ] to conspiring to violate the Travel Act and to commit money laundering, as well as substantive counts of these offenses. [ ] At all times relevant to the charges, Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES) was a state-run economic development bank in Venezuela. The Venezuelan government had a majority ownership interest in BANDES and provided it with substantial funding. \r\n  \r\n According to court records, Gonzalez was an official at BANDES and oversaw the development bank\u2019s overseas trading activity. At her direction, BANDES conducted substantial trading through the Broker-Dealer. Most of the trades executed by the Broker-Dealer on behalf of BANDES involved fixed income investments for which the Broker-Dealer charged the bank a mark-up on purchases and a mark-down on sales.\r\n \r\n  From early 2009 through 2012, Gonzalez participated in a bribery scheme in which she directed trading business she controlled at BANDES to the Broker-Dealer and, in return, agents and employees of the Broker-Dealer shared the revenue the Broker-Dealer generated from this trading business with Gonzalez. During this time period, the Broker-Dealer generated over $60 million in mark-ups and mark-downs from trades with BANDES. Agents and employees of the Broker-Dealer devised a split with Gonzalez of the commissions paid by BANDES to the Broker-Dealer. Emails, account records, and other documents collected from the Broker-Dealer and other sources reveal that Gonzalez received a substantial share of the revenue generated by the Broker-Dealer for BANDES-related trades. Specifically, Gonzalez received millions in bribe payments from Broker-Dealer agents and employees.\r\n \r\n  Additionally, Gonzalez paid a portion of the bribe payments she received to another BANDES employee who was also involved in the scheme. \r\n \r\n To further conceal the scheme, the kickbacks to Gonzalez were often paid using intermediary corporations and offshore accounts that Gonzalez and others held in Switzerland, among other places.\u0022 (Source: US Department of Justice Press Release, \u0022High-Ranking Bank Official at Venezuelan State Development Bank Pleads Guilty to Participating in Bribery Scheme,\u0022 November 18, 2013.)\r\n \r\n According to the Final Order of Forfeiture, Ms. De los Angeles Gonzalez de Hernandez was ordered to forfeit $8,347,849, in assetsheld held at Bank Hapoalim in the name of Maria de los Angeles Gonzalez and Jorge Hernandez and accounts held at Rahn \u0026 Bobmer and Banque Prevee BCP in the name of Wersen Group Ltd. (Source: US v. De los Angeles Gonzalez de Hernandez, Case No. 13-cr-901 (SDNY), FInal Order of Forfeiture filed April 1, 2016.)","Sources ":"US v. De Los Angeles Gonzalez de Hernandez, Case No. 13-cr-901 (SDNY), Final Order of Forfeiture filed April 1, 2016, accessed at Pacer; other court documents and Department of Justice Press Release, \u0022High-Ranking Bank Official at Venezuelan State Development Bank Pleads Guilty to Participating in Bribery Scheme,\u0022 November 18, 2013, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-maria-de-los-angeles-gonzalez-de-hernandez-court-docket-number","Documents":""},{"Case ID":"ST-441","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"8\/30","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$18,514,560 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$18,514,560 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials; Conspiracy to Bribe Foreign Officials, Violate Travel Act, Commit Money Laundering","Offenses - Settled":"Bribery of Foreign Officials; Conspiracy to Bribe Foreign Officials, Violate Travel Act, Commit Money Laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Ernesto Lujan, Jose Alejandro Hurtado and Tomas Alberto Clarke Bethancourt pleaded guilty in New York federal court to conspiring to violate the Foreign Corrupt Practices Act (FCPA), to violate the Travel Act and to commit money laundering, as well as substantive counts of these offenses. These charges relate to a scheme to bribe a foreign official named Maria de los Angeles Gonzalez de Hernandez at Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES), a state economic development bank in Venezuela, in exchange for receiving trading business from BANDES. Lujan, Hurtado and Clarke each also pleaded guilty to an additional charge of conspiring to violate the FCPA in connection with a similar scheme to bribe a foreign official employed by Banfoandes (the \u201cBanfoandes Foreign Official\u201d), another state economic development bank in Venezuela, and to conspiring to obstruct an examination by the U.S. Securities and Exchange Commission (SEC) of the New York-based broker-dealer (the \u201cBroker-Dealer\u201d) where all three defendants had worked, to conceal the true facts of the Broker-Dealer\u2019s relationship with BANDES. [ ] \r\n \r\n Lujan, Clarke and Hurtado worked or were associated with the Broker-Dealer, principally through its Miami offices. In 2008, the Broker-Dealer established a group called the Global Markets Group, which included Lujan, Clarke and Hurtado, and which offered fixed income trading services to institutional clients. \r\n \r\n One of the Broker-Dealer\u2019s clients was BANDES, which operated under the direction of the Venezuelan Ministry of Finance. The Venezuelan government had a majority ownership interest in BANDES and provided it with substantial funding. Gonzalez was an official at BANDES and oversaw the development bank\u2019s overseas trading activity. At her direction, BANDES conducted substantial trading through the Broker-Dealer. Most of the trades executed by the Broker-Dealer on behalf of BANDES involved fixed-income investments for which the Broker-Dealer charged the bank a mark-up on purchases and a mark-down on sales. \r\n \r\n The Broker-Dealer also conducted business with Banfoandes, another state development bank in Venezuela that, along with its 2009 successor Banco Bicentenario, operated under the direction of the Venezuelan Ministry of Finance. Banfoandes acted as a financial agent of the Venezuelan government in order to promote economic and social development by, among other things, offering credit to low-income Venezuelans. The Banfoandes Foreign Official was responsible for some of Banfoandes\u2019s foreign investments.\r\n \r\n Court records state that from early 2009 through 2012, Lujan, Clarke and Hurtado participated in a bribery scheme in which Gonzalez allegedly directed trading business she controlled at BANDES to the Broker-Dealer, and in return, agents and employees of the Broker-Dealer split the revenue the Broker-Dealer generated from this trading business with Gonzalez. During this time period, the Broker-Dealer generated over $60 million in mark-ups and mark-downs from trades with BANDES. Agents and employees of the Broker-Dealer, including Lujan, Clarke and Hurtado, devised a split with Gonzalez of the commissions paid by BANDES to the Broker-Dealer. Emails, account records and other documents collected from the Broker-Dealer and other sources reveal that Gonzalez allegedly received a substantial share of the revenue generated by the Broker-Dealer for BANDES-related trades. Specifically, Gonzalez allegedly received kickbacks and payments from Broker-Dealer agents and employees that were frequently in six-figure amounts.\r\n \r\n To further conceal the scheme, the kickbacks to Gonzalez were often paid using intermediary corporations and offshore accounts that she held in Switzerland, among other places. For instance, Lujan, Clarke and Hurtado used accounts they controlled in Switzerland to transfer funds to an account Gonzalez allegedly controlled in Switzerland. Additionally, Hurtado and his spouse received substantial compensation from the Broker-Dealer, portions of which Hurtado transferred to an account allegedly held by Gonzalez in Miami and to an account held by an associate of Gonzalez in Switzerland. Hurtado also sought and allegedly received reimbursement from Gonzalez for the U.S. income taxes he had paid on money that he used to make kickback payments to Gonzalez. Lujan and Clarke also derived substantial profit from their roles in the bribery scheme.\r\n  \r\n According to court records, beginning in or about November 2010, the SEC commenced a periodic examination of the Broker-Dealer, and from November 2010 through March 2011 the SEC\u2019s examination staff made several visits to the Broker-Dealer\u2019s offices in Manhattan. In early 2011, Lujan, Clarke and Hurtado discussed their concern that the SEC was examining the Broker-Dealer\u2019s relationship with BANDES and asking questions regarding certain emails and other information that the SEC examination staff had discovered. Lujan, Clarke and Hurtado agreed that they would take steps to conceal the true facts of the Broker-Dealer\u2019s relationship with BANDES, including deleting emails. Lujan, Clarke and Hurtado then, in fact, deleted emails. Additionally as part of this effort to obstruct the SEC examination, Clarke lied to SEC examination staff in response to an interview question about his relationship to an individual who had received purported foreign associate payments relating to BANDES. \r\n \r\n In a related scheme, from 2008 through mid-2009, Lujan, Clarke and Hurtado paid bribes to the Banfoandes Foreign Official, who, in exchange, directed Banfoandes trading business to the Broker-Dealer.\u0022 (Source: DOJ Press Release, \u0022Three Former Broker-dealer Employees Plead Guilty in Manhattan Federal Court to Bribery of Foreign Officials, Money Laundering and Conspiracy to Obstruct Justice, August 30, 2013.)","Sources ":"US v. Lujan, Case No. 13-cr-671 (SDNY), Final Order of Forfeiture (February 10, 2016) and Judgment (December 7, 2015), Court Docket Report as of April 19, 2016, accessed at PACER; DOJ Press Release, \u0022Three Former Broker-dealer Employees Plead Guilty in Manhattan Federal Court to Bribery of Foreign Officials, Money Laundering and Conspiracy to Obstruct Justice, August 30, 2013 and other related court documents at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-jose-alejandro-hurtado-court-docket-number-13-crim-673.","Documents":""},{"Case ID":"ST-442","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"8\/30","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$11,896,743 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$11,896,743 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials, Conspiracy to Commit Money Laundering, Money Laundering, Conspiracy to Obstruct Justice, Violation of Travel Act","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials, Conspiracy to Commit Money Laundering, Money Laundering, Conspiracy to Obstruct Justice, Violation of Travel Act","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Ernesto Lujan, Jose Alejandro Hurtado and Tomas Alberto Clarke Bethancourt pleaded guilty in New York federal court to conspiring to violate the Foreign Corrupt Practices Act (FCPA), to violate the Travel Act and to commit money laundering, as well as substantive counts of these offenses. These charges relate to a scheme to bribe a foreign official named Maria de los Angeles Gonzalez de Hernandez at Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES), a state economic development bank in Venezuela, in exchange for receiving trading business from BANDES. Lujan, Hurtado and Clarke each also pleaded guilty to an additional charge of conspiring to violate the FCPA in connection with a similar scheme to bribe a foreign official employed by Banfoandes (the \u201cBanfoandes Foreign Official\u201d), another state economic development bank in Venezuela, and to conspiring to obstruct an examination by the U.S. Securities and Exchange Commission (SEC) of the New York-based broker-dealer (the \u201cBroker-Dealer\u201d) where all three defendants had worked, to conceal the true facts of the Broker-Dealer\u2019s relationship with BANDES. [ ] \r\n \r\n Lujan, Clarke and Hurtado worked or were associated with the Broker-Dealer, principally through its Miami offices. In 2008, the Broker-Dealer established a group called the Global Markets Group, which included Lujan, Clarke and Hurtado, and which offered fixed income trading services to institutional clients. \r\n \r\n One of the Broker-Dealer\u2019s clients was BANDES, which operated under the direction of the Venezuelan Ministry of Finance. The Venezuelan government had a majority ownership interest in BANDES and provided it with substantial funding. Gonzalez was an official at BANDES and oversaw the development bank\u2019s overseas trading activity. At her direction, BANDES conducted substantial trading through the Broker-Dealer. Most of the trades executed by the Broker-Dealer on behalf of BANDES involved fixed-income investments for which the Broker-Dealer charged the bank a mark-up on purchases and a mark-down on sales. \r\n \r\n The Broker-Dealer also conducted business with Banfoandes, another state development bank in Venezuela that, along with its 2009 successor Banco Bicentenario, operated under the direction of the Venezuelan Ministry of Finance. Banfoandes acted as a financial agent of the Venezuelan government in order to promote economic and social development by, among other things, offering credit to low-income Venezuelans. The Banfoandes Foreign Official was responsible for some of Banfoandes\u2019s foreign investments.\r\n \r\n Court records state that from early 2009 through 2012, Lujan, Clarke and Hurtado participated in a bribery scheme in which Gonzalez allegedly directed trading business she controlled at BANDES to the Broker-Dealer, and in return, agents and employees of the Broker-Dealer split the revenue the Broker-Dealer generated from this trading business with Gonzalez. During this time period, the Broker-Dealer generated over $60 million in mark-ups and mark-downs from trades with BANDES. Agents and employees of the Broker-Dealer, including Lujan, Clarke and Hurtado, devised a split with Gonzalez of the commissions paid by BANDES to the Broker-Dealer. Emails, account records and other documents collected from the Broker-Dealer and other sources reveal that Gonzalez allegedly received a substantial share of the revenue generated by the Broker-Dealer for BANDES-related trades. Specifically, Gonzalez allegedly received kickbacks and payments from Broker-Dealer agents and employees that were frequently in six-figure amounts.\r\n \r\n To further conceal the scheme, the kickbacks to Gonzalez were often paid using intermediary corporations and offshore accounts that she held in Switzerland, among other places. For instance, Lujan, Clarke and Hurtado used accounts they controlled in Switzerland to transfer funds to an account Gonzalez allegedly controlled in Switzerland. Additionally, Hurtado and his spouse received substantial compensation from the Broker-Dealer, portions of which Hurtado transferred to an account allegedly held by Gonzalez in Miami and to an account held by an associate of Gonzalez in Switzerland. Hurtado also sought and allegedly received reimbursement from Gonzalez for the U.S. income taxes he had paid on money that he used to make kickback payments to Gonzalez. Lujan and Clarke also derived substantial profit from their roles in the bribery scheme.\r\n  \r\n According to court records, beginning in or about November 2010, the SEC commenced a periodic examination of the Broker-Dealer, and from November 2010 through March 2011 the SEC\u2019s examination staff made several visits to the Broker-Dealer\u2019s offices in Manhattan. In early 2011, Lujan, Clarke and Hurtado discussed their concern that the SEC was examining the Broker-Dealer\u2019s relationship with BANDES and asking questions regarding certain emails and other information that the SEC examination staff had discovered. Lujan, Clarke and Hurtado agreed that they would take steps to conceal the true facts of the Broker-Dealer\u2019s relationship with BANDES, including deleting emails. Lujan, Clarke and Hurtado then, in fact, deleted emails. Additionally as part of this effort to obstruct the SEC examination, Clarke lied to SEC examination staff in response to an interview question about his relationship to an individual who had received purported foreign associate payments relating to BANDES. \r\n \r\n In a related scheme, from 2008 through mid-2009, Lujan, Clarke and Hurtado paid bribes to the Banfoandes Foreign Official, who, in exchange, directed Banfoandes trading business to the Broker-Dealer.\u0022 (Source: DOJ Press Release, \u0022Three Former Broker-dealer Employees Plead Guilty in Manhattan Federal Court to Bribery of Foreign Officials, Money Laundering and Conspiracy to Obstruct Justice, August 30, 2013.)","Sources ":"US v. Hurtado, Case No. 13-cr-673 (SDNY), Amended Judgment filed January 22, 2016 and Preliminary Consent Order of Forfeiture filed December 15, 2015 and Orer of Forfeiture, filed March 21, 2016, accessed at PACER; DOJ Press Release, \u0022Three Former Broker-dealer Employees Plead Guilty in Manhattan Federal Court to Bribery of Foreign Officials, Money Laundering and Conspiracy to Obstruct Justice, August 30, 2013 and other related court documents at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-jose-alejandro-hurtado-court-docket-number-13-crim-673.","Documents":""},{"Case ID":"ST-443","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2015","Month\/Day of Settlement (or Notes)":"3\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$2,670,612 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$2,670,612 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Travel Act","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Travel Act","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Benito Chinea, former chief executive officer and joseph DeMeneses, former managing director of a U.S. broker dealer Direct Access Partners Global [\u0022Broker Dealer\u0022]were sentenced in 2015 \u0022for their roles in a scheme to pay bribes to a senior official in Venezuela\u2019s state economic development bank, Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (Bandes), in return for trading business that generated more than $60 million in commissions. [ ] [Chinea and DeMeneses] were each sentenced to four years in prison. They were also ordered to pay $3,636,432 and $2,670,612 in forfeiture, respectively, which amounts represent their earnings from the bribery scheme. On Dec. 17, 2014, both defendants pleaded guilty to one count of conspiracy to violate the Foreign Corrupt Practices Act and the Travel Act.\u0022 According to the press release, it was alleged in the court documents that Chinea and DeMeneses, together with three Miami based employees participated in a bribery scheme that ran from late 2008 through 2012, in which Maria de los Angeles Gonzalez, a BANDES Vice President of Finance directed trading business to Direct Access Partners, and in return, agents and employees of DAP split the revenue that DAP generated from this trading business with Gonzalez. During this time period, DAP generated over $60 million in commissions from trades with BANDES. As further alleged in court documents, in order to conceal the scheme, payments to Gonzalez, frequently in six figure amounts, were routed through third parties posing as \u201cforeign finders\u201d and into offshore bank accounts. In several instances, Chinea personally signed checks worth millions of dollars that were made payable to one of these purported \u201cforeign finders\u201d and later deposited in a Swiss bank account. Chinea and DeMeneses admitted that they agreed to use DAP funds to reimburse DeMeneses and Clarke for the approximately $1.5 million from their personal funds they used to bribe Gonzalez. To conceal their true nature, Chinea and DeMeneses agreed to hide these reimbursements in DAP\u2019s books as sham loans from DAP to DeMeneses and Clarke. (Source: US DOJ Press Release, \u0022CEO and Managing Director Of US BrokerDealer Sentenced for\r\n International Bribery Scheme,\u0022 March 27, 2015.) Please note that the date of Mr. Chinea and Mr. DeMeneses\u0027 sentencing is used as the settlement date in this entry.","Sources ":"US v. Benito Chinea and Joseph DeMeneses, Case No. 14-cr-240, Indictment filed April 10, 2014 and DOJ Press Release, \u0022CEO and Managing Director Of US BrokerDealer Sentenced for International Bribery Scheme,\u0022 March 27, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-joseph-demeneses-court-docket-number-14-cr-240-dlc.","Documents":""},{"Case ID":"ST-444","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"8\/30","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$5,787,824 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$5,787,824 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Violate Travel Act, Commit Money Laundering; Bribery of Foreign Officials; Violation of Travel Act, Money Laundering, Conspiracy to Obstruct Justice","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Violate Travel Act, Commit Money Laundering; Bribery of Foreign Officials; Violation of Travel Act, Money Laundering, Conspiracy to Obstruct Justice","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, \u0022Ernesto Lujan, Jose Alejandro Hurtado and Tomas Alberto Clarke Bethancourt pleaded guilty in New York federal court to conspiring to violate the Foreign Corrupt Practices Act (FCPA), to violate the Travel Act and to commit money laundering, as well as substantive counts of these offenses. These charges relate to a scheme to bribe a foreign official named Maria de los Angeles Gonzalez de Hernandez at Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES), a state economic development bank in Venezuela, in exchange for receiving trading business from BANDES. Lujan, Hurtado and Clarke each also pleaded guilty to an additional charge of conspiring to violate the FCPA in connection with a similar scheme to bribe a foreign official employed by Banfoandes (the \u201cBanfoandes Foreign Official\u201d), another state economic development bank in Venezuela, and to conspiring to obstruct an examination by the U.S. Securities and Exchange Commission (SEC) of the New York-based broker-dealer (the \u201cBroker-Dealer\u201d) where all three defendants had worked, to conceal the true facts of the Broker-Dealer\u2019s relationship with BANDES. [ ] In a related scheme, from 2008 through mid-2009, Lujan, Clarke and Hurtado paid bribes to the Banfoandes Foreign Official, who, in exchange, directed Banfoandes trading business to the Broker-Dealer.\u0022 (Source: US Department of Justice Press Release, \u0022Three Former Broker-dealer Employees Plead Guilty in Manhattan Federal Court to Bribery of Foreign Officials, Money Laundering and Conspiracy to Obstruct Justice,\u0022 August 30, 2013, at https:\/\/www.justice.gov\/opa\/pr\/three-former-broker-dealer-employees-plead-guilty-manhattan-federal-court-bribery-foreign.)\r\n \r\n As part of his plea agreement, Mr. Clarke Bethancourt agreed and was ordered to forfeit: 1) real property at 485 Brickell Avenue, 2) $48,334.34 and $264,000 in cash, 3) all assets held by ETC Investments at accounts in Mirabaud \u0026 Cie in Switzerland, 4) any and all assets on deposit at Banco General SA in Panama, 5) any and all assets held at CBH Compagnie Bancaire Helvetique SA in Switzerland, and 5) all assets up to $1,247,057.50. (Source: US v. Clarke Bethancourt, Case No. 13-cr-670 (SDNY), Consent Preliminary Order of Forfeiture filed December 8, 2015.)","Sources ":"US v. Clarke Bethancourt, Case No. 13-cr-670 (SDNY), Consent Preliminary Order of Forfeiture filed December 8, 2015, accessed at Pacer; otehr related court documents at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-tomas-alberto-clarke-bethancourt-court-docket-number-13-crim-670","Documents":""},{"Case ID":"ST-445","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"https:\/\/www.sec.gov\/litigation\/litreleases\/2016\/lr23513.htm","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$3,636,432 ","Criminal Fine\/Penalty (US$) ":"$0 ","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"$3,636,432 ","Criminal Restitution \/ Reparation (US$)":"$0 ","Criminal Legal \/ Procedural Costs (US$)":"$0 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Travel Act","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Travel Act","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice, Benito Chinea, former chief executive officer and joseph DeMeneses, former managing director of a U.S. broker dealer Direct Access Partners Global [\u0022Broker Dealer\u0022]were sentenced in 2015 \u0022for their roles in a scheme to pay bribes to a senior official in Venezuela\u2019s state economic development bank, Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (Bandes), in return for trading business that generated more than $60 million in commissions. [ ] [Chinea and DeMeneses] were each sentenced to four years in prison. They were also ordered to pay $3,636,432 and $2,670,612 in forfeiture, respectively, which amounts represent their earnings from the bribery scheme. On Dec. 17, 2014, both defendants pleaded guilty to one count of conspiracy to violate the Foreign Corrupt Practices Act and the Travel Act.\u0022 According to the press release, it was alleged in the court documents that Chinea and DeMeneses, together with three Miami based employees participated in a bribery scheme that ran from late 2008 through 2012, in which Maria de los Angeles Gonzalez, a BANDES Vice President of Finance directed trading business to Direct Access Partners, and in return, agents and employees of DAP split the revenue that DAP generated from this trading business with Gonzalez. During this time period, DAP generated over $60 million in commissions from trades with BANDES. As further alleged in court documents, in order to conceal the scheme, payments to Gonzalez, frequently in six figure amounts, were routed through third parties posing as \u201cforeign finders\u201d and into offshore bank accounts. In several instances, Chinea personally signed checks worth millions of dollars that were made payable to one of these purported \u201cforeign finders\u201d and later deposited in a Swiss bank account. Chinea and DeMeneses admitted that they agreed to use DAP funds to reimburse DeMeneses and Clarke for the approximately $1.5 million from their personal funds they used to bribe Gonzalez. To conceal their true nature, Chinea and DeMeneses agreed to hide these reimbursements in DAP\u2019s books as sham loans from DAP to DeMeneses and Clarke. (Source: US DOJ Press Release, \u0022CEO and Managing Director Of US BrokerDealer Sentenced for\r\n International Bribery Scheme,\u0022 March 27, 2015.) Please note that the date of Mr. Chinea and Mr. DeMeneses\u0027 sentencing is used as the settlement date in this entry.","Sources ":"US v. Benito Chinea and Joseph DeMeneses, Case No. 14-cr-240, Indictment filed April 10, 2014 and DOJ Press Release, \u0022CEO and Managing Director Of US BrokerDealer Sentenced for International Bribery Scheme,\u0022 March 27, 2015, at https:\/\/www.justice.gov\/criminal-fraud\/case\/united-states-v-benito-chinea-court-docket-number-14-cr-240-dlc","Documents":""},{"Case ID":"ST-446","Case Cluster ":"Direct Access Partners  (DAP) Global","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2016","Month\/Day of Settlement (or Notes)":"","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$0 ","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"$0","Other Civil Monetary Sanctions (Explanation)":"$0 ","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"NA","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of Foreign Officials; Securities Fraud","Offenses - Settled":"Bribery of Foreign Officials; Securities Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, \u0022the global markets group at broker-dealer Direct Access Partners (DAP) executed fixed income trades for customers in foreign sovereign debt. DAP Global generated more than $66 million in revenue for DAP from transaction fees - in the form of markups and markdowns - on riskless principal trade executions in Venezuelan sovereign or state-sponsored bonds for Banco de Desarrollo Econ\u00f3mico y Social de Venezuela (BANDES). A portion of this revenue was illicitly paid to BANDES Vice President of Finance, Mar\u00eda de los \u00c1ngeles Gonz\u00e1lez de Hernandez, who authorized the fraudulent trades. [ ] \r\n \r\n The SEC\u0027s complaint charges the following individuals for the roles in the kickback scheme:\r\n \r\n Tomas Alberto Clarke Bethancourt, who lives in Miami and is an executive vice president at DAP. Known as \u0022Tomas Clarke,\u0022 he was responsible for executing the fraudulent trades and maintaining spreadsheets tracking the illicit markups and markdowns on those trades.\r\n Iuri Rodolfo Bethancourt, who lives in Panama and received more than $20 million in fraudulent proceeds from DAP via his Panamanian shell company, which then paid Gonzalez a portion of this amount.\r\n Jose Alejandro Hurtado, who lives in Miami and served as the intermediary between DAP and Gonzalez. Hurtado was paid more than $6 million in kickbacks disguised as salary payments from DAP, and he remitted some of that money to Gonzalez.\r\n Haydee Leticia Pabon, who is Hurtado\u0027s wife and received approximately $8 million in markups or markdowns on BANDES trades that were funneled to her from DAP in the form of sham finders\u0027 fees. [ ]\r\n \r\n According to the SEC\u0027s complaint, the scheme began in October 2008 and continued until at least June 2010. BANDES was a new customer to DAP brought in by DAP Global executives through their connections to Hurtado. As a result of the kickbacks to Gonzalez, DAP obtained BANDES\u0027 lucrative trading business and provided Gonzalez with the incentive to enter into trades with DAP at considerable markups or markdowns without regard to the prices paid by BANDES. Gonzalez used her senior role at the Caracas-based bank to ensure that its bond trades would continue to be steered to DAP. As the scheme evolved over time, the traders deceived DAP\u0027s clearing brokers, executed internal wash trades, inter-positioned another broker-dealer in the trades to conceal their role in the transactions, and engaged in massive roundtrip trades to pad their revenue.\r\n \r\n For example, the SEC alleges that in January 2010, the traders and Gonzalez arranged for two fraudulent roundtrip trades with BANDES as both buyer and seller. These trades - which lacked any legitimate business purpose - caused BANDES to pay DAP more than $10 million in fees, a portion of which was diverted to Gonzalez for authorizing the blatantly fraudulent trades.\r\n \r\n The SEC further alleges that, giving rise to the adage of no honor among thieves, Clarke and Hurtado frequently falsified the size of DAP\u0027s fees in their reports to Gonzalez, which enabled the traders to retain a greater share of the fraudulent profits.\u0022 (Source: US SEC Press Release,\u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013.) \r\n \r\n In April 2014, Benito Chinea and Joseph DeMeneses were added to the SEC\u0027s complaint. In 2016, seven defendants in the case were ordered to forfeit $42,506,171, which was deemed satisfied by the criminal judgments imposed against them. (Source: US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank.\u0022)","Sources ":"US Securities and Exchange Commission, Litigation Release No. 23513 \/ April 8, 2016, \u0022SEC Obtains Settlement in Kickback Scheme to Secure Business of Venezuelan Bank,\u0022 at https:\/\/www.sec.gov\/litigation\/litreleases\/2016\/lr23513.htm; US Securities and Exchange Commission v. Clarke Bethancourt, Bethancourt, Hurtado and Pabon, Case No. 13-cv-3074 (SDNY), Complaint filed May 7, 2013, at https:\/\/www.sec.gov\/litigation\/complaints\/2013\/comp-pr2013-84.pdf; SEC Press Release, \u0022SEC Charges Traders in Massive Kickback Scheme Involving Venezuelan Official,\u0022 May 7, 2013, at https:\/\/www.sec.gov\/News\/PressRelease\/Detail\/PressRelease\/1365171514248","Documents":""},{"Case ID":"ST-260","Case Cluster ":"Lucent Technologies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"12\/21","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$1,500,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$1,500,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Lucent Technologies, Inc. at 68-69, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf:  DOJ - $1 million fine; SEC - $1.5 million civil penalties; Misconduct in China, 2000-2003, company spent over $1.3 million in travel and other things of value for senior level government officials, including heads of state-owned telecommunications companies in Beijing and leaders of provincial telecommunications subsidiaries.  Resulting Criminal Enforcement Action: In Re Lucent Technologies inc. (December 21, 2007); Civil action: SEC v. Lucent Technologies Inc. (D.D.C., December 21, 2007). According to the Statement of Facts attached to the non-prosecution agreement by the US Department of Justice and Lucent, from at least 2000 to 2003, Lucent provided approximately 315 trips for Chinese government officials which were primarily for sightseeing, entertainment, and leisure in Boston, Las Vegas, the Grand Canyon and Hawaii; an April 2001 personal visit to San Francisco by a director of a regional, state-owned broadband provider and her guest; a January 2003 travel to Hong Kong and Thailand for a seven-day vacation by the deputy manager of a subsidiary of a large state-owned telecommunications service provider in China, his wife and daughter and other pre- and post-sales trips and paying for educational (MBA) costs, paid internship for a daughter of a Chinese government official working at the Chinese embassy in the U.S. (Source: Non-Prosecution Agreement, Appendix A: Statement of Facts, In Re Lucent Technologies, Inc. dated November 14, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/lucent-tech\/11-14-07lucent-agree.pdf.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Lucent Technologies, Inc. at 68-69, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-apppx-c.pdf; US Department of Justice Press Release, \u0022Lucent Technologies Inc. Agrees to Pay $1 Million Fine to Resolve FCPA Allegations,\u0022 December 21, 2007, accessed at http:\/\/www.justice.gov\/opa\/pr\/2007\/December\/07_crm_1028.html (accessed September 15, 2011); In Re Lucent Technologies, Inc., Department of Justice Non-Prosecution Agreement and Appendix A: Statement of Facts (dated November 14, 2007), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/lucent-tech\/11-14-07lucent-agree.pdf; SEC v. Lucent Technologies, Case No. 1:07-cv-02301-RBW (D.D.C.), Complaint filed December 21, 2007, accessed at http:\/\/fcpa.shearman.com\/files\/2df\/2df2c9377360116808a51bd869d91227.pdf?i=d127b5a5143e9fa5206999c01419e264; Securities and Exchange Commission Litigation Release No. 20414 \/ December 21, 2007, accessed at http:\/\/fcpa.shearman.com\/files\/22b\/22bad0eccb9eefdb54f168bafc03db0d.pdf?i=359c3469ccf281e16e805da3d9dce8f6.","Documents":""},{"Case ID":"ST-259","Case Cluster ":"Lucent Technologies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"12\/21","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,000,000.00","Criminal Fine\/Penalty (US$) ":"$1,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Lucent Technologies, Inc. at 68-69, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf:  DOJ - $1 million fine; SEC - $1.5 million civil penalties; Misconduct in China, 2000-2003, company spent over $1.3 million in travel and other things of value for senior level government officials, including heads of state-owned telecommunications companies in Beijing and leaders of provincial telecommunications subsidiaries.  Resulting Criminal Enforcement Action: In Re Lucent Technologies inc. (December 21, 2007); Civil action: SEC v. Lucent Technologies Inc. (D.D.C., December 21, 2007). According to the Statement of Facts attached to the non-prosecution agreement by the US Department of Justice and Lucent, from at least 2000 to 2003, Lucent provided approximately 315 trips for Chinese government officials which were primarily for sightseeing, entertainment, and leisure in Boston, Las Vegas, the Grand Canyon and Hawaii; an April 2001 personal visit to San Francisco by a director of a regional, state-owned broadband provider and her guest; a January 2003 travel to Hong Kong and Thailand for a seven-day vacation by the deputy manager of a subsidiary of a large state-owned telecommunications service provider in China, his wife and daughter and other pre- and post-sales trips and paying for educational (MBA) costs, paid internship for a daughter of a Chinese government official working at the Chinese embassy in the U.S. (Source: Non-Prosecution Agreement, Appendix A: Statement of Facts, In Re Lucent Technologies, Inc. dated November 14, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/lucent-tech\/11-14-07lucent-agree.pdf.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Lucent Technologies, Inc. at 68-69, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-apppx-c.pdf; US Department of Justice Press Release, \u0022Lucent Technologies Inc. Agrees to Pay $1 Million Fine to Resolve FCPA Allegations,\u0022 December 21, 2007, accessed at http:\/\/www.justice.gov\/opa\/pr\/2007\/December\/07_crm_1028.html (accessed September 15, 2011); In Re Lucent Technologies, Inc., Department of Justice Non-Prosecution Agreement and Appendix A: Statement of Facts (dated November 14, 2007), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/lucent-tech\/11-14-07lucent-agree.pdf; SEC v. Lucent Technologies, Case No. 1:07-cv-02301-RBW (D.D.C.), Complaint filed December 21, 2007, accessed at http:\/\/fcpa.shearman.com\/files\/2df\/2df2c9377360116808a51bd869d91227.pdf?i=d127b5a5143e9fa5206999c01419e264; Securities and Exchange Commission Litigation Release No. 20414 \/ December 21, 2007, in same case, accessed at http:\/\/fcpa.shearman.com\/files\/22b\/22bad0eccb9eefdb54f168bafc03db0d.pdf?i=359c3469ccf281e16e805da3d9dce8f6.","Documents":""},{"Case ID":"ST-299","Case Cluster ":"Pacific Consolidated Industries LP","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"United Kingdom","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"09\/03","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$7,500.00","Criminal Fine\/Penalty (US$) ":"$7,500","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering, Bribery of Foreign Officials, International Money Laundering, False Statement in a Tax Return","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering, Bribery of Foreign Officials, International Money Laundering, False Statement in a Tax Return","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Pacific Consolidated Industries LP, at 63-64, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: Time period of misconduct in United Kingdom, 1993-2003; Martin Eric Self and Leo Winston Smith, two executives of Pacific Consolidated Industries (which later went defunct) caused PCI to enter into a marketing agreement with  a person they understood to be a relative of the UK-MOD official\/project manager directly involved in the procurement of Air Separation Units (which PCI manufactured) on behalf of the UK-Ministry of Defence.  The ASU and related contracts awarded to PCI were valued at over $11 million. The executives were charged with participating in a scheme to make more than $370,000 in illicit payments, and Smith was also charged with failing to report nearly $500,000 in commissions from PCI on his tax returns.  Self pleaded guilty and was ordered to pay $7,500 criminal fine; Smith also pleaded guilty and was ordered to pay $20,000 in criminal fine. PCI was a private company. The UK-MOD official pleaded guilty in the UK to accepting more than $300,000 in bribes from PCI and was sentenced to two years in prison.  According to the United Kingdom\u0027s \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 Ministry of Defence official, Michael Hale, was convicted in April 2007, on nine counts of accepting bribes totalling \u00a3217,000. (Source:  United Kingdom\u0027s \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 September 2008, accessed at www.dfid.gov.uk\/documents).  The UK\u0027s MailOnline (and other media) reported on April 16, 2007 that Michael Hale, a senior military official, had plead guilty in Southwark Crown Court to charges of receiving bribes from Pacific Consolidated Industries. (Source: MailOnline, \u0022Senior MoD jailed for taking bribes from US arms dealer,\u0022 April 16, 2007, accessed at http:\/\/www.dailymail.co.uk\/news\/article-448968\/Senior-MoD-jailed-taking-bribes-US-arms-dealer.html.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Pacific Consolidated Industries LP, at 63-64, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf:  US Department of Justice Press Release, \u0022Former Pacific Consolidated Industries LP Executive [Martin Eric Self] Pleads Guilty in Connection with Bribes Paid to U.K. Ministry of Defence Official,\u0022 May 8, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/May\/08-crm-394.html; US Department of Justice Press Release, \u0022Former Pacific Consolidated Industries LP Executive [Leo Winston Smith] Pleads Guilty in Connection with Bribes Paid to U.K. Ministry of Defense Official,\u0022 September 3, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/September\/09-crm-928.html;  US v. Leo Winston Smith, Case No. 8:07-cr-00069-AG (C.D.Ca.),  Amended Judgment filed January 11, 2011, accessed at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/smithl\/01-11-11smith-leo-amended.pdf; US v. Martin Eric Self, Case No. 8:08-cr-00110-AG (C.D. Ca.), Judgment filed November 17, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/selfm\/11-17-08self-judgment.pdf; United Kingdom\u0027s \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 September 2008, accessed at www.dfid.gov.uk\/documents; MailOnline, \u0022Senior MoD jailed for taking bribes from US arms dealer,\u0022 April 16, 2007, accessed at http:\/\/www.dailymail.co.uk\/news\/article-448968\/Senior-MoD-jailed-taking-bribes-US-arms-dealer.html.","Documents":""},{"Case ID":"ST-322","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Munich Public Prosecution Office","Jurisdiction of Foreign Public Official(s) ":"Various","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"12\/15","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Art. 30 Administrative Code-OWiG","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$528,585,548.00","Criminal Fine\/Penalty (US$) ":"$334,548","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$528,251,000","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Sections 130 and 30 AdministrativeCode-OWiG (Breach of Directors Duties)","Offenses - Settled":"Sections 130 and 30 Administrative Code-OWiG (Breach of Directors Duties)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the March 2011 Report by the Organisation for Economic Co-Operation and Development (OECD) on Germany\u0027s Enforcement of the Anti-Bribery Convention, Germany prosecuted two Siemens-related cases, and cited as sources: \u0022i) Decision of the Munich I Regional Court of 4 October 2007 pursuant to section 30 OWiG in conjunction with section 334 CC - against the telecommunication unit of Siemens \u2013 fine of EUR 201 million (see also Annual reports 2006-2007 and 2007-2008 Bavaria (i) and Germany\u2019s reply to Phase 3 questionnaires), hereinafter Case \u201cTelecommunications Unit of Siemens\u201d; ii) Decision of the Munich I Public Prosecution office of 15 December 2008 pursuant to sections 130 and 30 OWiG - against Siemens \u2013 Fine of EUR 395 million (see all Annual reports, about a \u00ab Hesse based Company \u00bb and related decision of the Federal Court of Justice of 28 August 2008 - Ref. Supra.), hereinafter Case \u201cSiemens (except Telecommunications Unit)\u201d  (Source: Organisation for Economic Co-operation and Development, \u0022Germany: Phase 3, Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Transactions, approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011.\u0022)","Sources ":"Organisation for Economic Co-operation and Development, \u0022Germany: Phase 3, Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Transactions, approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011,\u0022 accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf. US Department of Justice Press Release, \u0022Siemens AG and Three Subsidiaries Plead Guilty to Foreign Corrupt Practices Act Violations and Agree to Pay $450 million in Combined Criminal Fines,\u0022 December 15, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/December\/08-crm-1105.html; ","Documents":""},{"Case ID":"ST-329","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Munich Public Prosecution Office","Jurisdiction of Foreign Public Official(s) ":"Libya, Nigeria, Russia","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"10\/04","Other Jurisdictions of Settlement":"United States, The World Bank","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Art. 30 Administrative Code-OWiG","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$284,585,850.00","Criminal Fine\/Penalty (US$) ":"$1,415,850","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$283,170,000","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Breach of Trust (section 266(1) Criminal Code)","Offenses - Settled":"Breach of Trust (section 266(1) Criminal Code)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the March 2011 Report by the Organisation for Economic Co-Operation and Development (OECD) on Germany\u0027s Enforcement of the Anti-Bribery Convention, Germany prosecuted two Siemens-related cases, and cited as sources: \u0022i) Decision of the Munich I Regional Court of 4 October 2007 pursuant to section 30 OWiG in conjunction with section 334 CC - against the telecommunication unit of Siemens \u2013 fine of EUR 201 million (see also Annual reports 2006-2007 and 2007-2008 Bavaria (i) and Germany\u2019s reply to Phase 3 questionnaires), hereinafter Case \u201cTelecommunications Unit of Siemens\u201d; ii) Decision of the Munich I Public Prosecution office of 15 December 2008 pursuant to sections 130 and 30 OWiG - against Siemens \u2013 Fine of EUR 395 million (see all Annual reports, about a \u00ab Hesse based Company \u00bb and related decision of the Federal Court of Justice of 28 August 2008 - Ref. Supra.), hereinafter Case \u201cSiemens (except Telecommunications Unit)\u201d  (Source: Organisation for Economic Co-operation and Development, \u0022Germany: Phase 3, Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Transactions, approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011.\u0022)","Sources ":"Organisation for Economic Co-operation and Development, \u0022Germany: Phase 3, Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Transactions, approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011,\u0022 accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf. replace with: http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Germanyphase3reportEN.pdf  US Department of Justice Press Release, \u0022Siemens AG and Three Subsidiaries Plead Guilty to Foreign Corrupt Practices Act Violations and Agree to Pay $450 million in Combined Criminal Fines,\u0022 December 15, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/December\/08-crm-1105.html.","Documents":""},{"Case ID":"ST-242","Case Cluster ":"Johnson \u0026 Johnson","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Greece","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"04\/08","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Civil  Recovery Order (Proceeds of Crime Act)","Monetary Sanctions  (Types)":"Civil  Recovery Order ","Total Monetary Sanctions (US$)":"$7,877,400.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$7,877,400","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Unlawful Conduct - payments made by DePuy International Limited to intermediaries for the purpose of making corrupt payments to Greek medical professionals working in the Greek public health system","Offenses - Settled":"Unlawful Conduct - payments made by DePuy International Limited to intermediaries for the purpose of making corrupt payments to Greek medical professionals working in the Greek public health system","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a UK Serious Fraud Office Press Release, on April 8, 2011, the SFO obtained a Civil Recovery Order for GBP 4.829 million and prosecution costs against DePuy International Limited (a UK subsidiary of the US parent company Johnson \u0026 Johnson), \u0022in recognition of unlawful conduct relating to the sale of orthopaedic products in Greece between 1998 and 2006.\u0022  The SFO launched its investigation following a referral from the US Department of Justice in October 2007 and worked closely with the US DOJ and the Securities and Exchange Commission.  \u0022The unlawful conduct consisted of payments made by DePuy International Limited to intermediaries for the purpose of making corrupt payments to Greek medical professionals working in the Greek public health system. Payments to the intermediaries amounted to twenty percent of the price, at which the orthopaedic product was ultimately sold. These payments covered the commission for the intermediary and were available to be used to pay inducements or rewards for the use of orthopaedic products sold by DePuy International Limited. [  ] The corporate benefit sought by DePuy International Limited, as a result of the payments to intermediaries, was retention and enhancement of market position. The Greek government paid DePuy International Limited\u0027s intermediaries approximately \u00a333.5 million for orthopaedic products between 1998 and 2007.  [  ] On the facts of this case, criminal sanction of the Greek conduct has been achieved by the conclusion of a Deferred Prosecution Agreement with DePuy International Limited\u0027s parent company and the DOJ.  The Director of the Serious Fraud Office has concluded that a prosecution was therefore prevented in this jurisdiction by the principles of double jeopardy. The underlying purpose of the rule against double jeopardy is to stop a defendant from being prosecuted twice for the same offence in different jurisdictions. The DOJ Deferred Prosecution Agreement has the legal character of a formally concluded prosecution and punishes the same conduct in Greece that had formed the basis of the Serious Fraud Office investigation.  Combined criminal and civil sanctions have therefore been imposed in the United States in respect of Depuy International Limited\u0027s parent and assets have been frozen in the ongoing Greek investigation, all relating to the same conduct in Greece. Consequently the Serious Fraud office is satisfied that the most appropriate sanction is a Civil Recovery Order, under the Proceeds of Crime Act 2002.  As has been described approximately \u00a333.5 million represents the sales, tainted by the unlawful conduct, made to public hospitals by DePuy International Limited\u0027s Greek intermediaries. Approximately \u00a314.8 million of this passed from the Greek intermediary to DePuy International Limited in respect of orthopaedic products for use in the public health care system. Consequently \u00a314.8 million can be said to represent unlawfully obtained property.  In the context of a global resolution, the Serious Fraud Office has taken particular note of the fact of disgorgement and recovery in more than one jurisdiction for the same underlying unlawful conduct. The Serious Fraud Office has also taken into account asset tracing difficulties.\u0022 (Source:  UK Serious Fraud Office Press Release, \u0022DePuy International Limited ordered to pay 4.829 million pounds in Civil Recovery Order,\u0022 April 8, 2011.)","Sources ":"UK Serious Fraud Office Press Release, \u0022DePuy International Limited ordered to pay 4.829 million pounds in Civil Recovery Order,\u0022 April 8, 2011, accessed at: http:\/\/www.sfo.gov.uk\/press-room\/press-release-archive\/press-releases-2011\/depuy-international-limited-ordered-to-pay-4829-million-in-civil-recovery-order.aspx;  See also, UK Serious Fraud Office Press Release, \u0022British executive jailed for part in Greek healthcare corruption,\u0022 April 14, 2010, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2010\/british-executive-jailed-for-part-in-greek-healthcare-corruption.aspx.","Documents":""},{"Case ID":"ST-292","Case Cluster ":"Oil States International, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"04\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD, \u0022From 2003 through 2004, Oil States International, Inc. (Oil States), through certain employees of one of its subsidiaries, Hydraulic Well Control LLC (HWC), provided approximately $348,350 in improper payments to employees of Petr\u00f3leos de Venezuela, S.A. (PdVSA), an energy company owned by the government of Venezuela. Previously, HWC had hired a consultant to help it secure business from PdVSA. In December 2003, three PdVSA employees approached HWC\u2018s consultant and asked the consultant to submit inflated bills to HWC for his services and pay these excess funds to the PdVSA employees in the form of kickbacks. These employees also threatened to undermine or undo HWC\u2018s contracts with PdVSA if the company refused to pay the requested kickbacks. In turn, the consultant told three HWC employees about the scheme, and the employees agreed to accept inflated invoices. Ultimately, from December 2003 through November 2004, HWC approximately $348,350 in illicit payments to the consultant, knowing that some or all of this money would be transferred to foreign government officials for the purpose of obtaining or retaining business for HWC and Oil States. HWC then improperly recorded the payments in its accounting books and records as ordinary business expenses, which were subsequently incorporated into the books and records of its parent company.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Oil States International, Inc. Case Summary at 118.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Oil States International, Inc. Case Summary at 118, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Administrative Proceeding File No. 3-12280, Order Instituting Cease and Desist Proceedings, In the Matter of Oil States International, Inc. (April 27, 2006), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2006\/34-53732.pdf","Documents":""},{"Case ID":"ST-301","Case Cluster ":"Pacific Consolidated Industries LP","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Crown Prosecution Service","Jurisdiction of Foreign Public Official(s) ":"United Kingdom","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"04\/09","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Unknown if ordered","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unspecified","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Accepting Bribe Payment","Offenses - Settled":"Accepting Bribe Payment","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United Kingdom\u0027s \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 Ministry of Defence official, Michael Hale, was convicted in April 2007, on nine counts of accepting bribes totalling \u00a3217,000.\u0022 (Source:  United Kingdom\u0027s \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 September 2008, accessed at www.dfid.gov.uk\/documents).  The UK\u0027s MailOnline (and other media) reported on April 16, 2007 that Michael Hale, a senior military official, had plead guilty in Southwark Crown Court to charges of receiving bribes from Pacific Consolidated Industries. (Source: MailOnline, \u0022Senior MoD jailed for taking bribes from US arms dealer,\u0022 April 16, 2007, accessed at http:\/\/www.dailymail.co.uk\/news\/article-448968\/Senior-MoD-jailed-taking-bribes-US-arms-dealer.html.) According to the June 2011 United States Report to the OECD, \u0022the UK-MOD official pleaded guilty in the UK to accepting more than $300,000 in bribes from PCI and was sentenced to two years in prison.\u0022 (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Pacific Consolidated Industries, LP Case Summary at 81-82, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.)","Sources ":"United Kingdom\u0027s \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 September 2008, accessed at www.dfid.gov.uk\/documents; MailOnline, \u0022Senior MoD jailed for taking bribes from US arms dealer,\u0022 April 16, 2007, accessed at http:\/\/www.dailymail.co.uk\/news\/article-448968\/Senior-MoD-jailed-taking-bribes-US-arms-dealer.html; US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Pacific Consolidated Industries LP Case Summary at 81-82, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-324","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"[tax authorities]","Jurisdiction of Foreign Public Official(s) ":"Various","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"10\/04","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Tax Settlement (\u0022tatsthliche VerstUdigung\u0022) ","Monetary Sanctions  (Types)":"Tax Settlement (tatsthliche VerstUdigung) ","Total Monetary Sanctions (US$)":"$253,446,100.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"$253,446,100","Other Civil Monetary Sanctions (Explanation)":"Taxes Owed","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$253,446,100","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Taxes Owed","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":" Tax violations (liability relating to payments in connection with BCAs, other sales-related agreements with third-party intermediaries and other payments relating to the former Com Group at Siemens AG)","Offenses - Settled":" Tax violations (liability relating to payments in connection with BCAs, other sales-related agreements with third-party intermediaries and other payments relating to the former Com Group at Siemens AG)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"From Siemens Annual Report 2007 Incl. Consolidated Financial Statements of Siemens AG at 170-171 (30 Nov 2007): \u0022The Company has accounted for income tax-related charges with respect to fiscal 2000-2006 and adjusted comparative amounts for fiscal 2005 and 2006 as summarized below: In October 2007, the Company reached a final settlement (tats\u00e4chliche Verst\u00e4ndigung) with the German tax authorities regarding the deductibility for tax purposes of certain payments at the former Com Group at Siemens AG with respect to fiscal 2000-2006. Pursuant to the settlement, the Company\u2019s income tax obligation relating to payments in connection with BCAs [Business Consultant Agreements], other sales-related agreements with third-party intermediaries and other payments relating to the former Com Group at Siemens AG was determined to be \u20ac179 million. Payments of approximately \u20ac449 million were determined to be non-deductible for tax purposes. The Company also recorded interest charges of \u20ac12 million related to the tax obligations.\u0022  (Source: Siemens Annual Report 2007, at 170.","Sources ":"Siemens AG, Annual Report 2007, accessed at http:\/\/www.siemens.com\/annual\/07\/pool\/download\/pdf\/e07_00_gb2007.pdf, replace with http:\/\/www.siemens.com\/investor\/pool\/en\/investor_relations\/financial_publications\/annual_reports\/2007\/e07_00_gb2007.pdf","Documents":""},{"Case ID":"ST-300","Case Cluster ":"Pacific Consolidated Industries LP","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"United Kingdom","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"03\/08","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$20,000.00","Criminal Fine\/Penalty (US$) ":"$20,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Pacific Consolidated Industries LP, at 63-64, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: Time period of misconduct in United Kingdom, 1993-2003; Martin Eric Self and Leo Winston Smith, two executives of Pacific Consolidated Industries (which later went defunct) caused PCI to enter into a marketing agreement with  a person they understood to be a relative of the UK-MOD official\/project manager directly involved in the procurement of Air Separation Units (which PCI manufactured) on behalf of the UK-Ministry of Defence.  The ASU and related contracts awarded to PCI were valued at over $11 million. The executives were charged with participating in a scheme to make more than $370,000 in illicit payments, and Smith was also charged with failing to report nearly $500,000 in commissions from PCI on his tax returns.  Self pleaded guilty and was ordered to pay $7,500 criminal fine; Smith also pleaded guilty and was ordered to pay $20,000 in criminal fine. PCI was a private company. The UK-MOD official pleaded guilty in the UK to accepting more than $300,000 in bribes from PCI and was sentenced to two years in prison.  According to the United Kingdom\u0027s \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 Ministry of Defence official, Michael Hale, was convicted in April 2007, on nine counts of accepting bribes totalling ?17,000. (Source:  United Kingdom\u0027s \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 September 2008, accessed at www.dfid.gov.uk\/documents).  The UK\u0027s MailOnline (and other media) reported on April 16, 2007 that Michael Hale, a senior military official, had plead guilty in Southwark Crown Court to charges of receiving bribes from Pacific Consolidated Industries. (Source: MailOnline, \u0022Senior MoD jailed for taking bribes from US arms dealer,\u0022 April 16, 2007, accessed at http:\/\/www.dailymail.co.uk\/news\/article-448968\/Senior-MoD-jailed-taking-bribes-US-arms-dealer.html.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Pacific Consolidated Industries LP, at 63-64, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf:  US Department of Justice Press Release, \u0022Former Pacific Consolidated Industries LP Executive [Martin Eric Self] Pleads Guilty in Connection with Bribes Paid to U.K. Ministry of Defence Official,\u0022 May 8, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/May\/08-crm-394.html; US Department of Justice Press Release, \u0022Former Pacific Consolidated Industries LP Executive [Leo Winston Smith] Pleads Guilty in Connection with Bribes Paid to U.K. Ministry of Defense Official,\u0022 September 3, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/September\/09-crm-928.html;  US v. Leo Winston Smith, Case No. 8:07-cr-00069-AG (C.D.Ca.),  Amended Judgment filed January 11, 2011, accessed at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/smithl\/01-11-11smith-leo-amended.pdf; US v. Martin Eric Self, Case No. 8:08-cr-00110-AG (C.D. Ca.), Judgment filed November 17, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/selfm\/11-17-08self-judgment.pdf; United Kingdom\u0027s \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 September 2008, accessed at www.dfid.gov.uk\/documents; MailOnline, \u0022Senior MoD jailed for taking bribes from US arms dealer,\u0022 April 16, 2007, accessed at http:\/\/www.dailymail.co.uk\/news\/article-448968\/Senior-MoD-jailed-taking-bribes-US-arms-dealer.html.","Documents":""},{"Case ID":"ST-297","Case Cluster ":"Oxford University Press","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Unspecified sub-Saharan African countries (acts by Kenyan and Tanzanian subsidiaries whose geographical region included Kenya, Burundi, Malawi, Rwanda, Sudan, Uganda, Tanzania, Zanzibar archipelago)","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"07\/03","Other Jurisdictions of Settlement":"World Bank","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Civil Recovery Order (Proceeds of Crime Act)","Monetary Sanctions  (Types)":"Civil Recovery Order, Legal Costs, Voluntary Payment","Total Monetary Sanctions (US$)":"$6,126,115.10","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$2,971,300 ","Other Civil Monetary Sanctions (US$)":"$3,154,815","Other Civil Monetary Sanctions (Explanation)":"Investigation costs of $19,595.10 and $3,135,220 in voluntary unilateral payment to non-profit organizations","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$3,135,220 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Voluntary payment to non-profit organizations","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Irregularities in tender bidding; revenues derived from unlawful conduct (bribery and\/or corruption)","Offenses - Settled":"Irregularities in tender bidding; revenues derived from unlawful conduct (bribery and\/or corruption)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office press release, \u0022OPL is a wholly owned subsidiary of Oxford University Press (OUP), which pursues its mission through five publishing divisions, including the International Division.  [ ]  Oxford University Press East Africa (OUPEA) is based in Kenya but covers a geographical region which includes Kenya, Burundi, Malawi, Rwanda, Sudan and Uganda.  Oxford University Press Tanzania (OUPT) is based in mainland Tanzania but also has responsibility for the semi-autonomous Zanzibar archipelago.  Both OUPT and OUPEA are wholly owned subsidiaries of OPL and part of the International Division of OUP. [ ]  In 2011, OUP became aware of the possibility of irregular tendering practices involving its education business in East Africa.  OUP acted immediately to investigate the matter, instructing independent lawyers and forensic accountants to undertake a detailed investigation. As a result of the investigation, in November 2011 OUP voluntarily reported certain concerns in relation to contracts arising from a number of tenders which its Kenyan and Tanzanian subsidiaries, OUPEA and OUPT, entered into between the years 2007 and 2010.  [ ] The product of [the company\u0027s self investigation] led the SFO and the World Bank to believe that OUPEA and OUPT had offered and made payments, directly and through agents, intended to induce the recipients to award competitive tenders and\/or publishing contracts for schoolbooks to OUPEA and OUPT.  [ ] The value of the Order made by the High Court is \u00a31,895,435 [ ]. OPL will also pay the SFO costs of pursuing the order which amount to \u00a312,500. [ ] In addition to the property recovered under the civil recovery order, OUP unilaterally offered to contribute \u00a31,000,000 to not-for-profit organisations for teacher training and other educational purposes in sub-Saharan Africa.  This was a reflection of the seriousness with which OUP views the course of events that were subject to the investigation and a wish to acknowledge that the conduct of OUPEA and OUPT fell short of that expected within its wider organisation.  The contribution would benefit the people within the affected region and be consistent with the overall mission of OUP.  The offer also confirmed that the funds would not be used so as to provide OUP with a commercial advantage.  Although the benefits to the people of the affected region are acknowledged by the SFO, the SFO decided that the offer should not be included in the terms of the court order as the SFO considers it is not its function to become involved in voluntary payments of this kind.   However, the SFO welcomes OUP\u0027s commitment to make this contribution and to work with a range of not-for-profit organisations in sub-Saharan Africa to achieve the above objectives.\u0022  (Source: UK Serious Fraud Office press release, \u0022Oxford Publishing Ltd to pay almost ?.9 million as settlement after admitting unlawful conduct in its East African operations,\u0022 July 3, 2012.) ","Sources ":"UK Serious Fraud Office press release, \u0022Oxford Publishing Ltd to pay almost \u00a31.9 million as settlement after admitting unlawful conduct in its East African operations,\u0022 July 3, 2012, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2012\/oxford-publishing-ltd-to-pay-almost-19-million-as-settlement-after-admitting-unlawful-conduct-in-its-east-african-operations.aspx; Consent Order (July 2, 2012), accessed at http:\/\/www.sfo.gov.uk\/media\/215466\/sealed_consent_order.pdf; Claim Form, accessed at http:\/\/www.sfo.gov.uk\/media\/215458\/part_8_claim_form_n208.pdf; Application Notice Form, accessed at http:\/\/www.sfo.gov.uk\/media\/215462\/application_notice_form_n244.pdf","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Oxford_Univ_Press_Settlement_SFO_Press_Release_Jul_3_2012.pdf"},{"Case ID":"ST-381","Case Cluster ":"Weir Group plc","Jurisdiction of Settlement":"","Jurisdiction of Settlement \/ Enforcement Agency":"Crown Office (Scotland); Procurator Fiscal Service (Scotland)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea, Confiscation Order (Proceeds of Crime Act 2002 and Proceeds of Crime Act (Scotland) Act 1995)","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$26,767,500.00","Criminal Fine\/Penalty (US$) ":"$4,751,800","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$22,015,700","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$2,375,790","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Kick-back payments","Offenses - Settled":"Kick-back payments","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Crown Office and Procurator Fiscal Service news release dated December 15, 2010, \u0022The Crown Office has secured \u00a313.9 million under Proceeds of Crime legislation after a Scottish engineering company pled guilty to paying \u2018kickbacks\u2019 in return for contracts from Saddam Hussein\u2019s government. The confiscation order, made against Glasgow-based Weir Group Plc, is the biggest ever made by a Scottish court.  At the High Court in Edinburgh today, the company was also fined \u00a33 million after pleading guilty to paying more than \u00a33m in \u2018kickbacks\u2019, in contravention of UN sanctions against Iraq, through a Swiss bank account.  The Weir Group also admitted facilitating the payment of kickbacks by paying a fee of more than \u00a31.4 m to their agent, an Iraqi national, to the same Swiss bank account. The agent made the payments to the Iraqi government on behalf of Weir.  The kickbacks were paid to the Iraqi Government from funds in the UN\u2019s Oil for Food Programme, which should have been used for humanitarian purposes. An Independent Inquiry Committee set up by the UN has estimated that, in total, about US $1.5 billion that could have been used to ease the suffering of the Iraqi people was paid as kickbacks to Saddam Hussein\u0027s government. The Lord Advocate, the Right Honourable Elish Angiolini QC, said: \u0027This case represents the biggest single confiscation order made so far in Scotland using the Proceeds of Crime legislation. It is the result of a highly successful collaboration between National Casework Division of the Crown Office and Procurator Fiscal Service, Strathclyde Police and the Serious Fraud Office. In this year alone we have recovered over \u00a324 million, a record amount under the Proceeds of Crime legislation.\u0027\u0022  The news release added that in notes to editors: \u0022Weir Group companies secured 16 contracts for which they were paid \u00a334,340,204 by paying kickbacks of \u00a33,104,527. The confiscation order has been granted for \u00a313,945,962.\u0022 This includes Weir\u2019s gross profit of \u00a39, 414,283 from the contracts - plus the kickback of \u00a33,104,527 and the fee of \u00a31,427,152 paid to Weir\u2019s agent in Iraq.(Source:  The Crown Office and Procurator Fiscal Service news release, \u0022CROWN SECURES RECORD \u00a313.9M AS WEIR GROUP CONVICTED OF PAYING KICKBACKS FOR IRAQ CONTRACTS,\u0022 December 15, 2010.)  According to a February 13, 2011 press statement by the Government of Scotland, GBP1.5 million of the GBP 13.9 million seized under the Proceeds of Crime Act will support water development in Iraq and humanitarian programmes in Iraq and Afghanistan. Specifically, GBP1.4 million were to go towards projects in Iraq and GBP 100,000 to a Scottish charity for humanitarian work in Afghanistan. The remainder, GBP 12.4 million \u0022will be used to fund community projects in Scotland.\u0022  (Source: The Scottish Government, \u0022Seized cash returned to Iraq,\u0022 February 13, 2011.)","Sources ":"Crown Office and Procurator Fiscal Service Press Release, \u0022Crown Secures record \u00a313.9 million as Weir Group convicted of paying kickbacks for Iraq contracts,\u0022 December 15, 2010, accessed at http:\/\/www.copfs.gov.uk\/News\/Releases\/2010\/12\/Crown-Secures-record-%C2%A3139-million-Weir-Group-convicted-paying-kickbacks-Iraq-contracts; The Scottish Government, \u0022Seized cash returned to Iraq,\u0022 February 13, 2011, at http:\/\/www.scotland.gov.uk\/News\/Releases\/2011\/02\/14085030.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Weir_Group_COPFS_Settlement_Dec_15_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Weir_Group_Scotland_PR_Feb_14_2011.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Scotland_Crown_Office_POCA_Record_News_Release_June_2011.pdf"},{"Case ID":"ST-394","Case Cluster ":"Willis Ltd.","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Financial Services Authority","Jurisdiction of Foreign Public Official(s) ":"Egypt, Russia","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"07\/21","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Final Notice (of Penalty)","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$11,120,800.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$11,120,800","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Breaches of Principle 3 of the FSA\u0027s Principles for Businesses and Rule SYSC 3.2.6 R of the FSA?s Senior Management Arrangements, Systems and Controls Handbook (\u0022failings in its anti-bribery and corruption systems and controls\u0022)","Offenses - Settled":"Breaches of Principle 3 of the FSA\u0027s Principles for Businesses and Rule SYSC 3.2.6 R of the FSA\u0027s Senior Management Arrangements, Systems and Controls Handbook (\u0022failings in its anti-bribery and corruption systems and controls\u0022)","Public Procurement Contract \/ SOE Involved?":"No","Summary":"According to a July 21, 2011 press release by the UK Financial Services Authority (FSA\/PN\/066\/2011), the FSA \u0022has today fined Willis Limited \u00a36.895 million [US $11,120,800] for failings in its anti-bribery and corruption systems and controls. These failings created an unacceptable risk that payments made by Willis Limited to overseas third parties could be used for corrupt purposes. This is the biggest fine imposed by the FSA in relation to financial crime systems and controls to date.  Between January 2005 and December 2009, Willis Limited made payments to overseas third parties who assisted it in winning and retaining business from overseas clients, particularly in high risk jurisdictions. These payments totalled \u00a327 million. The FSA investigation found that, up until August 2008, Willis Limited failed to: \u2022ensure that it established and recorded an adequate commercial rationale to support its payments to overseas third parties; \u2022ensure that adequate due diligence was carried out on overseas third parties to evaluate the risk involved in doing business with them; and \u2022adequately review its relationships on a regular basis to confirm whether it was still necessary and appropriate for Willis Limited to continue with the relationship.\u0022  The press release also noted that Willis Ltd. agreed to settle at an early stage and was therefore given a 30% (stage 1) discount, without which the fine would have been GBP 9.85 million [US$15,886,900]. (Source: UK Financial Services Authority Press Release, \u0022FSA fines Willis Limited \u00a36.895 million for anti-bribery and corruption systems and controls failings,\u0022 FSA\/PN\/066\/2011,\u0022 July 21, 2011.)  According to the penalty notice issued to Willis Limited, \u0022One of the Overseas Third Parties engaged by Willis provided consultancy services in respect of a company based in Russia during the Relevant Period. This Overseas Third Party had a complex operational structure. The company was registered as a foreign company in Liberia, had a bank account in Switzerland and was controlled by a Trust Company in the Isle of Man.\u0022 (para 4.19); Willis Limited is a wholly-owned subsidiary of the Willis group of companies, whose ultimate parent is the Willis Group Holdings Plc, incorporated in Dublin, Ireland. (Source: UK Financial Services Authority, Final Notice to Willis Limited, July 21, 2011, accessed at   http:\/\/www.fsa.gov.uk\/pubs\/final\/willis_ltd.pdf.);  According to the FSA website, \u0022Facts and figures\u0022: Who pays for the FSA?  Our budget is met from a levy on the firms we regulate. We receive no funding from the taxpayer. The amount each firm pays is determined according to its size and the types of business it undertakes. When financial penalties are imposed on firms or individuals, the proceeds are used to reduce fees in the following financial year.\u0022 Link at http:\/\/www.fsa.gov.uk\/Pages\/About\/Media\/Facts\/index.shtml.","Sources ":"UK Financial Services Authority Press Release, \u0022FSA fines Willis Limited \u00a36.895 million for anti-bribery and corruption systems and controls failings,\u0022 FSA\/PN\/066\/2011,\u0022 July 21, 2011, accessed at http:\/\/www.fsa.gov.uk\/pages\/Library\/Communication\/PR\/2011\/066.shtml; UK Financial Services Authority, Final Notice to Willis Limited, July 21, 2011, accessed at http:\/\/www.fsa.gov.uk\/pubs\/final\/willis_ltd.pdf; United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf","Documents":""},{"Case ID":"ST-24","Case Cluster ":"Alcatel-Lucent S.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Costa Rica, Honduras, Malaysia, Taiwan","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/27","Other Jurisdictions of Settlement":"Costa Rica","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit","Total Monetary Sanctions (US$)":"$45,372,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$45,372,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission, the Commission filed a complaint which \u0022alleges that Alcatel\u0027s bribes went to government officials in Costa Rica, Honduras, Malaysia, and Taiwan between December 2001 and June 2006.  An Alcatel subsidiary provided at least $14.5 million to consulting firms through sham consulting agreements for use in the bribery scheme in Costa Rica.  Various high-level government officials in Costa Rica received at least $7 million of the $14.5 million to ensure Alcatel obtained or retained three contracts to provide telephone services in Costa Rica.  The SEC alleges that the same Alcatel subsidiary bribed officials in the government of Honduras to obtain or retain five telecommunications contracts.  Another Alcatel subsidiary made bribery payments to Malaysian government officials in order to procure a telecommunications contract.  An Alcatel subsidiary also made illegal payments to various officials in the government of Taiwan to win a contract to supply railway axle counters to the Taiwan Railway Administration. According to the SEC\u0027s complaint, all of the bribery payments were undocumented or improperly recorded as consulting fees in the books of Alcatel\u0027s subsidiaries and then consolidated into Alcatel\u0027s financial statements.  The leaders of several Alcatel subsidiaries and geographical regions, including some who reported directly to Alcatel\u0027s executive committee, either knew or were severely reckless in not knowing about the misconduct. [ ]  The SEC acknowledges the assistance of  [ ] the Office of the Attorney General in Costa Rica; the Fiscalia de Delitos Econ\u0026oacute;icos, Corrupci\u0026oacute; Tributarios in Costa Rica; and the Service Central de Preion de la Corruption in France.\u0022  (Source:  US Securities and Exchange Commission Litigation Release No. 21795\/ December 27, 2010, SEC v. Alcatel-Lucent, S.A., Civil Action No. 1:10-CV-24620-GRAHAM (S.D. FL.) (December 27, 2010), \u0022SEC Files Settled Foreign Corrupt Practices Act Charges Against Alcatel-Lucent, S.A. With Total Disgorgement and Criminal Fines of Over $137 Million.\u0022)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Alcatel-Lucent S.A. (Matter #11) Case Summary at 27-29, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 21795\/ December 27, 2010, SEC v. Alcatel-Lucent, S.A., Civil Action No. 1:10-CV-24620-GRAHAM (S.D. FL.) (December 27, 2010), \u0022SEC Files Settled Foreign Corrupt Practices Act Charges Against Alcatel-Lucent, S.A. With Total Disgorgement and Criminal Fines of Over $137 Million,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21795.htm; Complaint filed December 27, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21795.pdf.","Documents":""},{"Case ID":"ST-52","Case Cluster ":"BAE Systems plc","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Tanzania","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/21","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea  ","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Reparation, Legal Costs","Total Monetary Sanctions (US$)":"$46,914,016.00","Criminal Fine\/Penalty (US$) ":"$776,080","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$45,788,700","Criminal Legal \/ Procedural Costs (US$)":"$349,236 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$45,788,700 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Ex Gratia Payment to Tanzania","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Failure to Keep Accounting Records contravening section 221(5) of the Companies Act 1985","Offenses - Settled":"Failure to Keep Accounting Records contravening section 221(5) of the Companies Act 1985","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office Press Release, \u0022Today at Southwark Crown Court BAE Systems Plc was fined \u00a3500,000 after admitting it had failed to keep adequate accounting records in relation to a defence contract for the supply of an air traffic control system to the Government of Tanzania.  This outcome follows a settlement by BAE as part of a global agreement it reached earlier this year with the Serious Fraud Office and the US Department of Justice concerning contracts in a number of countries. The settlement with the SFO relates to the Tanzania contract whereby BAE agreed to pay an ex-gratia payment for the benefit of the people of Tanzania of \u00a340 million less any fine imposed by the Crown Court.  Additionally, BAE was ordered to pay \u00a3225,000 costs to the SFO.  [  ] A contract for the supply of a radar defence system for Dar-es-Salaam International Airport was agreed in 1999 between British Aerospace Defence Systems Ltd and the government of Tanzania. (This followed negotiations that had been conducted since 1992 initially by Siemens Plessey Systems which was acquired by BAE in 1998). The value of the contract was US $39.97 million. BAE\u0027s practice was to engage advisers to help with its marketing. These advisers were either classified by BAE as \u0027overt\u0027 (i.e. that is they operated openly as BAE\u0027s in-country representatives), or \u0027covert\u0027. The latter operated in circumstances where there was a need for confidentiality. In order to maximise confidentiality with regard to its use of covert advisers and the making of payments to them, BAE set up Red Diamond Trading Company, incorporated in the British Virgin Islands. In Tanzania a local businessman, Shailesh Vithlani, was recruited at an early stage (initially by Siemens) to advise BAE on its negotiations with the government on the radar contract. Shortly before the contract was signed two new adviser arrangements with Vithlani were concluded. One was made between Red Diamond and a Vithlani-controlled Panama-incorporated company, Envers Trading Corporation. This was a \u0027covert\u0027 arrangement where the fee for Vithlani\u0027s services was to be not more than 30.025% of the radar contract price. The other arrangement was \u0027overt\u0027 and was for services direct to BAE by a Vithlani-controlled business, Merlin International, registered in the B.V.I. It did not involve Red Diamond and the fee was 1% of the radar contract value.  Between January 2000 and December 2005 around $12.4 million was paid to Vithlani\u0027s two companies. BAE has accepted that there was a high probability that part of this sum would be used to favour it in the contract negotiations.  The payments were not subject to proper and adequate scrutiny or review.  Furthermore, it was not possible for any person auditing the accounts to investigate and determine whether the payments were properly accounted for or were lawful. In sentencing BAE, the Judge said that he took the view that BAE were concealing from the auditors and ultimately the public the fact that they were making payments to Vithlani; 97% of them via two offshore companies, with the intention that he should have free rein to make such payments to such people as he thought fit in order to secure the radar contract for BAE but that BAE did not want to know the details.  The Judge took into account in sentencing BAE that the group had committed itself to a process of change following the Report of Lord Woolf and that BAE would be making a payment for the benefit of the people of Tanzania of \u00a340 million less the fine. The Judge said that the people of Tanzania were the real victims. The Judge decided in these circumstances to impose a fine of \u00a3500,000.\u0022 (Source:  UK Serious Fraud Office Press Release, \u0022BAE fined in Tanzania defence contract case,\u0022 December 21, 2010, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2010\/bae-fined-in-tanzania-defence-contract-case.aspx.)","Sources ":"United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf; UK Serious Fraud Office Press Release, \u0022BAE fined in Tanzania defence contract case,\u0022 December 21, 2010, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2010\/bae-fined-in-tanzania-defence-contract-case.aspx; Between: R - and - BAE SYSTEMS PLC, Case No. Case No: S2010565 (Southwark Crown Court), December 21, 2010, accessed at http:\/\/www.judiciary.gov.uk\/Resources\/JCO\/Documents\/Judgments\/r-v-bae-sentencing-remarks.pdf; Prosecution Note for Opening, accessed at http:\/\/www.sfo.gov.uk\/media\/133543\/bae%20opening%20statement%2020.12.10.pdf; Settlement Agreement between the Serious Fraud Office and BAE Systems plc, February 2010, accessed at http:\/\/www.sfo.gov.uk\/media\/133535\/bae%20-%20settlement%20agreement%20and%20basis%20of%20plea.pdf; Charge, accessed at http:\/\/www.sfo.gov.uk\/media\/133535\/bae%20-%20settlement%20agreement%20and%20basis%20of%20plea.pdf.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/BAE_UK_SFO_Court_Sentencing_Remarks_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/BAE_UK_Settlement_Tanzania_SFO_PR_Feb_5_2010.pdf"},{"Case ID":"ST-74","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"02\/11","Other Jurisdictions of Settlement":"Nigeria, United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Civil Recovery Order (Proceeds of Crime Act) ","Monetary Sanctions  (Types)":"Civil Recovery Order","Total Monetary Sanctions (US$)":"$11,303,600.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$11,303,600","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Proceeds of Unlawful Conduct (Bribery by a Third Party)","Offenses - Settled":"Proceeds of Unlawful Conduct","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office Press Release, \u0022The Serious Fraud Office (SFO) has taken action in the High Court today which has resulted in an Order for the company, M.W. Kellogg Limited (MWKL), to pay just over \u00a37 million in recognition of sums it is due to receive which were generated through the criminal activity of third parties. The High Court made the Order under Part 5 of the Proceeds of Crime Act 2002. The SFO recognised that MWKL took no part in the criminal activity which generated the funds. The funds due to MWKL are share dividends payable from profits and revenues generated by contracts obtained by bribery and corruption undertaken by MWKL\u0027s parent company and others.  The agreement will lead to the payment of \u00a37,028,077 within fourteen days in full and final settlement of the case.  This sum represents the share dividends due and the interest which has accrued on these sums.The contracts were awarded to a company partly owned by MWKL on behalf of its US parent company.  MWKL reported concerns to the SFO under the \u0022self referral\u0022 scheme and fully co-operated with the subsequent investigation. The SFO, working in partnership with the US Department of Justice, reviewed the conduct of MWKL and decided that the most appropriate approach was to remove the funds which will become due to the company through the unlawful conduct. This reflects the finding that MWKL was used by the parent company and was not a willing participant in the corruption.\u0022 (Source: UK Serious Fraud Office, \u0022MW Kellogg Ltd to pay 7 million pounds in SFO High Court action,\u0022 February 16, 2011.)","Sources ":"UK Serious Fraud Office Press Release, \u0022MW Kellogg Ltd to pay 7 million pounds in SFO High Court action,\u0022 February 16, 2011, http:\/\/www.sfo.gov.uk\/press-room\/press-release-archive\/press-releases-2011\/mw-kellogg-ltd-to-pay-7-million-in-sfo-high-court-action.aspx; United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf","Documents":""},{"Case ID":"ST-110","Case Cluster ":"Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Haiti","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"05\/19","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Restitution, Criminal Forfeiture","Total Monetary Sanctions (US$)":"$3,302,675.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$1,028,851","Criminal Restitution \/ Reparation (US$)":"$2,273,824","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$73,824","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Haiti (unconfirmed as to $2.2m)","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 4, 2009, two former executives of a Florida-based telecommunications company, the president of a Florida-based intermediary company, and two former Haitian government officials were charged in an indictment for their alleged roles in a foreign bribery, wire fraud, and money laundering scheme that lasted from at least November 2001 through March 2005. Joel Esquenazi, the former president of the telecommunications company; Carlos Rodriguez, the former executive vice-president of the telecommunications company; Marguerite Grandison, the former president of Telecom Consulting Services Corp.; Robert Antoine, a former director of international relations at the Republic of Haiti\u0027s state-owned national telecommunications company, Telecommunications D\u0027Haiti (Haiti Teleco); and Jean Rene Duperval, another former director of international relations at Haiti Teleco, were charged in connection with a scheme whereby the telecommunications company paid more than $800,000 to shell companies, including Grandison\u0027s Telecom Consulting Services Corp., to be used for bribes to foreign officials of Haiti Teleco. The purpose of these bribes was to obtain various business advantages from the Haitian officials for the telecommunications company, including issuing preferred telecommunications rates, reducing the number of minutes for which payment was owed, and giving a variety of credits toward owed sums, as well as to defraud the Republic of Haiti of revenue.Previously, on April 22, 2009, Juan Diaz, the president of J.D. Locator Services Inc., a Florida-based intermediary, and Antonio Perez, the former controller of the Florida-based telecommunications company, were charged in connection with their roles in the alleged foreign bribery scheme. According to court documents, from 1998 to 2003, Diaz and Perez conspired to make \u0022side payments\u0022 totaling $1 million to the Haitian government officials through a shell company belonging to Diaz, all on behalf of the Florida-based telecommunications company.On February 1, 2010, Jean Fourcand, the president of Fourcand Enterprises, Inc., another intermediary company, was charged in a one-count criminal information with engaging in monetary transactions involving property derived from the scheme to bribe the former Haitian government officials. Specifically, between November 2001 and August 2002, Fourcand received funds originating from this and other U.S. telecommunications companies for the benefit of Robert Antoine. A portion of these funds came in the form of a check from J.D. Locator Services Inc., and a portion of these funds were used to engage in a real estate transaction that benefitted Antoine.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco) Case Summary at 51-52.)  Diaz\u0027s Information included the following Notice of Forfeiture: \u0022the defendant shall forfeit to the United States any property, real or personal, which constitutes proceeds traceable to the Title 18, United States Code, Section 371 conspiracy to commit a violation of the Foreign Corrupt Practices Act, Title 15, United States Code, Section 78dd-2, a specified unlawful activity as defined in Title 18, United States Code, Section 1956(c)(7), which is $1,028,851.95 in United States currency.\u0022 (Source:  US v. Diaz, Case No. 1:09-cr-20346-JEM (S.D. Fla.), Information filed April 22, 2009, at p. 10.) According to the Sentencing Hearing Transcript, the victim recipient of the restitution is the Government of Haiti. (Source: US v. Diaz, Case No. 1:09-cr-20346-JEM (S.D. Fla.), Sentencing Hearing (July 30, 2010) Transcript filed August 5, 2010, accessed via Pacer.)  According to the Amended Judgment in US v. Esquenazi, Esquenazi, Rodriguez, Perez, Fourcand and Antoine were ordered joint and severally liable for $2.2 million in restitution.  (Source: US v. Esquenazi, Case No. 1:09-cr-20210-JEM (S.D. Fla.), Amended Judgment filed November 3, 2011, accessed via Pacer.)  Esquenazi and Rodriguez were sentenced following their convictions; hence there is no entry on their cases and the restitution sum is noted only in this entry as to avoid double counting of the sum. According to the US Department of Justice Press Release, \u0022The Department of Justice is grateful to the government of Haiti for providing substantial assistance in gathering evidence during this investigation. In particular, Haiti\u0027s financial intelligence unit, the Unite de Renseignements Financiers, the Bureau des Affaires Financierses et Economiques, which is a specialized component of the Haitian National Police, and the Ministry of Justice and Public Security provided significant cooperation and coordination in this ongoing investigation.\u0022 (Source:  US Department of Justice Press Release, \u0022Florida Businessman Sentenced to 57 Months in Prison for Role in Foreign Bribery Scheme,\u0022 July 30, 2010.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco) Case Summary at 51-52, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Diaz, Case No. 1:09-cr-20346-JEM (S.D. Fla.), Information filed April 22, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/diazj\/04-22-09diaz-info.pdf; Plea Agreement filed May 18, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/diazj\/05-18-09diaz-plea-agree.pdf; Factual Agreement filed May 18, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/diazj\/05-18-09diaz-fatual-agree.pdf; Judgment filed August 5, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/diazj\/08-05-10diaz-judgment.pdf; and Sentencing Hearing (July 30, 2010) Transcript filed August 5, 2010, accessed via Pacer.  US Department of Justice Press Release, \u0022Florida Businessman Sentenced to 57 Months in Prison for Role in Foreign Bribery Scheme,\u0022 July 30, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/July\/10-crm-883.html.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Haiti_Teleco_Diaz_Sentencing_Hearing_Transcript_Aug_2010.pdf"},{"Case ID":"ST-114","Case Cluster ":"CBRN Ltd.","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Crown Prosecution Service","Jurisdiction of Foreign Public Official(s) ":"Uganda","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"09\/21","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Restitution","Total Monetary Sanctions (US$)":"$96,682.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$96,682","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$73,242","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Uganda","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Receipt of corrupt funds; money laundering","Offenses - Settled":"Receipt of Bribery","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK\u0027s Self-Assessment related to the United Nations Convention against Corruption, \u0022R v Tumokunde \u0026 Tobiasen - Tumukunde, from Uganda advised his government on science and technology.  In May 2007 he signed a contract worth \u00a3210,000 with British company CBRN Ltd, for CBRN to supply services to the government for a forthcoming Commonwealth visit by heads of state. Following the agreement, Tumukunde approached CBRN Managing Director, Niels Tobiasen, claiming that he would need to make additional payments via Tumukunde to meet a local tax of 10%.  Tobiasen agreed and a total of six payments worth over \u00a383,000 were made to both Tumukunde and another Ugandan, Rusoke Tagaswire between 1 June 2007 and 1 February 2008. Tumukunde and Tagaswire recorded the money as being paid to them as agents of the Ugandan government working on the contract, when in fact they were inducements going directly into two bank accounts Tumukunde had opened in his own name in the UK.  Tumukunde was charged with four counts of money laundering and sentenced to 12 months in prison on 22nd September 2008.  Niels Tobiasen pleaded guilty to making corrupt payments and given a suspended sentence after cooperating fully with police enquiries. It is currently estimated that up to \u00a340,000 of the monies will be repatriated to the Government of Uganda.\u0022  (Source:  United Kingdom, \u0022Self-assessment checklist on the implementation of the United Nations Convention against Corruption,\u0022 September 2008, at www.dfid.gov.uk.)  According to the Norton Rose law firm Case Study cited in the July 13, 2011 United Kingdom\u0027s UNCAC Self-Assessment Report, the London Police received information of Tumukunde\u0027s plans to travel to the UK and Tumukunde was arrested by Scotland Yard at Heathrow Airport. (Tobiasen later pleaded guilty to making corrupt payments to Tobiasen. On September 22, 2008, Tumukunde pleaded guilty, before His Honour Judge Wadsworth in the Southwark Crown Court to accepting corrupt payments and was sentenced to 12 months\u0027 imprisonment; he also signed a disclaimer releasing the GBP 52,800 from his bank account into the custody of the City of London Police for restitution. (Sources: Norton Rose (law firm), \u0022Case Study: CBRN Team Ltd (non-FCPA)\u0022; City of London Police Statement, \u0022Guilty plea to bribery sets legal landmark,\u0022 July 27, 2010.) Source:Vhttp:\/\/www.nortonrose.com\/expertise\/business-ethics-and-anti-corruption\/business-ethics-and-anti-corruption-case-study-cbrn-team-ltd-non-fcpa-18410.as","Sources ":"United Kingdom, \u0022Self-assessment checklist on the implementation ofthe United Nations Convention against Corruption,\u0022 September 2008, at www.dfid.gov.uk; Paul Lewis and Rob Evans, \u0022Ugandan is jailed in UK bribery crackdown,\u0022 The Guardian, September 22, 2008, accessed at http:\/\/www.guardian.co.uk\/uk\/2008\/sep\/23\/ukcrime.law; United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf","Documents":""},{"Case ID":"ST-202","Case Cluster ":"Hydro Kleen Systems Inc.","Jurisdiction of Settlement":"Canada","Jurisdiction of Settlement \/ Enforcement Agency":"Crown Prosecutors (Alberta)","Jurisdiction of Foreign Public Official(s) ":"Canada, United States","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"01\/10","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$20,279.00","Criminal Fine\/Penalty (US$) ":"$20,279","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign official [subparagraph 426(1)(a)(i) of the Criminal Code (secret commissions) and paragraph 3(1)(a) of the Corruption of Foreign Public Officials Act (CFPOA)]","Offenses - Settled":"Bribery of foreign official (Corruption of Foreign Public Officials Act)","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to Canada\u0027s Phase 3 Report by the OECD (March 2011), \u0022At the time of the Phase 2 on-site visit to Canada in 2003, proceedings were ongoing in respect of charges against Hydro Kleen Group Inc., an Alberta-based company, and two individuals, concerning the bribes of approximately CAD 30 000 paid to a US Immigration official contrary to subparagraph 426(1)(a)(i) of the Criminal Code (secret commissions) and paragraph 3(1)(a) of the Corruption of Foreign Public Officials Act (CFPOA).  In January 2005, Hydro Kleen admitted guilt to one count under the CFPOA as part of a plea agreement. The company was fined CAD 25 000. The two other charges, against a director and an officer of the company, were stayed as part of the plea agreement.\u0022  (Source:  Canada Report to the OECD: Phase 3 - Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, 18 March 2011.) According to the Sentencing hearing transcripts in R. v. Watts, et al [2005] A.J. No. 568, \u0022Between the 1st day of August, 2000, and the 1st day of December, 2001, at or near Red Deer and elsewhere in the Province of Alberta, in order to obtain or retain an advantage in the course of business directly or indirectly gave, offered, or agreed to give or offer a loan, reward, advantage or benefit, to wit: the sum of $28,299.88 more or less to a foreign public official, to wit: Hector Ramirez Garcia for the benefit of Hector Ramirez Garcia as consideration for an act or omission by Hector Ramirez Garcia in connection with the performance of his duties or functions on behalf of the United States of America, United States Department of Justice, Immigration and Naturalization Service, contrary to section 3(1)(a) of the Corruption of Foreign Public Officials Act SC 1998, C34.\u0022 (Source: R. v. Watts [2005] A.J. No. 568, Oral Judgment and Sentencing Hearing, January 10, 2005).  Please note that during sentencing a victim, the competitor company - Innovative Coke Expulsion Inc. - that lost the contract due to the bribery by Hydro Kleen, read a \u0022victim impact statement\u0022 pursuant to section 722 of the Criminal Code.  (Source: Ibid.)   The three individuals were charged with violations of Canada\u0027s Corruption of Foreign Public 2002 Year in Review: Developments in U.S. and International Efforts to Combat Transnational Commercial Bribery Officials Act and of the Criminal Code of Canada. Mr. Garcia pleaded guilty and served a six-month jail sentence. Upon his release in February 2003, Mr. Garcia was deported tothe United States where he faces prosecution by the DOJ. [ ]  A related civil lawsuit was filed in Canada by another refinery cleaning company, Innovative Coke Expulsion Inc. (\u0022ICE\u0022 on the grounds that Garcia accepted bribes to deny its employees entry into the United States. ICE also filed a civil RICO suit against Hydro Kleen, which has a U.S. subsidiary, in the United States. In May 2002, Hydro Kleen paid ICE $300,000 in settlement.\u0022  (Source: American Bar Association, \u00222002 Year in Review: Developments in U.S. and International Efforts to Combat Transnational Commercial Bribery.\u0022)","Sources ":"Canada Report to the OECD: Phase 3 - Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (18 March 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/55\/25\/47438413.pdf; R. v. Watts, et al [2005] A.J. No. 568, Oral Judgment and Sentencing Hearing, January 10, 2005, accessed at http:\/\/www.cba.org\/cba\/dublin2009\/pdf\/Gowlings_Appendix%20A%20-%20R%20v.%20Watts.pdf  (Hydro Kleen sentencing); American Bar Association, \u00222002 Year in Review: Developments in U.S. and International Efforts to Combat Transnational Commercial Bribery,\u0022 accessed at http:\/\/apps.americanbar.org\/intlaw\/committees\/special_projects\/corrupt_practices\/yir_corrupt.pdf.","Documents":""},{"Case ID":"ST-261","Case Cluster ":"Mabey \u0026 Johnson Ltd.","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Ghana, Jamaica, Iraq (UN Oil-for-Food)","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"09\/25","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Restitution, Criminal Confiscation, Legal  Costs, Monitoring Costs","Total Monetary Sanctions (US$)":"$10,733,697.45","Criminal Fine\/Penalty (US$) ":"$5,679,205","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$1,784,893","Criminal Restitution \/ Reparation (US$)":"$2,296,021","Criminal Legal \/ Procedural Costs (US$)":"$973,578 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$2,296,021","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Ghana, Iraq via Development Fund for Iraq, Jamaica","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials, Breach of UN Sanctions","Offenses - Settled":"Bribery of foreign officials, Breach of UN Sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office Press Release of September 25, 2009, \u0022Mabey \u0026 Johnson Ltd appeared at Southwark Crown Court today for sentence in relation to admitted offences of overseas corruption and breaching UN sanctions. The company is to pay  \u00a3.6M. This is the first prosecution brought in the UK against a  company for these offences. The company, which is a supplier of steel bridging and is based in Twyford, Berkshire, had already indicated at a magistrates\u0027 court hearing on 10 July 2009 that it would plead guilty to these offences. \/ Corruption - The prosecution for corruption arises from the company\u0027s voluntary disclosure to the SFO of evidence to indicate that the company had sought to influence decision-makers in public contracts in Jamaica and Ghana between 1993 and 2001. The decision to voluntarily disclose the corruption offences to the SFO was taken by the management of Mabey \u0026 Johnson\u0027s holding company in February 2008 whereupon an investigation was opened. \/ Breach of UN sanctions - The prosecution for breach of UN sanctions during 2001\/02, as they applied to contracts in the Iraq \u0022Oil-for-food\u0022 programme, arises from an investigation commenced in January 2007.  The details of the sentence today are:  Fines: Ghana  \u00a3750,000; Jamaica  \u00a3750,000; Iraq  \u00a32 million; Confiscation order  \u00a31.1million; Reparations: Ghana  \u00a3658,000; Jamaica  \u00a3139,000; Iraq  \u00a3618,000. Costs to the SFO  \u00a3350,000First year monitoring cost up to  \u00a3250,000.\u0022  (Source: UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd Sentencing,\u0022 September 25, 2009.)  According to a UK Parliamentary Report, \u0022In respect of Jamaica and Ghana the company undertook to offer the sums described above to its customers in Jamaica and Ghana. The undertaking by the company included a provision dealing with the possibility that the company would be unable to reach an agreement with its customers within six years or if it became evident at a prior date that no such agreement was likely to be reached. In those circumstances the payment would be made to the SFO or any successor body. The SFO\u0027s understanding is that the reparation payment has been made to the customer in Jamaica. The company has been unsuccessful, however, in its attempts to reach agreement with its Ghanaian customer. It is understood that the issue here concerns the reluctance of the Ghanaian authorities to accept that any corruption was involved. A different scheme is in operation relating to Iraq. A Development Fund for Iraq was set up internationally and payments in Oil for Food cases are made to that fund. There is therefore an international mechanism for compensation.\u0022 (Source: UK House of Commons, International Development Financial Crime and Development, Eleventh Report of Session 2010?12, Volume I (November 30, 2011), Appendix B, \u0022Notes on Other Cases by the Serious Fraud Office.\u0022) ","Sources ":"United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf; UK Serious Fraud Office, \u0022Mabey \u0026 Johnson Ltd Sentencing,\u0022 September 25, 2009, accessed at http:\/\/www.sfo.gov.uk\/press-room\/press-release-archive\/press-releases-2009\/mabey--johnson-ltd-sentencing-.aspx;  UK House of Commons, International Development Financial Crime and Development, Eleventh Report of Session 2010?12, Volume I (November 30, 2011), Appendix B, \u0022Notes on Other Cases by the Serious Fraud Office,\u0022 accessed at http:\/\/www.publications.parliament.uk\/pa\/cm201012\/cmselect\/cmintdev\/847\/84702.htm","Documents":""},{"Case ID":"ST-243","Case Cluster ":"Johnson \u0026 Johnson","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Greece","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"04\/14","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to make corrupt payments (section 1 of the Prevention of Corruption Act 1906)","Offenses - Settled":"Conspiracy to make corrupt payments (section 1 of the Prevention of Corruption Act 1906)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the August 2011 Report by the United Kingdom to the OECD, \u0022Former DePuy executive Robert John Dougall pleaded guilty after admitting his involvement in making \u00a34.5 million of corrupt payments to medical professionals within the Greek state healthcare system. He was originally sentenced to 12 months imprisonment. Recognising the important public interest issues raised in this case, Mr. Dougall was granted leave to appeal. On appeal the sentence was suspended. The Court of Appeal emphasised [sic] that where a defendant entered a guilty plea and provided full co-operation with the authorities investigating a major crime involving fraud or corruption and the level of criminality and mitigation meant that the sentence of imprisonment would be 12 months or less, then -- the argument that the sentence should be suspended is very powerful and that --  this result will normally follow.\u0022 (Source:  United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, Information as of 16 August 2011).  There is no mention of a monetary penalty ordered in this case in the UK Serious Fraud Office\u0027s Press Release on his case. (Source: US Serious Fraud Office Press Release, \u0022British executive jailed for part in Greek healthcare corruption,\u0022 April 14, 2010.)","Sources ":"United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf;  US Serious Fraud Office Press Release, \u0022British executive jailed for part in Greek healthcare corruption,\u0022 April 14, 2010, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2010\/british-executive-jailed-for-part-in-greek-healthcare-corruption.aspx; R. v. Dougall, Case No: 2010\/02063\/A3,  [2010] EWCA Crim 1048 (May 13, 2010), accessed at http:\/\/openmedicineeu.blogactiv.eu\/files\/2011\/06\/JJ-DOUGALL-Appeal-Judgement.pdf","Documents":""},{"Case ID":"ST-262","Case Cluster ":"Mabey \u0026 Johnson Ltd.","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"02\/23","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None ","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"\u0022Sanctions Offenses\u0022","Offenses - Settled":"\u0022Sanctions Offenses\u0022","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office Press Release, on February 23, 2011, \u0022Two former directors and a sales manager of engineering firm Mabey \u0026 Johnson Ltd have been sentenced today for providing kickbacks to the Iraqi government of Saddam Hussein. Charles Forsyth, David Mabey and Richard Gledhill inflated the contract price for the supply of steel bridges and disguised illegal payments that were channelled through Jordanian banks.The sentences are: *Richard Charles Edward Forsyth, 63, former managing director was sentenced to 21 months imprisonment, disqualified from acting as a company director for five years and was ordered to pay prosecution costs of   \u00a375,000. *David Mabey, 49, former sales director, to eight months imprisonment, disqualified from acting as a company director for two years and was ordered to pay prosecution costs of  \u00a3125,000. *Richard Gledhill, 64, former sales manager, to eight months imprisonment, suspended for two years.  On 10 February 2011, a Southwark Crown Court jury found Charles Forsyth and David Mabey guilty of making illegal payments to Iraq during 2001\/02 in breach of United Nations sanctions. Richard Gledhill, who was sales manager for contracts in Iraq, pleaded guilty to sanctions offences at an earlier hearing and gave evidence for the Prosecution.  The company, Mabey \u0026 Johnson Ltd, of Twyford, Berkshire, had entered into a contract under the UN Oil-For-Food Programme to supply 13 steel modular bridges.  The illegal payments of over \u20ac420,000 that secured the contract with the Iraqi government represented 10% of the total contract value.\u0022  (Source:  UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd: Former executives jailed for helping finance Saddam Hussein\u0027s government,\u0022 February 23, 2011.  For background on the case, see UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson directors made illegal payments to Sadam Hussein\u0027s Iraq to gain contract,\u0022 February 10, 2011.)","Sources ":"UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson Ltd: Former executives jailed for helping finance Saddam Hussein\u0027s government,\u0022 February 23, 2011, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2011\/mabey--johnson-ltd-former-executives-jailed-for-helping-finance-saddam-hussein\u0027s-government.aspx; UK Serious Fraud Office Press Release, \u0022Mabey \u0026 Johnson directors made illegal payments to Sadam Hussein\u0027s Iraq to gain contract,\u0022 February 10, 2011, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2011\/mabey--johnson-directors-made-illegal-payments-to-sadam-hussein\u0027s-iraq-to-gain-contract.aspx","Documents":""},{"Case ID":"ST-263","Case Cluster ":"Mabey \u0026 Johnson Ltd.","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"01\/13","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Civil Recovery Order (Proceeds of Crime Act)","Monetary Sanctions  (Types)":"Civil Recovery Order, Legal Costs","Total Monetary Sanctions (US$)":"$204,835.86","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"$3,739.86 ","Civil Disgorgement of Profits (US$) ":"$201,096","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Share Dividends Received from Contracts Won through Unlawful Conduct","Offenses - Settled":"Share Dividends Received from Contracts Won through Unlawful Conduct","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Press Release by the UK Serious Fraud Office, \u0022The Director of the Serious Fraud Office (SFO) has taken action in the High Court, which has resulted in an Order for the company, Mabey Engineering (Holdings) Ltd, to pay over \u00a3130,000 in recognition of sums it received through share dividends derived from contracts won through unlawful conduct. Mabey Engineering (Holdings) Ltd is the parent company of modular bridge manufacturers Mabey and Johnson Ltd and part of the Mabey Holdings group. Mabey and Johnson (M\u0026J) has been working with the SFO since the beginning of 2008 when it approached the authorities to highlight irregularities it had identified as a result of an internal investigation. Following the self-referral and subsequent co-operation with the SFO\u0027s investigations M\u0026J pleaded guilty to charges of corruption and breaches of United Nations sanctions and was convicted at Southwark Crown Court in September 2009. [ ]  The settlement will see the shareholder of M\u0026J pay \u00a3131,201 under Part 5 of the Proceeds of Crime Act 2002.  The action, which represents the conclusion of all matters related to the self-referral, arises from the successful prosecution in February 2011 of former M\u0026J company officers; David Mabey and Charles Forsyth and the earlier conviction of M\u0026J employee Richard Gledhill for their part in breaching UN Sanctions with Iraq.  The sum represents the dividends which the parent company collected from the contracts at the centre of the UN Sanctions prosecutions.  The company will also pay costs of \u00a32,440.\u0022  (Source: UK Serious Fraud Office Press Release, \u0022Shareholder agrees civil recovery by SFO in Mabey \u0026 Johnson,\u0022 January 13, 2012.)\r\n","Sources ":"UK Serious Fraud Office Press Release, \u0022Shareholder agrees civil recovery by SFO in Mabey \u0026 Johnson,\u0022 January 13, 2012, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2012\/shareholder-agrees-civil-recovery-by-sfo-in-mabey--johnson.aspx","Documents":""},{"Case ID":"ST-355","Case Cluster ":"Tenaris, S.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Uzbekistan","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"05\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$3,500,000.00","Criminal Fine\/Penalty (US$) ":"$3,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, on May 17, 2011, Tenaris S.A., a publicly traded corporation headquartered in Luxembourg agreed to pay $3.5 million in criminal penalties for violation of the Foreign Corrupt Practices Act and entered into a Non-Prosecution Agreement with the Department of Justice. (Source: US Department of Justice Press Release, \u0022Tenaris S.A. Agrees to Pay $3.5 Million Criminal Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 May 17, 2011.)   The NPA included a provision which states \u0022It is understood that Tenaris admits, accepts, and acknowledges responsibility for the conduct of its employees, agents, and subsidiaries set forth in Appendix A [Statement of Facts],\u0022 namely that employees and agents of Tenaris offered and made improper payments to officials of OJSC O\u0027ztashqineftgaz, an Uzbekistan state-controlled oil and gas production company, and failed to record such payments in Tenaris\u0027s books and records.  (Source: In Re Tenaris, Department of Justice Non-Prosecution Agreement dated March 14, 2011.)  According to the United States June 2011 \u0022Steps taken to implement and enforce the OECD Convention on Combatting Bribery of Foreign Public Officials in International Business Transactions,\u0022 Report to the OECD, \u0022This enforcement action marked the first-ever use of a DPA [Deferred Prosecution Agreement] to facilitate and reward cooperation in a SEC investigation.\u0022 (at 11)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 June 2011, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf;  In Re Tenaris, S.A., DOJ Non-Prosecution Agreement dated March 14, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tenaris-sa\/2011-03-14-tenaris.pdf and Press Release of May 17, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/May\/11-crm-629.html.","Documents":""},{"Case ID":"ST-356","Case Cluster ":"Tenaris, S.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Uzbekistan","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"05\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Deferred Prosecution Agreement ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$5,428,338.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$4,786,438","Civil Prejudgment Interest (US$) ":"$641,900","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States June 2011 \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Report to the OECD, \u0022This enforcement action marked the first-ever use of a DPA [Deferred Prosecution Agreement] to facilitate and reward cooperation in a SEC investigation.\u0022 (at 11)  Please note that the Tenaris DPA with the SEC includes a \u0022Statement of Facts,\u0022 but as noted in the document, Tenaris agreed to the settlement \u0022without admitting or denying the allegations\u0022 made against it by the SEC. (Source: In Re Tenaris, S.A., SEC Deferred Prosecution Agreement, May 17, 2011.)  According to the DPA, \u0022Between in or around April 2006 through May 2007, Tenaris bid on a series of contracts with OJSC O\u0027ztashqineftgaz (\u0022OAO\u0022), to supply OAO with pipeline for use in the development and production of oil and natural gas in Uzbekistan. OAO was a subsidiary ofUzbekneftegaz, the state-owned holding company of Uzbekistan\u0027s oil and gas industry.\u0022  The SEC had alleged that Tenaris retained an agent in connection with those contract bids and made commission payments to the agent, and that \u0022Tenaris\u0027s then-regional sales personnel understood that a portion of the commission Tenaris paid to the Agent for services related to contracts M-07-53, M-0770, M-07-71 and M-07-72 would be used to pay OAO officials for opening competitors\u0027 bids, providing confidential bid information to Tenaris, and replacing Tenaris\u0027s original bids with its revised bids.\u0022 (at para 6n)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 June 2011, Tenaris Case Summary, at 11-12, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   In Re Tenaris, S.A., SEC Deferred Prosecution Agreement, May 17, 2011, accessed at  http:\/\/www.sec.gov\/news\/press\/2011\/2011-112-dpa.pdf.","Documents":""},{"Case ID":"ST-357","Case Cluster ":"Textron Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Egypt, India, Indonesia, Iraq (UN Oil-for-Food), United Arab Emirates ","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"08\/23","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,150,000.00","Criminal Fine\/Penalty (US$) ":"$1,150,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records","Offenses - Settled":"Bribery of Foreign Officials, Falsification of Books and Records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On August 23, 2007, Textron, Inc., a Rhode Island-based industrial equipment company, settled allegations with the Department of Justice and the SEC relating to kickbacks paid to the former Government of Iraq under the United Nations Oil for Food Program (OFFP). As part of a consent agreement with the SEC and a non-prosecution agreement with the Department, Textron acknowledged responsibility for kickbacks paid to the Iraqi government by its David Brown French subsidiaries in exchange for contracts worth $1,936,936 to provide industrial pumps, gears, and other equipment to Iraqi ministries under the OFFP. According to settlement documents, the subsidiaries in Textron\u0027s Fluid and Power Business Unit paid a total of more than $650,000 in kickbacks by inflating the price of contracts by 10 percent before submitting the contracts to the U.N. for approval. These kickback payments, which bypassed the U.N. escrow account, were paid by third parties to Iraqi government-controlled accounts. During the course of its own internal investigation, Textron also uncovered an additional 36 illicit payments totaling almost $115,000 that were made to officials of state-owned companies in countries other than Iraq, including the United Arab Emirates, Bangladesh, Indonesia, Egypt, and India, in order to obtain similar contracts.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 June 2011, Textron inc. Case Summary, at 99-100.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 June 2011, Textron inc. Case Summary, at 99-100, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  In re: Textron, Inc., Non-Prosecution Agreement and Statement of Facts (August 23, 2007), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/textron-inc\/08-21-07textron-agree.pdf and US Department of Justice Press Release, \u0022Textron Inc. Agrees to $1.15 Million Fine in Connection with Payment of $600,000 in Kickbacks by its French Subsidiaries under the United Nations Oil for Food Program,\u0022 August 23, 2007, accessed at http:\/\/fcpa.shearman.com\/files\/04e\/04e42ef825608000bc64d754b81f7093.pdf?i=92fe69b0c1a0458c55646f7fc899da95 (also available at http:\/\/www.justice.gov\/opa\/pr\/2007\/August\/07_crm_646.html); SEC v. Textron, Inc. (D.D.C.), Complaint filed on August 23, 2007 and Final Judgment filed August 31, 2007, accessed at http:\/\/fcpa.shearman.com\/files\/479\/479ab232d795496347543f9673c118e3.pdf?i=b403e47bd0a0e0e148a9d284811430d3 and http:\/\/fcpa.shearman.com\/files\/2a9\/2a95205e0169f1db9e04408b41e6ddc6.pdf?i=7c4b4d50118071cab831985af973acff, respectively.","Documents":""},{"Case ID":"ST-358","Case Cluster ":"Textron Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Bangladesh, Egypt, India, Indonesia, Iraq (UN Oil-for-Food), United Arab Emirates ","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"08\/23","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$3,535,040.68","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$2,284,579","Civil Prejudgment Interest (US$) ":"$450,462","Civil Fine \/ Penalty (US$)":"$800,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On August 23, 2007, Textron, Inc., a Rhode Island-based industrial equipment company, settled allegations with the Department of Justice and the SEC relating to kickbacks paid to the former Government of Iraq under the United Nations Oil for Food Program (OFFP). As part of a consent agreement with the SEC and a non-prosecution agreement with the Department, Textron acknowledged responsibility for kickbacks paid to the Iraqi government by its David Brown French subsidiaries in exchange for contracts worth $1,936,936 to provide industrial pumps, gears, and other equipment to Iraqi ministries under the OFFP. According to settlement documents, the subsidiaries in Textron\u0027s Fluid and Power Business Unit paid a total of more than $650,000 in kickbacks by inflating the price of contracts by 10 percent before submitting the contracts to the U.N. for approval. These kickback payments, which bypassed the U.N. escrow account, were paid by third parties to Iraqi government-controlled accounts. During the course of its own internal investigation, Textron also uncovered an additional 36 illicit payments totaling almost $115,000 that were made to officials of state-owned companies in countries other than Iraq, including the United Arab Emirates, Bangladesh, Indonesia, Egypt, and India, in order to obtain similar contracts.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 June 2011, Textron inc. Case Summary, at 99-100.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 June 2011, Textron inc. Case Summary, at 99-100, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  SEC v. Textron, Inc. (D.D.C.), Complaint filed on August 23, 2007 and Final Judgment filed August 31, 2007, accessed at http:\/\/fcpa.shearman.com\/files\/479\/479ab232d795496347543f9673c118e3.pdf?i=b403e47bd0a0e0e148a9d284811430d3 and http:\/\/fcpa.shearman.com\/files\/2a9\/2a95205e0169f1db9e04408b41e6ddc6.pdf?i=7c4b4d50118071cab831985af973acff, respectively. SEC press release accessed at; http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20251.htm","Documents":""},{"Case ID":"ST-359","Case Cluster ":"Titan Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Benin","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"03\/01","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$15,479,195.47","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$12,620,000","Civil Prejudgment Interest (US$) ":"$2,859,195","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States June 2011 Report to the OECD, \u0022Titan Corporation (Titan), a Delaware Corporation headquartered in San Diego, CA, is a global provider of military intelligence and communications solutions. In October 1998, Titan established a joint venture with Afronetwork, a Benin telecommunications company, to build a satellite-based telephone system in Benin. In a November meeting between Titan and Afronetwork, Titan was introduced to a \u0022business advisor\u0022 to the president of Benin. Titan subsequently hired the \u0022advisor\u0022 to assist with the contract in exchange for 5% of the value of all equipment installed in Benin. Revenues from the contract were close to $100 million, and Titan subsequently made over $2.3 million in payments to the agent, including via offshore accounts in Monaco. Titan recorded the payments as \u0022consulting services\u0022 in its corporate books and records and broke the payments into smaller increments to make them appear more reasonable.\u0022  (Source: Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Titan Corporation Case Summary at 116-117.)   According to the SEC Litigation Release, to settle the SEC\u0027s civil charges, Titan agreed to pay $12.62 million in disgorgement along with $2,859,195.47 million in prejudgment interest. In addition, Titan was ordered to pay a civil penalty of $13 million, which was deemed satisfied by payment of the same amount in criminal fines. (Source: US Securities and Exchange Commission Litigation Release No. 19107 \\ March 1, 2005, Securities and Exchange Commission v. The Titan Corporation, Case No. 05-0411 (D.D.C.) (JR) (filed March 1, 2005), \u0022SEC Sues The Titan Corporation for Payments to Campaign of Benin President.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Titan Corporation Case Summary at 116-117, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 19107 \\ March 1, 2005, Securities and Exchange Commission v. The Titan Corporation, Case No. 05-0411 (D.D.C.) (JR) (filed March 1, 2005), \u0022SEC Sues The Titan Corporation for Payments to Campaign of Benin President,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr19107.htm; Complaint filed March 1, 2005, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/comp19107.pdf; Investigation Report, Release No. 51283 \/ March 1, 2005, accessed at http:\/\/www.sec.gov\/litigation\/investreport\/34-51238.htm","Documents":""},{"Case ID":"ST-360","Case Cluster ":"Titan Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Benin","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"03\/01","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$13,000,000.00","Criminal Fine\/Penalty (US$) ":"$13,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Filing a false tax return","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records, Filing a false tax return","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States June 2011 Report to the OECD, \u0022Titan Corporation (Titan), a Delaware Corporation headquartered in San Diego, CA, is a global provider of military intelligence and communications solutions. In October 1998, Titan established a joint venture with Afronetwork, a Benin telecommunications company, to build a satellite-based telephone system in Benin. In a November meeting between Titan and Afronetwork, Titan was introduced to a \u0022business advisor\u0022 to the president of Benin. Titan subsequently hired the \u0022advisor\u0022 to assist with the contract in exchange for 5% of the value of all equipment installed in Benin. Revenues from the contract were close to $100 million, and Titan subsequently made over $2.3 million in payments to the agent, including via offshore accounts in Monaco. Titan recorded the payments as \u0022consulting services\u0022 in its corporate books and records and broke the payments into smaller increments to make them appear more reasonable.\u0022  (Source: Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Titan Corporation Case Summary at 116-117.)   See also, US v. Titan Corporation, Case No. 05-cr-0314 (S.D. Cal.) documents listed in Sources field.","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Titan Corporation Case Summary at 116-117, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Titan Corporation, Case No. 05-cr-314 (S.D. Cal.), Information filed on March 1, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/titan-corp\/03-01-05titan-info.pdf; Plea Agreement filed March 1, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/titan-corp\/03-01-05titan-plea.pdf; Office of the United States Attorney for the Southern District of California, News Release March 1, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/titan-corp\/03-01-05titan-pr-plea.pdf; Judgment filed March 21, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/titan-corp\/03-21-05titan-judgment.pdf; Amended Judgment filed April 13, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/titan-corp\/04-13-05titan-judgment.pdf","Documents":""},{"Case ID":"ST-361","Case Cluster ":"Titan Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Benin","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"06\/23","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$5,000.00","Criminal Fine\/Penalty (US$) ":"$5,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Falsification of books and records","Offenses - Settled":"Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States June 2011 Report to the OECD, \u0022Titan Corporation (Titan), a Delaware Corporation headquartered in San Diego, CA, is a global provider of military intelligence and communications solutions. In October 1998, Titan established a joint venture with Afronetwork, a Benin telecommunications company, to build a satellite-based telephone system in Benin. In a November meeting between Titan and Afronetwork, Titan was introduced to a \u0022business advisor\u0022 to the president of Benin. Titan subsequently hired the \u0022advisor\u0022 to assist with the contract in exchange for 5% of the value of all equipment installed in Benin. Revenues from the contract were close to $100 million, and Titan subsequently made over $2.3 million in payments to the agent, including via offshore accounts in Monaco. Titan recorded the payments as \u0022consulting services\u0022 in its corporate books and records and broke the payments into smaller increments to make them appear more reasonable.\u0022  The Report also noted that Steven Lynwood Head, Chief Executive Officer of Titan Africa, Inc. also pleaded guilty to charge of falsification of books and records and was fined $5,000.  (Source: Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Titan Corporation Case Summary at 116-117.)   See also, US v. Steven Lynwood Head, Case No. 06-cr-1380-BEN (S.D. Cal.) documents listed in source column.  ","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Titan Corporation Case Summary at 116-117, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Steven Lynwood Head, Case No. 3:06-cr-1380-BEN (S.D. Cal.), Information filed June 23, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/heads\/06-27-06head-info.pdf; Plea Agreement filed June 26, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/heads\/06-23-6head-plea.pdf; Government\u0027s Motion for Downward Departure in Sentencing filed September 21, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/heads\/09-21-07headgovt5k1-depart.pdf; Judgment filed October 4, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/heads\/10-04-07head-judgment.pdf","Documents":""},{"Case ID":"ST-362","Case Cluster ":"Tyco International Ltd.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Brazil, South Korea","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"04\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Civil Penalty ","Total Monetary Sanctions (US$)":"$50,000,001.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$50,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations. Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the SEC Litigation Release in SEC v. Tyco International, Ltd., the company settled a civil injunctive action in the U.S. District Court for the Southern District of New York.  The SEC\u0027s complaint alleged that, from 1996 through 2002, Tyco violated federal securities laws including inflating operating income, failure to disclose executive compensation, and violated antibribery provisions of the Foreign Corrupt Practices Act when employees or agents of its Earth Tech Brasil Ltds. subsidiary made payments to Brazilian officials for the purpose of obtaining or retaining business for Tyco. The final judgment also orders Tyco to pay $1 in disgorgement and a $50 million civil penalty. (Source: Securities and Exchange Commission Litigation Release No. 19657 (April 17, 2006) in SEC v. Tyco International Ltd., Case No. 2:06-cv-2942 (S.D.N.Y. 2006).  Pleae note that as part of the settlement, a Final Judgment was entered against Tyco International without the company admitting or denying the allegations of the Complaint (except as to jurisdiction).  (Source: SEC v. Tyco International Ltd., Case No. 2:06-cv-2942 (S.D.N.Y.), Final Judgment filed April 27, 2006.) [The US June 2011 Report to the OECD, Tyco case summary noted that $1 million in disgorgement had been ordered.]","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Tyco Internatonal Ltd., at 107; Securities and Exchange Commission Litigation Release No. 19657 (April 17, 2006) in SEC v. Tyco International Ltd., Case No. 2:06-cv-2942 (S.D.N.Y.), Complaint filed April 17, 2006.  Litigation Release accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2006\/lr19657.htm and Complaint at http:\/\/www.sec.gov\/litigation\/complaints\/2006\/comp19657.pdf; Final Judgment filed April 27, 2006 at http:\/\/fcpa.shearman.com\/files\/274\/27418a1c06809e1f95673bd0d7a0921f.pdf?i=82ab60c8ea2f89f59d46535a2094a129.","Documents":""},{"Case ID":"ST-363","Case Cluster ":"Tyson Foods, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"02\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$4,000,000.00","Criminal Fine\/Penalty (US$) ":"$4,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"No (Inspectors)","Summary":"According to the US Department of Justice Press Release, \u0022As part of a deferred prosecution agreement with the department, Tyson acknowledged responsibility for the actions of its subsidiaries, employees and agents who made improper payments to government-employed veterinarians who inspected two of its chicken processing plants in Gomez Palacio, Mexico.  [  ] According to documents filed in court, Tyson\u0027s Mexican subsidiary, Tyson de Mexico, paid approximately $90,000 between 2004 and 2006, to two publicly-employed veterinarians who inspected its Mexican plants, resulting in profits of approximately $880,000.  The payments were made both directly to the veterinarians and indirectly through their wives, who Tyson de Mexico listed on its payroll, although neither performed any services for Tyson.  According to court documents, the bribe payments were made to keep the veterinarians from disrupting the operations of the meat-production facilities.  When payments to the spouses were terminated in 2004, Tyson representatives agreed to increase the amount paid to the veterinarians to match the amount previously paid to their spouses.\u0022 (Source: US Department of Justice Press Release, \u0022Tyson Foods Inc. Agrees to Pay $4 Million Criminal Penalty to Resolve Foreign Bribery Allegations,\u0022 February 10, 2011.)","Sources ":"US Department of Justice Press Release, \u0022Tyson Foods Inc. Agrees to Pay $4 Million Criminal Penalty to Resolve Foreign Bribery Allegations,\u0022 February 10, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/February\/11-crm-171.html;  US v. Tyson Foods, Inc., Case No. 1:11-cr-00037 (D.D.C.), Information filed February 10, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tyson-foods\/02-10-11tyson_foods_info.pdf; and Deferred Prosecution Agreement dated February 4, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tyson-foods\/02-10-11tyson_foods_dpa.pdf.","Documents":""},{"Case ID":"ST-364","Case Cluster ":"Tyson Foods, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Mexico","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"02\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest ","Total Monetary Sanctions (US$)":"$1,214,477.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$880,786","Civil Prejudgment Interest (US$) ":"$333,691","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art.1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"NO (INSPECTORS)","Summary":"According to the US Department of Justice Press Release, \u0022As part of a deferred prosecution agreement with the department, Tyson acknowledged responsibility for the actions of its subsidiaries, employees and agents who made improper payments to government-employed veterinarians who inspected two of its chicken processing plants in Gomez Palacio, Mexico.  [  ] According to documents filed in court, Tyson\u0027s Mexican subsidiary, Tyson de Mexico, paid approximately $90,000 between 2004 and 2006, to two publicly-employed veterinarians who inspected its Mexican plants, resulting in profits of approximately $880,000.  The payments were made both directly to the veterinarians and indirectly through their wives, who Tyson de Mexico listed on its payroll, although neither performed any services for Tyson.  According to court documents, the bribe payments were made to keep the veterinarians from disrupting the operations of the meat-production facilities.  When payments to the spouses were terminated in 2004, Tyson representatives agreed to increase the amount paid to the veterinarians to match the amount previously paid to their spouses.\u0022 (Source: US Department of Justice Press Release, \u0022Tyson Foods Inc. Agrees to Pay $4 Million Criminal Penalty to Resolve Foreign Bribery Allegations,\u0022 February 10, 2011.)   The US Securities and Exchange Commission made the same allegations and also alleged that the company failed to keep accurate books and records and to implement a system of effective internal controls to prevent improper payments.  (Source: SEC v. Tyson Foods, Inc., Case No. 1:11-cv-00350 (D.D.C.), Complaint filed February 10, 2011.)  Without admitting or denying the SEC\u0027s allegations, Tyson Foods consented to the entry of a final judgment ordering disgorgement of profits and prejudgment interest and enjoining the company from future FCPA violations. (Source: SEC v. Tyson Foods, Inc., Case No. 1:11-cv-00350 (D.D.C.), Final Judgment filed February 15, 2011.)","Sources ":"U.S. Securities and Exchange Commission, Litigation Release No. 21851 \/ February 10, 2011, \u0022SEC Charges Tyson Foods With FCPA Violations; Tyson Foods to Pay Disgorgement Plus Pre-judgment Interest of More Than $1.2 million; Tyson Foods to Pay Criminal Penalty of $4 Million,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr21851.htm; SEC v. Tyson Foods, Inc., Case No. 1:11-cv-00350 (D.D.C.), Complaint filed February 10, 2011, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp21851.pdf and Final Judgment filed February 15, 2011 (accessed via Pacer).  DOJ:  US Department of Justice Press Release, \u0022Tyson Foods Inc. Agrees to Pay $4 Million Criminal Penalty to Resolve Foreign Bribery Allegations,\u0022 February 10, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/February\/11-crm-171.html;  US v. Tyson Foods, Inc., Case No. 1:11-cr-00037 (D.D.C.), Information filed February 10, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tyson-foods\/02-10-11tyson_foods_info.pdf; and Deferred Prosecution Agreement dated February 4, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tyson-foods\/02-10-11tyson_foods_dpa.pdf.","Documents":""},{"Case ID":"ST-365","Case Cluster ":"UNC \/ Lear Services Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2000","Month\/Day of Settlement (or Notes)":"03\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Restitution, Special Assessment","Total Monetary Sanctions (US$)":"$844,200.00","Criminal Fine\/Penalty (US$) ":"$75,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$768,000","Criminal Legal \/ Procedural Costs (US$)":"$1,200 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Falsification of books and records, Mail fraud, Making a false statement","Offenses - Settled":"Falsification of books and records,Mail fraud, Making a false statement","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 UNC\/Lear Services, Inc. at 122: Misconduct took place in Saudi Arabia between 1993 and 1995; the US Department of Justice charged UNC\/Lear Services on February 17, 2000; the charges arose from the company\u0027s efforts to conceal $140,000 in illicit payments which were made to a Kentucky corporation for the benefit of a Saudi Arabian consultant; the payments were descibed in the company\u0027s books and records as \u0022fees for engineering services\u0022 and the consultant provided UNC\/Lear with false invoices to support the payments.   The Court Docket report in US v. UNC\/Lear Services, Case No. 3:00-cr-00031-EHJ (W.D. Ky.) noted that on September 10, 2000, UNC\/Lear pleaded guilty to all charges on March 6, 2000, and was sentenced to pay SPA $1200, $75,000 criminal fine, and $768,000 in restitution; the documents in the case were unavailable via Pacer.  The Docket Report does not indicate the recipient of the restitution ordered.","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 UNC\/Lear Services Inc.,  at 122, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US v. UNC\/Lear Services, Case No. 3:00-cr-00031-EHJ (W.D. Ky.), Court Docket Report accessed via Pacer on October 24, 2011.  See also, US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, UNC\/Lear Services Inc. Case Summary at 132, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-366","Case Cluster ":"United Industrial Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Egypt","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"05\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$337,679.42","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$267,571","Civil Prejudgment Interest (US$) ":"$70,108.42","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On May 29, 2009, the SEC filed a settled enforcement action in the U.S. District Court for the District of Columbia against Thomas Wurzel, the former President of ACL Technologies, Inc. (ACL), formerly a subsidiary of United Industrial Corporation (UIC), which provided aerospace and defense systems. In a related action, the SEC also instituted, on May 29, 2009, a settled administrative proceeding against UIC.The Commission\u0027s complaint against Wurzel alleged that he authorized illicit payments to an Egyptian-based agent while he knew or consciously disregarded the high probability that the agent would offer, provide, or promise at least a portion of such payments to Egyptian Air Force officials for the purpose of influencing these officials to award business related to a military aircraft depot in Cairo, Egypt to UIC. In relation to this misconduct, the Commission charged Wurzel with violations of the anti-bribery, books and records and internal controls provisions of the FCPA, and with aiding and abetting UIC\u0027s violations of the anti-bribery and books and records provisions of the FCPA.The Commission\u0027s complaint alleges that from late 2001 through 2002, Wurzel authorized three forms of illicit payments to the agent: (1) payments to the agent ostensibly for labor subcontracting work; (2) a $100,000 advance payment to the agent in June 2002 for \u0022equipment and materials;\u0022 and (3) a $50,000 payment to the agent in November 2002 for \u0022marketing services.\u0022 Furthermore, Wurzel later directed his subordinates to create false invoices to conceal the fact that the $100,000 \u0022advance payment\u0022 in June 2002 was never repaid. As a result, UIC, through ACL, was awarded a contract with gross revenues and net profits of approximately $5.3 million and $267,000, respectively.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, United Industrial Corporation Case Summary at 65-66.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, United Industrial Corporation Case Summary at 65-66, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, In the Matter of United Industrial Corporation, Administrative Proceedings File No. 3-13495, Corrected Order Instituting Cease and Desist Proceedings, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2009\/34-60005.pdf","Documents":""},{"Case ID":"ST-367","Case Cluster ":"United Industrial Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Egypt","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"05\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$35,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$35,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"False accounting, Aiding and Abetting UIC\u0027s Bribery of Foreign Officials, Aiding adn Abetting UIC\u0027s Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On May 29, 2009, the SEC filed a settled enforcement action in the U.S. District Court for the District of Columbia against Thomas Wurzel, the former President of ACL Technologies, Inc. (ACL), formerly a subsidiary of United Industrial Corporation (UIC), which provided aerospace and defense systems. In a related action, the SEC also instituted, on May 29, 2009, a settled administrative proceeding against UIC.The Commission\u0027s complaint against Wurzel alleged that he authorized illicit payments to an Egyptian-based agent while he knew or consciously disregarded the high probability that the agent would offer, provide, or promise at least a portion of such payments to Egyptian Air Force officials for the purpose of influencing these officials to award business related to a military aircraft depot in Cairo, Egypt to UIC. In relation to this misconduct, the Commission charged Wurzel with violations of the anti-bribery, books and records and internal controls provisions of the FCPA, and with aiding and abetting UIC\u0027s violations of the anti-bribery and books and records provisions of the FCPA.The Commission\u0027s complaint alleges that from late 2001 through 2002, Wurzel authorized three forms of illicit payments to the agent: (1) payments to the agent ostensibly for labor subcontracting work; (2) a $100,000 advance payment to the agent in June 2002 for \u0022equipment and materials;\u0022 and (3) a $50,000 payment to the agent in November 2002 for \u0022marketing services.\u0022 Furthermore, Wurzel later directed his subordinates to create false invoices to conceal the fact that the $100,000 \u0022advance payment\u0022 in June 2002 was never repaid. As a result, UIC, through ACL, was awarded a contract with gross revenues and net profits of approximately $5.3 million and $267,000, respectively.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, United Industrial Corporation Case Summary at 65-66.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, United Industrial Corporation Case Summary at 65-66, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  SEC v. Thomas Wurzel, Case No. 1:09-cv-01005 (D.D.C.), Complaint filed May 29, 2009, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp21063.pdf and SEC Litigation Release No. 21063 in SEC v. Wurzel, accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21063.htm; and In the Matter of United Industrial Corporation, Administrative Proceeding File No. 3-13495, Corrected Order Instituting Cease-and-Desist Proceedings Pursuant to Section 21C of the Securities and Exchange Act of 1934, Making Findings and Imposing a Cease-and-Desist Order, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2009\/34-60005.pdf.","Documents":""},{"Case ID":"ST-368","Case Cluster ":"Universal Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Malawi, Mozambique, Thailand","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine (if subsidiary does not make payment)","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Conspiracy to Falsify Books and Records, Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Conspiracy to Falsify Books and Records, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, On August 6, 2010, \u0022Universal Leaf Tabacos Ltda. (Universal Brazil), the Brazilian subsidiary of Universal Corporation (Universal), was charged in the Eastern District of Virginia with conspiring to violate the anti-bribery and books and records provisions of the FCPA, and with violating the anti-bribery provisions of the FCPA. On the same date, the SEC filed a settled civil action against Universal in the District of Columbia, charging the parent company with violations of the anti-bribery, books and records, and internal controls provisions of the FCPA. The criminal and civil charges against Universal and its subsidiary stem from schemes to bribe foreign officials in Thailand, Mozambique, and Malawi.  From 2000 to 2004, Universal Brazil and two of its competitors, Dimon Incorporated and Standard Commercial Corporation, sold Brazilian-grown tobacco to the Thailand Tobacco Monopoly (TTM). Each of these three companies retained sales agents in Thailand, and collaborated through those agents to apportion tobacco sales to the TTM among themselves, coordinate their sales prices, and pay kickbacks to officials of the Thailand Tobacco Monopoly in order to ensure that each company would share in the Thai tobacco market. These companies made annual sales to the TTM, and in order to secure these sales contracts, each company paid kickbacks to certain TTM representatives based on the number of kilograms of tobacco they sold to the TTM. To obtain these contracts, Universal Brazil paid approximately $697,000 in bribes to TTM officials during this period. In addition, Universal Brazil employees then falsely characterized the corrupt payments on the company\u0027s books and records as \u0022commissions\u0022 paid to the company\u0027s sales agents.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Universal Corporation Case Summary at 44-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.)  According to the Universal Corporation\u0027s Non-Prosecution Agreement with the Department of Justice, \u0022It is understood that [Universal Corporation\u0027s subsidiary] Universal Brazil has agreed to pay a monetary penalty in the amount of $4,400,000. Universal agrees to pay this monetary penalty to the United States Treasury on behalf of Universal Brazil if for any reason Universal Brazil has not paid this amount within ten days of the sentencing of Universal Brazil.\u0022  (Source: In Re: Universal Corporation, Department of Justice Non-Prosecution Agreement and Statement of Facts, August 6, 2010.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Universal Corporation Case Summary at 44-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  In Re: Universal Corporation, Department of Justice Non-Prosecution Agreement and Statement of Facts, August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/universal-corp.html and US Department of Justice Press Release, \u0022Alliance One International Inc. and Universal Corporation Resolve Related FCPA Matters Involving Bribes Paid to Foreign Government Officials,\u0022 August 6, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/August\/10-crm-903.html.  US Department of Justice Press Release, \u0022Alliance One International Inc. and Universal Corporation Resolve Related FCPA Matters Involving Bribes Paid to Foreign Government Officials,\u0022 August 6, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/August\/10-crm-903.html","Documents":""},{"Case ID":"ST-369","Case Cluster ":"Universal Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Thailand, Malawi, Mozambique","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit","Total Monetary Sanctions (US$)":"$4,581,276.51","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$4,581,276.51","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records, Internal Controls Violations ","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, on August 6, 2010, the Commission charged Universal Corporation with violations of the FCPA, namely \u0022According to the SEC\u0027s complaint, between 2000 and 2004, Universal, in coordination with two of its competitors, Dimon, Inc. (\u0022Dimon\u0022) and Standard Commercial Corporation (\u0022Standard\u0022), paid approximately $800,000 to bribe officials of the government-owned Thailand Tobacco Monopoly (\u0022TTM\u0022) in exchange for securing approximately $11.5 million in sales contracts for its subsidiaries in Brazil and Europe. From 2004 through 2007, Universal also made a series of payments in excess of $165,000 to government officials in Mozambique through corporate subsidiaries in Belgium and Africa. Universal made these payments, among other things, to secure an exclusive right to purchase tobacco from regional growers and to procure legislation beneficial to the company\u0027s business. Between 2002 and 2003, Universal subsidiaries paid a total of $850,000 to high-ranking Malawian government officials. Universal did not accurately record these payments in its books and records.\u0022 (Source:  US Securities and Exchange Commission Litigation Release No. 21618 \/ August 6, 2010, Securities and Exchange Commission v. Universal Corporation Inc., Civil Action No. 01:10-cv-01318 (RWR) (D.D.C.) (filed August 6, 2010), Securities and Exchange Commission v. Alliance One International, Inc., Civil Action No. 01:10-cv-01319 (RMU) (D.D.C.) (filed August 6, 2010), \u0022SEC Files Anti-Bribery Charges Against Two Global Tobacco Companies.\u0022)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Universal Corporation Case Summary at 44-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 21618 \/ August 6, 2010, Securities and Exchange Commission v. Universal Corporation Inc., Civil Action No. 01:10-cv-01318 (RWR) (D.D.C.) (filed August 6, 2010), Securities and Exchange Commission v. Alliance One International, Inc., Civil Action No. 01:10-cv-01319 (RMU) (D.D.C.) (filed August 6, 2010), \u0022SEC Files Anti-Bribery Charges Against Two Global Tobacco Companies,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21618.htm; Complaint filed August 6, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21618-universal.pdf","Documents":""},{"Case ID":"ST-370","Case Cluster ":"Universal Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Malawi, Mozambique, Thailand","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$4,400,000.00","Criminal Fine\/Penalty (US$) ":"$4,400,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Conspiracy to Falsify Books and Records, Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Conspiracy to Falsify Books and Records, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, On August 6, 2010, \u0022Universal Leaf Tabacos Ltda. (Universal Brazil), the Brazilian subsidiary of Universal Corporation (Universal), was charged in the Eastern District of Virginia with conspiring to violate the anti-bribery and books and records provisions of the FCPA, and with violating the anti-bribery provisions of the FCPA. On the same date, the SEC filed a settled civil action against Universal in the District of Columbia, charging the parent company with violations of the anti-bribery, books and records, and internal controls provisions of the FCPA. The criminal and civil charges against Universal and its subsidiary stem from schemes to bribe foreign officials in Thailand, Mozambique, and Malawi.  From 2000 to 2004, Universal Brazil and two of its competitors, Dimon Incorporated and Standard Commercial Corporation, sold Brazilian-grown tobacco to the Thailand Tobacco Monopoly (TTM). Each of these three companies retained sales agents in Thailand, and collaborated through those agents to apportion tobacco sales to the TTM among themselves, coordinate their sales prices, and pay kickbacks to officials of the Thailand Tobacco Monopoly in order to ensure that each company would share in the Thai tobacco market. These companies made annual sales to the TTM, and in order to secure these sales contracts, each company paid kickbacks to certain TTM representatives based on the number of kilograms of tobacco they sold to the TTM. To obtain these contracts, Universal Brazil paid approximately $697,000 in bribes to TTM officials during this period. In addition, Universal Brazil employees then falsely characterized the corrupt payments on the company\u0027s books and records as \u0022commissions\u0022 paid to the company?s sales agents.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Universal Corporation Case Summary at 44-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.)  According to the Universal Corporation\u0027s Non-Prosecution Agreement with the Department of Justice, \u0022It is understood that [Universal Corporation\u0027s subsidiary] Universal Brazil has agreed to pay a monetary penalty in the amount of $4,400,000. Universal agrees to pay this monetary penalty to the United States Treasury on behalf of Universal Brazil if for any reason Universal Brazil has not paid this amount within ten days of the sentencing of Universal Brazil.\u0022  (Source: In Re: Universal Corporation, Department of Justice Non-Prosecution Agreement and Statement of Facts, August 6, 2010.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Universal Corporation Case Summary at 44-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Universal Leaf Tabacos Ltda., Case No. 3:10-cr-225-REP (E.D. Va.), Information filed August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/universal-leaf\/08-06-10universal-leaf-info.pdf; Plea Agreement filed August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/universal-leaf\/08-06-10universal-leaf-plea-agmt.pdf; Agreed Sentencing Memorandum filed August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/universal-leaf\/08-06-10universal-leaf-sentencing-memo.pdf; Judgment filed August 31, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/universal-leaf\/08-31-universal-leaf-judgment.pdf.  US Department of Justice Press Release, \u0022Alliance One International Inc. and Universal Corporation Resolve Related FCPA Matters Involving Bribes Paid to Foreign Government Officials,\u0022 August 6, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/August\/10-crm-903.html","Documents":""},{"Case ID":"ST-371","Case Cluster ":"UTStarcom, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"12\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine  ","Total Monetary Sanctions (US$)":"$1,500,000.00","Criminal Fine\/Penalty (US$) ":"$1,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 31, 2009, UTStarcom, Inc. (UTSI), a global telecommunications company that designs, manufactures, and sells network equipment and handsets, entered into a non-prosecution agreement with the Department of Justice regarding the improper provision of travel and other things of value to employees at state-owned telecommunications firms in the People\u0027s Republic of China, in violation of the FCPA. On the same date, the SEC filed a settled civil complaint against UTSI in relation to this conduct.  As part of these agreements, UTSI acknowledged responsibility for the actions of its wholly-owned subsidiary, UTStarcom China Co. Ltd. (UTS-China), and its employees and agents, who arranged and paid for employees of Chinese state-owned telecommunications companies to travel to popular tourist destinations in the United States, including Hawaii, Las Vegas, and New York City. The trips were purportedly for individuals to participate in training at UTSI facilities. In fact, UTSI had no facilities in those locations and conducted no training. UTS-China then falsely recorded these trips as \u0022training\u0022 expenses, while the true purpose for providing these trips was to obtain and retain lucrative telecommunications contracts. The civil complaint filed by the SEC also stated that UTSI had arranged for expensive gifts and all-expense paid trips for officials from government customers in Thailand. In addition, the SEC stated that UTSI made sham payments to a Mongolian consulting company for the purpose of bribing a Mongolian government official to help UTSI obtain a favorable ruling in a license dispute.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, UTStarcom Inc. Case Summary at 56-57.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, UTStarcom Inc. Case Summary at 56-57, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   In Re UTStarcom Inc., Non-Prosecution Agreement filed December 31, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/utstarcom-inc\/12-31-09utstarcom-agree.pdf; US Department of Justice Press Release, \u0022UTStarcom Inc. Agrees to Pay $1.5 Million Penalty for Acts of Foreign Bribery in China,\u0022 December 31, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/December\/09-crm-1390.html","Documents":""},{"Case ID":"ST-372","Case Cluster ":"UTStarcom, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"12\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$1,500,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$1,500,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"$0","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 31, 2009, UTStarcom, Inc. (UTSI), a global telecommunications company that designs, manufactures, and sells network equipment and handsets, entered into a non-prosecution agreement with the Department of Justice regarding the improper provision of travel and other things of value to employees at state-owned telecommunications firms in the People\u0027s Republic of China, in violation of the FCPA. On the same date, the SEC filed a settled civil complaint against UTSI in relation to this conduct.  As part of these agreements, UTSI acknowledged responsibility for the actions of its wholly-owned subsidiary, UTStarcom China Co. Ltd. (UTS-China), and its employees and agents, who arranged and paid for employees of Chinese state-owned telecommunications companies to travel to popular tourist destinations in the United States, including Hawaii, Las Vegas, and New York City. The trips were purportedly for individuals to participate in training at UTSI facilities. In fact, UTSI had no facilities in those locations and conducted no training. UTS-China then falsely recorded these trips as \u0022training\u0022 expenses, while the true purpose for providing these trips was to obtain and retain lucrative telecommunications contracts. The civil complaint filed by the SEC also stated that UTSI had arranged for expensive gifts and all-expense paid trips for officials from government customers in Thailand. In addition, the SEC stated that UTSI made sham payments to a Mongolian consulting company for the purpose of bribing a Mongolian government official to help UTSI obtain a favorable ruling in a license dispute.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, UTStarcom Inc. Case Summary at 56-57.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, UTStarcom Inc. Case Summary at 56-57, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 21357 \/ December 31, 2009, Securities and Exchange Commission v. UTStarcom, Inc., Case No. CV-09-6094 (JSW) (N.D. Cal. filed Dec. 31, 2009), \u0022SEC Charges California Telecom Company with Bribery and Other FCPA Violations,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21357.htm; Complaint filed December 31, 2009, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp21357.pdf","Documents":""},{"Case ID":"ST-373","Case Cluster ":"Veraz Networks, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, Vietnam","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"06\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$300,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$300,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"$0","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On June 29, 2010, the SEC filed a settled civil complaint against Veraz Networks, Inc. (\u0022Veraz\u0022), a San Jose, California-based telecommunications company. The SEC alleged that Veraz violated the books and records and internal controls provisions of the FCPA in connection with improper payments to foreign officials in China and Vietnam. These payments took place after the company went public in 2007.  Specifically, the SEC alleged that Veraz engaged a consultant in China who in 2007 and 2008 gave gifts and offered improper payments together valued at approximately $40,000 to officials at a government controlled telecommunications company in China in an attempt to win business for Veraz. A Veraz supervisor who approved the gifts described them in an internal Veraz email as the \u0022gift scheme.\u0022 Similarly, the SEC alleged that in 2007 and 2008, a Veraz employee made improper payments to the CEO of a government controlled telecommunications company in Vietnam in order to win business for Veraz.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Veraz Networks Inc. Case Summary at 48-49.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Veraz Networks Inc. Case Summary at 48-49, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21581 \/ June 29, 2010, Securities and Exchange Commission v. Veraz Networks, Inc., Case No. CV-10-2849 (PVT) (N.D. Cal. filed June 29, 2010), \u0022SEC Charges California Telecommunications Company with FCPA Violations,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21581.htm; Complaint filed June 29, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21581.pdf","Documents":""},{"Case ID":"ST-374","Case Cluster ":"Vetco International Ltd.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"11\/21","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$4,200,000.00","Criminal Fine\/Penalty (US$) ":"$4,200,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"$0","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the June 2011 United States Report to the OECD, \u0022On January 5, 2007, three wholly-owned subsidiaries of Vetco International, Ltd., a global supplier of products and services for oil drilling production, were charged in the Southern District of Texas with conspiring to violate the FCPA and violating the anti-bribery provisions of the FCPA in connection with the corrupt payment of approximately $2.1 million to Nigerian government officials. According to court documents, beginning in February 2001, Vetco International, and its predecessor and several related companies, began providing engineering and procurement services, as well as subsea construction equipment, for Nigeria\u0027s first deepwater oil drilling operation, known as the Bonga Project. From at least September 2002 to at least April 2005, in connection with their business in Nigeria, these subsidiaries made at least 378 corrupt payments through a major international freight forwarding and customs clearance company to employees of the Nigerian Customs Service, and these payments were intended to assist Vetco in avoiding paying customs duties. On the same date, Aibel Group, Ltd. (Aibel Group), another wholly owned subsidiary of Vetco International, entered into a deferred prosecution agreement regarding the same bribery scheme. Subsequently, on November 12, 2008, Aibel Group, a United Kingdom corporation, was charged in a two-count superseding information charging the company with a conspiracy to violate the FCPA and a substantive violation of the FCPA.\u0022 (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Vetco International Ltd. Case Summary at 110-111.) ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Vetco International Ltd. Case Summary at 110-111, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Aibel Group Ltd., Case No. 4:07-cr-00005 (S.D. Tex.), Deferred Prosecution Agreement filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/aibelgrp\/02-06-07aibelgrp-agree.pdf; Order of Dismissal of Information and Deferred Prosecution Agreement filed November 21, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/aibelgrp\/11-21-08aibelgrp-dismiss.pdf; Superseding Information filed November 12, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/aibelgrp\/11-12-08aibelgrp-info.pdf; Plea Agreement filed November 12, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/aibelgrp\/11-21-08aibelgrp-plea.pdf; Judgment filed December 10, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/aibelgrp\/12-10-08aibelgrp-judgment.pdf","Documents":""},{"Case ID":"ST-375","Case Cluster ":"Vetco International Ltd.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"02\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$8,000,000.00","Criminal Fine\/Penalty (US$) ":"$8,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"$0","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the June 2011 United States Report to the OECD, \u0022On January 5, 2007, three wholly-owned subsidiaries of Vetco International, Ltd., a global supplier of products and services for oil drilling production, were charged in the Southern District of Texas with conspiring to violate the FCPA and violating the anti-bribery provisions of the FCPA in connection with the corrupt payment of approximately $2.1 million to Nigerian government officials. According to court documents, beginning in February 2001, Vetco International, and its predecessor and several related companies, began providing engineering and procurement services, as well as subsea construction equipment, for Nigeria\u0027s first deepwater oil drilling operation, known as the Bonga Project. From at least September 2002 to at least April 2005, in connection with their business in Nigeria, these subsidiaries made at least 378 corrupt payments through a major international freight forwarding and customs clearance company to employees of the Nigerian Customs Service, and these payments were intended to assist Vetco in avoiding paying customs duties.  On the same date, Aibel Group, Ltd. (Aibel Group), another wholly owned subsidiary of Vetco International, entered into a deferred prosecution agreement regarding the same bribery scheme. Subsequently, on November 12, 2008, Aibel Group, a United Kingdom corporation, was charged in a two-count superseding information charging the company with a conspiracy to violate the FCPA and a substantive violation of the FCPA.\u0022 (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Vetco International Ltd. Case Summary at 110-111.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Vetco International Ltd. Case Summary at 110-111, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Vetco Gray Controls, Inc., Vetco Gray UK Limited and Vetco Gray Controls Limited, Case No. 4:07-cr-00004 (S.D. Tex.), Information filed January 5, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-info.pdf; Plea Agreement (as to Vetco Gray Controls Inc.), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-inc-plea.pdf; Plea Agreement (as to Vetco Gray Controls Limited), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-plea.pdf; Plea Agreement (as to Vetco Gray UK Ltd.); Judgment (as to Vetco Gray Controls, Inc.), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-judgment.pdf; Judgment (as to Vetco Gray UK Limited) filed February 17, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-17-07vetcogray-uk-judgement.pdf; Judgment (as to Vetco Gray Controls Limited), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-limited-judgment.pdf","Documents":""},{"Case ID":"ST-376","Case Cluster ":"Vetco International Ltd.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"02\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$6,000,000.00","Criminal Fine\/Penalty (US$) ":"$6,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"$0","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the June 2011 United States Report to the OECD, \u0022On January 5, 2007, three wholly-owned subsidiaries of Vetco International, Ltd., a global supplier of products and services for oil drilling production, were charged in the Southern District of Texas with conspiring to violate the FCPA and violating the anti-bribery provisions of the FCPA in connection with the corrupt payment of approximately $2.1 million to Nigerian government officials. According to court documents, beginning in February 2001, Vetco International, and its predecessor and several related companies, began providing engineering and procurement services, as well as subsea construction equipment, for Nigeria\u0027s first deepwater oil drilling operation, known as the Bonga Project. From at least September 2002 to at least April 2005, in connection with their business in Nigeria, these subsidiaries made at least 378 corrupt payments through a major international freight forwarding and customs clearance company to employees of the Nigerian Customs Service, and these payments were intended to assist Vetco in avoiding paying customs duties.  On the same date, Aibel Group, Ltd. (Aibel Group), another wholly owned subsidiary of Vetco International, entered into a deferred prosecution agreement regarding the same bribery scheme. Subsequently, on November 12, 2008, Aibel Group, a United Kingdom corporation, was charged in a two-count superseding information charging the company with a conspiracy to violate the FCPA and a substantive violation of the FCPA.\u0022 (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Vetco International Ltd. Case Summary at 110-111.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Vetco International Ltd. Case Summary at 110-111, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Vetco Gray Controls, Inc., Vetco Gray UK Limited and Vetco Gray Controls Limited, Case No. 4:07-cr-00004 (S.D. Tex.), Information filed January 5, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-info.pdf; Plea Agreement (as to Vetco Gray Controls Inc.), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-inc-plea.pdf; Plea Agreement (as to Vetco Gray Controls Limited), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-plea.pdf; Plea Agreement (as to Vetco Gray UK Ltd.); Judgment (as to Vetco Gray Controls, Inc.), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-judgment.pdf; Judgment (as to Vetco Gray UK Limited) filed February 17, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-17-07vetcogray-uk-judgement.pdf; Judgment (as to Vetco Gray Controls Limited), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-limited-judgment.pdf","Documents":""},{"Case ID":"ST-377","Case Cluster ":"Vetco International Ltd.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"02\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$12,000,000.00","Criminal Fine\/Penalty (US$) ":"$12,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"$0","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the June 2011 United States Report to the OECD, \u0022On January 5, 2007, three wholly-owned subsidiaries of Vetco International, Ltd., a global supplier of products and services for oil drilling production, were charged in the Southern District of Texas with conspiring to violate the FCPA and violating the anti-bribery provisions of the FCPA in connection with the corrupt payment of approximately $2.1 million to Nigerian government officials. According to court documents, beginning in February 2001, Vetco International, and its predecessor and several related companies, began providing engineering and procurement services, as well as subsea construction equipment, for Nigeria\u0027s first deepwater oil drilling operation, known as the Bonga Project. From at least September 2002 to at least April 2005, in connection with their business in Nigeria, these subsidiaries made at least 378 corrupt payments through a major international freight forwarding and customs clearance company to employees of the Nigerian Customs Service, and these payments were intended to assist Vetco in avoiding paying customs duties.  On the same date, Aibel Group, Ltd. (Aibel Group), another wholly owned subsidiary of Vetco International, entered into a deferred prosecution agreement regarding the same bribery scheme. Subsequently, on November 12, 2008, Aibel Group, a United Kingdom corporation, was charged in a two-count superseding information charging the company with a conspiracy to violate the FCPA and a substantive violation of the FCPA.\u0022 (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Vetco International Ltd. Case Summary at 110-111.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Vetco International Ltd. Case Summary at 110-111, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Vetco Gray Controls, Inc., Vetco Gray UK Limited and Vetco Gray Controls Limited, Case No. 4:07-cr-00004 (S.D. Tex.), Information filed January 5, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-info.pdf; Plea Agreement (as to Vetco Gray Controls Inc.), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-inc-plea.pdf; Plea Agreement (as to Vetco Gray Controls Limited), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-plea.pdf; Plea Agreement (as to Vetco Gray UK Ltd.); Judgment (as to Vetco Gray Controls, Inc.), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-judgment.pdf; Judgment (as to Vetco Gray UK Limited) filed February 17, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-17-07vetcogray-uk-judgement.pdf; Judgment (as to Vetco Gray Controls Limited), filed February 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vetco-controls\/02-06-07vetcogray-limited-judgment.pdf","Documents":""},{"Case ID":"ST-378","Case Cluster ":"Vitol SA","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"New York County District Attorney\u0027s Office","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"11\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Restitution; Legal Costs","Total Monetary Sanctions (US$)":"$17,500,000.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$13,000,000","Criminal Legal \/ Procedural Costs (US$)":"$4,500,000 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$13,000,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Iraq via Development Fund for Iraq","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Grand Larceny","Offenses - Settled":"Grand Larceny","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the New York County District Attorney\u0027s Office Press Release, on November 20, 2007, \u0022Manhattan District Attorney Robert M. Morgenthau announced today the guilty plea of a Switzerland-based oil trading company for its involvement in a scheme to pay kickbacks to Iraq in connection with oil purchases made under the United Nations Oil-for-Food Programme. VITOL, S.A. (VITOL) pleaded guilty today in New York State Court to Grand Larceny in the First Degree in connection with the scheme.  According to the plea, VITOL paid $13 million in kickbacks to Iraqi officials in connection with oil purchases but allowed false representations to be made to the United Nations that no kickbacks were paid.  Relying on those false representations, United Nations officials approved the contracts and authorized millions of dollars in payments for the benefit of Iraq from the Oil-for-Food Programme.  Instead of halting these transactions, United Nations officials were duped into allowing the Oil-for-Food Programme to continue unchanged. As a result of its guilty plea, VITOL will pay restitution of $13 million to the Iraqi people through the Development Fund for Iraq and a payment of $4.5 million in lieu of fines, forfeiture and to cover the cost of prosecution.  The plea by VITOL is part of a continuing investigation by the Manhattan District Attorney\u0027s Office into the Oil-for-Food Programme.  This investigation began as a result of this office\u0027s cooperation with the Independent Inquiry Committee into the United Nations Oil-for-Food Programme, headed by Paul Volcker. Mr. Morgenthau said, \u0027The Oil for Food Programme was established by the United Nations with the noble goal of providing for the humanitarian needs of the Iraqi people.  One outcome of this investigation, and last week\u0027s joint investigation involving Chevron, is to insure that illegal funds that were paid to Saddam Hussein\u0027s government are redirected to benefit the Iraqi people.\u0027  Through its representative, duly appointed by Vitol\u0027s Board of Directors, VITOL admitted in court today that while the United Nations Oil-for-Food Programme was in effect, VITOL purchased Iraqi crude oil first as a direct purchaser and later from third-parties.  In June 2001, after an OPEC meeting, an agent of VITOL was told by Iraqi officials that surcharges had to be paid in order for Iraqi crude oil to be lifted.  Over the next year, VITOL paid or caused surcharges to be paid on certain oil purchases in two ways.   In direct purchases, VITOL had an associated entity called Vitol Bahrain send the surcharge monies to accounts controlled by the Iraqi regime.  In indirect purchases, VITOL financed the purchase of oil through third-parties who then paid the surcharge to the Iraqi regime.  VITOL did not inform the UN about the surcharge payments.  During the period from June 2001 through September 2002, approximately $13,000,000 in surcharge monies were paid directly to the Iraqi regime in connection with crude oil purchased directly or indirectly by VITOL.  The investigation into the United Nations? Oil-for-Food Programme has resulted into two other actions against oil companies.  Last week, there was a settlement with the  Chevron Oil Company in which Chevron paid $27 million, of which $20 million was paid as restitution for the benefit of the Iraqi people.  In October 2005, Midway Trading pleaded guilty for paying kickbacks to Iraq for oil purchases.\u0022  Mr. Morgenthau thanked the Independent Inquiry Committee into the United Nations Oil-for-Food Programme and Paul Volcker who heads the Committee. (Source: New York County District Attorney\u0027s Office, News Release on Vitol SA Plea, November 20, 2007.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Vitol S.A. Case Summary at 90-91, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  New York County District Attorney\u0027s Office, News Release on Vitol SA Plea, November 20, 2007, accessed at http:\/\/manhattanda.client.tagonline.com\/whatsnew\/press\/2007-11-20.shtml","Documents":""},{"Case ID":"ST-379","Case Cluster ":"Watts Water Technologies, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"10\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profit, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$3,776,606.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$2,755,815","Civil Prejudgment Interest (US$) ":"$820,791","Civil Fine \/ Penalty (US$)":"$200,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Failure to Maintain Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the finding of facts in US Securities and Exchange Commission\u0027s Cease and Desist Order, which the company and Chang neither admitted or denied as part of their settlement, the violations of FCPA books and records and internal controls provisions took place at Watts Valve Changsha Co., Ltd. (\u0022CWV\u0022) a wholly owned Chinese subsidiary established in 2005 by Watts to purchase the assets and businesses of Changsha Valve Works (\u0022Changsha Valve\u0022). CWV acquired Changsha Valve in April 2006 and Watts sold CWV in January 2010.  CWV produced and supplied large valve products for infrastructure projects in China which are mostly developed, constructed and owned by state-owned entities. These entities routinely retain state-owned design institutes to assist in the design and construction of these projects.  CWV employees made improper payments to employees at certain design institutes, thereby generating profits for Watts of more than $2.7 million. Chang is a former interim general manager of CWV and vice president of sales for Watts\u0027 management subsidiary in China, and approved many of hte payments to the design institutes which were improperly recorded on Watts\u0027 books as commission.  Specifically, the CWV Sales policy provided that all sales-related expenses, including travel, meals and entertainment and payment of \u0022consultant fees\u0022 to design institutes would be borne by the CWV sales employees\u0027 commissions. The typical commission was 7 to 7-1\/2 percent of the contract price with the Sales Policy expressly providing that sales personnel could use their commissions to make payments to design institutes of up to 3% of the total contract amount.   (Source: In the Matter of Watts Water Technologies, Inc. and Lessen Chang (October 13, 2011), Administrative Proceeding File No. 3-14585, Order Instituting Cease-and-Desist Proceedings Pursuant to Section 21C of the Securities Exchange Act of 1934, Making Findings, and Imposing Cease-and-Desist Orders and Civil Penalties.)","Sources ":"In the Matter of Watts Water Technologies, Inc. and Lessen Chang (October 13, 2011), Administrative Proceeding File No. 3-14585, Order Instituting Cease-and-Desist Proceedings Pursuant to Section 21C of the Securities Exchange Act of 1934, Making Findings, and Imposing Cease-and-Desist Orders and Civil Penalties, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2011\/34-65555.pdf.","Documents":""},{"Case ID":"ST-380","Case Cluster ":"Watts Water Technologies, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"10\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$25,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"$25,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Failure to Maintain Books and Records ","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the finding of facts in US Securities and Exchange Commission\u0027s Cease and Desist Order, which the company and Chang neither admitted or denied as part of their settlement, the violations of FCPA books and records and internal controls provisions took place at Watts Valve Changsha Co., Ltd. (\u0022CWV\u0022) a wholly owned Chinese subsidiary established in 2005 by Watts to purchase the assets and businesses of Changsha Valve Works (\u0022Changsha Valve\u0022). CWV acquired Changsha Valve in April 2006 and Watts sold CWV in January 2010.  CWV produced and supplied large valve products for infrastructure projects in China which are mostly developed, constructed and owned by state-owned entities. These entities routinely retain state-owned design institutes to assist in the design and construction of these projects.  CWV employees made improper payments to employees at certain design institutes, thereby generating profits for Watts of more than $2.7 million. Chang is a former interim general manager of CWV and vice president of sales for Watts\u0027 management subsidiary in China, and approved many of hte payments to the design institutes which were improperly recorded on Watts\u0027 books as commission.  Specifically, the CWV Sales policy provided that all sales-related expenses, including travel, meals and entertainment and payment of \u0022consultant fees\u0022 to design institutes would be borne by the CWV sales employees\u0027 commissions. The typical commission was 7 to 7-1\/2 percent of the contract price with the Sales Policy expressly providing that sales personnel could use their commissions to make payments to design institutes of up to 3% of the total contract amount.   (Source: In the Matter of Watts Water Technologies, Inc. and Lessen Chang (October 13, 2011), Administrative Proceeding File No. 3-14585, Order Instituting Cease-and-Desist Proceedings Pursuant to Section 21C of the Securities Exchange Act of 1934, Making Findings, and Imposing Cease-and-Desist Orders and Civil Penalties.)","Sources ":"In the Matter of Watts Water Technologies, Inc. and Lessen Chang (October 13, 2011), Administrative Proceeding File No. 3-14585, Order Instituting Cease-and-Desist Proceedings Pursuant to Section 21C of the Securities Exchange Act of 1934, Making Findings, and Imposing Cease-and-Desist Orders and Civil Penalties, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2011\/34-65555.pdf.","Documents":""},{"Case ID":"ST-382","Case Cluster ":"Westinghouse Air Brake Technologies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"India","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"02\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$300,000.00","Criminal Fine\/Penalty (US$) ":"$300,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Westinghouse Air Brake Technologies Corporation, at 67-68, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: time period of misconduct in India is 2001-2005; Westinghouse\u0027s Indian subsidiary Pioneer Friction Limited (Pioneer) made over $137,400 in improper cash payments to officials of the Indian Railways Board, a government agency which is part of India\u0027s Ministry of Railroads. The payments were made in order to: (a) assist Pioneer in obtaining and retaining business with the IRB; (b) schedule pre-shipping product inspections; (c) obtain issuance of product delivery certificates; and (d) curb what Pioneer considered to be excessive tax audits. ","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Westinghouse Air Brake Technologies Corporation, at 67-68, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf;  US Department of Justice Press Release, \u0022Westinghouse Air Brake Technologies Corporation Agrees to Pay $300,000 Penalty to Resolve Foreign Bribery Violations in India,\u0022 February 14, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/February\/08_crm_116.html (accessed on September 15, 2011).","Documents":""},{"Case ID":"ST-383","Case Cluster ":"Westinghouse Air Brake Technologies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"India","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"02\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$288,351.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$259,000","Civil Prejudgment Interest (US$) ":"$29,351","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US Securities and Exchange Commission Litigation Release, \u0022On February 14, 2008, the Securities and Exchange Commission filed two settled enforcement proceedings charging Westinghouse Air Brake Technologies Corporation (\u0022Wabtec\u0022), which is headquartered in western Pennsylvania, with violations of the Foreign Corrupt Practices Act (\u0022FCPA\u0022) in connection with certain improper payments that Wabtec\u0027s Indian subsidiary, Pioneer Friction Limited (\u0022Pioneer\u0022), made to employees of the government of India in order to obtain or retain business from the Indian national railway system. Wabtec manufactures, among other things, brake subsystems and related products for locomotives, freight cars and passenger vehicles. The Commission filed a civil action in the United States District Court for the Eastern District of Pennsylvania charging Wabtec with violating the anti-bribery, books-and-records and internal controls provisions of the FCPA and seeking a civil penalty. The Commission also issued an administrative order finding that Wabtec violated the same provisions of the FCPA. In the administrative proceeding, the Commission ordered Wabtec to cease and desist from such violations, and to disgorge $259,000, together with $29,351 in prejudgment interest. The Commission also required Wabtec to retain an independent consultant to review and make recommendations concerning the company\u0027s FCPA compliance policies and procedures. In the federal civil action, Wabtec agreed to the entry of a final judgment requiring it to pay a civil penalty in the amount of $87,000.Pioneer, incorporated and headquartered in India, manufactures low and high friction brake blocks for rail operations. Pioneer\u0027s financial results are reported on a consolidated basis as part of Wabtec\u0027s consolidated financial statements. In both its administrative order and federal court complaint, the Commission charged that, from at least 2001 through 2005, Pioneer made over $137,400 in improper cash payments to employees of the Indian government in order to have its competitive bids for government business granted or considered. As a result of being awarded contracts in 2005, Pioneer realized profits of $259,000. In connection with the improper payments, Wabtec failed to keep accurate books and records, and failed to devise and maintain effective internal accounting controls.\u0022 (Source: US Securities and Exchange Commission Litigation Release No. 20457 \/ February 14, 2008, SEC v. Westinghouse Air Brake Technologies Corporation, Civil Action No. 08-CV-706 (E.D.Pa.), \u0022SEC Sanctions Westinghouse Air Brake Technologies Corporation for Improper Payments to Indian Government Employees.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Westinghouse Air Brake Technologies Corporation Case Summary at 85-86, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20457 \/ February 14, 2008, SEC v. Westinghouse Air Brake Technologies Corporation, Civil Action No. 08-CV-706 (E.D.Pa.), \u0022SEC Sanctions Westinghouse Air Brake Technologies Corporation for Improper Payments to Indian Government Employees,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20457.htm; Complaint filed February 14, 2008, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20457.pdf","Documents":""},{"Case ID":"ST-384","Case Cluster ":"Westinghouse Air Brake Technologies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"India","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"2\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$87,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"$87,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US Securities and Exchange Commission Litigation Release, \u0022On February 14, 2008, the Securities and Exchange Commission filed two settled enforcement proceedings charging Westinghouse Air Brake Technologies Corporation (\u0022Wabtec\u0022), which is headquartered in western Pennsylvania, with violations of the Foreign Corrupt Practices Act (\u0022FCPA\u0022) in connection with certain improper payments that Wabtec\u0027s Indian subsidiary, Pioneer Friction Limited (\u0022Pioneer\u0022), made to employees of the government of India in order to obtain or retain business from the Indian national railway system. Wabtec manufactures, among other things, brake subsystems and related products for locomotives, freight cars and passenger vehicles. The Commission filed a civil action in the United States District Court for the Eastern District of Pennsylvania charging Wabtec with violating the anti-bribery, books-and-records and internal controls provisions of the FCPA and seeking a civil penalty. The Commission also issued an administrative order finding that Wabtec violated the same provisions of the FCPA. In the administrative proceeding, the Commission ordered Wabtec to cease and desist from such violations, and to disgorge $259,000, together with $29,351 in prejudgment interest. The Commission also required Wabtec to retain an independent consultant to review and make recommendations concerning the company\u0027s FCPA compliance policies and procedures. In the federal civil action, Wabtec agreed to the entry of a final judgment requiring it to pay a civil penalty in the amount of $87,000.Pioneer, incorporated and headquartered in India, manufactures low and high friction brake blocks for rail operations. Pioneer\u0027s financial results are reported on a consolidated basis as part of Wabtec\u0027s consolidated financial statements. In both its administrative order and federal court complaint, the Commission charged that, from at least 2001 through 2005, Pioneer made over $137,400 in improper cash payments to employees of the Indian government in order to have its competitive bids for government business granted or considered. As a result of being awarded contracts in 2005, Pioneer realized profits of $259,000. In connection with the improper payments, Wabtec failed to keep accurate books and records, and failed to devise and maintain effective internal accounting controls.\u0022 (Source: US Securities and Exchange Commission Litigation Release No. 20457 \/ February 14, 2008, SEC v. Westinghouse Air Brake Technologies Corporation, Civil Action No. 08-CV-706 (E.D.Pa.), \u0022SEC Sanctions Westinghouse Air Brake Technologies Corporation for Improper Payments to Indian Government Employees.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Westinghouse Air Brake Technologies Corporation Case Summary at 85-86, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20457 \/ February 14, 2008, SEC v. Westinghouse Air Brake Technologies Corporation, Civil Action No. 08-CV-706 (E.D.Pa.), \u0022SEC Sanctions Westinghouse Air Brake Technologies Corporation for Improper Payments to Indian Government Employees,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20457.htm; Complaint filed February 14, 2008, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20457.pdf; and final judgment in Eastern District of Pennsylvania case, accessed at http:\/\/fcpa.shearman.com\/files\/89b\/89b0f8ade28e8c6cb474081e1fdb3499.pdf?i=abde6828feb586da522341a4724e2f79.","Documents":""},{"Case ID":"ST-385","Case Cluster ":"Willbros Group Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Bolivia","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"05\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$35,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$35,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"False Accounting Violations, Aiding and Abetting Willbros\u0027 Bribery of Foreign Officials, Aiding and Abetting Willbros\u0027 Internal Controls Violations, Aiding and Abetting Willbros\u0027 Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States Securities and Exchange Commission Litigation Release, on May 14, 2008, the Commission \u0022filed a settled civil action against Willbros Group, Inc. and several former employees alleging that they violated, among other things, the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA) and the antifraud provisions of the federal securities laws. The complaint also names Jason Steph, a former supervisory employee in Nigeria, Gerald Jansen, a former administrative supervisor in Nigeria, Lloyd Biggers, a former employee in Nigeria and Carlos Galvez, a former accounting employee in Bolivia. According to the complaint, the company also violated the reporting, books and records and internal controls provisions of the Securities Exchange Act. Willbros Group, Steph, Jansen, Biggers and Galvez have agreed to settle the charges against them, without admitting or denying the Commission\u0027s allegations. The Commission alleges in its complaint that Willbros Group, through the actions of others acting on its behalf, engaged in multiple schemes to bribe foreign officials. First, the complaint alleges that, beginning by at least 2003, Willbros Group, through the conduct of a former executive officer, Steph and others, engaged in a scheme to pay over $6 million in bribes to Nigerian government officials and to employees of an operator of a joint venture majority-owned by the Nigerian government in order to obtain a significant contract. A similar scheme was used to help obtain a second significant contract. Together, these contracts resulted in net profits of approximately $8,900,000. In 2005, according to the complaint, Steph assisted in the payment of $850,000 to satisfy a portion of these earlier commitments. The complaint further alleges that Willbros Group, through acts by a former executive officer, Steph, Jansen, Biggers and others, employed a long-running scheme using fabricated invoices to procure cash from the company\u0027s administrative headquarters in Houston to, among other things, bribe Nigerian tax and court officials. This fraudulent cash abuse was also used to fund in part the bribes paid in 2005.  Second, Willbros Group, through the conduct of the same former executive officer and others schemed to pay a $300,000 bribe to officials of an oil and gas company owned by the Ecuador government in order to obtain a $3 million contract. Finally, Willbros Group, through the actions of the same former executive officer, an outside consultant and Galvez implemented a fraudulent tax avoidance scheme in Bolivia. This fraudulent scheme resulted in material misstatements in Willbros Group\u0027s financial statements.\u0022  (Source:  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20571.htm; Complaint in SEC v. Willbros et al. [Willbros Group, Inc, Jason Steph, Gerald Jansen, Lloyd Biggers, Carlos Galvez], Case No. 4:08-cv-01494 (S.D. Tex.) filed May 14, 2008, accessed at www.sec.gov\/litigation\/complaints\/2008\/comp20571.pdf","Documents":""},{"Case ID":"ST-386","Case Cluster ":"Willbros Group Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"05\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$30,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$30,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"False Accounting Violations, Aiding and Abetting Willbros\u0027 Bribery of Foreign Officials, Aiding and Abetting Willbros\u0027 Internal Controls Violations, Aiding and Abetting Willbros\u0027 Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States Securities and Exchange Commission Litigation Release, on May 14, 2008, the Commission \u0022filed a settled civil action against Willbros Group, Inc. and several former employees alleging that they violated, among other things, the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA) and the antifraud provisions of the federal securities laws. The complaint also names Jason Steph, a former supervisory employee in Nigeria, Gerald Jansen, a former administrative supervisor in Nigeria, Lloyd Biggers, a former employee in Nigeria and Carlos Galvez, a former accounting employee in Bolivia. According to the complaint, the company also violated the reporting, books and records and internal controls provisions of the Securities Exchange Act. Willbros Group, Steph, Jansen, Biggers and Galvez have agreed to settle the charges against them, without admitting or denying the Commission\u0027s allegations. The Commission alleges in its complaint that Willbros Group, through the actions of others acting on its behalf, engaged in multiple schemes to bribe foreign officials. First, the complaint alleges that, beginning by at least 2003, Willbros Group, through the conduct of a former executive officer, Steph and others, engaged in a scheme to pay over $6 million in bribes to Nigerian government officials and to employees of an operator of a joint venture majority-owned by the Nigerian government in order to obtain a significant contract. A similar scheme was used to help obtain a second significant contract. Together, these contracts resulted in net profits of approximately $8,900,000. In 2005, according to the complaint, Steph assisted in the payment of $850,000 to satisfy a portion of these earlier commitments. The complaint further alleges that Willbros Group, through acts by a former executive officer, Steph, Jansen, Biggers and others, employed a long-running scheme using fabricated invoices to procure cash from the company\u0027s administrative headquarters in Houston to, among other things, bribe Nigerian tax and court officials. This fraudulent cash abuse was also used to fund in part the bribes paid in 2005.  Second, Willbros Group, through the conduct of the same former executive officer and others schemed to pay a $300,000 bribe to officials of an oil and gas company owned by the Ecuador government in order to obtain a $3 million contract. Finally, Willbros Group, through the actions of the same former executive officer, an outside consultant and Galvez implemented a fraudulent tax avoidance scheme in Bolivia. This fraudulent scheme resulted in material misstatements in Willbros Group\u0027s financial statements.\u0022  (Source:  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20571.htm; Complaint in SEC v. Willbros et al. [Willbros Group, Inc, Jason Steph, Gerald Jansen, Lloyd Biggers, Carlos Galvez], Case No. 4:08-cv-01494 (S.D. Tex.) filed May 14, 2008, accessed at www.sec.gov\/litigation\/complaints\/2008\/comp20571.pdf","Documents":""},{"Case ID":"ST-387","Case Cluster ":"Willbros Group Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"11\/05","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,000.00","Criminal Fine\/Penalty (US$) ":"$2,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"","OECD Anti-Bribery Convention Articles Implicated":"Art. 1  ","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering, International Money Laundering","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States Report to the OECD, \u0022On May 14, 2008, Willbros Group Inc. (WGI), a publicly-traded company that provides construction, engineering and other services in the oil and gas industry, and Willbros International Inc. (WII), the wholly owned subsidiary through which it conducts international operations, were charged in a six-count criminal information with one count of conspiring to make bribe payments to Nigerian and Ecuadoran officials, two counts of violating the anti-bribery provisions of the FCPA, and three counts of violating the books and records provisions of the FCPA. These charges stemmed from a bribery scheme involving senior officials of WII, which involved the corrupt payment of more than $6.3 million to Nigerian officials in connection with a gas pipeline construction project and $300,000 to Ecuadorian officials in connection with a gas pipeline rehabilitation project.From late 2003 through March 2005, WII employees agreed to make corrupt payments totaling more than $6.3 million to officials of the Nigerian National Petroleum Corporation (NNPC), the state-owned oil company in Nigeria; NNPC\u0027s subsidiary, the National Petroleum Investment Management Services (NAPIMS); a senior official in the executive branch of the Nigerian federal government; officials of a multinational oil company; and a Nigerian political party. These bribes were paid to Nigerian government officials to assist in obtaining and retaining a $387 million contract for work on a major engineering, procurement and construction gas pipeline project known as the Eastern Gas Gathering System (EGGS). In addition, in 2004, various WII employees paid at least $300,000 to officials of the Ecuadorian state-owned oil company in order to obtain a gas pipeline rehabilitation contract. [ ] Jason Edward Steph, WII\u0027s General Manager-Onshore in Nigeria, was indicted July 19, 2007. Steph\u0027s charges stemmed from his role in causing a series of corrupt payments totaling more than $6 million to be made to various Nigerian officials in order to assist WII in obtaining and retaining the EGGS deal. According to court documents, in early 2005, as a senior WII executive, Steph authorized and arranged for the payment of $1.8 million in cash to the Nigerian officials to further the conspiracy.\u0022  On November 5, 2007, Steph pleaded guilty to participating in a conspiracy to violate the FCPA. (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81.) ","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Jason Edward Steph: Docket Number: 07-CR-307 (S.D. Tex.), Indictment filed July 19, 2007, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/stephj\/07-19-07steph-indict.pdf;  Plea Agreement filed November 5, 2007; Judgment filed February 1, 2010, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/stephj\/02-01-10steph-judgment.pdf","Documents":""},{"Case ID":"ST-388","Case Cluster ":"Willbros Group Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"05\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, False Accounting Violations, Aiding and Abetting Willbros\u0027 Bribery of Foreign Officials, Aiding and Abetting Willbros\u0027 Internal Controls Violations, Aiding and Abetting Willbros\u0027 Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States Securities and Exchange Commission Litigation Release, on May 14, 2008, the Commission \u0022filed a settled civil action against Willbros Group, Inc. and several former employees alleging that they violated, among other things, the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA) and the antifraud provisions of the federal securities laws. The complaint also names Jason Steph, a former supervisory employee in Nigeria, Gerald Jansen, a former administrative supervisor in Nigeria, Lloyd Biggers, a former employee in Nigeria and Carlos Galvez, a former accounting employee in Bolivia. According to the complaint, the company also violated the reporting, books and records and internal controls provisions of the Securities Exchange Act. Willbros Group, Steph, Jansen, Biggers and Galvez have agreed to settle the charges against them, without admitting or denying the Commission\u0027s allegations. The Commission alleges in its complaint that Willbros Group, through the actions of others acting on its behalf, engaged in multiple schemes to bribe foreign officials. First, the complaint alleges that, beginning by at least 2003, Willbros Group, through the conduct of a former executive officer, Steph and others, engaged in a scheme to pay over $6 million in bribes to Nigerian government officials and to employees of an operator of a joint venture majority-owned by the Nigerian government in order to obtain a significant contract. A similar scheme was used to help obtain a second significant contract. Together, these contracts resulted in net profits of approximately $8,900,000. In 2005, according to the complaint, Steph assisted in the payment of $850,000 to satisfy a portion of these earlier commitments. The complaint further alleges that Willbros Group, through acts by a former executive officer, Steph, Jansen, Biggers and others, employed a long-running scheme using fabricated invoices to procure cash from the company\u0027s administrative headquarters in Houston to, among other things, bribe Nigerian tax and court officials. This fraudulent cash abuse was also used to fund in part the bribes paid in 2005.  Second, Willbros Group, through the conduct of the same former executive officer and others schemed to pay a $300,000 bribe to officials of an oil and gas company owned by the Ecuador government in order to obtain a $3 million contract. Finally, Willbros Group, through the actions of the same former executive officer, an outside consultant and Galvez implemented a fraudulent tax avoidance scheme in Bolivia. This fraudulent scheme resulted in material misstatements in Willbros Group\u0027s financial statements.\u0022  (Source:  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees.) According to the Agreed Judgment in Steph\u0027s case, there was no monetary penalty ordered. (Source: US v. Willbros Group Inc. Case No. 4:08-cv-1494 (S.D. Tex.), Agreed Judgment as to Jason Stephs dated May 27, 2008, accessed at http:\/\/fcpa.shearman.com\/files\/7d4\/7d4bde190ba89e2405d4d9a1a1d20f03.pdf?i=11ae1adbca1d3c212c85c0df61982ced.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20571.htm; Complaint in SEC v. Willbros et al. [Willbros Group, Inc, Jason Steph, Gerald Jansen, Lloyd Biggers, Carlos Galvez], Case No. 4:08-cv-01494 (S.D. Tex.) filed May 14, 2008, accessed at www.sec.gov\/litigation\/complaints\/2008\/comp20571.pdf; Agreed Judgment as to Jason Stephs dated May 27, 2008","Documents":""},{"Case ID":"ST-389","Case Cluster ":"Willbros Group Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Ecuador","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"09\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$17,500.00","Criminal Fine\/Penalty (US$) ":"$17,500","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States Report to the OECD, \u0022On May 14, 2008, Willbros Group Inc. (WGI), a publicly-traded company that provides construction, engineering and other services in the oil and gas industry, and Willbros International Inc. (WII), the wholly owned subsidiary through which it conducts international operations, were charged in a six-count criminal information with one count of conspiring to make bribe payments to Nigerian and Ecuadoran officials, two counts of violating the anti-bribery provisions of the FCPA, and three counts of violating the books and records provisions of the FCPA. These charges stemmed from a bribery scheme involving senior officials of WII, which involved the corrupt payment of more than $6.3 million to Nigerian officials in connection with a gas pipeline construction project and $300,000 to Ecuadorian officials in connection with a gas pipeline rehabilitation project.From late 2003 through March 2005, WII employees agreed to make corrupt payments totaling more than $6.3 million to officials of the Nigerian National Petroleum Corporation (NNPC), the state-owned oil company in Nigeria; NNPC\u0027s subsidiary, the National Petroleum Investment Management Services (NAPIMS); a senior official in the executive branch of the Nigerian federal government; officials of a multinational oil company; and a Nigerian political party. These bribes were paid to Nigerian government officials to assist in obtaining and retaining a $387 million contract for work on a major engineering, procurement and construction gas pipeline project known as the Eastern Gas Gathering System (EGGS). In addition, in 2004, various WII employees paid at least $300,000 to officials of the Ecuadorian state-owned oil company in order to obtain a gas pipeline rehabilitation contract. [ ]  Jim Bob Brown, WII\u0027s Managing Director (Nigeria and Ecuador), was charged September 11, 2006. Brown was charged in connection with conspiring with other WII executives to pay approximately $1.5 million in cash to Nigerian officials and $300,000 to Ecuadorian officials. According to court documents, from 1996 through 2005, Brown also conspired with other WII executives to approve a scheme in which WII\u0027s Nigerian operations submitted fictitious invoices for payment by WGI. These funds were used, in part, to make corrupt payments to officials of the Nigerian revenue agencies and courts in order to lower taxes that would have otherwise been assessed, and to influence favorably litigation in Nigeria affecting the business of WGI.\u0022  In September 2006, Brown pleaded guilty and was sentenced in January 2010. (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81.) ","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Jim Bob Brown, Case No. 4:06-cr-316 (S.D. Tex.), Indictment filed September 11, 2006, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/brownj\/09-11-06brown-info.pdf; Plea Agreement filed September 14, 2006, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/brownj\/09-14-09brown-plea-agree.pdf; Judgment filed January 29, 2010, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/brownj\/01-29-10brown-judgment.pdf","Documents":""},{"Case ID":"ST-390","Case Cluster ":"Willbros Group Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Ecuador, Nigeria","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"09\/14","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Aiding and Abetting Willbros\u0027 Bribery of Foreign Officials, Aiding and Abetting Willbros\u0027 Internal Controls Violations, Aiding and Abetting Willbros\u0027 Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, on September 14, 2006, the Commission \u0022filed a civil action against Jim Bob \u0022J.B.\u0022 Brown, a former employee of a subsidiary of Willbros Group, Inc. [  ] The Commission alleges in its complaint that Brown, a former supervisory employee in Willbros\u0027s Nigerian and Latin American operations, participated in three separate schemes to bribe foreign officials. First, the complaint alleges that, in February and March 2005, Brown procured $1 million on behalf of a Willbros affiliate and delivered that money as partial payment of previously-made commitments to Nigerian government officials and to employees of the operator of a joint venture majority owned by an arm of the Nigerian government. He also assisted, according to the complaint, in the payment of an additional $550,000 that was also used to satisfy the earlier commitments. Second, Brown, in return for the granting to Willbros of a $3 million contract, knowingly assisted a scheme to pay a $300,000 bribe to officials of an oil and gas company owned by the government of Ecuador and its subsidiary. Finally, Brown knowingly assisted a long-running scheme in which employees of Willbros affiliates used fabricated invoices to procure cash from the company\u0027s administrative headquarters in Houston that was used to, among other things, bribe Nigerian tax and court officials.\u0022 (Source:  US Securities and Exchange Commission, Litigation Release No. 19832 \/ September 14, 2006, SEC v. Jim Bob Brown, Civil Action No. 06-CV-2919, U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Charges Former Employee of A Willbros Group, Inc. Subsidiary With FCPA Violations.\u0022)  According  to the Final Judgment against Brown, there was no monetary penalty assessed as part of his civil case.  (Source: US v. Jim Bob Brown, Case No. 4:06-cv-2919 (S.D. Tex.), Final Judgment filed May 10, 2010.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 19832 \/ September 14, 2006, SEC v. Jim Bob Brown, Civil Action No. 06-CV-2919, U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Charges Former Employee of A Willbros Group, Inc. Subsidiary With FCPA Violations,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2006\/lr19832.htm; Complaint filed September 14, 2006, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2006\/comp19832.pdf; Final Judgment filed May 10, 2010, accessed at http:\/\/fcpa.shearman.com\/files\/898\/898e03234c3a08fb6e835438e886a801.pdf?i=7196cb3d3c4105606f49eaf41e4dab95","Documents":""},{"Case ID":"ST-391","Case Cluster ":"Willbros Group Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"05\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"False Accounting Violations, Aiding and Abetting Willbros\u0027 Bribery of Foreign Officials, Aiding and Abetting Willbros\u0027 Internal Controls Violations, Aiding and Abetting Willbros\u0027 Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States Securities and Exchange Commission Litigation Release, on May 14, 2008, the Commission \u0022filed a settled civil action against Willbros Group, Inc. and several former employees alleging that they violated, among other things, the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA) and the antifraud provisions of the federal securities laws. The complaint also names Jason Steph, a former supervisory employee in Nigeria, Gerald Jansen, a former administrative supervisor in Nigeria, Lloyd Biggers, a former employee in Nigeria and Carlos Galvez, a former accounting employee in Bolivia. According to the complaint, the company also violated the reporting, books and records and internal controls provisions of the Securities Exchange Act. Willbros Group, Steph, Jansen, Biggers and Galvez have agreed to settle the charges against them, without admitting or denying the Commission\u0027s allegations. The Commission alleges in its complaint that Willbros Group, through the actions of others acting on its behalf, engaged in multiple schemes to bribe foreign officials. First, the complaint alleges that, beginning by at least 2003, Willbros Group, through the conduct of a former executive officer, Steph and others, engaged in a scheme to pay over $6 million in bribes to Nigerian government officials and to employees of an operator of a joint venture majority-owned by the Nigerian government in order to obtain a significant contract. A similar scheme was used to help obtain a second significant contract. Together, these contracts resulted in net profits of approximately $8,900,000. In 2005, according to the complaint, Steph assisted in the payment of $850,000 to satisfy a portion of these earlier commitments. The complaint further alleges that Willbros Group, through acts by a former executive officer, Steph, Jansen, Biggers and others, employed a long-running scheme using fabricated invoices to procure cash from the company\u0027s administrative headquarters in Houston to, among other things, bribe Nigerian tax and court officials. This fraudulent cash abuse was also used to fund in part the bribes paid in 2005.  Second, Willbros Group, through the conduct of the same former executive officer and others schemed to pay a $300,000 bribe to officials of an oil and gas company owned by the Ecuador government in order to obtain a $3 million contract. Finally, Willbros Group, through the actions of the same former executive officer, an outside consultant and Galvez implemented a fraudulent tax avoidance scheme in Bolivia. This fraudulent scheme resulted in material misstatements in Willbros Group\u0027s financial statements.\u0022  (Source:  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20571.htm; Complaint in SEC v. Willbros et al. [Willbros Group, Inc, Jason Steph, Gerald Jansen, Lloyd Biggers, Carlos Galvez], Case No. 4:08-cv-01494 (S.D. Tex.) filed May 14, 2008, accessed at www.sec.gov\/litigation\/complaints\/2008\/comp20571.pdf","Documents":""},{"Case ID":"ST-392","Case Cluster ":"Willbros Group Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Ecuador","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"05\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$22,000,000.00","Criminal Fine\/Penalty (US$) ":"$22,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States Report to the OECD, \u0022On May 14, 2008, Willbros Group Inc. (WGI), a publicly-traded company that provides construction, engineering and other services in the oil and gas industry, and Willbros International Inc. (WII), the wholly owned subsidiary through which it conducts international operations, were charged in a six-count criminal information with one count of conspiring to make bribe payments to Nigerian and Ecuadoran officials, two counts of violating the anti-bribery provisions of the FCPA, and three counts of violating the books and records provisions of the FCPA. These charges stemmed from a bribery scheme involving senior officials of WII, which involved the corrupt payment of more than $6.3 million to Nigerian officials in connection with a gas pipeline construction project and $300,000 to Ecuadorian officials in connection with a gas pipeline rehabilitation project.From late 2003 through March 2005, WII employees agreed to make corrupt payments totaling more than $6.3 million to officials of the Nigerian National Petroleum Corporation (NNPC), the state-owned oil company in Nigeria; NNPC\u0027s subsidiary, the National Petroleum Investment Management Services (NAPIMS); a senior official in the executive branch of the Nigerian federal government; officials of a multinational oil company; and a Nigerian political party. These bribes were paid to Nigerian government officials to assist in obtaining and retaining a $387 million contract for work on a major engineering, procurement and construction gas pipeline project known as the Eastern Gas Gathering System (EGGS). In addition, in 2004, various WII employees paid at least $300,000 to officials of the Ecuadorian state-owned oil company in order to obtain a gas pipeline rehabilitation contract.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Willbros Group, Inc., et al, Case No. 4:08-cr-287 (S.D. Tex.), ,Information filed May 14, 2008, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/willbros-group\/05-14-08willbros-info.pdf; Deferred Prosecution Agreement filed May 14, 2007, accessed at  www.justice.gov\/criminal\/fraud\/fcpa\/cases\/willbros-group\/05-14-08willbros-deferred.pdf.  US Department of Justice Press Release, \u0022Willbros Group Inc. Enters Deferred Prosecution Agreement and Agrees to Pay $22 Million Penalty for FCPA Violations,\u0022 May 14, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/May\/08-crm-417.html","Documents":""},{"Case ID":"ST-393","Case Cluster ":"Willbros Group Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Ecuador, Bolivia","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"05\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit, Prejudgment Interest","Total Monetary Sanctions (US$)":"$10,300,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$8,900,000","Civil Prejudgment Interest (US$) ":"$1,400,000","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Fraud in Connection with the Purchase and Sale of Securities, Disclosure Violations, Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United States Securities and Exchange Commission Litigation Release, on May 14, 2008, the Commission \u0022filed a settled civil action against Willbros Group, Inc. and several former employees alleging that they violated, among other things, the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA) and the antifraud provisions of the federal securities laws. The complaint also names Jason Steph, a former supervisory employee in Nigeria, Gerald Jansen, a former administrative supervisor in Nigeria, Lloyd Biggers, a former employee in Nigeria and Carlos Galvez, a former accounting employee in Bolivia. According to the complaint, the company also violated the reporting, books and records and internal controls provisions of the Securities Exchange Act. Willbros Group, Steph, Jansen, Biggers and Galvez have agreed to settle the charges against them, without admitting or denying the Commission\u0027s allegations. The Commission alleges in its complaint that Willbros Group, through the actions of others acting on its behalf, engaged in multiple schemes to bribe foreign officials. First, the complaint alleges that, beginning by at least 2003, Willbros Group, through the conduct of a former executive officer, Steph and others, engaged in a scheme to pay over $6 million in bribes to Nigerian government officials and to employees of an operator of a joint venture majority-owned by the Nigerian government in order to obtain a significant contract. A similar scheme was used to help obtain a second significant contract. Together, these contracts resulted in net profits of approximately $8,900,000. In 2005, according to the complaint, Steph assisted in the payment of $850,000 to satisfy a portion of these earlier commitments. The complaint further alleges that Willbros Group, through acts by a former executive officer, Steph, Jansen, Biggers and others, employed a long-running scheme using fabricated invoices to procure cash from the company\u0027s administrative headquarters in Houston to, among other things, bribe Nigerian tax and court officials. This fraudulent cash abuse was also used to fund in part the bribes paid in 2005.  Second, Willbros Group, through the conduct of the same former executive officer and others schemed to pay a $300,000 bribe to officials of an oil and gas company owned by the Ecuador government in order to obtain a $3 million contract. Finally, Willbros Group, through the actions of the same former executive officer, an outside consultant and Galvez implemented a fraudulent tax avoidance scheme in Bolivia. This fraudulent scheme resulted in material misstatements in Willbros Group\u0027s financial statements.\u0022  (Source:  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Willbros Group, Inc. Case Summary at 79-81, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20571 \/ May 14, 2008, SEC v. Willbros Group, Inc., et al., Civil Action No. 4:08-CV-01494 U.S.D.C.\/Southern District of Texas (Houston Division), \u0022SEC Files Settled FCPA Action Against Willbros Group, Inc. and Several Former Employees,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20571.htm; Complaint in SEC v. Willbros et al. [Willbros Group, Inc, Jason Steph, Gerald Jansen, Lloyd Biggers, Carlos Galvez], Case No. 4:08-cv-01494 (S.D. Tex.) filed May 14, 2008, accessed at www.sec.gov\/litigation\/complaints\/2008\/comp20571.pdf","Documents":""},{"Case ID":"ST-395","Case Cluster ":"York International Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food), United Arab Emirates","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"10\/01","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$10,000,000.00","Criminal Fine\/Penalty (US$) ":"$10,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud, Falsification of books and records, Wire fraud","Offenses - Settled":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud, Falsification of books and records, Wire fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 York International Corporation, at 47-48, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: the charges against York stemmed in part from the actions of its Dubai-headquartered subsidiary, York Air Conditioning and Refrigeration FZE (\u0022York FZE\u0022), whose employees and agents paid approximately $647,110 in kickbacks to Iraqi government officials from 2000 to 2003 in order to obtain contracts to provide air conditioning, ventilation and refrigeration equipment and services to Iraq under the UN Oil-for-Food program.  (York FZE was a subsidiary of York Air Conditioning and Refrigeration Inc., a Delaware formed subsidiary of York International, whose branch office in Dubai served as headquarters of York\u0027s Middle East operations.)  According to the Statement of Facts, approximately $7 milion in Iraqi contracts were obtained as a result; all contracts through the UN Oil-for-Food program. Additionally, from 1999 to 2005, employees of YACR and York FZE paid kickbacks and bribes to employees of government customers and contractors of government customers in order to obtain and retain approximately $42 million in contracts on government projects in UAE, Egypt, Babrain, Turkey, and India.  In the UAE, during 2003-20004, YACR and York FZE secured contractss worth $3.7 million related to a luxury hotel and convention complex in Abu Dhabi; the subsidiaries made 13 payments totalling $550,000 to an intermediary  in circumstances that make it likely that the intermediary made corrupt payments to members of the hotel and convention complex\u0027s executive committee, which was established by UAE government decree and which represented the UAE\u0027s Ministry of Finance and Industry in managing the construction of the complex. (para 41)  (Source:  US v. York International Corporation, Case No. 1:07-cr-00253-RJL (D.D.C.), Deferred Prosecution Agreement and Statement of Facts, filed October 15, 2007).  No additional details were given in the Statement of Facts with regard to the misconduct in the other jurisdictions noted in the Securities and Exchange Commission complaint.","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 York International Corporation, at 76-77, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.  US v. York International Corporation, Case No. 1:07-cr-00253-RJL (D.D.C.), Information filed October 1, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/york\/10-01-07york-info.pdf; Deferred Prosecution Agreement and Statement of Facts filed October 15, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/york\/10-15-07york-agree.pdf;  Department of Justice Press Release, \u0022Justice Department Agrees to Defer Prosecution of York International Corporation in Connection With Payment of Kickbacks Under the U.N. Oil For Food Program,\u0022 October 1, 2007, accessed at http:\/\/www.justice.gov\/opa\/pr\/2007\/October\/07_crm_783.html.","Documents":""},{"Case ID":"ST-396","Case Cluster ":"York International Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food), Bahrain, Egypt, India, Turkey, UAE, Nigeria, China and various other European and Middle Eastern countries 1999-2006","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"10\/01","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit, Prejudgment Interest, Civil Penalty ","Total Monetary Sanctions (US$)":"$12,032,880.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$8,949,132","Civil Prejudgment Interest (US$) ":"$1,083,748","Civil Fine \/ Penalty (US$)":"$2,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, on October 1, 2007, the Commission \u0022filed anti-bribery, internal controls, and books and records charges under the Foreign Corrupt Practices Act against York International Corporation (\u0022York International\u0022) in the U.S. District Court for the District of Columbia. York International, a global provider of heating, ventilation, air conditioning, and refrigeration products and services, was acquired by Johnson Controls, Inc. in 2005. The Commission\u0027s complaint alleges that York International\u0027s Delaware subsidiary paid approximately $522,500 to an intermediary while knowing that most of the money was intended to bribe United Arab Emirate officials; York International\u0027s Dubai subsidiary authorized and made approximately $647,110 in kickback payments under the U.N. Oil for Food Program; and that York International\u0027s subsidiaries devised elaborate schemes to conceal kickback payments of over $7.5 million made to secure orders on certain commercial and government projects in the Middle East, India, China, Nigeria and Europe.\u0022 (Source:  US Securitites and Exchange Commission, Litigation Release No. 20319 \/ October 1, 2007, Securities and Exchange Commission v. York International Corporation, 07 CV 01750 (D.D.C.)(RCL), \u0022SEC Files Settled Foreign Corrupt Practices Act Charges Against York International Corporation For Improper Payments to UAE Officials, to Iraq Under the U.N. Oil for Food Program, and to Others - - Company Agrees to Pay Over $12 Million and to Retain an Independent Compliance Monitor.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 York International Corporation, at 76-77, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.  US Securitites and Exchange Commission, Litigation Release No. 20319 \/ October 1, 2007, Securities and Exchange Commission v. York International Corporation, 07 CV 01750 (D.D.C.)(RCL), \u0022SEC Files Settled Foreign Corrupt Practices Act Charges Against York International Corporation For Improper Payments to UAE Officials, to Iraq Under the U.N. Oil for Food Program, and to Others - - Company Agrees to Pay Over $12 Million and to Retain an Independent Compliance Monitor,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20319.htm; Complaint filed October 1, 2007, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2007\/comp20319.pdf.","Documents":""},{"Case ID":"ST-302","Case Cluster ":"Paradigm, B.V.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China, Indonesia, Kazakhstan, Mexico, Nigeria","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"09\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,000,000.00","Criminal Fine\/Penalty (US$) ":"$1,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Paradigm BV, at 82-83, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: Misconduct involved corrupt payments to employees of state-owned oil and gas companies in China (2006), Indonesia (2003), Kazakhstan (2005-2006), Latvia [dates not given], Mexico (2004-2005), and Nigeria (2003-2005). Resulting criminal enforcement action: In Re Paradigm B.V. (November 24, 2007). Settlement amount: Criminal fine of $1 million. The involved misconduct is detailed in the Statement of Facts attached to the Non-prosecution agreement, which also noted that Paradigm is a Dutch Limited Liability Company, which moved its principal place of business in 2005 to Houston.  (Source: In Re Paradigm BV, Non-prosecution agrement and statement of facts (September 21, 2007).  According to the June 2011 United States Report to the OECD, \u0022In one instance, the company paid $22,250 into the Latvian bank account of a British West Indies company recommended as a consultant by an official of KazMunaiGas, Kazakhstan\u0027s national oil company, to secure a tender for geological software. [ ] Paradigm also used an agent in China to make commission payments to representatives of a subsidiary of the China National Offshore Company in connection with the sale of a software [  ] Paradigm also admitted to similar conduct in dealings in Mexico, Indonesia, and Nigeria.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Paradigm B.V. Case Summary at 98-99.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Paradigm B.V. at 82-83, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf;  In Re Paradigm BV, Non-Prosecution Agreement and Statement of Facts (September 21, 2007), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/paradigm\/09-21-07paradigm-agree.pdf; US Department of Justice Press Release, \u0022Paradigm B.V. Agrees to Pay $1 Million Penalty to Resolve Foreign Bribery Issues in Multiple Countries,\u0022 September 24, 2007, accessed at http:\/\/www.justice.gov\/opa\/pr\/2007\/September\/07_crm_751.html. US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Paradigm B.V. Case Summary at 98-99, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. ","Documents":""},{"Case ID":"ST-303","Case Cluster ":"Ports Engineering Consultants Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Panama","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"04\/19","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$15,000.00","Criminal Fine\/Penalty (US$) ":"$15,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art.1, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials, Making a False Statement","Offenses - Settled":"Bribery of Foreign Officials, Making a False Statement","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On November 10, 2009 and December 15, 2009, respectively, Charles Paul Edward Jumet and John W. Warwick were charged in connection with a conspiracy to make corrupt payments to Panamanian government officials in exchange for certain maritime contracts. Jumet was charged in a two-count criminal information with conspiracy to bribe foreign officials in violation of the FCPA and with making a false statement to the FBI. Warwick, the former president of Ports Engineering Consultants Corporation (PECC), was indicted on one-count of conspiracy to authorize and cause corrupt payments to be made to foreign government officials for the purpose of securing business for PECC, in violation of the FCPA. According to court documents, from 1997 through approximately July 2003, Warwick, Jumet, and others conspired to authorize and cause corrupt payments totaling more than $200,000 to be made to the former administrator and deputy administrator of the Panama Maritime Ports Authority, as well as to a former, high-ranking elected executive official of the Republic of Panama. These corrupt payments were made so that the Panamanian officials would award contracts to maintain lighthouses and buoys along Panama\u0027s waterways to PECC, a company incorporated under the laws of Panama and affiliated with Overman Associates, an engineering firm based in Virginia. In 1997, the Panamanian government awarded PECC a no-bid 20-year concession to perform these duties. As a result of these contracts, PECC earned approximately $18 million in revenue from 1997 to 2000. In 2000, Panama?s Comptroller General Office suspended the contract while it investigated the government\u0027s decision to award PECC a contract without soliciting a bid from any other entities. In 2003, the Panamanian government resumed making payments to PECC.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011.)  According to the US Government\u0027s Sentencing Memorandum in co-defendant Warwick\u0027s case, \u0022Defendant Warwick is a United States citizen who was President of Ports Engineering Consultants Corporation (PECC), Overman Associates, and Overman de Panama during this conspiracy. He, Charles Jumet, and others authorized and caused corrupt payments to be made to Panamanian government officials, through shell corporations -- Warmspell Holding Corporation and Soderville Corporation -- and through the issuance of checks made payable to the \u0027bearer.\u0027\u0022  (Source: US v. Warwick, Case No. 3:09-cr-449-HEH (E.D. Va.), US Government Sentencing Memorandum filed June 14, 2010.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  Ports Engineering Consultants Corporation Case Summary at 57-58.  US v. Charles Paul Edward Jumet, Case No. 3:09-cr-397 (E.D.Va.), Information filed November 10, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/jumetc\/11-10-09jumet-info.pdf; Plea Agreement filed November 13, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/jumetc\/11-13-09jumet-plea-agree.pdf; Statement of Facts filed November 13, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/jumetc\/11-12-09jumet-statement-facts.pdf; Judgment filed April 22, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/jumetc\/04-22-10jumet-judgment.pdf.  US Department of Justice Press Release, \u0022Virginia Resident Sentenced to 87 Months in Prison for Bribing Foreign Government Officials, Longest Prison Sentence Ever Imposed Related to Foreign Corrupt Practices Act (FCPA) Violations,\u0022 April 22, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/April\/10-crm-442.html","Documents":""},{"Case ID":"ST-304","Case Cluster ":"Ports Engineering Consultants Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Panama","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"02\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$331,000.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$331,000","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On November 10, 2009 and December 15, 2009, respectively, Charles Paul Edward Jumet and John W. Warwick were charged in connection with a conspiracy to make corrupt payments to Panamanian government officials in exchange for certain maritime contracts. Jumet was charged in a two-count criminal information with conspiracy to bribe foreign officials in violation of the FCPA and with making a false statement to the FBI. Warwick, the former president of Ports Engineering Consultants Corporation (PECC), was indicted on one-count of conspiracy to authorize and cause corrupt payments to be made to foreign government officials for the purpose of securing business for PECC, in violation of the FCPA.  According to court documents, from 1997 through approximately July 2003, Warwick, Jumet, and others conspired to authorize and cause corrupt payments totaling more than $200,000 to be made to the former administrator and deputy administrator of the Panama Maritime Ports Authority, as well as to a former, high-ranking elected executive official of the Republic of Panama. These corrupt payments were made so that the Panamanian officials would award contracts to maintain lighthouses and buoys along Panama\u0027s waterways to PECC, a company incorporated under the laws of Panama and affiliated with Overman Associates, an engineering firm based in Virginia. In 1997, the Panamanian government awarded PECC a no-bid 20-year concession to perform these duties. As a result of these contracts, PECC earned approximately $18 million in revenue from 1997 to 2000. In 2000, Panama\u0027s Comptroller General Office suspended the contract while it investigated the government\u0027s decision to award PECC a contract without soliciting a bid from any other entities. In 2003, the Panamanian government resumed making payments to PECC.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011.)  According to the US Government\u0027s Sentencing Memorandum, \u0022Defendant Warwick is a United States citizen who was President of Ports Engineering Consultants Corporation (PECC), Overman Associates, and Overman de Panama during this conspiracy. He, Charles Jumet, and others authorized and caused corrupt payments to be made to Panamanian government officials, through shell corporations -- Warmspell Holding Corporation and Soderville Corporation -- and through the issuance of checks made payable to the \u0027bearer.\u0027\u0022  (Source: US v. Warwick, Case No. 3:09-cr-449-HEH (E.D. Va.), US Government Sentencing Memorandum filed June 14, 2010.)  Forfeiture Agreement contained in Warwick\u0027s Plea Agreement filed February 10, 2010.","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Ports Engineering Consultants Corporation Case Summary at 57-58, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. John W. Warwick, Case No. 3:09-cr-449-HEH (E.D. Va.), Indictment filed December 15, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/warwickj\/12-15-09warwick-indict.pdf; Plea Agreement filed February 10, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/warwickj\/02-10-10warwick-plea-agree.pdf; Statement of Facts filed February 10, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/warwickj\/02-10-10warwick-statement-facts.pdf;  US Government Sentencing Memorandum filed June 14, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/warwickj\/06-14-10warwick-senten-memo.pdf.  See also, US Department of Justice Press Release, \u0022Virginia Resident Sentenced to 37 Months in Prison for Bribing Foreign Government Officials,\u0022 June 25, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/June\/10-crm-750.html","Documents":""},{"Case ID":"ST-305","Case Cluster ":"Prodetra bv, Wadinxveen","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Rijksrecherche (Dutch Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Out of court settlement","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$158,168.10","Criminal Fine\/Penalty (US$) ":"$103,203","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$54,965.10","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"","Offenses - Settled":"Sanctions legislation by paying kickbacks when implementing UN Oil-for-Food Programme","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Netherlands Phase 2 Report of the OECD Anti-Bribery Working Group (December 17, 2008): \u0022As of October 2008, no foreign bribery cases had been brought before the Dutch courts. Nevertheless, the prosecution authorities have concluded out-of-court transactions with seven companies for paying kickbacks in the context of the Oil-for-Food Programme in Iraq, although the offence charged was the violation of sanctions legislation and not the foreign bribery offence.\u0022 (para 2); \u0022 the Prosecution Department reports that it has concluded financial transactions (out of court settlements) with 7 companies for violating sanction legislation by paying kickbacks when implementing the Oil for Food Programme. Criminal gains have also been confiscated. In July 2008 a press release has been issued about these settlements. Together with the names of the companies (Alfasan International B.V., N.V. Organon, Flowserve B.V. , OPW Fluid Transfer Group Europe B.V., Prodetra B.V. Solvochem Holland B.V., Stet Holland B.V.) the settlements have been made public. For the following Oil-for-food transactions out-of-court settlements have been reached: 1. Alfasan International BV Woerden, fine: \u20ac 31.800,-- and confiscation \u20ac 10.183,55 2. NV Organon Oss, fine: \u20ac 381.602 3. Flowerserve bv te Etten-Leur, fine: \u20ac 76.274 and confiscation \u20ac180.260 4. OPW Fluid Transfer Group Europe BV, Nieuw Vennep, fine \u20ac 57.204 and confiscation \u20ac 24.600 5. Prodetra bv,Wadinxveen, fine: 64.751 and confiscation \u20ac 34.485,95 6. Solvochem Holland bv, Rotterdam, fine \u20ac 136.000 and confiscation \u20ac 144.592 7. Stet Holland bv,Emmeloord, fine \u20ac 119.712 and confiscation \u20ac 54.458.\u0022 (Source: Ibid., at 14.)","Sources ":"OECD Anti-Bribery Working Group, The Netherlands Phase 2 Report (December 17, 2008), accessed at http:\/\/www.oecd.org\/dataoecd\/61\/59\/41919004.pdf; Melissa Lipman, \u0022Cos. Settle Dutch Probe Into Oil-For-Food For ?1.3M,\u0022 Law 360, July 16, 2008, accessed at http:\/\/www.law360.com\/articles\/62486\/cos-settle-dutch-probe-into-oil-for-food-for-1-3m (partial article, gives date of Dutch Public Prosecution Service press release.)","Documents":""},{"Case ID":"ST-306","Case Cluster ":"RAE Systems, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,700,000.00","Criminal Fine\/Penalty (US$) ":"$1,700,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"Falsification of books and records, Internal controls violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 10, 2010, RAE Systems, Inc. entered into a non-prosecution agreement with the Department of Justice regarding alleged violations of the books and records and internal controls provisions of the FCPA. On the same date, the SEC filed a settled civil complaint against RAE Systems in the U.S. District Court for the District of Columbia, charging the company with violations of the anti-bribery, books and records, and internal controls provisions of the FCPA.  [  ] According to court records, from 2005 to 2008, the company had significant operations in the People\u0027s Republic of China (PRC), and sold its products and services primarily through two subsidiaries organized as joint ventures with local Chinese entities: RAE-KLH (Beijing) Co. Limited (RAE-KLH) and RAE Coal Mine Safety Instruments (Fushun) Co. Ltd. (RAE Fushun). A significant number of RAE-KLH\u0027s and RAE Fushun\u0027s customers were PRC government departments and bureaus, and large state-owned agencies and instrumentalities, including regional fire departments, emergency response departments and entities under the supervision of the provincial environmental agency.  As described in the agreement [with the Department of Justice], RAE Systems accepted responsibility for violating the internal controls and books and records provisions of the FCPA arising from and related to improper benefits corruptly paid by employees of RAE-KLH and RAE Fushun to foreign officials in the PRC. As a result of due diligence conducted by RAE Systems before acquiring the majority of the joint venture that became known as RAE-KLH, RAE Systems was aware of improper commissions, kickbacks and \u0022under table greasing to get deals\u0022 by employees.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, RAE Systems, Inc. Case Summary at 30-32.) ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, RAE Systems, Inc. Case Summary at 30-32, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  In Re: RAE Systems, Inc., Non-Prosecution Agreement and Statement of Facts, December 10, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/rae-systems\/12-10-10rae-systems.pdf;  US Department of Justice Press Release, \u0022RAE Systems Agrees to Pay $1.7 Million Criminal Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 December 10, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/December\/10-crm-1428.html.","Documents":""},{"Case ID":"ST-307","Case Cluster ":"RAE Systems, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$1,257,012.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,147,800","Civil Prejudgment Interest (US$) ":"$109,212","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 10, 2010, RAE Systems, Inc. entered into a non-prosecution agreement with the Department of Justice regarding alleged violations of the books and records and internal controls provisions of the FCPA. On the same date, the SEC filed a settled civil complaint against RAE Systems in the U.S. District Court for the District of Columbia, charging the company with violations of the anti-bribery, books and records, and internal controls provisions of the FCPA.  [  ] According to court records, from 2005 to 2008, the company had significant operations in the People\u0027s Republic of China (PRC), and sold its products and services primarily through two subsidiaries organized as joint ventures with local Chinese entities: RAE-KLH (Beijing) Co. Limited (RAE-KLH) and RAE Coal Mine Safety Instruments (Fushun) Co. Ltd. (RAE Fushun). A significant number of RAE-KLH\u0027s and RAE Fushun\u0027s customers were PRC government departments and bureaus, and large state-owned agencies and instrumentalities, including regional fire departments, emergency response departments and entities under the supervision of the provincial environmental agency.  As described in the agreement [with the Department of Justice], RAE Systems accepted responsibility for violating the internal controls and books and records provisions of the FCPA arising from and related to improper benefits corruptly paid by employees of RAE-KLH and RAE Fushun to foreign officials in the PRC. As a result of due diligence conducted by RAE Systems before acquiring the majority of the joint venture that became known as RAE-KLH, RAE Systems was aware of improper commissions, kickbacks and \u0022under table greasing to get deals\u0022 by employees.\u0022  The SEC complaint alleged that \u0022employees of RAE-KLH and RAW Fushun paid approximately $400,000 to Chinese government officials in violation of the FCPA\u0027s anti-bribery provisions.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, RAE Systems, Inc. Case Summary at 30-32.) ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, RAE Systems, Inc. Case Summary at 30-32, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission v. RAE Systems, Inc., Case No. 1:10-cv-2093 (D.D.C.), Complaint filed December 10, 2010,  accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21770.pdf and SEC Litigation Release No. 21770 (December 10, 2010), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21770.htm.","Documents":""},{"Case ID":"ST-308","Case Cluster ":"Rockwell Automation Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"05\/03","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$2,761,091.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,771,000","Civil Prejudgment Interest (US$) ":"$590,091","Civil Fine \/ Penalty (US$)":"$400,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Books and records, internal controls failure","Offenses - Settled":"No admission of SEC findings","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Law.com, citing Alexandra Wrage of Trace International as source, this case was unusual in that the Department of Justice chose not to bring charges against the company (termed \u0022split decision\u0022 by SEC and DOJ).  (Source: Brian Zabcik, \u0022Reasonable Minds Can Disagree: SEC, DOJ Part Ways on Rockwell Payments,\u0022 Law.com, May 5, 2011, accessed at http:\/\/www.law.com\/jsp\/cc\/PubArticleCC.jsp?id=1202492959767).  The SEC Cease-and-Desist Order made the following findings of misconduct (which Rockwell did not admit or deny as part of the settlement agreement):  (1) from 2003 to 2006, payment of $615,000 by certain employees of Rockwell\u0027s former subsidiary in China, China Rockwell Automation Power Systems (Shangai) Ltd. to Design Institutes, which were typically state-owned enterprises and (2) approximately $450,000 to fund sightseeing and other non-business trips for employees of Design Institutes and other state-owned companies. Rockwell realized approximately $1.7 million in net profits on sales contracts with end-user Chinese government-owned companies that were associated with payments to the Design Institutes. (Source: In the Matter of Rockwell Automation, Inc., Order Instituting Cease and Desist Order, SEC Administrative Proceeding File No. 3-14364 (May 3, 2011). ","Sources ":"In the Matter of Rockwell Automation, Inc., Administrative Proceeding, File No. 3-14364, Order Instituting Cease-and_Desist Proceedings (May 3, 2011), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2011\/34-64380.pdf; Brian Zabcik, \u0022Reasonable Minds Can Disagree: SEC, DOJ Part Ways on Rockwell Payments,\u0022 Law.com, May 5, 2011, accessed at http:\/\/www.law.com\/jsp\/cc\/PubArticleCC.jsp?id=1202492959767.","Documents":""},{"Case ID":"ST-309","Case Cluster ":"Samir A. Vincent","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"01\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to Defraud the United States, Impersonating Agents of Foreign Governments, Violation of the International Emergency Economic Powers Act, Fraud and False Statements","Offenses - Settled":"Conspiracy to Defraud the United States, Impersonating Agents of Foreign Governments, Violation of the International Emergency Economic Powers Act, Fraud and False Statements","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Press Release by the United States Attorney for the Southern District, among that Office\u0027s UN Oil-for-Food investigations were \u0022on January 18, 2005, SAMIR A. VINCENT, an Iraqi-American businessman, pleaded guilty before JudgeCHIN to, among other things, conspiring to serve in the United States as an unregistered agent of the Hussein regime.\u0022 (Source: United States Attorney for the Southern District of New York Press Release, \u0022Texas Oil Executive and Two Corporations Sentenced on Charges Involving a Scheme to Pay Secret Kickbacks to the Former Government of Saddam Hussein,\u0022 March 7, 2008.)  According to the Court Docket Report in his case, Vincent was not assessed monetary penalties. (Source:  US v. Vincent et al, Case No. 1:05-cr-00059-DC (SDNY), Court Docket Report  (accessed on October 26, 2011 via Pacer).","Sources ":"United States Attorney for the Southern District of New York Press Release, \u0022Texas Oil Executive and Two Corporations Sentenced on Charges Involving a Scheme to Pay Secret Kickbacks to the Former Government of Saddam Hussein,\u0022 March 7, 2008, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/March08\/chalmersetalsentencingpr.pdf; US v. Vincent et al, Case No. 1:05-cr-00059-DC (SDNY), Court Docket Report  (accessed on October 26, 2011 via Pacer).","Documents":""},{"Case ID":"ST-310","Case Cluster ":"Saybolt Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Panama","Year of Settlement":"1998","Month\/Day of Settlement (or Notes)":"12\/03","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,500,000.00","Criminal Fine\/Penalty (US$) ":"$1,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD, \u0022In April 1998, a grand jury sitting in Trenton, New Jersey, returned an indictment charging Frerik Pluimers, a Dutch national, and David Mead, a British national, both of whom were officers of an American company, Saybolt Inc., with conspiracy and violations of the FCPA and the Travel Act in connection with a $50,000 bribe paid to Panamanian officials. The bribe was paid to secure a lease for Saybolt Panama to move into the Panama canal free zone, which would reduce the company\u0027s tax liability. The bribe was discussed and approved at a board meeting of Saybolt Inc. in New Jersey, but the bribe itself was paid from the company\u0027s Dutch parent, Saybolt N.A., with the authorization of Pluimers. \/ Criminal Disposition:  On December 3, 1998, Saybolt Inc. and its subsidiary, Saybolt North America, pled guilty to violating the FCPA and paid a $1.5 million fine. In a related case, Saybolt Inc. was sentenced to pay a $3.4 million fine and required to retain a compliance monitor in relation to charges that it had falsified environmental tests of certain of its products.  [  ] Mr. Mead was convicted at trial in October 1998 and sentenced to four months in prison and a $20,000 fine. The United States requested that the Netherlands extradite Mr. Pluimers in March 2000. Despite extended litigation, including a decision of the Dutch Supreme Court authorizing the extradition, the Dutch authorities have refused and rejected the U.S. request for Mr. Pluimers? extradition. The United States is still seeking Mr. Pluimers return to the United States to stand trial.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Saybolt Inc. Case Summary at 134-35.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Saybolt Inc. Case Summary at 134-35, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Saybolt North America, Inc. and Saybolt Inc., Case No. 98-cr-10266-WGY (D. Mass.), Information filed August 10, 1998, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/saybolt\/08-10-98saybolt-info.pdf; Plea Agreement dated August 18, 1998, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/saybolt\/08-18-98saybolt-plea-agree.pdf; Judgment (as to Saybolt North America, Inc.), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/saybolt\/01-26-99saybolt-northamerica-judg.pdf; Judgment (as to Saybolt Inc.), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/saybolt\/01-26-99saybolt-inc-judgment.pdf","Documents":""},{"Case ID":"ST-311","Case Cluster ":"Schering-Plough Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Poland","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"06\/09","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order ","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$500,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$500,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission\u0027s litigation release, \u0022The Commission\u0027s complaint alleges that, between February 1999 and March 2002, one of Schering-Plough\u0027s foreign subsidiaries, Schering-Plough Poland, made improper payments to a charitable organization called the Chudow Castle Foundation. The Foundation was headed by an individual who was the Director of the Silesian Health Fund during the relevant time. The health fund was a Polish governmental body that, among other things, provided money for the purchase of pharmaceutical products and influenced the purchase of those products by other entities, such as hospitals, through the allocation of health fund resources. According to the complaint, Schering-Plough Poland paid 315,800 zlotys (approximately $76,000) to the Chudow Castle Foundation to induce the Director to influence the health fund\u0027s purchase of Schering-Plough\u0027s pharmaceutical products. The complaint alleges that none of the payments made by Schering-Plough Poland to the Foundation was accurately reflected on the subsidiary\u0027s books and records. The complaint also alleges that the company\u0027s system of internal accounting controls was inadequate to prevent or detect the improper payments. Without admitting or denying the allegations in the complaint, Schering-Plough consented to pay a $500,000 civil penalty.\u0022   In a related enforcement matter, Schering-Plough, without admitting or denying the allegations in the SEC complaint, consented to a cease and desist order enjoining the company from FCPA violations and other conditions. Schering-Plough Poland was a subsidiary of Schering-Plough Central East AG, a wholly owned Swiss subsidiary of Plough-Schering with headquarters in Lucerne, Switzerland.  (Source:  US Securities and Exchange Commission, Litigation Release No. 18740, June 9, 2004, Securities and Exchange Commission v. Schering-Plough Corporation, United States District Court for the District of Columbia, Civil Action No. 1:04CV00945 (PLF), \u0022SEC FILES SETTLED ENFORCEMENT ACTION AGAINST SCHERING-PLOUGH CORPORATION FOR FOREIGN CORRUPT PRACTICES ACT VIOLATIONS,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr18740.htm, and June 9, 2004 Complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/comp18740.pdf.","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Schering-Plough Corporation Case Summary at 133,  accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Securities and Exchange Commission, Litigation Release No. 18740, June 9, 2004, Securities and Exchange Commission v. Schering-Plough Corporation, United States District Court for the District of Columbia, Civil Action No. 1:04CV00945 (PLF), \u0022SEC Files Settled Enforcement Action against Schering-Plough Corporation for Foreign Corrupt Practices Act Violations,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr18740.htm, and June 9, 2004 Complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/comp18740.pdf.","Documents":""},{"Case ID":"ST-312","Case Cluster ":"Schnitzer Steel Industries, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China, South Korea","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"10\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"None","Offenses - Settled":"None","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On October 10, 2006, SSI International Far East Ltd. (SSI Korea), a wholly-owned subsidiary of Schnitzer Steel Industries Inc. (SSI), was charged with conspiracy, bribery in violation of the FCPA, wire fraud, and aiding and abetting the making of false entries in SSI\u0027s books and records. These charges stemmed from a decade-long scheme to bribe foreign officials in China and South Korea in order to obtain and retain business for SSI Korea and its Oregon-based parent company.  [  ]  SSI entered into a three-year deferred prosecution agreement with the Department [of Justice] and agreed to appoint an independent compliance monitor.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Schnitzer Steel Industries Inc. Case Summary at 88-90.)  According to SSI\u0027s Deferred Prosecution Agreement with the Department of Justice, SSI agreed that its subsidiary SSI Korea would pay $7.5 million in fines to the U.S.  (Source: Schnitzer Steel Industries, Inc. Deferred Prosecution Agreement Octobet 16, 2006.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Schnitzer Steel Industries Inc. Case Summary at 88-90,  accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  Schnitzer Steel Industries, Inc. Deferred Prosecution Agreement Octobet 16, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/ssi-intl\/10-16-06schnitzer-agree.pdf","Documents":""},{"Case ID":"ST-313","Case Cluster ":"Schnitzer Steel Industries, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, South Korea","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"10\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$7,725,201.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$6,279,095","Civil Prejudgment Interest (US$) ":"$1,446,106","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Internal Controls Violatons, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On October 10, 2006, SSI International Far East Ltd. (SSI Korea), a wholly-owned subsidiary of Schnitzer Steel Industries Inc. (SSI), was charged with conspiracy, bribery in violation of the FCPA, wire fraud, and aiding and abetting the making of false entries in SSI\u0027s books and records. These charges stemmed from a decade-long scheme to bribe foreign officials in China and South Korea in order to obtain and retain business for SSI Korea and its Oregon-based parent company.[ ] In a related action, on December 13, 2007, the SEC filed a settled civil complaint charging former Chairman and CEO of SSI, Robert W. Philip, with violating the anti-bribery provisions of the FCPA and with aiding and abetting SSI\u0027s anti-bribery, books and records, and internal controls violations. According to the SEC\u0027s complaint, from 1999 to 2004, Philip authorized the payment of more than $200,000 to managers of government-owned steel mills in China in order to induce them to purchase scrap metal from SSI. In addition, the complaint charged Philip with authorizing more than $1.7 million in payments to managers of privately-owned steel mills in both China and South Korea. SSI later described these payments as \u0022sales commissions,\u0022 \u0022commissions to the customer,\u0022 \u0022refunds,\u0022 or \u0022rebates\u0022 in its books and records, in violation of the FCPA.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Schnitzer Steel Industries Inc. Case Summary at 88-90,  accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Schnitzer Steel Industries Inc. Case Summary at 88-90,  accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  In the Matter of Schnitzer Steel Industries, Inc., US Securities and Exchange Commission (October 16, 2006), Administrative Proceeding File No. 3-12456, Order Instituting Cease-and-Desist Proceedings, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2006\/34-54606.pdf","Documents":""},{"Case ID":"ST-314","Case Cluster ":"Schnitzer Steel Industries, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, South Korea","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"12\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment","Monetary Sanctions  (Types)":"Disgorgement of Bonuses, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$261,400.42","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$169,864","Civil Prejudgment Interest (US$) ":"$16,536.63","Civil Fine \/ Penalty (US$)":"$75,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Aiding and Abetting Schnitzer Steel Industries\u0027 Bribery of Foreign Officials; Aiding and Abetting Schnitzer Steel Industries\u0027 Internal Controls Violatons, Aiding and Abetting Schnitzer Steel Industries\u0027 Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, on December 13, 2007, the Commssion \u0022charged the former Chairman and CEO of Schnitzer Steel Industries, Inc., with violating anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA) by approving cash payments and other gifts to officials at Chinese  government-owned steel mills to entice their business. [  ] The Commission\u0027s complaint, filed in U.S. district court in Portland, Ore., alleges that from at least 1999 through 2004, Philip authorized payment of more than $200,000 in cash bribes and other gifts to managers at government-owned steel mills in China to induce them to purchase scrap metal from Portland-based Schnitzer. The Commission alleges that Schnitzer generated more than $96 million in revenue, and more than $6.2 million in profits, from sales to customers who had received the improper payments. The complaint further alleges that Philip authorized more than $1.7 million in payments to managers of privately owned steel mills in both China and South Korea, generating more than $500 million in additional revenue for the company.\u0022  (Source: US Securities and Exchange Commission Litigation Release No. 20397 \/ December 13, 2007, Securities and Exchange Commission v. Robert W. Philip, Case No. CV 07-1836 (MO) (D. Or. filed December 13, 2007), \u0022SEC Charges Former Chairman\/CEO of Schnitzer Steel for Authorizing Cash Bribes to Foreign Officials.\u0022)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Schnitzer Steel Industries Inc. Case Summary at 88-90,  accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20397 \/ December 13, 2007, Securities and Exchange Commission v. Robert W. Philip, Case No. CV 07-1836 (MO) (D. Or. filed December 13, 2007), \u0022SEC Charges Former Chairman\/CEO of Schnitzer Steel for Authorizing Cash Bribes to Foreign Officials,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20397.htm; Complaint filed December 13, 2007, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2007\/comp20397.pdf","Documents":""},{"Case ID":"ST-315","Case Cluster ":"Schnitzer Steel Industries, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, South Korea","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"06\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Bonuses, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$41,131.90","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$14,819","Civil Prejudgment Interest (US$) ":"$1,312.52 ","Civil Fine \/ Penalty (US$)":"$25,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Aiding and Abetting Schnitzer Steel Industries\u0027 Bribery of Foreign Officials; Aiding and Abetting Schnitzer Steel Industries\u0027 Internal Controls Violatons, Aiding and Abetting Schnitzer Steel Industries\u0027 Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, on June 29, 2007, the Commission \u0022announced charges against a former executive of Portland, Oregon-based Schnitzer Steel Industries, Inc., for violating the anti-bribery provisions of the Foreign Corrupt Practices Act (\u0022FCPA\u0022). Without admitting or denying the allegations, Si Chan Wooh of Tacoma, Washington, the former Executive Vice President and head of a Schnitzer subsidiary, agreed to pay approximately $40,000 in disgorgement, interest and penalties.  The Commission\u0027s complaint, filed in federal district court in Portland, Oregon, alleges that from at least 1999 through 2004, Wooh paid over $200,000 in cash bribes and other gifts to managers of government-owned steel mills in China to induce them to purchase scrap metal from Schnitzer. According to the Commission, Schnitzer realized over $6.2 million in profits from sales to customers procured through these illicit payments. The Complaint further alleges that during the same period, Wooh made or authorized similar payments totaling over $1.7 million to managers of privately owned steel mills in both China and South Korea.\u0022 (Source: US Securities and Exchange Commission Litigation Release No. 20174 \/ June 29, 2007, SEC v. Si Chan Wooh, Case No. CV-07-957 ST. (D. Or. filed June 29, 2007), \u0022SEC Settles Charges Against Former Portland Steel Executive for Anti-Bribery Statute Violations.\u0022)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Schnitzer Steel Industries Inc. Case Summary at 88-90,  accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20174 \/ June 29, 2007, SEC v. Si Chan Wooh, Case No. CV-07-957 ST. (D. Or. filed June 29, 2007), \u0022SEC Settles Charges Against Former Portland Steel Executive for Anti-Bribery Statute Violations,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20174.htm; Complaint filed June 29, 2007, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2007\/comp20174.pdf","Documents":""},{"Case ID":"ST-316","Case Cluster ":"Schnitzer Steel Industries, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China, South Korea","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"10\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$7,500,000.00","Criminal Fine\/Penalty (US$) ":"$7,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Freign Oficials, Conspiracy to Falsify Books and Records, Conspiracy to Commit Wire Fraud, Bribery of Foreign Officials, Falsification of Books and Records, Wire Fraud, Aiding and Abetting Schnitzer Steel Industries\u0027 Falsification of Books and Records ","Offenses - Settled":"Conspiracy to Bribe Freign Oficials, Conspiracy to Falsify Books and Records, Conspiracy to Commit Wire Fraud, Bribery of Foreign Officials, Falsification of Books and Records, Wire Fraud, Aiding and Abetting Schnitzer Steel Industries\u0027 Falsification of Books and Records ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to United States Report to the OECD, \u0022On October 10, 2006, SSI International Far East Ltd. (SSI Korea), a wholly-owned subsidiary of Schnitzer Steel Industries Inc. (SSI), was charged with conspiracy, bribery in violation of the FCPA, wire fraud, and aiding and abetting the making of false entries in SSI\u0027s books and records. These charges stemmed from a decade-long scheme to bribe foreign officials in China and South Korea in order to obtain and retain business for SSI Korea and its Oregon-based parent company. In June 2007, Si Chan Wooh, a former senior executive officer of SSI, was charged by both the DOJ and SEC in connection with his role in the bribery scheme.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Schnitzer Steel Industries Inc. Case Summary at 88-90,  accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.)   According to court documents, on October 14, 2011, the Department dropped its charges against Wooh.  (Sources:  US v. Si Chan Wooh, Case No. 3:07-cr-244 (D. Or.), Government\u0027s Unopposed Motion to Dismiss Information, filed October 14, 2011; Court Docket Entry indicating Order to Dismiss signed October 17, 2011.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Schnitzer Steel Industries Inc. Case Summary at 88-90,  accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  SSI International Far East Ltd., Case No. 06-cr-398-KI (D. Or.), Information filed October 10, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/ssi-intl\/10-10-06ssi-information.pdf; Plea Agreement filed October 10, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/ssi-intl\/10-10-06ssi-fareast-plea.pdf; Judgment dated October 17, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/ssi-intl\/10-17-06ssi-fareast-judg.pdf.  US v. Si Chan Wooh, Case No. 3:07-cr-244 (D. Or.), Government\u0027s Unopposed Motion to Dismiss Information, filed October 14, 2011; Court Docket Entry indicating Order to Dismiss signed October 17, 2011 (Both accessed via Pacer.)","Documents":""},{"Case ID":"ST-317","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"Nigeria","Jurisdiction of Settlement \/ Enforcement Agency":"Economic and Financial Crimes Commission; Attorney General","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"11\/22","Other Jurisdictions of Settlement":"Germany, United States, World Bank","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine, Disgorgement","Total Monetary Sanctions (US$)":"$46,000,000.00","Criminal Fine\/Penalty (US$) ":"$46,000,000","Criminal Fine \/ Penalty (Explanation)":"Please note that the December 22, 2010 press briefing by the Nigerian Attorney General noted that $170.8 million had been paid in total by companies and individuals; no specific figure was given as to each company.  The press statement noted that the sums had been paid by the companies as fines and disgorgement but no breakdown was given. ","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$46,000,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction (Amount from secondary sources)","UNCAC Articles(s) Implicated":"","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Unknown","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the May 4, 2011 Siemens Company Statement on Legal Proceedings against it around the world, the criminal charges filed against it by the Nigerian Economic and Financial Crimes Commission (EFCC) was dismissed in November 2010, pursuant to a settlement agreement between Siemens and the Nigerian authorities. (Source: Siemens, \u0022Legal Proceedings,\u0022 May 4, 2011.)  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.  However, on December 22, 2010, the Nigerian Attorney General and Minister of Justice stated at a media briefing that the total sum of $170.8 million had been paid by foreign companies to settle bribery charges and\/or allegations and that the sums represented fines and disgorgement of profits.  (Source: 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010.)","Sources ":"2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010, provided to the study by the Nigerian Economic and Financial Crimes Commission; Marcus Cohen, David Elesinmogun \u0026 Obumneme Egwuatu, \u0022Will Nigeria Take Another Bite?,\u0022 FCPA Blog, August 4, 2011, accessed at http:\/\/www.fcpablog.com\/blog\/tag\/shell; Siemens, \u0022Legal Proceedings,\u0022 May 4, 2011, accessed at http:\/\/www.siemens.com\/press\/pool\/de\/events\/2011\/corporate\/2011-q2\/2011-q2-legal-proceedings-e.pdf; US v. Siemens A.G., Case No. 08-cr-367-RJL (D.D.C.), Plea Agreement and Statement of Offense, both filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens-aktiengesellschaft.html.","Documents":""},{"Case ID":"ST-318","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Argentina, Bangladesh, Iraq (UN Oil-for-Food), Venezuela","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"12\/15","Other Jurisdictions of Settlement":"Germany, World Bank ","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$448,500,000.00","Criminal Fine\/Penalty (US$) ":"$448,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Falsification of Books and Records","Offenses - Settled":"Falsification of Books and Records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 11, 2008, Siemens Aktiengesellschaft (Siemens AG), a German corporation, and three of its subsidiaries were charged in separate criminal informations filed in the U.S. District Court for the District of Columbia for their roles in a scheme to bribe foreign officials in several countries. Siemens AG was charged with two counts of violating the internal controls and books and records provisions of the FCPA, while Siemens S.A. - Argentina was charged with conspiracy to violate the books and records provisions. In addition, Siemens Bangladesh Limited (Siemens Bangladesh) and Siemens S.A. - Venezuela (Siemens Venezuela) were each charged with one count of conspiracy to violate the anti-bribery and books and records provisions of the FCPA.  According to court documents filed in these criminal cases, beginning in the mid-1990s, Siemens AG engaged in systematic efforts to falsify its corporate books and records and knowingly failed to implement existing internal controls. As a result of Siemens AG\u0027s knowing failures in and circumvention of internal controls, from the time of its listing on the New York Stock Exchange on March 12, 2001, through approximately 2007, Siemens AG made payments totaling approximately $1.36 billion through various mechanisms. Of this amount, approximately $554.5 million was paid for unknown purposes, including approximately $341 million in direct payments to business consultants for unknown purposes. The remaining $805.5 million of this amount was intended in whole or in part as corrupt payments to foreign officials in Asia, Africa, Europe, the Middle East and the Americas, which were to be paid through various mechanisms, including cash desks and slush funds. The criminal charges against Siemens AG and its three subsidiaries stem from bribery schemes and related accounting misconduct involving its operations in Iraq, Argentina, Venezuela, and Bangladesh.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Siemens Aktiengesellschaft (Siemens AG) Case Summary at 70-73.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Siemens Aktiengesellschaft (Siemens AG) Case Summary at 70-73, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Siemens AG, Case No. 1:08-cr-367-RJL (D.D.C.), Information filed December 12, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-12-08siemensakt-info.pdf; Plea Agreement filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-15-08siemensakt-plea.pdf; Statement of Offense filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-15-08siemens-statement.pdf; Government Sentencing Memorandum filed December 12, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-12-08siemensvenez-sent.pdf; Judgment filed January 6, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/01-06-09siemensakt-judgment.pdf.  US Department of Justice Press Release, \u0022Siemens AG and Three Subsidiaries Plead Guilty to Foreign Corrupt Practices Act Violations and Agree to Pay $450 Million in Combined Criminal Fines,\u0022 December 15, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/December\/08-crm-1105.html","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_AG_DOJ_Information_Dec_12_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_AG_DOJ_Statement_of_Offense_December_15_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_AG_DOJ_Judgment_Jan_6_2009.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_AG_DOJ_Govt_Sentencing_Memorandum_Dec_12_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_AG_DOJ_Plea_Transcript_Press_Conference_Dec_15_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_AG_DOJ_Plea_PR_Dec_15_2008.pdf"},{"Case ID":"ST-319","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"Milan Prosecutors Office","Jurisdiction of Foreign Public Official(s) ":"Italy","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"07\/25","Other Jurisdictions of Settlement":"Germany, United States, World Bank","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Fine, Disgorgement of Profits","Total Monetary Sanctions (US$)":"$8,373,905.00","Criminal Fine\/Penalty (US$) ":"$632,375","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$7,741,530","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Legislative Decree No. 231 of 8 June 2001 - Administrative Liability of Legal Persons ","Offenses - Settled":"Legislative Decree No. 231 of 8 June 2001 - Administrative Liability of Legal Persons ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the July 2006 Sentence ordered by the Milan Tribunal, Siemens entered into a plea agreement regarding the bribery by its executives of officials at state owned-Enelpower.  According to the Sentence, the executives made bribery payments to the CEO of  EnelProduzione and CEO of Enelpower in order to obtain secret information related to the bids.  The bribe payments passed from bank accounts in Liechtenstein or via the Emirates Bank International (subsidiary of a British Virgin Island company) to different accounts of which the Enel executives were beneficiaries, via accounts of a foreign established company (the MEEISCO LLC), which was under the control of an intermediary. (Source: Sentence against Siemens AG and individual defendants issued by the Il Tribunale Ordinario di Milano (25 July 2006)).  ","Sources ":"Sentence against Siemens AG and individual defendants issued by the Il Tribunale Ordinario di Milano (25 July 2006), accessed at http:\/\/www.penalecontemporaneo.it\/upload\/Trib.%20Milano,%2025.7.2006%20_sent._,%20GUP%20Varanelli%20_Confisca_.pdf; text of Legislative Decree No. 231 of 8 June 2001 -- Administrative Liability of Legal Persons excerpted in Phase 3 Report on Implementing the OECD Anti Bribery Convention in Italy (December 2011), accessed at  http:\/\/www.oecd.org\/dataoecd\/59\/47\/49377261.pdf repalce with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Trib.%20Milano%2C%2025.7.2006%20_sent._%2C%20GUP%20Varanelli%20_Confisca_it.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/OECD_Italy_Phase_3_Report_Dec_2011.pdf"},{"Case ID":"ST-320","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina, Bangladesh, China, Iraq (UN Oil-for-Food), Israel, Mexico, Nigeria, Russia, Venezuela, Vietnam","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"12\/15","Other Jurisdictions of Settlement":"Germany, World Bank ","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits","Total Monetary Sanctions (US$)":"$350,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$350,000,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, on December 12, 2008, the Commission filed a settled civil complaint which alleged that \u0022Between March 12, 2001 and September 30, 2007, Siemens violated the FCPA by engaging in a widespread and systematic practice of paying bribes to foreign government officials to obtain business. Siemens created elaborate payment schemes to conceal the nature of its corrupt payments, and the company\u0027s inadequate internal controls allowed the conduct to flourish. The misconduct involved employees at all levels, including former senior management, and revealed a corporate culture long at odds with the FCPA. During this period, Siemens made thousands of payments to third parties in ways that obscured the purpose for, and the ultimate recipients of, the money. At least 4,283 of those payments, totaling approximately $1.4 billion, were used to bribe government officials in return for business to Siemens around the world. Among others, Siemens paid bribes on transactions to design and build metro transit lines in Venezuela; metro trains and signaling devices in China; power plants in Israel; high voltage transmission lines in China; mobile telephone networks in Bangladesh; telecommunications projects in Nigeria; national identity cards in Argentina; medical devices in Vietnam, China, and Russia; traffic control systems in Russia; refineries in Mexico; and mobile communications networks in Vietnam. Siemens also paid kickbacks to Iraqi ministries in connection with sales of power stations and equipment to Iraq under the United Nations Oil for Food Program. Siemens earned over $1.1 billion in profits on these transactions.   An additional approximately 1,185 separate payments to third parties totaling approximately $391 million were not properly controlled and were used, at least in part, for illicit purposes, including commercial bribery and embezzlement.\u0022  The Litigation Release also noted that Siemens consented to the SEC \u0022ordering it to pay $350 million in disgorgement of wrongful profits, which does not include profits factored into Munich\u0027s fine.\u0022  The Litigation Release also noted that assistance was provided to the SEC investigation by the Office of the Prosecutor General in Munich, Germany; the U.K. Financial Services Authority; and the Hong Kong Securities and Futures Commission. (Source:  US Securities and Exchange Commission Litigation Release No. 20829 \/ December 15, 2008, Securities and Exchange Commission v. Siemens Aktiengesellschaft, Civil Action No. 08 CV 02167 (D.D.C.), \u0022SEC Files Settled Foreign Corrupt Practices Act Charges Against Siemens AG for Engaging in Worldwide Bribery With Total Disgorgement and Criminal Fines of Over $1.6 Billion.\u0022)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Siemens Aktiengesellschaft (Siemens AG) Case Summary at 70-73, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20829 \/ December 15, 2008, Securities and Exchange Commission v. Siemens Aktiengesellschaft, Civil Action No. 08 CV 02167 (D.D.C.), \u0022SEC Files Settled Foreign Corrupt Practices Act Charges Against Siemens AG for Engaging in Worldwide Bribery With Total Disgorgement and Criminal Fines of Over $1.6 Billion,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20829.htm; Complaint filed December 12, 2008, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20829.pdf","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_SEC_Amended_Complaint.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_SEC_Litigation_Release_Settlement_Dec_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_SEC_Litigation_Release.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_SEC_DDC_Docket_Report.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_SEC_Final_Judgment.pdf"},{"Case ID":"ST-321","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"","Jurisdiction of Settlement \/ Enforcement Agency":"Integrity Vice Presidency","Jurisdiction of Foreign Public Official(s) ":"Various","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"7\/2","Other Jurisdictions of Settlement":"Germany, United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Establishment of Special Fund, Debarment,  \u0022Voluntary restraint\u0022 from bidding on World Bank projects for two years","Monetary Sanctions  (Types)":"Special Fund","Total Monetary Sanctions (US$)":"$100,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"$100,000,000","Other Civil Monetary Sanctions (Explanation)":"Special Fund","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$100,000,000","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Integrity initiative fund","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Corruption in a project in Russia involving a subsidiary","Offenses - Settled":"Corruption in a project in Russia involving a subsidiary","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the World Bank Press Release, \u0022The World Bank Group today announced a comprehensive settlement with Siemens AG in the wake of the company\u0027s acknowledged past misconduct in its global business and a World Bank investigation into corruption in a project in Russia involving a Siemens subsidiary. The settlement includes a commitment by Siemens to pay $100 million over the next 15 years to support anti-corruption work, an agreement of up to a four-year debarment for Siemens\u0027 Russian subsidiary, and a voluntary two-year shut-out from bidding on Bank business for Siemens AG and all of its consolidated subsidiaries and affiliates. [  ]  Siemens\u0027 commitment to pay $100 million to support global efforts to fight fraud and corruption would include providing funds to organizations and projects aimed at combating corruption through collective action, training, education. The money will also be directed to helping governments to recover assets stolen by corrupt leaders, and strengthening efforts to identify and crack-down on corrupt practices.  The World Bank Group will have audit rights over the use of these funds and veto rights over the selection of anticorruption groups or programs receiving funds.\u0022 (Source:  The World Bank, \u0022Siemens to pay $100m to fight corruption as part of World Bank Group settlement,\u0022 Press Release No:2009\/001\/EXT, July 2, 2009.)","Sources ":"World Bank Group -  Siemens Settlement Agreement, \u0022FACT SHEET,\u0022 accessed at http:\/\/siteresources.worldbank.org\/INTDOII\/Resources\/Siemens_Fact_Sheet_Nov_11.pdf; The World Bank, \u0022Siemens to pay $100m to fight corruption as part of World Bank Group settlement,\u0022 Press Release No:2009\/001\/EXT, July 2, 2009, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,contentMDK:22234573~pagePK:34370~piPK:34424~theSitePK:4607,00.html;  Siemens and The World Bank, \u0022Siemens selects initial projects for US$100 million Integrity Initiative,\u0022 December 9, 2010, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/TOPICS\/EXTLAWJUSTICE\/0,,contentMDK:22786119~menuPK:2643814~pagePK:64020865~piPK:149114~theSitePK:445634,00.html.  Additional information on Integrity Initiative at http:\/\/www.siemens.com\/sustainability\/en\/core-topics\/collective-action\/integrity-initiative\/index.php","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_World_Bank_Settlement_Press_Release_2009.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_Fact_Sheet_Nov_11_World_Bank_Settlement.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Siemens_World_Bank_2010_Initiative_Recipients_PR_Dec_2010.pdf"},{"Case ID":"ST-323","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"12\/13","Other Jurisdictions of Settlement":"Germany","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Aiding and Abetting Siemens\u0027 Bribery of Foreign Officials; Falsification of Books and Records; Aiding and Abetting Siemens\u0027 Failure to Maintain Internal Controls; Aiding and Abetting Siemens\u0027 Failure to Maintain Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Litigation Release, \u0022From approximately 1996 until early 2007, senior executives at Siemens and its regional company in Argentina, Siemens S.A. (\u0022Siemens Argentina\u0022), paid bribes to senior Argentine government officials -- including two Presidents, and Cabinet Ministers in two Presidential administrations. The bribes were initially paid to secure a $1 billion government contract (the \u0022DNI Contract\u0022) to produce national identity cards, or Documentos Nacionales de Identidad, for every Argentine citizen. Later, after a change in Argentine political administrations resulted in the DNI Contract being suspended and then canceled, Siemens paid additional bribes in a failed effort to bring the DNI Contract back into force. Still later, after the company instituted an arbitration proceeding to recover its costs and expected profits from the canceled DNI Contract, Siemens paid additional bribes to suppress evidence that the DNI Contract had originally been obtained through corruption. Over the course of the bribery scheme, over $100 million in bribes were paid, approximately $31.3 million of which were made after March 12, 2001, when Siemens became a U.S. issuer subject to U.S. securities laws. As a result of the bribe payments it made, Siemens received an arbitration award in 2007 against the government of Argentina of over $217 million plus interest for the DNI Contract. In August 2009, after settling bribery charges with the U.S. and Germany, Siemens waived the arbitration award.  During the relevant 2001 to 2007 time period, defendants Uriel Sharef, Ulrich Bock, Carlos Sergi, Stephan Signer, Herbert Steffen, Andres Truppel, and Bernd Regendantz each had a role in authorizing, negotiating, facilitating, or concealing bribe payments in connection with the DNI Contract. Siemens employed a group of consultants, designated the Project Group and led by defendant Sergi, to serve as payment intermediaries between the company and the Argentine government officials.\u0022  Without admitting or denying the SEC\u0027s allegations, defendant Bernd Regendantz has consented to the entry of a final judgment that permanently enjoins him from future violations and orders him to pay a civil penalty of $40,000, deemed satisfied by Regendantz\u0027 payment of a ?30,000 administrative fine ordered by the Public Prosecutor General in Munich, Germany. (Source: Securities and Exchange Commission Litigation Release No. 22190 \/ December 13, 2011, \u0022Securities and Exchange Commission v. Uriel Sharef, Ulrich Bock, Carlos Sergi, Stephan Signer, Herbert Steffen, Andres Truppel and Bernd Regendantz, Civil Action No. 11 civ 9073 (Judge Scheidlin\/Pitman) (S.D.N.Y.) \/ SEC Charges Seven Former Siemens Executives with Bribing Leaders in Argentina.\u0022)","Sources ":"US Securities and Exchange Commission v. Sharef, et al, Case No. 1:11-cv-9073 (S.D.N.Y.), Complaint filed December 13, 2011, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp22190.pdf; Securities and Exchange Commission Litigation Release No. 22190 \/ December 13, 2011, \u0022Securities and Exchange Commission v. Uriel Sharef, Ulrich Bock, Carlos Sergi, Stephan Signer, Herbert Steffen, Andres Truppel and Bernd Regendantz, Civil Action No. 11 civ 9073 (Judge Scheidlin\/Pitman) (S.D.N.Y.) \/ SEC Charges Seven Former Siemens Executives with Bribing Leaders in Argentina,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr22190.htm","Documents":""},{"Case ID":"ST-325","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice ","Jurisdiction of Foreign Public Official(s) ":"Bangladesh","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"12\/15","Other Jurisdictions of Settlement":"Germany, World Bank ","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$500,000.00","Criminal Fine\/Penalty (US$) ":"$500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 11, 2008, Siemens Aktiengesellschaft (Siemens AG), a German corporation, and three of its subsidiaries were charged in separate criminal informations filed in the U.S. District Court for the District of Columbia for their roles in a scheme to bribe foreign officials in several countries.  [  ] Bangladesh: From 2001 through 2006, Siemens Bangladesh caused corrupt payments of at least $5,319,839 to be made through purported business consultants to various Bangladeshi officials in exchange for favorable treatment during the bidding process on a mobile telephone project. At least one payment to each of these purported consultants was paid from a U.S. bank account.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Siemens Aktiengesellschaft (Siemens AG) Case Summary at 70-73.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Siemens Aktiengesellschaft (Siemens AG) Case Summary at 70-73, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Siemens Bangladesh Limited, Case No. 1:08-cr-369-RJL (D.D.C.), Information filed December 12, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-12-08siemensbangla-info.pdf; Plea Agreement filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-15-08siemensbangla-plea.pdf; Statement of Facts filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-15-08siemensbangla-statement.pdf; Judgment filed January 6, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/01-06-09siemensbangla-judgment.pdf","Documents":""},{"Case ID":"ST-326","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"Greece","Jurisdiction of Settlement \/ Enforcement Agency":"Parliament","Jurisdiction of Foreign Public Official(s) ":"Greece","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"04\/05","Other Jurisdictions of Settlement":"Italy, Nigeria, United States, World Bank","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Other","Legal Form of Settlement":"Parliamentary Decree","Monetary Sanctions  (Types)":"Other (Waiver of EUR80 million in obligations owed by Greek Government to Siemens; Payment of EUR90 million to finance anti-corruption platform; Investment of EUR 100 million to Siemens\u0027 activities within Greece)","Total Monetary Sanctions (US$)":"$355,703,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"$355,703,000","Other Civil Monetary Sanctions (Explanation)":"various; please see case summary","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$355,703,000","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the April 5, 2012 press release by Siemens, \u0022Today, the Hellenic Parliament ratified the settlement agreement between Siemens and the Greek State. This marks the beginning of a new chapter in Siemens\u0027 long history in Greece. The Greek Government\u0027s commitment to foster growth was one of the pillars on which this agreement was based. This agreement will allow Siemens to continue to be a real supporter. To this end, Siemens will explore actual and substantial areas of investment in Greece, with special emphasis to sectors which increase employment and support the economy. In total, this settlement will reach approximately 270 million Euro. In this context, Siemens waives claims of ?80 million that concern implemented projects and the delivery of equipment to the Greek State. Siemens will dispense up to the amount of 90 million Euro for transparency initiatives and anti-corruption programs, as well as for academic and research programs that aim at enhancing Greece\u0027s competitiveness. Finally, Siemens will spend over ?100 million, in order to enhance its activities in Greece and preserve a significant number of jobs in the local market.\u0022 (Source: Siemens AG Company Press Release, \u0022Siemens and the Hellenic Republic reach a settlement agreement and mark a new beginning,\u0022 April 5, 2012.)","Sources ":"Siemens AG Company Press Release, \u0022Siemens and the Hellenic Republic reach a settlement agreement and mark a new beginning,\u0022 April 5, 2012, accessed at http:\/\/www.siemens.com\/press\/pool\/de\/pressemitteilungen\/2012\/corporate\/AXX20120420e.pdf; Organisation for Economic Co-operation and Development, \u0022PHASE 3 REPORT ON IMPLEMENTING THE OECD ANTI-BRIBERY CONVENTION IN GREECE, JUNE 2012,\u0022 accessed at http:\/\/www.oecd.org\/dataoecd\/21\/2\/50633313.pdf","Documents":""},{"Case ID":"ST-327","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"12\/15","Other Jurisdictions of Settlement":"Germany, World Bank ","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$500,000.00","Criminal Fine\/Penalty (US$) ":"$500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to Falsifiy Books and Records","Offenses - Settled":"Conspiracy to Falsify Books and Records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 11, 2008, Siemens Aktiengesellschaft (Siemens AG), a German corporation, and three of its subsidiaries were charged in separate criminal informations filed in the U.S. District Court for the District of Columbia for their roles in a scheme to bribe foreign officials in several countries.  [  ]   From 1998 through 2007, Siemens Argentina made and caused to be made significant payments to various Argentine officials, both directly and indirectly, in exchange for favorable business treatment in connection with a $1 billion national identity card project. From March 2001 through January 2007, Siemens Argentina paid approximately $31,263,000 in corrupt payments to various Argentine officials through purported consultants and other conduit entities, and improperly characterized those corrupt payments in its books and records as legitimate payments for \u0022consulting fees\u0022 or \u0022legal fees.\u0022  Siemens Argentina\u0027s books and records were subsequently incorporated into the books and records of Siemens AG.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Siemens Aktiengesellschaft (Siemens AG) Case Summary at 70-73.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Siemens Aktiengesellschaft (Siemens AG) Case Summary at 70-73, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Siemens Argentina S.A., Case No. 1:08-cr368-RJL (D.D.C.), Information filed December 12, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-12-08siemensargen-info.pdf; Plea Agreement filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-15-08siemensargen-plea.pdf; Statement of Offense filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-15-08siemensargen-statement.pdf; Judgment filed January 6, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/01-06-09siemensarg-judgment.pdf.","Documents":""},{"Case ID":"ST-328","Case Cluster ":"Siemens AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"12\/15","Other Jurisdictions of Settlement":"Germany, The World Bank","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$500,000.00","Criminal Fine\/Penalty (US$) ":"$500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 11, 2008, Siemens Aktiengesellschaft (Siemens AG), a German corporation, and three of its subsidiaries were charged in separate criminal informations filed in the U.S. District Court for the District of Columbia for their roles in a scheme to bribe foreign officials in several countries.  [  ]  From 2001 through 2007, Siemens Venezuela made and caused to be made corrupt payments of at least $18,782,965 to various Venezuelan officials, indirectly through purported business consultants, in exchange for favorable business treatment in connection with two major metropolitan mass transit projects called Metro Valencia and Metro Maracaibo. Some of those payments were made using U.S. bank accounts controlled by the purported business consultants.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Siemens Aktiengesellschaft (Siemens AG) Case Summary at 70-73.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Siemens Aktiengesellschaft (Siemens AG) Case Summary at 70-73, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US v. Siemens S.A. (Venezuela), Case No. 1:08-cr-370-RJL (D.D.C.), Information filed December 12, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-12-08siemensvenez-info.pdf; Plea Agreement filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-15-08siemensvenez-plea.pdf; Statement of Offense filed December 15, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-15-08siemensvenez-statement.pdf; Judgment filed January 6, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/siemens\/12-15-08siemensvenez-statement.pdf","Documents":""},{"Case ID":"ST-330","Case Cluster ":"SINTEF Petroleum Research","Jurisdiction of Settlement":"Norway","Jurisdiction of Settlement \/ Enforcement Agency":"\u00d8kokrim","Jurisdiction of Foreign Public Official(s) ":"Iran","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"11\/02","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Penalty Notice","Monetary Sanctions  (Types)":"Criminal Penalty","Total Monetary Sanctions (US$)":"$370,782.00","Criminal Fine\/Penalty (US$) ":"$370,782","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Aggravated Bribery (criminal law, section 276b)","Offenses - Settled":"[Aggravated Bribery] - unclear from sources what was agreed to","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a SINTEF Petroleum Research\u0027s statement posted on its website: \u0022The Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime (\u00d8kokrim) has fined SINTEF Petroleum Research (SPR) NOK 2 million in connection with a consulting contract signed with an Iranian company in 2002. \u201cWe accept the fine\u201d, says SPR President May Britt Myhr. \u201cSINTEF has prioritised upgrading its routines from the day we became aware of this matter, so we are pleased that \u00d8kokrim acknowledges that we have implemented a number of measures to prevent such incidents from happening again. We will certainly use this experience in our continued development of SINTEF into an internationally leading research company\u201d, states SINTEF President Unni Steinsmo. [  ] \u00d8kokrim has concluded that a consulting contract SPR signed with an Iranian company in 2002 broke the law. \u00d8kokrim launched an investigation of SPR in August 2005 after the NOPEF trade union had reported the company to the authorities. \u00d8kokrim believes that the contract was in breach of criminal law. It has therefore fined SPR and has charged the former President of SPR with serious corruption (General Civil Penal Code, \u00a7276a, see \u00a7276b).\u0022  (Source:  SINTEF Press Release, \u0022SINTEF Petroleum Research Accepts Fine,\u0022 Published November 2, 2007.).  The second case concerns bribery by a research and consulting company (\u201cthe Research Company case\u201d). According to Norway\u0027s June 2011 OECD Phase 3 Report on the enforcement of the Anti-Bribery Convention, \u0022\u00d8kokrim charged a senior executive of that company with serious corruption, and issued a penalty notice to the company in connection with a consulting contract signed with a foreign company in 2002. \u00d8kokrim launched an investigation on the company in 2005, following an internal whistleblower report. \u00d8kokrim believed that the contract was in breach of criminal law, section 276b (aggravated bribery). The company\u201fs fine was in the amount of NOK 2 million, which was accepted. In May 2007, the senior executive was acquitted by the Court of First Instance, who found there was insufficient evidence to convict.\u0022 (Source: Norway Phase-3 Report at para 16.)  The case summary on \u00d8kokrim\u0027s website states that SINTEF\u0027s contract involved an Iranian entity, as well as payments to Hinson Engineering Limited, which was registered in the British Virgin Islands and held a bank account in Switzerland (\u0022Hinson Agreement\u0022) (Source: \u00d8kokrim, \u0022Korrupsjon - SINTEF Petroleumsforskning AS,\u0022 updated April 22, 2009.)","Sources ":"SINTEF Press Release, \u0022SINTEF Petroleum Research Accepts Fine,\u0022 Published November 2, 2007, accessed at http:\/\/www.sintef.no\/home\/Press-Room\/Press-Releases\/SINTEF-Petroleum-Research-accepts-fine\/; Organisation for Economic Co-operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Norway, June 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/38\/59\/48286802.pdf;  replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Norwayphase3reportEN.pdf;  \u00d8kokrim, \u0022SINTEF Petroleumsforskning AS,\u0022 updated April 22, 2009, accessed at http:\/\/www.okokrim.no\/artikler\/sak-sintef","Documents":""},{"Case ID":"ST-331","Case Cluster ":"Smith \u0026 Nephew plc","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Greece","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"02\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$5,426,799.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$4,028,000","Civil Prejudgment Interest (US$) ":"$1,398,799","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, \u0022Smith \u0026 Nephew PLC, headquartered in London, England, is a global medical device company with operations around the world. The SEC alleges that, from 1997 to June 2008, two of Smith \u0026Nephew PLC\u0027s subsidiaries, including its U.S. subsidiary, Smith \u0026 Nephew Inc., used a distributor to create a slush fund to make illicit payments to public doctors employed by government hospitals or agencies in Greece. [  ] The SEC\u0027s complaint alleges that, starting in 1997, Smith \u0026 Nephew PLC\u0027s subsidiaries developed a scheme to create an offshore fund to pay Greek public doctors to purchase products from two Smith \u0026 Nephew PLC subsidiaries, Smith \u0026 Nephew Inc. and Smith \u0026 Nephew GmbH. According to the complaint, Smith \u0026 Nephew PLC\u0027s subsidiaries made payments to a total of three shell entities in the United Kingdom controlled by the distributor that were used to pay bribes. The complaint alleges that on paper, it appeared as if Smith \u0026 Nephew PLC\u0027s subsidiaries were paying for marketing services, but no services were actually performed. The complaint also alleges that Smith \u0026 Nephew PLC failed to act on numerous red flags of bribery and that employees at Smith \u0026 Nephew PLC and its subsidiaries were aware of the payments.\u0022 (Source: US Securities and Exchange Commission Litigation Release, Litigation Release 22252 \/ February 6, 2012, Securities and Exchange Commission v. Smith \u0026 Nephew PLC, Civil Action No. 1: 12-CV-00187 (D.D.C.)(GK) (February, 6, 2012).","Sources ":"US Securities and Exchange Commission Litigation Release, Litigation Release 22252 \/ February 6, 2012, Securities and Exchange Commission v. Smith \u0026 Nephew PLC, Civil Action No. 1: 12-CV-00187 (D.D.C.)(GK) (February, 6, 2012), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2012\/lr22252.htm; complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp22252.pdf","Documents":""},{"Case ID":"ST-332","Case Cluster ":"Smith \u0026 Nephew plc","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Greece","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"02\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$16,800,000.00","Criminal Fine\/Penalty (US$) ":"$16,800,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022Smith \u0026 Nephew Inc. has entered into a deferred prosecution agreement with the Department of Justice to resolve improper payments by the company and certain affiliates in violation of the Foreign Corrupt Practices Act (FCPA) [ ].  Smith \u0026 Nephew, a Delaware corporation, is headquartered in Memphis, Tenn., and is a wholly-owned subsidiary of Smith \u0026 Nephew plc, an English company traded on the New York Stock Exchange.  The company manufactures and sells medical devices worldwide.  Smith \u0026 Nephew acknowledged responsibility for the actions of its affiliates, subsidiaries, employees and agents who made various improper payments to publicly-employed health care providers in Greece from 1998 until 2008 to secure lucrative business.  According to the criminal information filed today in U.S. District Court in the District of Columbia in connection with the agreement, Smith \u0026 Nephew, through certain executives, employees and affiliates, agreed to sell products at full list price to a Greek distributor based in Athens, and then pay the amount of the distributor discount to an off-shore shell company controlled by the distributor. These off-the-books funds were then used by the distributor to pay cash incentives and other things of value to publicly-employed Greek health care providers to induce the purchase of Smith \u0026 Nephew products. In total, from 1998 to 2008, Smith \u0026 Nephew, its affiliates and employees authorized the payment of approximately $9.4 million to the distributor\u0027s shell companies, some or all of which was passed on to physicians to corruptly induce them to purchase medical devices manufactured by Smith \u0026 Nephew. [  ] The Justice Department acknowledges and expresses its appreciation for the assistance provided by the authorities of the 8th Ordinary Interrogation Department of the Athens Court of First Instance and the Athens Economic Crime Squad in Greece.\u0022  (Source: US Department of Justice Press Release, \u0022Medical Device Company Smith \u0026 Nephew Resolves Foreign Corrupt Practices Act Investigation,\u0022 February 6, 2012.)","Sources ":"US Department of Justice Press Release, \u0022Medical Device Company Smith \u0026 Nephew Resolves Foreign Corrupt Practices Act Investigation,\u0022 February 6, 2012, accessed at http:\/\/www.justice.gov\/opa\/pr\/2012\/February\/12-crm-166.html.","Documents":""},{"Case ID":"ST-333","Case Cluster ":"Solvochem Holland BV","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Rijksrecherche (Dutch Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Out of court settlement","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$447,219.00","Criminal Fine\/Penalty (US$) ":"$216,762","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$230,457","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"","Offenses - Settled":"Sanctions legislation by paying kickbacks when implementing UN Oil-for-Food Programme","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Netherlands Phase 2 Report of the OECD Anti-Bribery Working Group (December 17, 2008): \u0022As of October 2008, no foreign bribery cases had been brought before the Dutch courts. Nevertheless, the prosecution authorities have concluded out-of-court transactions with seven companies for paying kickbacks in the context of the Oil-for-Food Programme in Iraq, although the offence charged was the violation of sanctions legislation and not the foreign bribery offence.\u0022 (para 2); \u0022 the Prosecution Department reports that it has concluded financial transactions (out of court settlements) with 7 companies for violating sanction legislation by paying kickbacks when implementing the Oil for Food Programme. Criminal gains have also been confiscated. In July 2008 a press release has been issued about these settlements. Together with the names of the companies (Alfasan International B.V., N.V. Organon, Flowserve B.V. , OPW Fluid Transfer Group Europe B.V., Prodetra B.V. Solvochem Holland B.V., Stet Holland B.V.) the settlements have been made public. For the following Oil-for-food transactions out-of-court settlements have been reached: 1. Alfasan International BV Woerden, fine: \u20ac 31.800,-- and confiscation \u20ac 10.183,55 2. NV Organon Oss, fine: \u20ac 381.602 3. Flowerserve bv te Etten-Leur, fine: \u20ac 76.274 and confiscation \u20ac180.260 4. OPW Fluid Transfer Group Europe BV, Nieuw Vennep, fine \u20ac 57.204 and confiscation \u20ac 24.600 5. Prodetra bv,Wadinxveen, fine: 64.751 and confiscation \u20ac 34.485,95 6. Solvochem Holland bv, Rotterdam, fine \u20ac 136.000 and confiscation \u20ac 144.592 7. Stet Holland bv,Emmeloord, fine \u20ac 119.712 and confiscation \u20ac 54.458.\u0022 (Source: Ibid., at 14.)","Sources ":"Organisation for Economic Co-Operation and Development Anti-Bribery Working Group, The Netherlands Phase 2 Report (December 17, 2008), accessed at http:\/\/www.oecd.org\/dataoecd\/61\/59\/41919004.pdf; Melissa Lipman, \u0022Cos. Settle Dutch Probe Into Oil-For-Food For \u20ac1.3M,\u0022 Law 360, July 16, 2008, accessed at http:\/\/www.law360.com\/articles\/62486\/cos-settle-dutch-probe-into-oil-for-food-for-1-3m (partial article, gives date of Dutch Public Prosecution Service press release which is July 15, 2008.)","Documents":""},{"Case ID":"ST-334","Case Cluster ":"Statoil ASA","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iran","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"10\/13","Other Jurisdictions of Settlement":"Norway","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$10,500,000.00","Criminal Fine\/Penalty (US$) ":"$10,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022In 2001 and 2002, Statoil sought to expand its business internationally, and focused specifically on Iran as a country in which to secure oil and gas development rights. At the time, Iran was awarding contracts for the development of the South Pars field, one of the largest natural gas fields in the world. In 2001, Statoil developed contacts with an Iranian government official who was believed to have influence over the award of oil and gas contracts in Iran. Following a series of negotiations with the Iranian official in 2001 and 2002, Statoil entered into a -- consulting contract\u2016 with an offshore intermediary company. The purpose of that consulting contract -- which called for the payment of more than $15 million over 11 years -- was to induce the Iranian official to use his influence to assist Statoil in obtaining a contract to develop portions of the South Pars field and to open doors to additional Iranian oil and gas projects in the future. Two bribe payments totaling more than $5 million were actually made by wire transfer through a New York bank account, and Statoil was awarded a South Pars development contract that was expected to yield millions of dollars in profit.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Statoil ASA Case Summary at 112-113.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Statoil ASA Case Summary at 112-113, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Statoil ASA, Case No. 1:06-cv-00960-RJH-1 (SDNY), Information filed October 13, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/statoil-asa-inc\/10-13-09statoil-information.pdf; Deferred Prosecution Agreement accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/statoil-asa-inc\/10-09-06statoil-agree.pdf.  See also, US Dept. of Justice Press Release, \u0022U.S. Resolves Probe against Oil Company that Bribed Iranian Official,\u0022 October 13, 2006, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/October06\/statoildeferredprosecutionagreementpr.pdf.","Documents":""},{"Case ID":"ST-335","Case Cluster ":"Statoil ASA","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iran","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"10\/13","Other Jurisdictions of Settlement":"Norway","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits","Total Monetary Sanctions (US$)":"$10,500,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$10,500,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, False Accounting Violations, Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022In 2001 and 2002, Statoil sought to expand its business internationally, and focused specifically on Iran as a country in which to secure oil and gas development rights. At the time, Iran was awarding contracts for the development of the South Pars field, one of the largest natural gas fields in the world. In 2001, Statoil developed contacts with an Iranian government official who was believed to have influence over the award of oil and gas contracts in Iran. Following a series of negotiations with the Iranian official in 2001 and 2002, Statoil entered into a -- consulting contract\u2016 with an offshore intermediary company. The purpose of that consulting contract -- which called for the payment of more than $15 million over 11 years -- was to induce the Iranian official to use his influence to assist Statoil in obtaining a contract to develop portions of the South Pars field and to open doors to additional Iranian oil and gas projects in the future. Two bribe payments totaling more than $5 million were actually made by wire transfer through a New York bank account, and Statoil was awarded a South Pars development contract that was expected to yield millions of dollars in profit.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Statoil ASA Case Summary at 112-113.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Statoil ASA Case Summary at 112-113.  US Securities and Exchange Commission, In the Matter of Statoil ASA, Administrative Proceeding File No. 3-12453, Order Instituting Cease-and-Desist Proceedings, October 13, 2006, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2006\/34-54599.pdf","Documents":""},{"Case ID":"ST-336","Case Cluster ":"Statoil ASA","Jurisdiction of Settlement":"Norway","Jurisdiction of Settlement \/ Enforcement Agency":"\u00d8kokrim","Jurisdiction of Foreign Public Official(s) ":"Iran","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"06\/29","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Penalty Notice ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$3,000,000.00","Criminal Fine\/Penalty (US$) ":"$3,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Breach of trading influence (section 276c of the General Civil Penal Code); Bribery of Foreign Officials","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 OECD Phase 3 Report on Norway: \u0022A first case (\u201cthe Oil Company case\u201d) had been initiated at the time of the Phase 2 evaluation of Norway in 2004. \u00d8kokrim issued penalty notices to a large state-owned oil company, and a senior executive of the company. On 28 June 2004, \u00d8kokrim issued penalty notices to the oil company and the company\u201fs former executive Vice President. The Vice President had negotiated an agreement with a company registered in an off-shore jurisdiction, according to which the latter was to perform various consulting services for the oil company for an 11 year period. The oil company was to pay a total fee of USD 15.2 million for these alleged services. Payments were made to a foreign bank account in the name of a third company. In September 2003, following exposure by a Norwegian newspaper, the agreement was terminated. The real purpose of the agreement was to channel funds to a foreign citizen in return for his or others influencing individuals who were involved in decision-making relevant to the company\u201fs commercial activities in the foreign jurisdiction, including administrative acts concerning the awarding of contracts in the oil and gas sector. The advantage to be conferred according to the agreement was improper, notably because of the amount of the remuneration, and because the true purpose of the agreement was concealed. This consultancy contract was entered into in breach of the oil company\u201fs internal guidelines. The penalty notice stated that the senior executive failed to arrange for the termination of the agreement as soon as possible after the entering into force of the new Norwegian corruption legislation on 4 July 2003. The penalty notices describe the offences as a breach of the trading of influence statute (section 276c of the General Civil Penal Code) [ ]  The company\u201fs fine was in the amount of NOK 20 million (EUR 2.4 million; USD 3 million), and the vice president\u201fs NOK 200 000 (EUR 24 000). Both fines were accepted.15 As the oil company was listed on the New York Stock Exchange, it was also fined, in a deferred prosecution agreement, USD 10.5 million by the Department of Justice (out of which the USD 3 million already paid to Norway was deducted); the Securities and Exchange Commission further required the company to disgorge USD 10.5 million.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Norway,\u0022 June 2011, at 7-8.)","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Norway,\u0022 June 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/38\/59\/48286802.pdf, replace with  http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Norwayphase3reportEN.pdf ; Staoil Company Press Release, \u0022Statoil accepts \u00d8kokrim penalty in the Horton case,\u0022 October 14, 2004, accessed at http:\/\/www.statoil.com\/en\/NewsAndMedia\/News\/2004\/Pages\/StatoilAcceptsOkokrimPenaltyInTheHortonCase.aspx","Documents":""},{"Case ID":"ST-337","Case Cluster ":"Statoil ASA","Jurisdiction of Settlement":"Norway","Jurisdiction of Settlement \/ Enforcement Agency":"\u00d8kokrim","Jurisdiction of Foreign Public Official(s) ":"Iran","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"06\/29","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Penalty Notice ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$29,225.70","Criminal Fine\/Penalty (US$) ":"$29,225.70","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Breach of trading influence (section 276c of the General Civil Penal Code)","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 OECD Phase 3 Report on Norway: \u0022A first case (\u0022the Oil Company case\u0022) had been initiated at the time of the Phase 2 evaluation of Norway in 2004. \u00d8kokrim issued penalty notices to a large state-owned oil company, and a senior executive of the company. On 28 June 2004, \u00d8kokrim issued penalty notices to the oil company and the company\u0027s former executive Vice President. The Vice President had negotiated an agreement with a company registered in an off-shore jurisdiction, according to which the latter was to perform various consulting services for the oil company for an 11 year period. The oil company was to pay a total fee of USD 15.2 million for these alleged services. Payments were made to a foreign bank account in the name of a third company. In September 2003, following exposure by a Norwegian newspaper, the agreement was terminated. The real purpose of the agreement was to channel funds to a foreign citizen in return for his or others influencing individuals who were involved in decision-making relevant to the company\u0027s commercial activities in the foreign jurisdiction, including administrative acts concerning the awarding of contracts in the oil and gas sector. The advantage to be conferred according to the agreement was improper, notably because of the amount of the remuneration, and because the true purpose of the agreement was concealed. This consultancy contract was entered into in breach of the oil company\u0027s internal guidelines. The penalty notice stated that the senior executive failed to arrange for the termination of the agreement as soon as possible after the entering into force of the new Norwegian corruption legislation on 4 July 2003. The penalty notices describe the offences as a breach of the trading of influence statute (section 276c of the General Civil Penal Code) [ ]  The company\u0027s fine was in the amount of NOK 20 million (EUR 2.4 million; USD 3 million), and the vice president\u0027s NOK 200 000 (EUR 24 000). Both fines were accepted. [  ]  As the oil company was listed on the New York Stock Exchange, it was also fined, in a deferred prosecution agreement, USD 10.5 million by the Department of Justice (out of which the USD 3 million already paid to Norway was deducted); the Securities and Exchange Commission further required the company to disgorge USD 10.5 million.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Norway,\u0022 June 2011, at 7-8.)","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Norway,\u0022 June 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/38\/59\/48286802.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Norwayphase3reportEN.pdf; Staoil Company Press Release, \u0022Statoil accepts \u00d8kokrim penalty in the Horton case,\u0022 October 14, 2004, accessed at http:\/\/www.statoil.com\/en\/NewsAndMedia\/News\/2004\/Pages\/StatoilAcceptsOkokrimPenaltyInTheHortonCase.aspx","Documents":""},{"Case ID":"ST-338","Case Cluster ":"Stet Holland bv Emmeloord","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Rijksrecherche (Dutch Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Out of court settlement","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$277,599.30","Criminal Fine\/Penalty (US$) ":"$190,802","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$86,797","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Sanctions legislation by paying kickbacks when implementing UN Oil-for-Food Programme","Offenses - Settled":"Sanctions legislation by paying kickbacks when implementing UN Oil-for-Food Programme","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Netherlands Phase 2 Report of the OECD Anti-Bribery Working Group (December 17, 2008): \u0022As of October 2008, no foreign bribery cases had been brought before the Dutch courts. Nevertheless, the prosecution authorities have concluded out-of-court transactions with seven companies for paying kickbacks in the context of the Oil-for-Food Programme in Iraq, although the offence charged was the violation of sanctions legislation and not the foreign bribery offence.\u0022 (para 2); \u0022 the Prosecution Department reports that it has concluded financial transactions (out of court settlements) with 7 companies for violating sanction legislation by paying kickbacks when implementing the Oil for Food Programme. Criminal gains have also been confiscated. In July 2008 a press release has been issued about these settlements. Together with the names of the companies (Alfasan International B.V., N.V. Organon, Flowserve B.V. , OPW Fluid Transfer Group Europe B.V., Prodetra B.V. Solvochem Holland B.V., Stet Holland B.V.) the settlements have been made public. For the following Oil-for-food transactions out-of-court settlements have been reached: 1. Alfasan International BV Woerden, fine: \u20ac 31.800,-- and confiscation \u20ac 10.183,55 2. NV Organon Oss, fine: \u20ac 381.602 3. Flowerserve bv te Etten-Leur, fine: \u20ac 76.274 and confiscation \u20ac180.260 4. OPW Fluid Transfer Group Europe BV, Nieuw Vennep, fine \u20ac 57.204 and confiscation \u20ac 24.600 5. Prodetra bv,Wadinxveen, fine: 64.751 and confiscation \u20ac 34.485,95 6. Solvochem Holland bv, Rotterdam, fine \u20ac 136.000 and confiscation \u20ac 144.592 7. Stet Holland bv,Emmeloord, fine \u20ac 119.712 and confiscation \u20ac 54.458.\u0022 (Source: Ibid., at 14.)","Sources ":"OECD Anti-Bribery Working Group, The Netherlands Phase 2 Report (December 17, 2008), accessed at http:\/\/www.oecd.org\/dataoecd\/61\/59\/41919004.pdf; Melissa Lipman, \u0022Cos. Settle Dutch Probe Into Oil-For-Food For ?1.3M,\u0022 Law 360, July 16, 2008, accessed at http:\/\/www.law360.com\/articles\/62486\/cos-settle-dutch-probe-into-oil-for-food-for-1-3m (partial article, gives date of Dutch Public Prosecution Service press release.)","Documents":""},{"Case ID":"ST-339","Case Cluster ":"Switzerland \/ Individual Defendant X","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Switzerland, Unspecified Jurisdictions","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/02","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Summary Punishment Order","Monetary Sanctions  (Types)":"Criminal Fine, Suspended Criminal Fine","Total Monetary Sanctions (US$)":"$11,958.10","Criminal Fine\/Penalty (US$) ":"$11,958.10","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of Foreign Officails","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022On 17 February 2010, the Tax Administration of the Canton of Geneva advised the cantonal Office of the Attorney-General of illegal payments that had been made by a director of several Geneva hotels. Following this report, a case was opened by the Geneva Office of the Attorney-General. The investigation showed that between 2003 and 2007, X \u2013 a Swiss national \u2013 had paid intermediaries cash commissions totalling CHF 109 100 (approximately EUR 90 000) so that foreign diplomatic representations would choose to stay in his establishments. Examination of the accounting records of the companies operating the hotels showed in particular that CHF 48 000 had been paid in 2006-07 so that representatives of Office XY would stay in these establishments; that CHF 27 100 had been paid between 2003 and 2007 so that customers from consulate XY and permanent mission XY would stay there; and that CHF 34 000 had been paid so that customers connected with mission XY would stay there. The investigation determined that the payment of these commissions had enabled the hotels in question to generate turnover of CHF 1.5 million (or approximately EUR 1.2 million).  When questioned by the Geneva law enforcement authorities, the defendant acknowledged having paid commissions to attract customers, while contending that the customers brought in by the commissions had not, in his opinion, been members of official representations. The prosecutor in the case deemed, however, that a review of the accounting documents in evidence clearly showed that the customers were in fact official representatives, that a 2009 letter clearly indicated that the accused habitually paid commissions to foreign officials and lastly, that it made little difference whether the intermediaries receiving the commissions did not work formally for the various foreign missions insofar as a purpose of the commissions was to attract diplomatic clientele. The Geneva law enforcement authorities also rejected the defendant\u2018s contention that the payment of commissions to foreign public officials was a recurring practice in the hotel industry. After taking account of the defendant\u0027s lack of a criminal record and his personal and economic circumstances, and considering that the deeds of which he was accused were not serious enough to take the accused to trial, X was sentenced by Summary punishment order to a suspended fine of CHF 49 500 (approximately EUR 41 000), three years\u2018 probation and a fine of CHF 12 000 (approximately EUR 10 000).\u0022 (Source:  Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 54 and citing as its source Summary Punishment Order of the Attorney-General of the Republic and Canton of Geneva, 2 December 2010.).  The suspended fine has not been included in the monetary total for this entry.","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with: http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-340","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 1 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Criminal Confiscation","Total Monetary Sanctions (US$)":"$19,844,400.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$19,844,400","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-341","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 10 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"Unknown","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-342","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 11 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"Unknown","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-343","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 2 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"Unknown","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-344","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 3 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"Unknown","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-345","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 4 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"Unknown","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-346","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 5 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"Unknown","Criminal Fine\/Penalty (US$) ":"Unknown","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-347","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 6 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"Unknown","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with  http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-348","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 7 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"Un","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, repalce with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-349","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 8 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"Unknown","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-350","Case Cluster ":"Switzerland \/ UN Oil-for-Food \/ Case 9 of 11","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Confiscation","Total Monetary Sanctions (US$)":"Unknown","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Violation of laws implementing sanctions","Offenses - Settled":"Violation of laws implementing sanctions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Switzerland, \u0022Some of the cases also had to be closed for lack of evidence. For example, of the 36 OAG [Office of the Attorney General] investigations relating to the United Nations Oil for Food programme, involving some 30 businesses headquartered in Switzerland, none resulted in a conviction for bribery of foreign public officials, as the necessary evidence could not be collected because certain countries refused mutual legal assistance (MLA). This does not mean that the companies involved were not punished: in 11 cases, sentences were handed down for violation of laws implementing sanctions. Confiscations totalling CHF 18.8 million (around \u20ac11 million) were ordered against the companies involved.\u0022 (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, at 10.)  Please note that as no dates were given for the confiscations, the OECD Report date of December 16, 2011 was used for the purposes of converting the total confiscation sum to US Dollars.  Please note that as only one total amount of confiscation was available, it was included in this entry but not for cases 2-11, so as to avoid double counting of amount of confiscation. ","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf, replace with http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf","Documents":""},{"Case ID":"ST-351","Case Cluster ":"Syncor International Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Taiwan, China","Year of Settlement":"2002","Month\/Day of Settlement (or Notes)":"12\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil (Administrative Order)","Legal Form of Settlement":"Consent to Cease-and-Desist Order ","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$500,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$500,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Syncor International Corporation, at 79-80, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf:  Misconduct in Taiwan, 1997-2002; Criminal and civil charges stemmed from (1) series of payments totalling at least $344,110 in \u0022commissions\u0022 by Syncor and its employees to physicians employed by hospitals owned by the legal authorities in Taiwan for the purpose of obtaining and retaining business from the hospitals and in connection with the purchase and sale of unit dosages of certain radiopharmaceuticals.  Monty Fu, Syncor Taiwan\u0027s founder and board chairman authorized the payments and (2) at least $113,007 in improper payments (1998-2002) authorized by Fu and made by Syncor Taiwan to physicians employed at hospitals owned by the legal authorities in Taiwan in exchange for their referrals of patients to medical imaging centers owned and operated by Syncor. Settlement amounts: criminal fine of $2 million (Syncor); Civil: $500,000 civil penalty (Syncor), $75,000 civil penalty (Fu).  Resulting criminal enforcement actions: US v. Syncor Taiwan, Inc. (C.D. Cal., December 4, 2002); Civil: SEC v. Monty Fu (D.D.C., September 27, 2008), SEC v. Syncor International Corporation (D.D.C., December 10, 2002), In the Matter of Syncor International Corporation (December 10, 2002).  The SEC Litigation Release acknowledged the investigative assistance by the Taiwan Taipei Prosecutors Office. ","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Syncor International Corporation at 79-80, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.  US v. Syncor International Corporation (D.D.C.), Complaint filed December 10, 2002, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/comp17887.htm; Add http:\/\/www.sec.gov\/litigation\/litreleases\/lr17887.htm US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Syncor International Corporation Case Summary at 95-96, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-352","Case Cluster ":"Syncor International Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Taiwan, China","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"09\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$75,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$75,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"False Accounting Violations, Aiding and Abetting Internal Controls Violations, Aiding and Abetting Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Syncor International Corporation, at 79-80, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf:  Misconduct in Taiwan, 1997-2002; Criminal and civil charges stemmed from (1) series of payments totalling at least $344,110 in \u0022commissions\u0022 by Syncor and its employees to physicians employed by hospitals owned by the legal authorities in Taiwan for the purpose of obtaining and retaining business from the hospitals and in connection with the purchase and sale of unit dosages of certain radiopharmaceuticals.  Monty Fu, Syncor Taiwan\u0027s founder and board chairman authorized the payments and (2) at least $113,007 in improper payments (1998-2002) authorized by Fu and made by Syncor Taiwan to physicians employed at hospitals owned by the legal authorities in Taiwan in exchange for their referrals of patients to medical imaging centers owned and operated by Syncor. Resulting civil enforcement actions: SEC v. Monty Fu (D.D.C., September 27, 2008), SEC v. Syncor International Corporation (D.D.C., December 10, 2002), In the Matter of Syncor International Corporation (December 10, 2002).  The SEC Litigation Release acknowledged the investigative assistance by the Taiwan Taipei Prosecutors Office. ","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Syncor International Corporation at 79-80, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.  US v. Monty Fu, Case No. 1:07-cv-01735 (D.D.C.), Complaint filed September 27, 2007, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2007\/comp20310.pdf; And SEC press release http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20310.htmUS Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Syncor International Corporation Case Summary at 95-96, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-353","Case Cluster ":"Syncor International Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Taiwan, China","Year of Settlement":"2002","Month\/Day of Settlement (or Notes)":"12\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,000,000.00","Criminal Fine\/Penalty (US$) ":"$2,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Syncor International Corporation, at 79-80, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf:  Misconduct in Taiwan, 1997-2002; Criminal and civil charges stemmed from (1) series of payments totalling at least $344,110 in \u0022commissions\u0022 by Syncor and its employees to physicians employed by hospitals owned by the legal authorities in Taiwan for the purpose of obtaining and retaining business from the hospitals and in connection with the purchase and sale of unit dosages of certain radiopharmaceuticals.  Monty Fu, Syncor Taiwan\u0027s founder and board chairman authorized the payments and (2) at least $113,007 in improper payments (1998-2002) authorized by Fu and made by Syncor Taiwan to physicians employed at hospitals owned by the legal authorities in Taiwan in exchange for their referrals of patients to medical imaging centers owned and operated by Syncor. Settlement amounts: criminal fine of $2 million (Syncor; noted in the DOJ press release as maximum penalty under FCPA); Civil: $500,000 civil penalty (Syncor), $75,000 civil penalty (Fu).  Resulting criminal enforcement actions: US v. Syncor Taiwan, Inc. (C.D. Cal., December 4, 2002.","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Syncor International Corporation at 79-80, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.  US v. Syncor Taiwan, Inc., Case No. 2-cr-12441 (C.D. Cal.), Information filed December 4, 2002; Plea Agreement dated December 4, 2002, accessed at ; http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/syncor-taiwan\/12-03-02syncor-taiwan-plea-agree.pdf; US Department of Justice Press Release, \u0022Syncor Taiwan, Inc. Pleads Guilty to Violating the Foreign Corrupt Practices Act,\u0022 December 10, 2002, accessed at  http:\/\/www.justice.gov\/opa\/pr\/2002\/December\/02_crm_707.htm; US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Syncor International Corporation Case Summary at 95-96, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-354","Case Cluster ":"Tanner Management Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"None (Sting Operation)","Year of Settlement":"1998","Month\/Day of Settlement (or Notes)":"08\/05","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$15,000.00","Criminal Fine\/Penalty (US$) ":"$15,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"No (Sting Operation) ","Summary":"According to the June 2011 US Report to the OECD, \u0022On March 24, 1998, Herbert Tannenbaum was arrested pursuant to a criminal complaint filed in the Southern District of New York, which charged him with conspiracy to violate the anti-bribery provisions of the FCPA. A one-count information, charging Tannenbaum with conspiracy to violate the FCPA, was subsequently filed on July 23, 1998. According to court documents, Tannenbaum, as President of Tanner Management Corporation, offered to make secret payments totaling 15% of the contract value to an undercover agent posing as a procurement officer of the Government of Argentina in order to induce the agent to purchase garbage incinerators. According to the plea agreement, the offered bribe totaled between $120,000 and $200,000. As part of the conspiracy and in an attempt to disguise the secret payment, Tannenbaum incorporated a fictitious entity named Cybernet USA and opened a bank account in the same name.  Tannenbaum pleaded guilty on August 5, 1998, and, pursuant to a plea agreement with the United States, was sentenced to a prison term of 1 year and 1 day, to be followed by 3 years of supervised release.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Tanner Management Corporation Case Summary at 135-36.)  According to the Judgment in his case, Mr. Tannenbaum was ordered to pay $15,000 in criminal fine. (Source: US v. Tannenbaum, Case No. 1:98-cr-784-TPG (S.D.N.Y.), Judgment in a criminal case dated March 19, 1999.)  The US Department of Justice Press Release stated that, \u0022According to the information, Tannenbaum helped incorporate and open a bank account in the name of Cybernet USA, a fictitious entity, to disguise the payment to the undercover agent.  During the investigation, the Argentine Ministry of Justice cooperated with the Department.\u0022 (Source: US Department of Justice Press Release, \u0022Long Island Man Pleads Guilty to Violating Foreign Corrupt Practices Act,\u0022 August 5, 1998.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Tanner Management Corporation Case Summary at 135-36, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Tannenbaum, Case No. 1:98-cr-784-TPG (S.D.N.Y.), Information of July 23, 1998, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tannenbaum\/07-23-98tannenbaum-info.pdf; Plea Agreement signed August 5, 1998, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tannenbaum\/06-23-98tannenbaum-plea-agree.pdf; Judgment in a criminal case dated March 19, 1999, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tannenbaum\/03-19-99tannenbaum-judgment.pdf; US Department of Justice Press Release, \u0022Long Island Man Pleads Guilty to Violating Foreign Corrupt Practices Act,\u0022 August 5, 1998, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tannenbaum\/08-05-98tannenbaum-pressrelease.pdf","Documents":""},{"Case ID":"ST-264","Case Cluster ":"Macmillan Publishers Limited","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Zambia, Rwanda, Uganda","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"07\/22","Other Jurisdictions of Settlement":"World Bank","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Civil Recovery Order (Proceeds of Crime Act) ","Monetary Sanctions  (Types)":"Civil Recovery Order, Legal Costs","Total Monetary Sanctions (US$)":"$18,298,658.80","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$18,254,901","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"$43,758","Other Civil Monetary Sanctions (Explanation)":"Legal Costs","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Sums derived from unlawful conduct","Offenses - Settled":"Sums derived from unlawful conduct ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a UK Serious Fraud Office press release, on July 22, 2011, the SFO obtained a Civil Recovery Order through the High Court in which Macmillan Publishers Limited will pay GBP 11,263,852.28 and also pay the SFO costs of pursuing the order which amount to GBP 27,000 (US$ 43,757.80).  The SFO acted on a referral from the World Bank regarding a World Bank tender to supply educational materials in Southern Sudan. The SFO, in cooperation with the City of London Police and the World Bank selected the three jurisdictions - Rwanda, Uganda and Zambia - in relation to which it would require the company\u0027s external lawyers to conduct detailed investigations into all public tender contracts in these three jurisdictions over the period of 2002-2009 whether funded by the World Bank or otherwise. These jurisdictions fell within the business activities of Macmillan\u0027s Education Division in East and West Africa. The press release stated that \u0022It was impossible to be sure that the awards of tender to the Company in the three jurisdictions were not accompanied by a corrupt relationship.\u0022  Richard Alderman, the then-Director of the SFO stated,\u0022Civil recovery allows us to deal with certain cases of corporate wrong-doing effectively. It delivers value for money to the public by saving the cost of lengthy investigations and protracted legal proceedings and removes any property obtained as a result of wrong-doing. At the same time it forces the company to reform its practices for the future.\u0022 (Source: UK Serious Fraud Office Press Release, \u0022Action on Macmillan Publishers Limited,\u0022 July 22, 2011, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2011\/action-on-macmillan-publishers-limited.aspx.)","Sources ":"UK Serious Fraud Office Press Release, \u0022Action on Macmillan Publishers Limited,\u0022 July 22, 2011, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2011\/action-on-macmillan-publishers-limited.aspx; MacMillan Press Release, \u0022MacMillan Publishers Ltd concludes co-operative process with SFO,\u0022 July 22, 2011, accessed at http:\/\/international.macmillan.com\/MediaArticle.aspx?id=3046\u0026SearchURL=http:--slh----slh--international.macmillan.com--slh--MediaCentreResults.aspx--Qst--Page=1--amp--SearchString=world%20bank;  United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf","Documents":""},{"Case ID":"ST-265","Case Cluster ":"Macmillan Publishers Limited","Jurisdiction of Settlement":"","Jurisdiction of Settlement \/ Enforcement Agency":"Integrity Vice Presidency","Jurisdiction of Foreign Public Official(s) ":"Southern Sudan","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"04\/30","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Debarment","Monetary Sanctions  (Types)":"None ","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Payment of bribery","Offenses - Settled":"Payment of bribery","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a World Bank Press Release of July 22, 2011 welcoming the UK Serious Fraud Office\u0027s announcement to order Macmillan Publishers Limited to pay penalties, \u0022In April 2010, the World Bank Group debarred Macmillan Limited, a U.K. company, declaring the company ineligible to be awarded Bank-financed contracts for a period of six years in the wake of the company\u0027s admission of bribery payments relating to a Trust Fund-supported education project in Sudan. [ ] Following the INT investigation, the World Bank referred its findings to the UK authorities, which launched their own investigation.\u0022  (Source: The World Bank Press Release, \u0022World Bank Applauds Action by the UK Serious Fraud Office in Relation to Bribery Charges Against Macmillan Publishers Limited In An Education Project in Sudan,\u0022 Press Release No:2012\/038\/INT, July 22, 2011.)","Sources ":"The World Bank Press Release, \u0022World Bank Applauds Action by the UK Serious Fraud Office in Relation to Bribery Charges Against Macmillan Publishers Limited In An Education Project in Sudan,\u0022 Press Release No:2012\/038\/INT, July 22, 2011, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,contentMDK:22967949~pagePK:34370~piPK:34424~theSitePK:4607,00.html; UK Serious Fraud Office Press Release, \u0022Action on Macmillan Publishers Limited,\u0022 July 22, 2011, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2011\/action-on-macmillan-publishers-limited.aspx; Mark Tran, \u0022Macmillan ordered to pay $17m for corruption in Southern Sudan,\u0022 The Guardian, July 25, 2011, at http:\/\/www.guardian.co.uk\/global-development\/2011\/jul\/25\/macmillan-education-deal-south-sudan\/print (accessed on September 12, 2011)http:\/\/www.guardian.co.uk\/global-development\/2011\/jul\/25\/macmillan-education-deal-south-sudan?INTCMP=SRCH;     MacMillan Press Release, \u0022MacMillan Publishers Ltd concludes co-operative process with SFO,\u0022 July 22, 2011, accessed at http:\/\/international.macmillan.com\/MediaArticle.aspx?id=3046\u0026SearchURL=http:--slh----slh--international.macmillan.com--slh--MediaCentreResults.aspx--Qst--Page=1--amp--SearchString=world%20bank. (not a functioning link)","Documents":""},{"Case ID":"ST-266","Case Cluster ":"MAN","Jurisdiction of Settlement":"","Jurisdiction of Settlement \/ Enforcement Agency":"Munich Public Prosecution Office","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"12\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Administrative Offences Act","Monetary Sanctions  (Types)":"Fine, Confiscation of Profits","Total Monetary Sanctions (US$)":"$110,859,672.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$110,418,000","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"$441,672","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Sections 130 and 30 OWiG","Offenses - Settled":"Sections 130 and 30 OWiG","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to the March 2011 Germany Phase 3 Report to the OECD, \u0022iv) Decision of Munich I Public Prosecution office of 10 December 2009 pursuant to sections 130 and 30 OWiG - against the Trucks unit of MAN - Fine of EUR 75.3 million (see Annual report 2009 Bavaria (d) and Germany\u0027s reply to Phase 3 questionnaires), hereinafter Case \u0022Trucks Unit of MAN\u0022 (Source: Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at footnote 49.)","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-267","Case Cluster ":"MAN","Jurisdiction of Settlement":"","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"12\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Administrative Offences Act","Monetary Sanctions  (Types)":"Fine, Confiscation of Profits","Total Monetary Sanctions (US$)":"$110,859,672.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$110,418,000","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"$441,672","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Section 30 OWiG in connection with sections 334 and 299 Criminal Code","Offenses - Settled":"Section 30 OWiG in connection with sections  334 and 299 Criminal Code","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to the March 2011 Germany Report to the OECD, \u0022v) Decision of a Munich I Regional Court of 10 December 2009 pursuant to section 30 OWiG in conjunction with sections 334 and 299 CC - against the Turbo engines Unit of MAN - Fine of EUR 75.3 million, hereinafter Case ?Turbo engines Unit of MAN\u0022 (Source: Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at footnote 49.)","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-268","Case Cluster ":"Maxwell Technologies Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; United States Attorney for the Southern District of California","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"1\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$8,000,000.00","Criminal Fine\/Penalty (US$) ":"$8,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Deferred Prosecution Agreement, Maxwell Technologies accepted the following Statement of Facts:  the company\u0027s wholly-owned subsidiary Maxwell Technologies S.A. (incorporated and headquartered in Switzerland) manufactured and sold high-voltage capacitors in several countries, inclding China.  \u0022Agent 1,\u0022 a Chinese national, was a third-party agent responsible for Maxwell S.A.\u0027s Chinese customers (listed in the Statement of Facts as (1) Pinggao Group Co. Ltd, a state-owned manufacturer of electric-utility infrastructure in Henan Province, (2) New Northeast Electric Shenyang HV Switchgear Co., Ltd., a state-owned manufacturer of electric-utility infrastructure in Liaoning Province, and (3) Xi-an XD High Voltage Apparatus Co., Ltd., a state-owned manufacturer of eletric-utility infrastructure in Shaanxi Province.  From at least 2002 to 2009, Maxwell and its subsidiaries paid approximately $2,789,131 to Agent 1 to be distributed to Chinese foreign officials, in return for securing contracts that profited Maxwell, namely by using a kick-back scheme in which Agent 1 requested quotes from Maxwell S.A. on behalf of prospective Chinese state-owned entities and then upon Agent 1\u0027s instruction, Maxwell S.A. added an \u0022extra\u0022 20 percent to the quoted amounts to arrive at a higher price for Maxwell S.A.\u0027s equipment.  Maxwell S.A. then invoiced the Chinese state-owned entities for equipment at the higher-priced rate, which the entities paid. Agent 1 distributed the \u0022extra amounts\u0022 to officials at the Chinese state-owned entities, including employees at Pinggao Group, shenyang HV, and Xi-an XD. (Source: US x. Maxwell Technologies, Inc., Case no. 3:11-cr-00329-JM (C.D. Cal.), Deferred Prosecution Agreement and Appendix A: Statement of Facts, filed January 31, 2011). ","Sources ":"US v. Maxwell Technologies, Inc., Case No. 11-cr-329-JM (D.D.C. 2011), Information filed January 31, 2011 and Deferred Prosecution Agreement (and Appensix A: Statement of Facts), filed January 31, 2011, both accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/maxwell-tech.html; SEC v. Maxwell Technologies, Inc., Case No. 1:11-cv-00258 (D.D.C.), Complaint filed January 31, 2011, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp21832.pdf;   U.S. Securities and Exchange Commission, Litigation Release No. 21832 \/ January 31, 2011, U.S. Securities and Exchange Commission v. Maxwell Technologies Inc., Civil Action No. 1:11-CV-00258 (DDC) (BAH), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr21832.htm.","Documents":""},{"Case ID":"ST-269","Case Cluster ":"Maxwell Technologies Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"01\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$6,350,890.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$5,654,576","Civil Prejudgment Interest (US$) ":"$696,314","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, improper internal controls, books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Deferred Prosecution Agreement, Maxwell Technologies accepted the following Statement of Facts:  the company\u0027s wholly-owned subsidiary Maxwell Technologies S.A. (incorporated and headquartered in Switzerland) manufactured and sold high-voltage capacitors in several countries, including China.  \u0022Agent 1,\u0022 a Chinese national, was a third-party agent responsible for Maxwell S.A.\u0027s Chinese customers (listed in the Statement of Facts as (1) Pinggao Group Co. Ltd, a state-owned manufacturer of electric-utility infrastructure in Henan Province, (2) New Northeast Electric Shenyang HV Switchgear Co., Ltd., a state-owned manufacturer of electric-utility infrastructure in Liaoning Province, and (3) Xi-an XD High Voltage Apparatus Co., Ltd., a state-owned manufacturer of eletric-utility infrastructure in Shaanxi Province.  From at least 2002 to 2009, Maxwell and its subsidiaries paid approximately $2,789,131 to Agent 1 to be distributed to Chinese foreign officials, in return for securing contracts that profited Maxwell, namely by using a kick-back scheme in which Agent 1 requested quotes from Maxwell S.A. on behalf of prospective Chinese state-owned entities and then upon Agent 1\u0027s instruction, Maxwell S.A. added an \u0022extra\u0022 20 percent to the quoted amounts to arrive at a higher price for Maxwell S.A.\u0027s equipment.  Maxwell S.A. then invoiced the Chinese state-owned entities for equipment at the higher-priced rate, which the entities paid. Agent 1 distributed the \u0022extra amounts\u0022 to officials at the Chinese state-owned entities, including employees at Pinggao Group, shenyang HV, and Xi-an XD. (Source: US x. Maxwell Technologies, Inc., Case no. 3:11-cr-00329-JM (C.D. Cal.), Deferred Prosecution Agreement and Appendix A: Statement of Facts, filed January 31, 2011).  ","Sources ":"US v. Maxwell Technologies, Inc., Case No. 11-cr-329-JM (D.D.C. 2011), Information filed January 31, 2011 and Deferred Prosecution Agreement (and Appendix A: Statement of Facts), filed January 31, 2011, both accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/maxwell-tech.html; SEC v. Maxwell Technologies, Inc., Case No. 1:11-cv-00258 (D.D.C.), Complaint filed January 31, 2011, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp21832.pdf;   U.S. Securities and Exchange Commission, Litigation Release No. 21832 \/ January 31, 2011, U.S. Securities and Exchange Commission v. Maxwell Technologies Inc., Civil Action No. 1:11-CV-00258 (DDC) (BAH), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr21832.htm.","Documents":""},{"Case ID":"ST-270","Case Cluster ":"Metcalf \u0026 Eddy International, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Egypt","Year of Settlement":"1999","Month\/Day of Settlement (or Notes)":"12\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty, Legal Costs","Total Monetary Sanctions (US$)":"$450,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$400,000","Other Civil Monetary Sanctions (US$)":"$50,000","Other Civil Monetary Sanctions (Explanation)":"Legal Costs","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Metcalf \u0026 Eddy International, Inc. at 123: On December 14, 1999, the Department of Justice initiated a settled civil enforcement action against Metcalf \u0026 Eddy International, Inc. in connection with a 1994 trip the company paid for the Chairman (of the Alexandria General Organization for Sanitary Drainage (AGOSD), an Egyptian government agency responsible for wastewater and sewage treatment in Alexandria, Egypt) and his family to Boston, Paris, and San Diego and \u0022per diem\u0022 payments given to him in advance in Alexandria. \u0022In exchange, the Chairman exerted influence over the board in charge of awarding these contracts and recommended that M\u0026E be given $36 million contracts, which were funded by the U.S. Agency for International Development.\u0022  On December 14, 1999, without admitting or denying the Department\u0027s allegations, M\u0026E consented to an injunction to pay a fine of $400,000 and costs of investigation of $50,0000, and to be permanently enjoined from FCPA violations.  According to the Court Docket Report in US v. Metcalf \u0026 Eddy International, Inc. Case No. 1;99-cv-12566-NG, the judgment was entered for USA against Metcalf \u0026 Eddy on December 17, 1999; a copy of the judgment (and the other case documents) are not available online via Pacer.  (Court Docket Report retrieved on October 19, 2011.) ","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Metcalf \u0026 Eddy International, Inc. at 123, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; Court Docket Report in US v. Metcalf \u0026 Eddy International, Inc. Case No. 1;99-cv-12566-NG, the judgment was entered for USA against Metcalf \u0026 Eddy on December 17, 1999; a copy of the judgment (and the other case documents) are not available online via Pacer.  (Court Docket Report retrieved on October 19, 2011.) ","Documents":""},{"Case ID":"ST-271","Case Cluster ":"Micrus Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"France, Germany, Spain, Turkey","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"02\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$450,000.00","Criminal Fine\/Penalty (US$) ":"$450,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations","Offenses - Settled":"Bribery of foreign officials, Internal controls violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice\u0027s Press Release on its settlement agreement with the Micrus Corporation and its Swiss subsidiary Micrus S.A., \u0022The investigation by the Department revealed that Micrus, through the conduct of certain officers, employees, agents and salespeople paid more than $105,000 - disguised in Micrus\u0027s books and records as stock options, honorariums and commissions - to doctors employed at publicly owned and operated hospitals in [France, Turkey, Spain and Germany] in return for the hospitals\u0027 purchase of embolic coils from Micrus. An additional $250,000 was comprised of payments for which Micrus did not obtain the necessary prior administrative or legal approval, as required under the laws of the relevant foreign jurisdiction.\u0022  (Source: US Department of Justice Press Release, \u0022Micrus Corporation Enters into Agreement to Resolve Potential Foreign Corrupt Practices Act Liability,\u0022 March 2, 2005.) ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Micrus Corporation Case Summary at 121-122, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Department of Justice Press Release, \u0022MICRUS CORPORATION ENTERS INTO AGREEMENT TO RESOLVE POTENTIAL FOREIGN CORRUPT PRACTICES ACT LIABILITY,\u0022 March 2, 2005, accessed at http:\/\/www.justice.gov\/opa\/pr\/2005\/March\/05_crm_090.htm; In Re: Micrus Corporation, Non-Prosecution Agreement (dated February 28, 2005), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/micrus-corp\/02-28-05micrus-agree.pdf","Documents":""},{"Case ID":"ST-272","Case Cluster ":"Midway Trading","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"New York County District Attorney\u0027s Office","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"10\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$250,000.00","Criminal Fine\/Penalty (US$) ":"$250,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art.2","Offenses - Alleged":"Grand Larceny","Offenses - Settled":"Grand Larceny","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the New York County District Attorney\u0027s Office Press Release on October 20, 2005, \u0022Manhattan District Attorney Robert M. Morgenthau announced today the guilty plea of a Reston, Virginia-based oil trading company for its involvement in a scheme to pay kickbacks to Iraq in connection with oil purchases made under the United Nations Oil-for-Food Program.  MIDWAY TRADING (MIDWAY) pleaded guilty in New York State Court to Grand Larceny in the First Degree in connection with the scheme. According to the charges, Midway and one of its trading partners, Bulf Oil, paid more than $440,000 in kickbacks to Iraqi officials in connection with oil purchases but falsely represented to the United Nations that no kickbacks were paid. Relying on those false representations, United Nations officials approved the contracts and authorized millions of dollars in payments for the benefit of Iraq from the Oil-for-Food Program. MIDWAY will pay a fine of $250,000, with $100,000 due by December 1, 2005. The plea by MIDWAY is part of a continuing investigation by the Manhattan District Attorney\u0027s Office into the Oil-for-Food Program. This investigation began as a result of this office\u0027s cooperation with the Independent Inquiry Committee into the United Nations Oil-for-Food Program, headed by Paul Volker.[  ]  Through its attorney, MIDWAY OIL admitted in court that in late 2000, the company purchased the right to lift oil from Iraq under the United Nations Oil-for-Food Program from Bulf Oil, a Romanian oil company. Under United Nations resolutions, all money paid for the purchase of Iraqi crude oil was deposited into a UN trust account at a branch of BNP Paribas, a French bank, in Manhattan. Payments from the trust account, including payments for so-called \u0022humanitarian goods\u0022 to be sent to Iraq, had to be authorized by United Nations officials. No money for the purchase of crude oil from Iraq was to go directly to Iraq.  Under its initial $42 million agreement with Bulf, MIDWAY was to provide financing for the purchase cost of the Iraqi crude oil and to share any profits from MIDWAY\u0027s subsequent sale of that crude oil. An employee of Bulf Oil asked MIDWAY to pay him an additional 25 cents per barrel, an extra payment that MIDWAY did not make, at first.  MIDWAY sold the Iraqi crude oil lift to Texaco Corp., which, in turn, sold the crude oil lift to British Petroleum (\u0027BP\u0027). MIDWAY provided BP with a price guarantee. On March 28, 2001, a ship chartered by BP arrived at the Turkish Port of Ceyhan, but was not allowed to lift the oil. On April 1, 2001, MIDWAY wired $225,000 from an account at SunTrust Bank in Virginia to the Jordan National Bank\u0027s correspondent bank account at Chase Manhattan Bank in New York for the benefit of an account in name of the Bulf employee. The $225,000 was the approximate equivalent of the 25 cent per barrel kickback that the Bulf employee had asked for. On April 2nd and 3rd, the oil was loaded onto BP\u0027s ship. MIDWAY later learned that the money wired to the Jordan National Bank was for the benefit of Iraqi government officials and that the \u0027surcharge\u0027 had to be paid as a precondition for oil to be loaded. As a consequence of the price guarantee given to BP and the delay in lifting the oil, MIDWAY lost $ 1 million on this initial transaction.  In September, 2001, MIDWAY acquired the remainder of Bulf Oil\u0027s allocation of oil, at a purchase price of $22 million, under the Oil-for-Food Program. This time, prior to the lift of oil, MIDWAY wired $215,442.25 to Jordan National Bank\u0027s correspondent account at Chase Manhattan Bank in New York in the name of an agent of MIDWAY\u0027s. Midway knew that, as in the first transaction, the money wired to the Jordan National Bank account was, in fact, a kickback to be paid to Iraqi officials, in violation of United Nations Security Council Resolution 986. MIDWAY did not inform the UN about its payment to the Jordan National Bank. And, as MIDWAY knew, Bulf Oil\u0027s contract for the purchase of Iraqi oil falsely represented that all of the United Nations Security Council resolutions had been complied with. The second lift went smoothly and Midway profited approximately $375,000 from the sale of the crude oil.  The contract purchase price for the oil, $22 million, was paid into the United Nations trust account for the Oil-for-Food Program. Subsequently, relying on the false representations that no kickbacks had been paid, United Nations officials authorized the disbursement from the account of a like amount, less fees and administrative costs, for various purposes in accordance with program regulations. This included $13 million in payments for goods to be sent to Iraq.\u0022 (Source:  New York County District Attorney\u0027s Office, News Release on Midway Trading Plea, October 20,2005.)","Sources ":"New York County District Attorney\u0027s Office, News Release on Midway Trading Plea, October 20,2005, accessed at http:\/\/manhattanda.client.tagonline.com\/whatsnew\/press\/2005-10-20.shtml; New York County District Attorney\u0027s Office, News Release on Vitol SA Plea, November 20, 2007, accessed at http:\/\/manhattanda.client.tagonline.com\/whatsnew\/press\/2007-11-20.shtml; http:\/\/www.nysun.com\/new-york\/morgenthau-gains-a-plea-of-guilty-in-un-scandal\/21880\/","Documents":""},{"Case ID":"ST-273","Case Cluster ":"Monsanto Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Indonesia","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"01\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,000,000.00","Criminal Fine\/Penalty (US$) ":"$1,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records","Offenses - Settled":"Bribery of Foreign Officials, Falsification of Books and Records","Public Procurement Contract \/ SOE Involved?":"No (License)","Summary":"According to the June 2011 United States Report to the OECD, \u0022Monsanto, a producer of various agricultural products, hired an Indonesian consulting company to assist it in obtaining various Indonesian governmental approvals and licenses necessary to sell its genetically modified products in Indonesia. At the time, the Indonesian government required an environmental impact study before authorizing the cultivation of genetically modified crops. After a change in governments in Indonesia, Monsanto sought, unsuccessfully, to have the new government, in which the senior environment official had a post, amend or repeal the requirement for the environmental impact statement. Having failed to obtain the senior environment official\u0027s agreement to amend or repeal this requirement, in 2002, Charles Martin, the Government Affairs Director for Asia for Monsanto, authorized and directed an Indonesian consulting firm to make an illegal payment totaling $50,000 to the senior environment official to \u0022incentivize\u0022 him to agree to do so. Martin also directed representatives of the Indonesian consulting company to submit false invoices to Monsanto for \u0022consultant fees\u0022 to obtain reimbursement for the bribe, and agreed to pay the consulting company for taxes that company would owe by reporting income from the \u0022consultant fees.\u0022  In February 2002, an employee of the Indonesian consulting company delivered $50,000 in cash to the senior environment official, explaining that Monsanto wanted to do something for him in exchange for repealing the environmental impact study requirement. The senior environment official promised that he would do so at an appropriate time. In March 2002, Monsanto, through its Indonesian subsidiary, paid the false invoices thus reimbursing the consulting company for the $50,000 bribe, as well as the tax it owed on that income. A false entry for these \u0022consulting services\u0022 was included in Monsanto\u0027s books and records. The senior environment official never authorized the repeal of the environmental impact study requirement.\u0022 (Source: .US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Monsanto Company Case Summary at 108-109.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Monsanto Company Case Summary at 108-109, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Monsanto Company, (D.D.C. 2005), Information filed January 6, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/monsanto-co\/01-06-05monsanto-info.pdf;  Deferred Prosecution Agreement and Statement of Facts filed January 6, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/monsanto-co\/01-06-05monsanto-agree.pdf; Order Approving the Deferred Prosecution Agreement filed March 16, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/monsanto-co\/03-16-05monsanto-order-dpa.pdf.  See also, US Department of Justice Press Release. \u0022Monsanto Company Charged with Bribing Indonesian Government Official: Prosecution Deferred for Three Years.\u0022 Jan. 6, 2005, accessed at http:\/\/www.justice.gov\/opa\/pr\/2005\/January\/05_crm_008.htm","Documents":""},{"Case ID":"ST-274","Case Cluster ":"Monsanto Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"01\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment, Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$500,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$500,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Internal Controls Violations, Falsification of Books and Records, False Accounting","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (License)","Summary":"According to the June 2011 United States Report to the OECD, \u0022Monsanto, a producer of various agricultural products, hired an Indonesian consulting company to assist it in obtaining various Indonesian governmental approvals and licenses necessary to sell its genetically modified products in Indonesia. At the time, the Indonesian government required an environmental impact study before authorizing the cultivation of genetically modified crops. After a change in governments in Indonesia, Monsanto sought, unsuccessfully, to have the new government, in which the senior environment official had a post, amend or repeal the requirement for the environmental impact statement. Having failed to obtain the senior environment official\u0027s agreement to amend or repeal this requirement, in 2002, Charles Martin, the Government Affairs Director for Asia for Monsanto, authorized and directed an Indonesian consulting firm to make an illegal payment totaling $50,000 to the senior environment official to \u0022incentivize\u0022 him to agree to do so. Martin also directed representatives of the Indonesian consulting company to submit false invoices to Monsanto for \u0022consultant fees\u0022 to obtain reimbursement for the bribe, and agreed to pay the consulting company for taxes that company would owe by reporting income from the \u0022consultant fees.\u0022  In February 2002, an employee of the Indonesian consulting company delivered $50,000 in cash to the senior environment official, explaining that Monsanto wanted to do something for him in exchange for repealing the environmental impact study requirement. The senior environment official promised that he would do so at an appropriate time. In March 2002, Monsanto, through its Indonesian subsidiary, paid the false invoices thus reimbursing the consulting company for the $50,000 bribe, as well as the tax it owed on that income. A false entry for these \u0022consulting services\u0022 was included in Monsanto\u0027s books and records. The senior environment official never authorized the repeal of the environmental impact study requirement.\u0022 (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Monsanto Company Case Summary at 108-109.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Monsanto Company Case Summary at 108-109, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 19023 \/ January 6, 2005, Securities and Exchange Commission v. Monsanto Company, Case No. 1:05CV00014 (U.S.D.C., D.D.C) (filed January 6, 2005), \u0022SEC Sues Monsanto Company for Paying a Bribe, Monsanto Settles Action and Agrees to Pay a  $500,000 Penalty,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr19023.htm; Complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/comp19023.pdf","Documents":""},{"Case ID":"ST-275","Case Cluster ":"Monsanto Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"03\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$30,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$30,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, False Accounting, Aiding and Abetting Monsanto\u0027s internal controls violations, Aiding and Abetting Monsanto\u0027s falsification of books and records ","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (License)","Summary":"According to the June 2011 United States Report to the OECD, \u0022Monsanto, a producer of various agricultural products, hired an Indonesian consulting company to assist it in obtaining various Indonesian governmental approvals and licenses necessary to sell its genetically modified products in Indonesia. At the time, the Indonesian government required an environmental impact study before authorizing the cultivation of genetically modified crops. After a change in governments in Indonesia, Monsanto sought, unsuccessfully, to have the new government, in which the senior environment official had a post, amend or repeal the requirement for the environmental impact statement.  Having failed to obtain the senior environment official\u0027s agreement to amend or repeal this requirement, in 2002, Charles Martin, the Government Affairs Director for Asia for Monsanto, authorized and directed an Indonesian consulting firm to make an illegal payment totaling $50,000 to the senior environment official to \u0022incentivize\u0022 him to agree to do so. Martin also directed representatives of the Indonesian consulting company to submit false invoices to Monsanto for \u0022consultant fees\u0022 to obtain reimbursement for the bribe, and agreed to pay the consulting company for taxes that company would owe by reporting income from the \u0022consultant fees.\u0022   In February 2002, an employee of the Indonesian consulting company delivered $50,000 in cash to the senior environment official, explaining that Monsanto wanted to do something for him in exchange for repealing the environmental impact study requirement. The senior environment official promised that he would do so at an appropriate time. In March 2002, Monsanto, through its Indonesian subsidiary, paid the false invoices thus reimbursing the consulting company for the $50,000 bribe, as well as the tax it owed on that income. A false entry for these \u0022consulting services\u0022 was included in Monsanto\u0027s books and records. The senior environment official never authorized the repeal of the environmental impact study requirement.\u0022 (Source: .US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Monsanto Company Case Summary at 108-109.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, NATCO Group, Inc. Case Summary at 55-56, accessed at http:\/\/www.oecd.org.  US Securities and Exchange Commission Litigation Release No. 2572 \/ March 6, 2007, SEC v. Charles Michael Martin, Case No. 1:07CV0434 (D.D.C.) (filed March 6, 2007), \u0022SEC Sues Former Senior Monsanto Manager Charles Martin for Authorizing a Bribe of $50,000; Martin Agrees to Pay a Penalty of $30,000,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20029.htm; Complaint filed March 6, 2007, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2007\/comp20029.pdf","Documents":""},{"Case ID":"ST-276","Case Cluster ":"Montedison S.p.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Italy","Year of Settlement":"2001","Month\/Day of Settlement (or Notes)":"03\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment ","Monetary Sanctions  (Types)":"Civil Penalty  ","Total Monetary Sanctions (US$)":"$300,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$300,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Anti-fraud, financial reporting and books and records of U.S. federal securities laws","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Regulator)","Summary":"According to the SEC Litigation Release of March 30, 2001, Montedison S.p.A., an Italian company whose senior management at the time fradulently overstated company income by at least $398 million through early 1993, without admitting or denying charges by the SEC agreed to pay a civil penalty for violating US federal securities laws.  The SEC Complaint had alleged that Montedison disguised hundreds of millions of dollars in payments that, among other things, were used to bribe politicians in Italy and other persons.  Virtually all of the former management at Montedison responsible for the fraud were convicted by Italian criminal authorities and were sued by the company. (Source: Litigation Release No. 16948, SEC v. Montedison, S.p.A., 1:96-cv-02631 (D.D.C.) and Complaint filed November 21, 1996.)   According to the Shearman \u0026 Sterling FCPA website case summary, \u0022This case was one of the first cases focusing on bribery brought by the SEC against a foreign issuer. The bribes formed the basis for the books and records violations and were allegedly paid by an Italian company to Italian politicians using offshore subsidiaries. It is, therefore, a unique FCPA case, as the bribes in question were paid by a foreign company to a foreign official in the same country, i.e., the officials were not \u0022foreign\u0022 to the company.\u0022 (Source: Case summary page, SEC v. Montedison, SpA, at http:\/\/fcpa.shearman.com\/?s=matter\u0026mode=form\u0026id=68.)  According  to the SEC Complaint, (1) Exilar Loan was one of the fake loans that Montedison made through a wholly-owned subsidiary to Financing and Investments NV, a wholly-owend Curacao corporation, which in turn \u0022loaned\u0022 the amount to Exilar International SA, a British Virgin Islands company.  The Complaint alleged that the Exilar Loan was designed to aggregate numerous bribes that had been paid over an extended period of time and disguise them as a single loan. Then in fiscal year ending in 1992, Montedison determined that the entire amount of the Exilar loan was uncollectible and should be written off.  (2) the ENIMONT Affair involved an effort by Montedison to gain control of ENIMONT, a joint venture by Montedison and the Italian state energy agency, ENI; Montedison management entered into an arrangment with a Rome real estate developer to pay artificially high prices thereby transferring  hundreds of millions of dollars with the Developer allegedly using this money to bribe politicians in Italy and other persons on Montedison\u0027s behalf. ","Sources ":"US Securities and Exchange Commission Litigation Release No. 16948 (March 30, 2001), re: settlement in SEC v. Montedison, S.p.A., Case No: 1:96-cv-02631-RWR (D.D.C.), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr16948.htm; SEC v. Montedison, S.p.A, Case No. 1:96-cv-02631-HHG (D.D.C.), Complaint filed November 21, 1996 and Final Judgment filed March 28, 2001, both accessed from www.fcpa.shearman.com","Documents":""},{"Case ID":"ST-277","Case Cluster ":"Morgan Stanley","Jurisdiction of Settlement":"","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"04\/25","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit, Prejudgment Interest","Total Monetary Sanctions (US$)":"$3,822,613.44","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$3,667,713","Civil Prejudgment Interest (US$) ":"$154,900","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign official, Books and Records, Internal Controls Provisions, Aiding and Abetting violations of Anti-fraud provisions of the Investment Advisers Act of 1940","Offenses - Settled":"Bribery of foreign official, Books and Records, Internal Controls Provisions, Aiding and Abetting violations of Anti-fraud provisions of the Investment Advisers Act of 1940","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the April 25, 2012 press release by the US Securities and Exchangeg Commission, Garth R. Peterson, formerly a managing director of Morgan Stanley consented to a civil settlement to resolve FCPA and other fraud charges pending against him.  According to the press release, \u0022The SEC alleges that Garth R. Peterson, who was a managing director in Morgan Stanley\u0027s real estate investment and fund advisory business, had a personal friendship and secret business relationship with the former Chairman of Yongye Enterprise (Group) Co.  - a Chinese state-owned entity with influence over the success of Morgan Stanley\u0027s real estate business in Shanghai. Peterson secretly arranged to have at least $1.8 million paid to himself and the Chinese official that he disguised as finder\u0027s fees that Morgan Stanley\u0027s funds owed to third parties. Peterson also secretly arranged for him, the Chinese official, and an attorney to acquire a valuable Shanghai real estate interest from a Morgan Stanley fund. Peterson was acquiring an interest from the fund but negotiated both sides of the transaction. In exchange for offers and payments from Peterson, the Chinese official helped Peterson and Morgan Stanley obtain business while personally benefitting from some of these same investments. Peterson\u0027s deception, self-dealing, and misappropriation breached the fiduciary duties he owed to Morgan Stanley\u0027s funds as their representative.\u0022  (Source: US Securities and Exchange Commission Press Release 2012-78, \u0022SEC Charges Former Morgan Stanley Executive with FCPA Violations and Investment Adviser Fraud,\u0022 April 25, 2012.) According to the SEC\u0027s complaint, Peterson and the Chinese official and involved Canadian lawyer used a British Virgin Islands registered entity, Asiasphere Holdings Ltd. to conceal their interest in the real estate; other BVI entities were used to hold ownership in Asiasphere:  Strong Man Ltd. and ParaPlay; the complaint alleges that the men misrepresented Asiasphere as a subsidiary of Yongye and that other legal entities were also employed to hold ownership in the real estate. (Source: SEC v. Garth Ronald Peterson, Case No. 1:12-cv-02033-JBW (E.D.N.Y.), Complaint filed April 25, 2012, paras 10, 14, 16.)  As part of the final judgment in his civil case, Mr. Peterson was ordered to pay $3,667,713 in disgorgement and $154,900.44 in prejudgment interest; the court specified that $2,741,693 represented profits by Mr. Peterson in the involved real estate. (Source: SEC v. Garth Ronald Peterson, Case No. 1:12-cv-02033-JBW (E.D.N.Y.), Final Judgment filed May 3, 2012.)","Sources ":"US Securities and Exchange Commission Press Release 2012-78, \u0022SEC Charges Former Morgan Stanley Executive with FCPA Violations and Investment Adviser Fraud,\u0022 April 25, 2012, accessed at http:\/\/www.sec.gov\/news\/press\/2012\/2012-78.htm; copy of Complaint filed in SEC v. Garth Ronald Peterson (E.D.N.Y.) accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-78.pdf;  SEC v. Garth Ronald Peterson, Case No. 1:12-cv-02033-JBW (E.D.N.Y.), Final Judgment filed May 3, 2012 (accessed via PACER). ","Documents":""},{"Case ID":"ST-278","Case Cluster ":"NATCO Group, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Kazakhstan","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"01\/11","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order, Consent to Final Judgment","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$65,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$65,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Immigration)","Summary":"According to the US Securities and Exchange Commission Litigation Release in SEC v. NATCO Group, Inc., on January 11, 2010, the SEC filed a settled civil action in the U.S. District Court for the Southern District of Texas charging NATCO Group Inc.  Without admitting or denying the allegations in the Commission\u0027s complaint, NATCO agreed to pay a $65,000 civil penalty.  The Complaint had alleged that NATCO\u0027s wholly-owned subsidiary TEST Automation \u0026 Controls, Inc. \u0022created and accepted false documents while paying extorted immigration fines and obtaining immigration visas in the Republic of Kazakhstan.\u0022 (Source: SEC Litigation Release No. 21374 \/ January 11, 2010, SEC v. NATCO Group Inc., Civil Action No. 4:10-CV-98 (S.D. Tex.).  According to the SEC Complaint, TEST maintained a branch office in Kazakhstan; in February and September 2007, Kazakh immigration prosecutors conducted audits and claimed that TEST expatriate employees were working in Kazkahstan without proper documentation and \u0022the prosecutors threatened to fine, jail or deport the workers if TEST Kazakhstan did not pay cash fines. [para 6]  Believing the prosecutor\u0027s threats to be genuine,\u0022 TEST employees paid and then were later reimbursed by the company. (Source: SEC v. NATCO Group, Inc., Case No. 4:10-cv-98 (S.D. Tex.), Complaint filed January 11, 2010.)  NATCO also consented to an SEC Cease and Desist Order, enjoining the company from future FCPA violations. (Source: In the Matter of NATCO Group Inc., Administrative Proceeding File No. 3-13742, Cease and Desist Order)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, NATGO Group Inc. Case Summary at 55-56, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. In the Matter of NATCO Group Inc., Administrative Proceeding File No. 3-13742, Cease and Desist Order, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2010\/34-61325.pdf; SEC Litigation Release No. 21374 \/ January 11, 2010, SEC v. NATCO Group Inc., Civil Action No. 4:10-CV-98 (S.D. Tex.), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21374.htm; Complaint, Consent Order and Final Judgment in SEC v. NATCO Group, Inc. Case No. 4:10-cv-98 (S.D. Tex.), accessed from The FCPA Blog at http:\/\/www.fcpablog.com\/blog\/2010\/1\/12\/natco-settles-extorted-bribe-case.html. ","Documents":""},{"Case ID":"ST-279","Case Cluster ":"Nature\u0027s Sunshine Products Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Brazil","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"07\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$600,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$600,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Fraud in Connection with the Purchase or Sale of Securities, Disclosure Violations, Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the June 2011 United States Report to the OECD, \u0022On July 31, 2009, the SEC filed a settled enforcement action against Nature\u0027s Sunshine Products Inc. (NSP), a manufacturer of nutritional and personal care products, as well as its Chief Executive Officer Douglas Faggioli and its former Chief Financial Officer Craig D. Huff. This complaint alleged that the defendants violated the antifraud, issuer reporting, books and records, and internal controls provisions of federal securities laws in connection with a series of cash payments to Brazilian government officials in 2000 and 2001. The complaint alleged that, faced with changes to Brazilian regulations which resulted in classifying many of NSP\u0027s products as medicines, which would have required NSP to register many of its products for importation and sale, NSP\u0027s Brazilian subsidiary made a series of cash payments to customs officials in order to induce them to allow NSP to import unregistered products into that country. NSP\u0027s Brazilian subsidiary then purchased false documentation to conceal the nature of the payments, which were later falsely recorded in the books and records of NSP. The complaint also alleged that Faggioli and Huff, in their capacities as control persons, violated the books and records and internal controls provisions of the FCPA in connection with the Brazilian cash payments. In addition, it is alleged that NSP failed to disclose the payments to Brazilian customs agents in its filings with the SEC.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Nature\u0027s Sunshine Products Inc. Case Summary at 61-62.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Nature\u0027s Sunshine Products Inc. Case Summary at 61-62, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 21162 \/ July 31, 2009, SEC v. Nature\u0027s Sunshine Products, Inc., Douglas Faggioli and Craig D. Huff, Case No. 09CV672 (D. Utah, Filed July 31, 2009), \u0022SEC Charges Nature\u0027s Sunshine Products, Inc. with Making Illegal Foreign Payments,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21162.htm; Complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp21162.pdf","Documents":""},{"Case ID":"ST-280","Case Cluster ":"Nature\u0027s Sunshine Products Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Brazil","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"07\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$25,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$25,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the June 2011 United States Report to the OECD, \u0022On July 31, 2009, the SEC filed a settled enforcement action against Nature\u2018s Sunshine Products Inc. (NSP), a manufacturer of nutritional and personal care products, as well as its Chief Executive Officer Douglas Faggioli and its former Chief Financial Officer Craig D. Huff. This complaint alleged that the defendants violated the antifraud, issuer reporting, books and records, and internal controls provisions of federal securities laws in connection with a series of cash payments to Brazilian government officials in 2000 and 2001. The complaint alleged that, faced with changes to Brazilian regulations which resulted in classifying many of NSP\u2018s products as medicines, which would have required NSP to register many of its products for importation and sale, NSP\u2018s Brazilian subsidiary made a series of cash payments to customs officials in order to induce them to allow NSP to import unregistered products into that country. NSP\u2018s Brazilian subsidiary then purchased false documentation to conceal the nature of the payments, which were later falsely recorded in the books and records of NSP. The complaint also alleged that Faggioli and Huff, in their capacities as control persons, violated the books and records and internal controls provisions of the FCPA in connection with the Brazilian cash payments. In addition, it is alleged that NSP failed to disclose the payments to Brazilian customs agents in its filings with the SEC.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Nature\u0027s Sunshine Products Inc. Case Summary at 61-62.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Nature\u0027s Sunshine Products Inc. Case Summary at 61-62, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 21162 \/ July 31, 2009, SEC v. Nature\u0027s Sunshine Products, Inc., Douglas Faggioli and Craig D. Huff, Case No. 09CV672 (D. Utah, Filed July 31, 2009), \u0022SEC Charges Nature\u0027s Sunshine Products, Inc. with Making Illegal Foreign Payments,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21162.htm; Complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp21162.pdf","Documents":""},{"Case ID":"ST-281","Case Cluster ":"Nature\u0027s Sunshine Products Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Brazil","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"07\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$25,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$25,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the June 2011 United States Report to the OECD, \u0022On July 31, 2009, the SEC filed a settled enforcement action against Nature\u2018s Sunshine Products Inc. (NSP), a manufacturer of nutritional and personal care products, as well as its Chief Executive Officer Douglas Faggioli and its former Chief Financial Officer Craig D. Huff. This complaint alleged that the defendants violated the antifraud, issuer reporting, books and records, and internal controls provisions of federal securities laws in connection with a series of cash payments to Brazilian government officials in 2000 and 2001. The complaint alleged that, faced with changes to Brazilian regulations which resulted in classifying many of NSP\u2018s products as medicines, which would have required NSP to register many of its products for importation and sale, NSP\u2018s Brazilian subsidiary made a series of cash payments to customs officials in order to induce them to allow NSP to import unregistered products into that country. NSP\u2018s Brazilian subsidiary then purchased false documentation to conceal the nature of the payments, which were later falsely recorded in the books and records of NSP. The complaint also alleged that Faggioli and Huff, in their capacities as control persons, violated the books and records and internal controls provisions of the FCPA in connection with the Brazilian cash payments. In addition, it is alleged that NSP failed to disclose the payments to Brazilian customs agents in its filings with the SEC.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Nature\u0027s Sunshine Products Inc. Case Summary at 61-62.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Nature\u0027s Sunshine Products Inc. Case Summary at 61-62, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 21162 \/ July 31, 2009, SEC v. Nature\u0027s Sunshine Products, Inc., Douglas Faggioli and Craig D. Huff, Case No. 09CV672 (D. Utah, Filed July 31, 2009), \u0022SEC Charges Nature\u0027s Sunshine Products, Inc. with Making Illegal Foreign Payments,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21162.htm; Complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp21162.pdf","Documents":""},{"Case ID":"ST-282","Case Cluster ":"Nexus Technologies Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; United States Attorney for the Eastern District of Pennsylania","Jurisdiction of Foreign Public Official(s) ":"Vietnam","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"06\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Special Assessment","Total Monetary Sanctions (US$)":"$11,200.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"$11,200 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy, Bribery of foreign officials, Commercial bribery,  Money laundering ","Offenses - Settled":"Conspiracy, Bribery of foreign officials, Commercial bribery, Money laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 57-58, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: Time period of misconduct in Vietnam 1999-2008; on September 4, 2008, Nexus and its employees Nam Quoc Nguyen, Kim Nguyen, and An Nguyen and joint venture partner Joseph Lukas were indicted by a grand jury in Philadephia on charges related to scheme to pay bribes totalling at least $250,000 to employees of state-owned enterprises in Vietnam in exchange for favorable treatment for Nexus in the award of procurement contracts.  In accordance with its plea agreement, Nexus was given 1 year of organizational probation in which to completely cease operations, formally dissolve, and turn over all assets to the court. Nexus was ordered to pay $11,200 in special assessment but no fine and no restitution. (Source: US v. Nexus Technologies, Inc. Case No. 2:08-cr-00522-TJS (E.D. Pa.), Final Judgment filed September 16, 2010.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 58-59, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Dept of Justice Press Release. \u0022Former Nexus Technologies Inc. Employees and Partner Sentenced for Roles in Foreign Bribery Scheme Involving Vietnamese Officials.\u0022 Sept. 16, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/September\/10-crm-1032.html; US Dept of Justice Press Release. \u0022Nexus Technologies Inc. and Three Employees Plead Guilty to Paying Bribes to Vietnamese Officials.\u0022 Mar. 16, 2010, accessed at www.justice.gov\/usao\/pae\/News\/Pr\/2010\/mar\/nexus_release.pdf; Superseding Indictment, U.S. v. Nexus Technologies, Inc. et al., no. 2:08-cr-00522-TJS (E.D. Pa., Oct. 29, 2009); Final Judgment filed September 16, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nguyenn\/09-16-10nguyennexus-judgment.pdf.  The Department of Justice press release on the sentencing of Nexus Technologies and related individual defendants acknowledged the assistance in the case by the Hong Kong\u0027s Independent Commission Against Corruption. (The bribery funds had been transferred from the US to HK).","Documents":""},{"Case ID":"ST-283","Case Cluster ":"Nexus Technologies Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; United States Attorney for the Eastern District of Pennsylania","Jurisdiction of Foreign Public Official(s) ":"Vietnam","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"9\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy, Bribery of foreign officials, Commercial bribery, Money laundering","Offenses - Settled":"Conspiracy, Bribery of foreign officials, Commercial bribery, Money laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 57-58, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: Time period of misconduct in Vietnam 1999-2008; on September 4, 2008, Nexus and its employees Nam Quoc Nguyen, Kim Nguyen, and An Nguyen and joint venture partner Joseph Lukas were indicted by a grand jury in Philadephia on charges related to scheme to pay bribes totalling at least $250,000 to employees of state-owned enterprises in Vietnam in exchange for favorable treatment for Nexus in the award of procurement contracts.  In accordance with its plea agreement, Nexus was given 1 year of organizational probation in which to completely cease operations, formally dissolve, and turn over all assets to the court. Nexus was ordered to pay $11,200 in special assessment but no fine and no restitution. (Source: US v. Nexus Technologies, Inc. Case No. 2:08-cr-00522-TJS (E.D. Pa.), Final Judgment filed September 16, 2010.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 58-59, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Dept of Justice Press Release. \u0022Former Nexus Technologies Inc. Employees and Partner Sentenced for Roles in Foreign Bribery Scheme Involving Vietnamese Officials.\u0022 Sept. 16, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/September\/10-crm-1032.html; US Dept of Justice Press Release. \u0022Nexus Technologies Inc. and Three Employees Plead Guilty to Paying Bribes to Vietnamese Officials.\u0022 Mar. 16, 2010, accessed at www.justice.gov\/usao\/pae\/News\/Pr\/2010\/mar\/nexus_release.pdf; Superseding Indictment, U.S. v. Nexus Technologies, Inc. et al., no. 2:08-cr-00522-TJS (E.D. Pa., Oct. 29, 2009); Final Judgment filed September 16, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nguyenn\/09-16-10nguyennexus-judgment.pdf.  The Department of Justice press release on the sentencing of Nexus Technologies and related individual defendants acknowledged the assistance in the case by the Hong Kong\u0027s Independent Commission Against Corruption. (The bribery funds had been transferred from the US to HK).","Documents":""},{"Case ID":"ST-284","Case Cluster ":"Nexus Technologies Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; United States Attorney for the Eastern District of Pennsylania","Jurisdiction of Foreign Public Official(s) ":"Vietnam","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"06\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,000.00","Criminal Fine\/Penalty (US$) ":"$1,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy, Bribery of foreign officials","Offenses - Settled":"Conspiracy, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 57-58, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: Time period of misconduct in Vietnam 1999-2008; on September 4, 2008, Nexus and its employees Nam Quoc Nguyen, Kim Nguyen, and An Nguyen and joint venture partner Joseph Lukas were indicted by a grand jury in Philadephia on charges related to scheme to pay bribes totalling at least $250,000 to employees of state-owned enterprises in Vietnam in exchange for favorable treatment for Nexus in the award of procurement contracts.  In accordance with its plea agreement, Nexus was given 1 year of organizational probation in which to completely cease operations, formally dissolve, and turn over all assets to the court. Nexus was ordered to pay $11,200 in special assessment but no fine and no restitution. (Source: US v. Nexus Technologies, Inc. Case No. 2:08-cr-00522-TJS (E.D. Pa.), Final Judgment filed September 16, 2010.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 58-59, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Dept of Justice Press Release. \u0022Former Nexus Technologies Inc. Employees and Partner Sentenced for Roles in Foreign Bribery Scheme Involving Vietnamese Officials.\u0022 Sept. 16, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/September\/10-crm-1032.html; US Dept of Justice Press Release. \u0022Nexus Technologies Inc. and Three Employees Plead Guilty to Paying Bribes to Vietnamese Officials.\u0022 Mar. 16, 2010, accessed at www.justice.gov\/usao\/pae\/News\/Pr\/2010\/mar\/nexus_release.pdf; Superseding Indictment, U.S. v. Nexus Technologies, Inc. et al., no. 2:08-cr-00522-TJS (E.D. Pa., Oct. 29, 2009); Final Judgment filed September 16, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nguyenn\/09-16-10nguyennexus-judgment.pdf.  The Department of Justice press release on the sentencing of Nexus Technologies and related individual defendants acknowledged the assistance in the case by the Hong Kong\u0027s Independent Commission Against Corruption. (The bribery funds had been transferred from the US to HK).","Documents":""},{"Case ID":"ST-285","Case Cluster ":"Nexus Technologies Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; United States Attorney for the Eastern District of Pennsylania","Jurisdiction of Foreign Public Official(s) ":"Vietnam","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"9\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$20,000.00","Criminal Fine\/Penalty (US$) ":"$20,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy, Bribery of foreign officials, Commercial bribery, Money laundering","Offenses - Settled":"Conspiracy, Bribery of foreign officials, Commercial bribery, Money laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 57-58, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: Time period of misconduct in Vietnam 1999-2008; on September 4, 2008, Nexus and its employees Nam Quoc Nguyen, Kim Nguyen, and An Nguyen and joint venture partner Joseph Lukas were indicted by a grand jury in Philadephia on charges related to scheme to pay bribes totalling at least $250,000 to employees of state-owned enterprises in Vietnam in exchange for favorable treatment for Nexus in the award of procurement contracts.  In accordance with its plea agreement, Nexus was given 1 year of organizational probation in which to completely cease operations, formally dissolve, and turn over all assets to the court. Nexus was ordered to pay $11,200 in special assessment but no fine and no restitution. (Source: US v. Nexus Technologies, Inc. Case No. 2:08-cr-00522-TJS (E.D. Pa.), Final Judgment filed September 16, 2010.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 58-59, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Dept of Justice Press Release. \u0022Former Nexus Technologies Inc. Employees and Partner Sentenced for Roles in Foreign Bribery Scheme Involving Vietnamese Officials.\u0022 Sept. 16, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/September\/10-crm-1032.html; US Dept of Justice Press Release. \u0022Nexus Technologies Inc. and Three Employees Plead Guilty to Paying Bribes to Vietnamese Officials.\u0022 Mar. 16, 2010, accessed at www.justice.gov\/usao\/pae\/News\/Pr\/2010\/mar\/nexus_release.pdf; Superseding Indictment, U.S. v. Nexus Technologies, Inc. et al., no. 2:08-cr-00522-TJS (E.D. Pa., Oct. 29, 2009); Final Judgment filed September 16, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nguyenn\/09-16-10nguyennexus-judgment.pdf.  The Department of Justice press release on the sentencing of Nexus Technologies and related individual defendants acknowledged the assistance in the case by the Hong Kong\u0027s Independent Commission Against Corruption. (The bribery funds had been transferred from the US to HK).","Documents":""},{"Case ID":"ST-286","Case Cluster ":"Nexus Technologies Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; United States Attorney for the Eastern District of Pennsylania","Jurisdiction of Foreign Public Official(s) ":"Vietnam","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"9\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy, Bribery of foreign officials, Commercial bribery, Money laundering","Offenses - Settled":"Conspiracy, Bribery of foreign officials, Commercial bribery, Money laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 57-58, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: Time period of misconduct in Vietnam 1999-2008; on September 4, 2008, Nexus and its employees Nam Quoc Nguyen, Kim Nguyen, and An Nguyen and joint venture partner Joseph Lukas were indicted by a grand jury in Philadephia on charges related to scheme to pay bribes totalling at least $250,000 to employees of state-owned enterprises in Vietnam in exchange for favorable treatment for Nexus in the award of procurement contracts.  In accordance with its plea agreement, Nexus was given 1 year of organizational probation in which to completely cease operations, formally dissolve, and turn over all assets to the court. Nexus was ordered to pay $11,200 in special assessment but no fine and no restitution. (Source: US v. Nexus Technologies, Inc. Case No. 2:08-cr-00522-TJS (E.D. Pa.), Final Judgment filed September 16, 2010.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Nexus Technologies, at 58-59, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Dept of Justice Press Release. \u0022Former Nexus Technologies Inc. Employees and Partner Sentenced for Roles in Foreign Bribery Scheme Involving Vietnamese Officials.\u0022 Sept. 16, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/September\/10-crm-1032.html; US Dept of Justice Press Release. \u0022Nexus Technologies Inc. and Three Employees Plead Guilty to Paying Bribes to Vietnamese Officials.\u0022 Mar. 16, 2010, accessed at www.justice.gov\/usao\/pae\/News\/Pr\/2010\/mar\/nexus_release.pdf; Superseding Indictment, U.S. v. Nexus Technologies, Inc. et al., no. 2:08-cr-00522-TJS (E.D. Pa., Oct. 29, 2009); Final Judgment filed September 16, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nguyenn\/09-16-10nguyennexus-judgment.pdf.  The Department of Justice press release on the sentencing of Nexus Technologies and related individual defendants acknowledged the assistance in the case by the Hong Kong\u0027s Independent Commission Against Corruption. (The bribery funds had been transferred from the US to HK).","Documents":""},{"Case ID":"ST-287","Case Cluster ":"Niko Resources Ltd.","Jurisdiction of Settlement":"Canada","Jurisdiction of Settlement \/ Enforcement Agency":"Crown Counsel","Jurisdiction of Foreign Public Official(s) ":"Bangladesh","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"06\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Victim Surcharge","Total Monetary Sanctions (US$)":"$9,731,180.00","Criminal Fine\/Penalty (US$) ":"$8,400,430","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$1,330,750","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Provide Improper Benefits to Foreign Official (Section 3(1)(b) of the Corruption of Foreign Public Officials Act) ","Offenses - Settled":"Provide Improper Benefits to Foreign Official (Section 3(1)(b) of the Corruption of Foreign Public Officials Act)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the press release issued by the Royal Canadian Mounted Police, \u0022As a result of a six-year investigation conducted by the Calgary RCMP International Anti-Corruption Unit, a Calgary based, publicly-traded corporation, Niko Resources Ltd., was charged with one count of Section 3(1)(b) of the Corruption of Foreign Public Officials Act covering the period of February 1st, 2005 to June 30th, 2005.  Between the dates of the indictment, Niko provided the following improper benefits:  In May 2005, the company, through its subsidiary Niko Bangladesh, provided the use of a vehicle to AKM Mosharraf Hossain, the former Bangladeshi State Minister for Energy and Mineral Resources. The vehicle, which cost $190,984 CAN, was provided in order to influence the Minister in dealings with Niko Bangladesh. In June 2005, Niko paid travel and accommodation expenses for Minister AKM Mosharraf Hossain to travel from Bangladesh to Calgary to attend the GO EXPO oil and gas exposition. Niko also improperly paid approximately $5000 for non-business travel to New York and Chicago so the Minister could visit his family.  Today, Niko Resources Ltd. attended the Court of Queen\u0027s Bench and entered a guilty plea to the charge. Counsel for the Crown and Niko made a recommendation to the Court for a fine of $8,200,000 and the victim surcharge for a total of $9,499,000.00, which Justice Brooker of the Court of Queen\u0027s Bench imposed as the appropriate sentence. Niko Resources Ltd. has also been placed under a Probation Order which puts the company under the Court?s supervision for the next three years to ensure that audits are completed to examine Niko\u0027s compliance with the Corruption of Foreign Public Officials Act.  These types of investigations are complex and resource intensive, involving many separate jurisdictions. In addition, they cannot be completed without the cooperation of authorities in other countries.  The RCMP\u0027s International Anti-Corruption Unit would like to thank the Bangladesh Anti-Corruption Commission, the United States Department of Justice Fraud Section, the Federal Bureau of Investigation International Corruption Unit, as well as various law enforcement and government agencies in Switzerland, Japan, the United Kingdom, and Barbados.\u0022 (Source: Royal Canadian Mounted Police Press Release, \u0022Corruption Charges Laid Against NIKO Resources,\u0022 June 24, 2011.)","Sources ":"Royal Canadian Mounted Police Press Release, \u0022Corruption Charges Laid Against NIKO Resources,\u0022 June 24, 2011, accessed at http:\/\/www.rcmp-grc.gc.ca\/ab\/news-nouvelles\/2011\/110624-niko-eng.htm; The Corruption of Foreign Public Officials Act \/ A Guide, accessed at http:\/\/www.justice.gc.ca\/eng\/dept-min\/pub\/cfpoa-lcape\/index.html;  Between Her Majesty the Queens and Niko Resources Ltd., Agreed Statement of Facts (Queen\u0027s Bench of Alberta, Judicial District of Calgary), June 23, 2011, accessed at http:\/\/www.osler.com\/uploadedFiles\/Agreed%20statement%20of%20facts.pdf","Documents":""},{"Case ID":"ST-288","Case Cluster ":"Novo Nordisk A\/S","Jurisdiction of Settlement":"Denmark","Jurisdiction of Settlement \/ Enforcement Agency":"Public Prosecutor for Serious Economic Crime","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"6\/26","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Criminal Confiscation","Total Monetary Sanctions (US$)":"$5,663,620.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$5,663,620","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"OECD Phase 2 report noted investigations under section 110c(2) of the Danish Criminal Code - known as \u0022breach of UN sanctions\u0022","Offenses - Settled":"OECD Phase 2 report noted investigations under section 110c(2) of the Danish Criminal Code - known as \u0022breach of UN sanctions\u0022","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 29, 2009 Press Release by the Novo Nordisk company, \u0022Novo Nordisk announced today that it has reached a settlement with the Danish Public Prosecutor for Serious Economic Crime regarding the company\u0027s sales to Iraq during 2000 to 2003 under the United Nations Oil-for-Food programme.  Under the terms of the settlement, Novo Nordisk will pay back past profits of 30 million Danish kroner. Novo Nordisk cooperated fully with the Public Prosecutor in his investigations of the company, which are now concluded. In May, Novo Nordisk reached settlements on the same issue with the US.\u0022  (Source: Novo Nordisk Company Press Release, \u0022Novo Nordisk reaches settlement with the Danish authorities regarding Oil-for-Food activities,\u0022 June 29, 2009.)","Sources ":"Novo Nordisk Company Press Release, \u0022Novo Nordisk reaches settlement with the Danishauthorities regarding Oil-for-Food activities,\u0022 June 29, 2009, accessed at http:\/\/www.novonordisk.com\/press\/sea\/sea.asp?sNewsTypeGUID=\u0026lMonth=6\u0026lYear=2009\u0026sLanguageCode=en-GB\u0026sSearchText=danish\u0026fb=2574\u0026cat=pr\u0026sShowNewsItemGUID=6f5581f7-a9f0-4f3a-b914-d5335dc0feeb\u0026sShowLanguageCode=en-GB","Documents":""},{"Case ID":"ST-289","Case Cluster ":"Novo Nordisk A\/S","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"5\/6","Other Jurisdictions of Settlement":"Denmark","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$9,000,000.00","Criminal Fine\/Penalty (US$) ":"$9,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"","Offenses - Alleged":"Conspiracy to Commit Wire Fraud, Conspiracy to Falsify Books and Records","Offenses - Settled":"Conspiracy to Commit Wire Fraud, Conspiracy to Falsify Books and Records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On May 11, 2009, Novo Nordisk A\/S (Novo), a Danish corporation based in Bagsvaerd, Denmark, was charged in a one-count criminal information with conspiracy to commit wire fraud and to violate the books and records provisions of the FCPA. On the same date, the SEC filed a settled civil complaint against Novo in the U.S. District Court for the District of Columbia. According to court documents, between 2001 and 2003, a Jordan-based agent acting on behalf of Novo, an international manufacturer of insulin, medicines and other pharmaceutical supplies, made improper payments worth approximately $1.4 million to the former Iraqi government in order to obtain contracts with the Iraqi Ministry of Health to provide insulin and other medicines as part of the Oil-for-Food Program (OFFP).Novo engaged its long-time Jordan-based agent to submit bids on Novo\u0027s behalf to Kimadia, the Iraqi State Company for the Importation and Distribution of Drugs and Medical Appliances, a state-owned company which was part of the Iraqi Ministry of Health. Two branches of Novo Nordisk - RONE, based in Athens, Greece, and NEO, based in Amman, Jordan - handled the sales to the Iraq and supplied the agent with bid prices for each contract. In late 2000 or early 2001, a Kimadia import manager advised the agent that Kimadia required Novo Nordisk to pay a ten percent kickback in order to obtain a contract under the Program. The Kimadia import manager told the agent that Novo Nordisk should increase its prices by ten percent and pay that amount to Kimadia. By doing so, Novo would recover the secret kickback from the U.N. escrow account when the contract, with the inflated price, was subsequently approved for disbursement and paid by the U.N.  Beginning in 2001 and continuing through 2003, Novo paid these kickbacks, characterized as \u0022after-sales service fees\u0022 (\u0022ASSFs\u0022), by inflating the price of contracts by 10 percent before submitting the contracts to the U.N. for approval. Novo also concealed from the U.N. the fact that the price contained a kickback to the former Iraqi government. In addition, on at least two occasions in 2001, Novo paid increased commissions to its agent to pay the kickbacks to Kimadia. The agent\u0027s commission was increased under the guise that the payment was used to cover the agent\u0027s increased distribution and marketing costs. All together, Novo paid over $1.4 million in kickbacks payments on eleven contracts through the agent, and agreed to pay approximately $1.3 million in ASSFs on two additional contracts. Novo then inaccurately recorded the kickback payments as \u0022commissions\u0022 in its books and records.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Novo Nordisk A\/S Case Summary at 66-68, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Novo Nordisk A\/S Case Summary at 66-68, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Novo Nordisk A\/S, Case No. 1:09-cr-00126-RJL (D.D.C.), Information filed May 11, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nordiskn\/05-11-09novo-info.pdf; Deferred Prosecution Agreement filed May 11, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nordiskn\/05-06-09novo-agree.pdf; US Department of Justice Press Release, \u0022Novo Nordisk Agrees to Pay $9 Million Fine in Connection with Payment of $1.4 Million in Kickbacks Through the United Nations Oil-for-food Program,\u0022 May 11, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nordiskn\/05-06-09novo-agree.pdf","Documents":""},{"Case ID":"ST-290","Case Cluster ":"Novo Nordisk A\/S","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"05\/11","Other Jurisdictions of Settlement":"Denmark","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$9,030,145.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$4,321,523","Civil Prejudgment Interest (US$) ":"$1,683,556","Civil Fine \/ Penalty (US$)":"$3,025,066","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art.1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On May 11, 2009, Novo Nordisk A\/S (Novo), a Danish corporation based in Bagsvaerd, Denmark, was charged in a one-count criminal information with conspiracy to commit wire fraud and to violate the books and records provisions of the FCPA. On the same date, the SEC filed a settled civil complaint against Novo in the U.S. District Court for the District of Columbia.According to court documents, between 2001 and 2003, a Jordan-based agent acting on behalf of Novo, an international manufacturer of insulin, medicines and other pharmaceutical supplies, made improper payments worth approximately $1.4 million to the former Iraqi government in order to obtain contracts with the Iraqi Ministry of Health to provide insulin and other medicines as part of the Oil-for-Food Program (OFFP).Novo engaged its long-time Jordan-based agent to submit bids on Novo?s behalf to Kimadia, the Iraqi State Company for the Importation and Distribution of Drugs and Medical Appliances, a state-owned company which was part of the Iraqi Ministry of Health. Two branches of Novo Nordisk - RONE, based in Athens, Greece, and NEO, based in Amman, Jordan -- handled the sales to the Iraq and supplied the agent with bid prices for each contract. In late 2000 or early 2001, a Kimadia import manager advised the agent that Kimadia required Novo Nordisk to pay a ten percent kickback in order to obtain a contract under the Program. The Kimadia import manager told the agent that Novo Nordisk should increase its prices by ten percent and pay that amount to Kimadia. By doing so, Novo would recover the secret kickback from the U.N. escrow account when the contract, with the inflated price, was subsequently approved for disbursement and paid by the U.N.Beginning in 2001 and continuing through 2003, Novo paid these kickbacks, characterized as \u0022after-sales service fees\u0022 (\u0022ASSFs\u0022), by inflating the price of contracts by 10 percent before submitting the contracts to the U.N. for approval. Novo also concealed from the U.N. the fact that the price contained a kickback to the former Iraqi government. In addition, on at least two occasions in 2001, Novo paid increased commissions to its agent to pay the kickbacks to Kimadia. The agent\u0027s commission was increased under the guise that the payment was used to cover the agent\u0027s increased distribution and marketing costs. All together, Novo paid over $1.4 million in kickbacks payments on eleven contracts through the agent, and agreed to pay approximately $1.3 million in ASSFs on two additional contracts. Novo then inaccurately recorded the kickback payments as \u0022commissions\u0022 in its books and records.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Novo Nordisk A\/S Case Summary at 66-68, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.)  According to the SEC Litigation Release, the Commission acknowledged the assistance of the United Nations Independent Inquiry Committee. (Source: US Securities and Exchange Commission, Litigation Release No. 21033 \/ May 11, 2009, Securities \u0026 Exchange Commission v. Novo Nordisk A\/S, Civil Action No. 1:09-CV-00862 (D.D.C.) (EGS), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Novo Nordisk for Improper Payments to Iraq Under the U.N. Oil for Food Program \/ Novo Nordisk Agrees to Pay Over $10 Million in Disgorgement, Interest, and Penalties.\u0022)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Novo Nordisk A\/S Case Summary at 66-68, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21033 \/ May 11, 2009, Securities \u0026 Exchange Commission v. Novo Nordisk A\/S, Civil Action No. 1:09-CV-00862 (D.D.C.) (EGS), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Novo Nordisk for Improper Payments to Iraq Under the U.N. Oil for Food Program \/ Novo Nordisk Agrees to Pay Over $10 Million in Disgorgement, Interest, and Penalties,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21033.htm; Complaint filed May 11, 2009, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp21033.pdf.","Documents":""},{"Case ID":"ST-291","Case Cluster ":"NV Organon Oss","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Rijksrecherche (Dutch Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Out of court settlement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$608,213.00","Criminal Fine\/Penalty (US$) ":"$608,213","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Unknown","Offenses - Settled":"Sanctions legislation by paying kickbacks when implementing UN Oil-for-Food Programme","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Netherlands Phase 2 Report of the OECD Anti-Bribery Working Group (December 17, 2008): \u0022As of October 2008, no foreign bribery cases had been brought before the Dutch courts. Nevertheless, the prosecution authorities have concluded out-of-court transactions with seven companies for paying kickbacks in the context of the Oil-for-Food Programme in Iraq, although the offence charged was the violation of sanctions legislation and not the foreign bribery offence.\u0022 (para 2); \u0022 the Prosecution Department reports that it has concluded financial transactions (out of court settlements) with 7 companies for violating sanction legislation by paying kickbacks when implementing the Oil for Food Programme. Criminal gains have also been confiscated. In July 2008 a press release has been issued about these settlements. Together with the names of the companies (Alfasan International B.V., N.V. Organon, Flowserve B.V. , OPW Fluid Transfer Group Europe B.V., Prodetra B.V. Solvochem Holland B.V., Stet Holland B.V.) the settlements have been made public. For the following Oil-for-food transactions out-of-court settlements have been reached: 1. Alfasan International BV Woerden, fine: \u20ac 31.800,-- and confiscation \u20ac 10.183,55 2. NV Organon Oss, fine: \u20ac 381.602 3. Flowerserve bv te Etten-Leur, fine: \u20ac 76.274 and confiscation \u20ac180.260 4. OPW Fluid Transfer Group Europe BV, Nieuw Vennep, fine \u20ac 57.204 and confiscation \u20ac 24.600 5. Prodetra bv,Wadinxveen, fine: 64.751 and confiscation \u20ac 34.485,95 6. Solvochem Holland bv, Rotterdam, fine \u20ac 136.000 and confiscation \u20ac 144.592 7. Stet Holland bv,Emmeloord, fine \u20ac 119.712 and confiscation \u20ac 54.458.\u0022 (Source: Ibid., at 14.)","Sources ":"OECD Anti-Bribery Working Group, The Netherlands Phase 2 Report (December 17, 2008), accessed at http:\/\/www.oecd.org\/dataoecd\/61\/59\/41919004.pdf;    http:\/\/www.oecd.org\/daf\/anti-bribery\/Netherlandsphase3reportEN.pdf    Melissa Lipman, \u0022Cos. Settle Dutch Probe Into Oil-For-Food For \u20ac1.3M,\u0022 Law 360, July 16, 2008, accessed at http:\/\/www.law360.com\/articles\/62486\/cos-settle-dutch-probe-into-oil-for-food-for-1-3m (partial article, gives date of Dutch Public Prosecution Service press release.)","Documents":""},{"Case ID":"ST-293","Case Cluster ":"Oily Rock","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Azerbaijan","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"06\/19","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Civil  Asset Forfeiture","Total Monetary Sanctions (US$)":"$500,000.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"$500,000","Other Civil Monetary Sanctions (Explanation)":"Forfeiture","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering, Bribery of Foreign Officials, Violation of Travel Act ","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On May 12, 2005, Viktor Kozeny, Frederic A. Bourke Jr., and David Pinkerton were indicted in the Southern District of New York on charges of conspiracy to violate the FCPA and Travel Act, substantive FCPA violations, substantive Travel Act Violations, conspiracy to commit money laundering, substantive money laundering charges, and, in the case of Bourke and Pinkerton, making false statements. These charges stemmed from their role in a scheme to pay millions of dollars worth of bribes to Azeri government officials to ensure that the defendants\u0027 investment consortium would gain, in secret partnership with the Azeri officials, a controlling interest in the State Oil Company of the Azerbaijan Republic (SOCAR) and its substantial oil reserves.  According to evidence presented in the trial of Bourke, in August 1997, Kozeny allegedly agreed to transfer to corrupt Azeri officials two-thirds of the vouchers and options purchased by his investment consortium, Oily Rock, and to give them two-thirds of all of the profits arising from his investment consortium\u0027s participation in SOCAR\u0027s privatization. In addition, evidence presented at trial showed that in June 1998, Bourke knew that Kozeny arranged for Oily Rock to increase its authorized share capital from $150 million to $450 million so that the additional $300 million worth of Oily Rock shares could be transferred to one or more of the Azeri officials as a further bribe payment. Bourke also arranged for two of the corrupt officials to travel to New York City on different occasions in 1998 to receive medical treatment, for which Oily Rock paid. Thereafter, in interviews with the FBI in April and May of 2002, Bourke falsely stated that he was not aware that Kozeny had made the alleged payments to the Azeri Officials.  Three others have been charged in connection with their roles in this bribery scheme. Thomas Farrell, a former employee of Oily Rock, was charged in an information with one count of conspiracy to violate the FCPA and one count of violating the FCPA\u0027s anti-bribery provisions. On July 31, 2003, Clayton Lewis, a former principal of Omega Advisors and a co-investor in the scheme, was indicted on one count of conspiracy to violate the FCPA and one count of conspiracy to commit money laundering. On August 5, 2003, a grand jury in New York returned an indictment charging the third individual, Hans Bodmer, a Swiss lawyer who represented Kozeny and his investment consortium, with conspiring to violate the FCPA\u0027s anti-bribery provisions and conspiracy to commit money laundering. At the United States\u0027 request, Korea extradited Mr. Bodmer to the United States in 2004.  In June 2007, the Department entered into a nonprosecution agreement with Omega Advisors, regarding its role as a major investor in the consortium.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Oily Rock Case Summary at 102-103.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Oily Rock Case Summary at 102-103, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  In Re: Omega Advisors, Inc., Non-Prosecution Agreement dated June 19,2007,accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/omega-advisors\/06-19-07omega-agree.pdf; United States Attorney for Southern District of New York Press Release, \u0022U.S. Announces Settlement with Hedge Fund Omega Advisors, Inc. in Connection with Omega\u0027s Investment in Privatization Program in Azerbaijan,\u0022  July 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/omega-advisors\/07-06-07omega-settlement.pdf (accessed on September 14, 2011).","Documents":""},{"Case ID":"ST-294","Case Cluster ":"OPW Fluid Transfer Group Europe BV","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Rijksrecherche (Dutch Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Out of court settlement ","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation ","Total Monetary Sanctions (US$)":"$130,382.50","Criminal Fine\/Penalty (US$) ":"$91,174","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$39,208.50","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Unspecified","Offenses - Settled":"Sanctions legislation by paying kickbacks when implementing UN Oil-for-Food Programme","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Netherlands Phase 2 Report of the OECD Anti-Bribery Working Group (December 17, 2008): \u0022As of October 2008, no foreign bribery cases had been brought before the Dutch courts. Nevertheless, the prosecution authorities have concluded out-of-court transactions with seven companies for paying kickbacks in the context of the Oil-for-Food Programme in Iraq, although the offence charged was the violation of sanctions legislation and not the foreign bribery offence.\u0022 (para 2); \u0022 the Prosecution Department reports that it has concluded financial transactions (out of court settlements) with 7 companies for violating sanction legislation by paying kickbacks when implementing the Oil for Food Programme. Criminal gains have also been confiscated. In July 2008 a press release has been issued about these settlements. Together with the names of the companies (Alfasan International B.V., N.V. Organon, Flowserve B.V. , OPW Fluid Transfer Group Europe B.V., Prodetra B.V. Solvochem Holland B.V., Stet Holland B.V.) the settlements have been made public. For the following Oil-for-food transactions out-of-court settlements have been reached: 1. Alfasan International BV Woerden, fine:  \u20ac 31.800,-- and confiscation \u20ac 10.183,55 2. NV Organon Oss, fine:  \u20ac 381.602 3. Flowerserve bv te Etten-Leur, fine:  \u20ac 76.274 and confiscation  \u20ac180.260 4. OPW Fluid Transfer Group Europe BV, Nieuw Vennep, fine  \u20ac 57.204 and confiscation  \u20ac 24.600 5. Prodetra bv,Wadinxveen, fine: 64.751 and confiscation  \u20ac 34.485,95 6. Solvochem Holland bv, Rotterdam, fine  \u20ac 136.000 and confiscation   \u20ac 144.592 7. Stet Holland bv,Emmeloord, fine  \u20ac 119.712 and confiscation  \u20ac 54.458.\u0022 (Source: Ibid., at 14.)","Sources ":"OECD Anti-Bribery Working Group, The Netherlands Phase 2 Report (December 17, 2008), accessed at http:\/\/www.oecd.org\/dataoecd\/61\/59\/41919004.pdf; Melissa Lipman, \u0022Cos. Settle Dutch Probe Into Oil-For-Food For  \u20ac1.3M,\u0022 Law 360, July 16, 2008, accessed at http:\/\/www.law360.com\/articles\/62486\/cos-settle-dutch-probe-into-oil-for-food-for-1-3m (partial article, gives date of Dutch Public Prosecution Service press release.)","Documents":""},{"Case ID":"ST-295","Case Cluster ":"Owl Securities and Investment Ltd.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Costa Rica","Year of Settlement":"2001","Month\/Day of Settlement (or Notes)":"08\/03","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1 ","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022In 2001, the Department of Justice filed charges against two executives and a part-owner of Owl Securities and Investment Ltd., a Missouri company, as well as an agent that represented the company and its wholly-owned Costa Rican subsidiary, OSI Proyectos. According to court documents, OSI Proyectos was engaged in the development of port facilities in Costa Rica, including an international airport and various luxury properties. In 1998, the ruling Costa Rican political party signed a letter agreeing to allow OSI and its subsidiary to move forward with developing the port facilities. However, before it granted formal permission, Pablo Barquero Hernandez, OSI\u0027s Costa Rican Representative indicated that OSI would be required to pay a final \u0022closing cost\u0022 or \u0022toll\u0022 of $1 million. This amount was later increased to $1.5 million. Together, Robert Richard King, a large shareholder in OSI, and Hernandez allegedly agreed to pay the Costa Rican ruling party a $1 million \u0022closing cost\u0022 to secure the contract. For their roles in this bribery scheme, King and Hernandez were indicted by a federal grand jury in the Western District of Missouri on June 27, 2001.  Two additional OSI executives were charged on August 3, 2001, for their roles in the illicit payments to Costa Rican officials. According to court documents, Richard K. Halford, then the CFO of OSI, had communicated with Hernandez and was aware of the payments to Costa Rican officials. He proposed opening a new account in Panama or the U.S. to route the payments. Albert Reitz, OSI?s Vice President and Secretary, assisted in raising funds from investors to pay for the bribe.\u0022  Reitz was sentenced to five years\u0027 probation. (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Owl Securities and Investment Ltd. Case Summary at 129-130.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Owl Securities and Investment Ltd. Case Summary at 129-130, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Albert Reitz, Case No. No.01-00222-01-Cr-W-1 (W.D. Mo.), Information filed August 3, 2001, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/reitz\/08-03-01reitz-info.pdf; Plea Agreement filed August 3, 2001, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/reitz\/08-03-01reitz-plea-agree.pdf","Documents":""},{"Case ID":"ST-296","Case Cluster ":"Owl Securities and Investment Ltd.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Costa Rica","Year of Settlement":"2001","Month\/Day of Settlement (or Notes)":"08\/03","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1 ","Offenses - Alleged":"Conspiracy to bribe foreign officials, Failure to Pay Taxes ","Offenses - Settled":"Conspiracy to bribe foreign officials, Failture to Pay Taxes","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022In 2001, the Department of Justice filed charges against two executives and a part-owner of Owl Securities and Investment Ltd., a Missouri company, as well as an agent that represented the company and its wholly-owned Costa Rican subsidiary, OSI Proyectos. According to court documents, OSI Proyectos was engaged in the development of port facilities in Costa Rica, including an international airport and various luxury properties. In 1998, the ruling Costa Rican political party signed a letter agreeing to allow OSI and its subsidiary to move forward with developing the port facilities. However, before it granted formal permission, Pablo Barquero Hernandez, OSI\u0027s Costa Rican Representative indicated that OSI would be required to pay a final \u0022closing cost\u0022 or \u0022toll\u0022 of $1 million. This amount was later increased to $1.5 million. Together, Robert Richard King, a large shareholder in OSI, and Hernandez allegedly agreed to pay the Costa Rican ruling party a $1 million \u0022closing cost\u0022 to secure the contract. For their roles in this bribery scheme, King and Hernandez were indicted by a federal grand jury in the Western District of Missouri on June 27, 2001.  Two additional OSI executives were charged on August 3, 2001, for their roles in the illicit payments to Costa Rican officials. According to court documents, Richard K. Halford, then the CFO of OSI, had communicated with Hernandez and was aware of the payments to Costa Rican officials. He proposed opening a new account in Panama or the U.S. to route the payments. Albert Reitz, OSI\u0027s Vice President and Secretary, assisted in raising funds from investors to pay for the bribe.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Owl Securities and Investment Ltd. Case Summary at 129-130.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Owl Securities and Investment Ltd. Case Summary at 129-130, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Richard K. Halford, Case No. 4:01-00221-cr-w-sow (W. Missouri), Information filed August 3, 2001, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/halford\/02-17-02halford-info.pdf; Plea Agreement filed June 26, 2001, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/halford\/06-26-01halford-plea.pdf; Government Motion for Downward Departure from the Sentencing Guidelines filed July 3, 2002, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/halford\/07-03-02halford-motion.pdf; and Judgment of July 9, 2002, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/halford\/07-0902halford-judgment.pdf","Documents":""},{"Case ID":"ST-298","Case Cluster ":"Oxford University Press","Jurisdiction of Settlement":"","Jurisdiction of Settlement \/ Enforcement Agency":"Integrity Vice Presidency","Jurisdiction of Foreign Public Official(s) ":"Unspecified sub-Saharan African countries (acts by Kenyan and Tanzanian subsidiaries whose geographical region included Kenya, Burundi, Malawi, Rwanda, Sudan, Uganda, Tanzania, Zanzibar archipelago)","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"07\/03","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Negotiated Resolution Agreement","Monetary Sanctions  (Types)":"Unspecified","Total Monetary Sanctions (US$)":"$500,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0 ","Civil Prejudgment Interest (US$) ":"$0 ","Civil Fine \/ Penalty (US$)":"$0 ","Other Civil Monetary Sanctions (US$)":"$500,000","Other Civil Monetary Sanctions (Explanation)":"Unspecified form of settlement payment","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Improper payments to government officials","Offenses - Settled":"Improper payments to government officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the World Bank Press Release, \u0022The World Bank Group today announced the debarment of two wholly-owned subsidiaries of Oxford University Press (OUP), namely: Oxford University Press East Africa Limited (OUPEA) and Oxford University Press Tanzania Limited (OUPT) - for a period of three years following OUP\u0027s acknowledgment of misconduct by its two subsidiaries in relation to two Bank-financed education projects in East Africa.  The debarment is part of a Negotiated Resolution Agreement between OUP and the World Bank Group.  In May 2011, investigators from the World Bank\u0027s Integrity Vice Presidency (INT) approached OUP about potential misconduct in Africa.  Following this, OUP conducted an internal investigation into its operations and reported its findings to INT. [ ]  The two companies made improper payments to government officials for two contracts to supply text books in relation to two World Bank-financed projects.  As a result, OUPEA and OUPT will be debarred for three years and OUP will receive a conditional non-debarment. In addition, in order to remedy part of the harm done by the misconduct, OUP has agreed to make a payment of US$500,000 to the World Bank as part of the Negotiated Resolution.\u0022 (Source: The World Bank Press Release, \u0022World Bank Sanctions Oxford University Press for Corrupt Practices Impacting Education Projects in East Africa,\u0022 July 3, 2012.)","Sources ":"The World Bank Press Release, \u0022World Bank Sanctions Oxford University Press for Corrupt Practices Impacting Education Projects in East Africa,\u0022 July 3, 2012, accessed at http:\/\/www.worldbank.org\/en\/news\/2012\/07\/03\/world-bank-sanctions-oxford-university-press-corrupt-practices-impacting-education-projects-east-africa","Documents":""},{"Case ID":"ST-207","Case Cluster ":"Innospec Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Treasury (Office of Foreign Assets Control)","Jurisdiction of Foreign Public Official(s) ":"Cuba  ","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/18","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Settlement Agreement","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$2,200,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"$2,200,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Violations of the Cuban Assets Control Regulations","Offenses - Settled":"Violations of the Cuban Assets Control Regulations","Public Procurement Contract \/ SOE Involved?":"No (Sanctions)","Summary":"According to the US Department of Treasury, Office of Foreign Assets Control Enforcement Notice, \u0022Innospec Inc., a Delaware corporation (\u0022Innospec\u0022), has agreed to pay $2.2 million to settle allegations of violations of the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (the \u0022CACR\u0022).  [  ] OFAC alleged that, after its acquisition of a foreign corporation that maintained a local sales office in Cuba, Innospec conducted business in Cuba through its acquired subsidiary, including conducting transactions in which the government of Cuba and\/or Cuban nationals had an interest in apparent violation of \u00a7 515.201(b) of the CACR.\u0022  Innospec admitted to allegations of violations of the CACR as part of its settlement agreement with the US Department of Justice. (Source: US Department of Treasury, Office of Foreign Assets Control, Enforcement Information for March 19, 2010, \u0022Innospec Inc. Settles Cuban Assets Control Regulations Allegations.\u0022) ","Sources ":"US Department of Treasury, Office of Foreign Assets Control, Enforcement Information for March 19, 2010, \u0022Innospec Inc. Settles Cuban Assets Control Regulations Allegations,\u0022 accessed at http:\/\/www.treasury.gov\/resource-center\/sanctions\/OFAC-Enforcement\/Documents\/03192010.pdf and text of Settlement Agreement at http:\/\/www.treasury.gov\/resource-center\/sanctions\/OFAC-Enforcement\/Documents\/innospec_ag.pdf.","Documents":""},{"Case ID":"ST-208","Case Cluster ":"Innospec Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia, Iraq (UN Oil-for-Food); Iraq","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/18","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits","Total Monetary Sanctions (US$)":"$11,200,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$11,200,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, \u0022Without admitting or denying the Commission\u0027s allegations, Innospec has consented to the entry of a court order [  ] ordering it to pay $60,071,613 in disgorgement, provided that the Commission waive all but $11,200,000 of disgorgement and permitting payment in four installments based upon Innospec\u0027s sworn Statement of Financial Condition.\u0022 (Source:  US Securities and Exchange Commission Litigation Release No. 21454 \/ March 18, 2010, in Securities \u0026 Exchange Commission v. Innospec, Inc., Civil Action No. 1:10-cv-00448 (RMC) (D.D.C.)).  The SEC had alleged that Innospec had paid bribes to Iraqi officials, from 2000-2007, in connection with their UN Oil-for-Food contracts and continued the misconduct after the UN Oil-for-Food Programme ended.  The bribes included lavish trips and entertainment. According to the SEC\u0027s Litigation Release, the agency had also alleged that \u0022Innospec also had several schemes to pay bribes to Indonesian government officials from at least 2000 through 2005 to win contracts with state owned oil and gas companies.  Approximately $2,883,507 in bribes was funneled through an Indonesian agent.  One scheme involved bribes paid annually to a senior official at BP Migas; another involved \u0022special commissions\u0022 paid to a Swiss account; and one involved a \u0022one off payment\u0022 of $300,000.\u0022 (Source: Ibid. and Securities and Exchange Commission v. Innospec Inc., Case No. 1:10-cv-00448 (D.D.C.), Complaint filed on March 18, 2010.)","Sources ":"US Securities and Exchange Commission Litigation Release No. 21454 \/ March 18, 2010, in Securities \u0026 Exchange Commission v. Innospec, Inc., Civil Action No. 1:10-cv-00448 (RMC) (D.D.C.), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21454.htm; Securities and Exchange Commission v. Innospec Inc., Case No. 1:10-cv-00448 (D.D.C.), Complaint filed on March 18, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21454.pdf.  See also, US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Innospec Inc. at 14-16, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf ","Documents":""},{"Case ID":"ST-209","Case Cluster ":"Innospec Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Cuba, Indonesia, Iraq (UN Oil-for-Food); Iraq","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/18","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$14,100,000.00","Criminal Fine\/Penalty (US$) ":"$14,100,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Conspiracy to commit wire fraud, Bribery of foreign officials; Falsificaton of books and records, Wire fraud","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Conspiracy to commit wire fraud, Bribery of foreign officials ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Plea Agreement filed in US v. Innospec Inc., the Delaware-incorporated company with executive offices located in the UK pleaded guilty on March 17, 2010 to a twelve-count information, accepting responsibility for (1) improper payments with regard to the UN Oil-for-Food Programme (during 2000-2003, in order for Innospec\u0027s Swiss subsidiary Alcor to obtain more then EU40 million in contracts with the Iraqi Ministry of Oil); (2) violation of the US Cuban embargo law in its sale of nearly $20 million in oil soluable fuel additives to state-owned Cuban power plants (La Empresa Importadora de Abastecimientos de Petroleo Abapet and Empresa Importadora de Objectivos Electroenergeticos) and facilitation of travel by a Specially Designated National; and (3) improper payments to Iraqi officials in connection wtih the 2004 and 2008 Long Term Purchase Agreements with the Ministry of Oil. (Source: US v. Innospec Inc., Case No. 1:10-cr-00061 (D.D.C.), Plea Agreement filed on March 18, 2010.)","Sources ":"US v. Innospec Inc., Case No. 1:10-cr-00061 (D.D.C.), Plea Agreement filed on March 18, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/innospec-inc\/03-18-10innospec-plea.pdf; Information filed March 17, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/innospec-inc\/03-17-10innospec-info.pdf; US Department of Justice Press Release, \u0022Innospec Inc. Pleads Guilty to FCPA Charges and Defrauding the United Nations; Admits to Violating the U.S. Embargo Against Cuba,\u0022 March 18, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/March\/10-crm-278.html; US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Innospec Inc. at 14-16, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf ","Documents":""},{"Case ID":"ST-210","Case Cluster ":"Innospec Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia, Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits","Total Monetary Sanctions (US$)":"$40,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$40,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations, Aiding and abetting Innospec\u0027s falsification of books and records, Aiding and abetting Innospec\u0027s internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Innospec, Inc. at 14-16: \u0022Turner and other senior Innospec officials also caused more than $2.8 million in bribes to be paid through an Indonesian agent to officials of the Indonesian government in order to secure contracts for Innospec.\u0022 Period of misconduct in Indonesia, 2000-2005.  The US v. Innospec, Case No. 1:10-cr-00061, Plea Agreement and Statement of Facts contains no additional details with respect to misconduct in Indonesia. According to the SEC litigation release (August 5, 2010) in Securities \u0026 Exchange Commission v. David P. Turner and Ousama M. Naaman., Civil Action No. 1:10-CV-01309 (D.D.C.) (RMC), Turner was Business Director of Innospec\u0027s Tetra Ethyl Lean group.  The SEC complaint had alleged that he engaged in bribery of Indonesian officials (officials V,X,Y and Z) in order to sell TEL to Indonesian stated-owned oil companies and the TEL was sold in until 2005 in Indonesia to state owned companies - Pertamina, BP Migas and Leimgas - through Alcor Chemie Vertriebs GMBH (\u0022Alcor\u0022), a wholly owned subsidiary of Innospec; Alcor is incorporated in Switzerland and headquartered in Zug, Switzerland. According to the Turner complaint, \u0022The bribes were made through Indonesian Agent and totaled approximately $2,883,507. Innospec\u0027s revenues in connection with the illicitbribes were approximately $48,571,937 and profits were $21,506,610.\u0022 (para 55.)  The payments were proportionate to the amount of product sold. (Source: SEC v. David P. Turner and Ousama M. Naaman, Case No. 1:10-cv-01309 (D.D.C.), Complaint of August 4, 2010). Turner was ordered to disgorge $40,000; the final judgment does not indicate how much of this amount is attributed to his misconduct in Indonesia. (Source: SEC v. Davis P. Turner, Case No. 1:10-cv-01309-RMC (D.D.C.), Final Judgment filed August 10, 2010, accessed at http:\/\/fcpa.shearman.com\/files\/d77\/d7776278ba193aae54822323ae19641e.pdf?i=a60613ed673d696fed541f265929a833.)","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Innospec, Inc. at 14-16, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c-.pdf; US v. Innospec, Case No. 1:10-cr-00061-ESH (D.D.C.), Information filed March 17, 2010 and Plea Agreement and Statement of Facts filed March 18, 2010, both accessed at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/innospec-inc.html; SEC v. David P. Turner and Ousama M. Naaman, Case No. 1:10-cv-01309 (D.D.C.), Complaint of August 4, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21615.pdf; SEC v. Davis P. Turner, Case No. 1:10-cv-01309-RMC (D.D.C.), Final Judgment filed August 10, 2010, accessed at http:\/\/fcpa.shearman.com\/files\/d77\/d7776278ba193aae54822323ae19641e.pdf?i=a60613ed673d696fed541f265929a833.","Documents":""},{"Case ID":"ST-211","Case Cluster ":"Innospec Inc.","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Indonesia; Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/18","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Civil Recovery Order (Proceeds of Crime Act)","Monetary Sanctions  (Types)":"Civil Recovery Order","Total Monetary Sanctions (US$)":"$12,700,000.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$12,700,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office Press Release, \u0022On 18 March 2010, Innospec Ltd appeared before Lord Justice Thomas at Southwark Crown Court and entered a plea of guilty to bribing employees of Pertamina (an Indonesian state owned refinery) and other government officials in Indonesia.  At that hearing the judge indicated he would impose a financial penalty of the sterling equivalent of US$12.7 million and he adjourned sentencing and remarks to today.  In sentencing today, Lord Justice Thomas stated that that sum is to be paid by way of a fine. The 14-page judgment also includes guidance.\u0022  The Judgment details the discussions between the United States and the United Kingdom with regards to the financial settlements by the two countries.  (Sources: US Serious Fraud Office Press Release, \u0022Innospec Judgment,\u0022 March 26, 2010 and R. v. Innospec Limited, In the Crown Court at Southwark, Sentencing remarks of Lord Justice Thomas (26 March 2010).)  In the Judgment, Lord Justice Thomas noted: \u0022Through agents in Indonesia, the directing minds of the company engaged in systematic and large-scale corruption of senior Government officials. Those corrupted in this way included Rachmat Sudibyo, Director-General of Oil and Gas in the Ministry of Energy and Mineral Resources in Indonesia and subsequently Chairman of Migas, an authority that regulated oil and gas in Indonesia, and Suroso Atmomartoyo, a Director of Pertamina, the Indonesian state oil company, and one of the most senior members of its management.  The bribes paid to Rachmat Sudibyo exceeded $1 million.  [ ] It is not possible to calculate precisely the total amount of the bribes, but the best estimate is approximately 5% of $160 million, namely $8 million.\u0022 (Source:  R. v. Innospec Limited, In the Crown Court at Southwark, Sentencing remarks of Lord Justice Thomas (26 March 2010).)  ","Sources ":"R. v. Innospec Limited, In the Crown Court at Southwark, Sentencing remarks of Lord Justice Thomas (26 March 2010), accessed at http:\/\/www.judiciary.gov.uk\/NR\/rdonlyres\/5343F038-A6E5-448B-BB2D-7CA31F9E2DDA\/0\/sentencingremarksthomasljinnospec.pdf;  UK Serious Fraud Office, \u0022Innospec Limited prosecuted for corruption by the SFO,\u0022 March 18, 2010, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2010\/innospec-limited-prosecuted-for-corruption-by-the-sfo.aspx;  http:\/\/www.sfo.gov.uk\/press-room\/press-release-archive\/press-releases-2010\/innospec-judgment.aspx; UK Serious Fraud Office, \u0022Innospec Judgment,\u0022 March 26, 2010, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2010\/innospec-judgment.aspx.  See also, United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf","Documents":""},{"Case ID":"ST-212","Case Cluster ":"Innospec Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/05","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$1,315,144.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$810,076","Civil Prejudgment Interest (US$) ":"$67,030","Civil Fine \/ Penalty (US$)":"$438,038","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records, Internal Controls Violations ","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, on August 5, 2010, the Commission filed a settled complaint which alleged that \u0022David P. Turner, a former Business Director at Innospec, Inc., and Ousama M. Naaman, Innospec\u0027s agent in Iraq, with violating the Foreign Corrupt Practices Act (FCPA) by paying bribes to numerous government officials to obtain and retain business.The SEC\u0027s complaint alleges that: Turner and Naaman engaged in widespread bribery of Iraqi government officials to obtain contracts under the United Nations Oil for Food Program, and in order to continue selling Tetra Ethyl Lean (TEL) to Iraq after the Oil for Food Program ended. Turner also violated the FCPA by paying bribes to Indonesian officials to sell TEL to Indonesian state owned oil companies.  From 2000 to 2008, Innospec, Inc., a manufacturer and distributor of fuel additives and specialty chemicals, routinely paid bribes to government officials in Iraq and Indonesia to sell TEL. The bribery activities in Iraq began with Innospec\u0027s participation in the United Nations (\u0022UN\u0022) Oil for Food Program in 2001, and extended all the way until at least 2008. Turner, the Business Director of Innospec\u0027s TEL group, and Naaman, Innospec\u0027s agent, both actively participated in the bribery and kickback schemes in Iraq. Innospec also paid bribes to government officials in Indonesia beginning as early as 2000, and continued until 2005, when Indonesia\u0027s need for TEL ended. Turner actively participated in the bribery scheme in Indonesia. In all, Innospec made illicit payments of over $6.3 million and promised an additional $2.8 million in illicit payments to Iraqi ministries and government officials as well as Indonesian government officials. The contracts that Innospec obtained in exchange for the bribes were worth approximately $176 million.  Naaman paid kickbacks to Iraq on Innospec\u0027s behalf so that Innospec could obtain five Oil-for-Food Program contracts for the sale of TEL to the Iraqi Ministry of Oil and its component oil refineries. Naaman aided Innospec in obtaining the Oil for Food contracts by paying kickbacks equaling 10 percent of the contract value on three of the contracts. When the Oil-for-Food Program ended shortly before Innospec was to pay promised kickbacks on the two remaining contracts, Innospec kept the promised payments as part of its profit. [  ] After the Oil for Food Program ended in late 2003, Turner and Naaman paid bribes to Iraqi officials in order to secure TEL business contracts from Iraq. Turner and senior officials at Innospec directed and approved the bribery payments. From at least 2004 through 2008, Innospec made payments totaling approximately $1,610,327 and promised an additional $884,480. In one e-mail, Naaman informed management, including Turner, that Iraqi officials were demanding a 2% kickback related to one TEL order. [  ]  Turner confirmed that the requested kickback would be paid through an additional 2% \u0022commission\u0022 to Naaman.  Turner and senior officials at Innospec also directed Naaman to pay a bribe of $155,000 to Iraqi officials to ensure the failure of a 2006 field trial test of MMT, a fuel product manufactured by a competitor of Innospec. Turner and other Innospec officials also authorized payments, through Naaman, to fund lavish trips for Iraqi officials [ ] and Turner also arranged for Naaman to pay thousands of dollars in cash to Iraqi officials for \u0022pocket money\u0022 on trips funded by Innospec.\u0022  The Litigation Release also noted that \u0022Naaman will disgorge $810,076 plus prejudgment interest of $67,030, and pay a civil penalty of $438,038, which will be deemed satisfied by a criminal order requiring Naaman to pay a criminal fine that is at least equal to the civil penalty amount. After his extradition to the United States, Naaman cooperated..\u0022  (Source:  US Securities and Exchange Commission Litigation Release No. 21615 \/ August 5, 2010, \u0022SEC Files Settled Charges Against David P. Turner and Ousama M. Naaman for Engaging in Bribery,\u0022 Securities \u0026 Exchange Commission v. David P. Turner and Ousama M. Naaman., Civil Action No. 1:10-CV-01309 (D.D.C.) (RMC).)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Innospec Inc. Case Summary at 24-27, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   US Securities and Exchange Commission Litigation Release No. 21615 \/ August 5, 2010, \u0022SEC Files Settled Charges Against David P. Turner and Ousama M. Naaman for Engaging in Bribery,\u0022 Securities \u0026 Exchange Commission v. David P. Turner and Ousama M. Naaman., Civil Action No. 1:10-CV-01309 (D.D.C.) (RMC), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21615.htm; Complaint filed August 5, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21615.pdf","Documents":""},{"Case ID":"ST-213","Case Cluster ":"Innospec Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"06\/25","Other Jurisdictions of Settlement":"[United Kingdom - ongoing criminal investigation]","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea  ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$250,000.00","Criminal Fine\/Penalty (US$) ":"$250,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8, Art. 10","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Conspiracy to Falsify Books and Records, Conspiracy to Commit Wire Fraud, Bribery of Foreign Officials ","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Conspiracy to Falsify Books and Records, Conspiracy to Commit Wire Fraud, Bribery of Foreign Officials ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022Canadian\/Lebanese dual national Ousama M. Naaman pleaded guilty today to participating in an eight-year conspiracy to defraud the United Nations Oil for Food Program (OFFP) and to bribe Iraqi government officials in connection with the sale of a chemical additive used in the refining of leaded fuel. [  ]  Naaman, 61, of Abu Dhabi, United Arab Emirates, was originally indicted on Aug. 7, 2008, in U.S. District Court for the District of Columbia.   Naaman was arrested on July 30, 2009, in Frankfurt, Germany, and extradited to the United States.   [ ]  Naaman and his companies were the Iraqi agents of Innospec Inc., a U.S. company.   On March 18, 2010, Innospec pleaded guilty to a 12-count indictment charging wire fraud in connection with its payment of kickbacks to the Iraqi government under the OFFP, as well as violations of the FCPA in connection with bribe payments it made to officials in the Iraqi Ministry of Oil.  From 2001 to 2003, acting on behalf of Innospec, Naaman offered and paid 10 percent kickbacks to the then Iraqi government in exchange for five contracts under the OFFP.   Naaman negotiated the contracts, including a 10 percent increase in the price to cover the kickback, and routed the funds to Iraqi government accounts in the Middle East.   Innospec inflated its prices in contracts approved by the OFFP to cover the cost of the kickbacks.  Naaman also admitted that from 2004 to 2008, he paid and promised to pay more than $3 million in bribes, in the form of cash, as well as travel, gifts and entertainment, to officials of the Iraqi Ministry of Oil and the Trade Bank of Iraq to secure sales of tetraethyl lead in Iraq, as well as to secure more favorable exchange rates on the contracts.   Naaman provided Innospec with false invoices to support the payments, and those invoices were incorporated into the books and records of Innospec.\u0022 (Source:  US Department of Justice Press Release, \u0022Innospec Agent Pleads Guilty to Bribing Iraqi Officials and Paying Kickbacks Under the Oil for Food Program,\u0022 June 25, 2010.)  According to the Court Docket Report in his case, on December 22, 2011, Naaman was sentenced and ordered to pay $250,000 fine. (Source: US v. Naaman, Case No. 1:08-cr-00246-ESH-1 (D.D.C.), Court Docket Report retrieved via Pacer on January 12, 2012.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Innospec Inc. Case Summary at 24-27, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   US v. Namaan, Case No. 1:08-cr-246-ESH (D.D.C.), Indictment filed August 7, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/naamano\/08-07-08naaman-indict.pdf;  Superseding Information filed June 24, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/naamano\/06-24-10naaman-supsersed-info.pdf; Plea Agreement filed June 25, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/naamano\/06-25-10naaman-plea-agmt.pdf; Statement of Offense filed June 25, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/naamano\/06-25-10naaman-state-offense.pdf; US v. Naaman, Case No. 1:08-cr-00246-ESH-1 (D.D.C.), Court Docket Report retrieved via Pacer on January 12, 2012.  US Department of Justice Press Release, \u0022Innospec Agent Pleads Guilty to Bribing Iraqi Officials and Paying Kickbacks Under the Oil for Food Program,\u0022 June 25, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/June\/10-crm-747.html.","Documents":""},{"Case ID":"ST-214","Case Cluster ":"Innospec Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia, Iraq (UN Oil-for-Food); Iraq","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"01\/24","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$229,037.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$116,092","Civil Prejudgment Interest (US$) ":"$12,945","Civil Fine \/ Penalty (US$)":"$100,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations, Aiding and Abetting Innospec\u0027s falsification of books and records, Aiding and Abetting Innospec\u0027s internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Litigation Release and Complaint in SEC v. Paul W. Jennings, Mr. Jennings joined Innospec in 2002 as the Chief Financial Officer. the SEC Complaint alleged that Mr. Jennings became aware of Innospec\u0027s bribery scheme in Iraq and as he took on additional executive roles, approved and\/or faciliated bribes and he also was aware of and approved bribery payments to Indonesian officials, including one scheme involving Pertamina, the Indonesian state-owned oil and gas company. (Sources:  US Securities and Exchange Commission Litigation Release No. 21822 \/ January 24, 2011, Securities \u0026 Exchange Commission v. Paul W. Jennings, 1:11-CV-00144 (D.D.C.) (RMC), \u0022SEC Files Settled Bribery Charges against Paul W. Jennings,\u0022 and Securities \u0026 Exchange Commission v. Paul W. Jennings, 1:11-CV-00144-RMC (D.D.C.), Complaint filed on January 24, 2011.)","Sources ":"US Securities and Exchange Commission Litigation Release No. 21822 \/ January 24, 2011, Securities \u0026 Exchange Commission v. Paul W. Jennings, 1:11-CV-00144 (D.D.C.) (RMC), \u0022SEC Files Settled Bribery Charges against Paul W. Jennings,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr21822.htm; Securities \u0026 Exchange Commission v. Paul W. Jennings, 1:11-CV-00144-RMC (D.D.C.), Complaint filed on January 24, 2011, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp21822.pdf","Documents":""},{"Case ID":"ST-215","Case Cluster ":"International Business Machines (Argentina)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2001","Month\/Day of Settlement (or Notes)":"01\/09","Other Jurisdictions of Settlement":"Argentina","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$300,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$300,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission\u0027s Litigation Release, \u0022Without admitting or denying the allegations in the complaint, IBM consented to the entry of a judgment ordering IBM to pay a $300,000 penalty. The Order finds that IBM violated Section 13(b)(2)(A) of the Exchange Act in connection with a $250 million contract to integrate and modernize the computer system of a commercial bank owned by the Argentine government. According to the Order, certain former senior management of IBM-Argentina, S.A. (\u0022IBM-Argentina\u0022), a wholly-owned subsidiary of IBM, caused IBM-Argentina to enter into a subcontract with Capacitacion Y Computacion Rural, S.A. (\u0022CCR\u0022), and money paid to CCR by IBM-Argentina in connection with the subcontract was apparently subsequently paid by CCR to certain bank officials. Specifically, the Order finds that, during 1994 and 1995, IBM-Argentina paid CCR approximately $22 million under the subcontract, of which at least $4.5 million was transferred to several bank directors by CCR.\u0022 (Source:  Securities and Exchange Commission, Litigation Release No. 16839 \/ December 21, 2000, SEC v. International Business Machines Corporation, Case No. 1:00-cv-03040-JR (D.D.C.), \u0022SEC Settles Foreign Corrupt Practices Act Case against IBM.\u0022)","Sources ":"Securities and Exchange Commission v. International Business Machines Corporation, Case No. 00-cv-3040-JR (D.D.C. January 9 2001), Final Judgment.  Background details in SEC Administrative Proceeding File No. 3-10397 and Litigation Release No. 16839 \/ December 21, 20000, \u0022SEC Settles Foreign Corrupt Practices Act Case against IBM,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr16839.htm; Complaint filed December 21, 2000, accessed at http:\/\/fcpa.shearman.com\/files\/d0c\/d0c38e4dd02cb168e08b10bfeb943905.pdf?i=213d33ba5837e54f76ad2217c8d46f7f and Final Judgment filed January 9, 2001, at http:\/\/fcpa.shearman.com\/files\/f6c\/f6c4f8147e24d085fe53df61f218f475.pdf?i=a6ed58903e4eafab05288d16d4de56b7.","Documents":""},{"Case ID":"ST-216","Case Cluster ":"International Business Machines (South Korea and China)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, South Korea","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"03\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$10,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$5,300,000","Civil Prejudgment Interest (US$) ":"$2,700,000","Civil Fine \/ Penalty (US$)":"$2,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violation","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"On March 18, 2011, the US Securities and Exchange Commission filed a settled civil complaint after International Business Marchines Corporation,  charging the company with violation of the books and records and internal controls provisions of the Foreign Corrupt Practices Act.  The SEC alleged (1) in South Korea, from 1998-2003, employees of IBM Korea, Inc., an IBM subsidiary and LG IBM PC Co., Ltd., a joint venture in which IBM held a majority interest, paid cash bribes (approximately $135,558 by IBM-Korea and $71,599 by LG-IBM Korea) and provided improper gifts and payments of travel and entertainment expenses to various government officials in South korea in order to secure the sale of IBM products.  The payments were alleged to have been made to \u0022South Korean Government Entities\u0022(SKGE) as SKGE 1, SKGE 2, SKGE 3, SKGE 3, SKGE 4, SKGE 5 and SKGE 6; (2) in China, between 2004 to early 2009, IBM China, a Hong Kong company owned by IBM, employees created slush funds at local travel agencies in China that were used to pay for overseas and other travel expenses incurred by Chinese government officials, and created slush funds at its business partners to provide a cash payment and improper gifts such as cameras and laptops to Chinese government officials. The complaint does not identify the involved Chinese officials.  (Source:  Securities and Exchange Commission v. International Business Machines Corporation, Case No. 1:11-cv-00563 (D.D.C.), Complaint filed March 18, 2011.)","Sources ":"Securities and Exchange Commission v. International Business Machines Corporation, Case No. 1:11-cv-00563 (D.D.C.), Complaint filed March 18, 2011, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp21889.pdf; US Securities and Exchange Commission, Litigation Release No. 21889 \/ March 18, 2011, \u0022IBM TO PAY $10 MILLION IN SETTLED FCPA ENFORCEMENT ACTION,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr21889.htm","Documents":""},{"Case ID":"ST-217","Case Cluster ":"International Materials Solutions Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Brazil","Year of Settlement":"1999","Month\/Day of Settlement (or Notes)":"02\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,000.00","Criminal Fine\/Penalty (US$) ":"$1,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 (June 2011): \u0022On February 8, 1999, the Department of Justice filed a two-count information in the Southern District of Ohio, charging International Materials Solutions Corporation (IMSC) and Thomas K. Qualey, IMSC\u0027s President, with one count of conspiring to violate the anti-bribery provisions of the FCPA and one count of bribing a foreign official. According to court documents, in 1995 and 1996, Qualey prepared and submitted bids on behalf of International Materials Solutions Corporation (IMSC) to sell forklifts to the Brazilian Air Force (BAF) and to service them. In order to secure these contracts, which were worth approximately $400,000, IMSC agreed to pay $67,000 in bribes to a Lieutenant Colonel in the BAF, who was stationed as a Foreign Liaison Officer in the United States. \/ Criminal Disposition: On February 10, 1999, Qualey pleaded guilty and was sentenced to four months home confinement and a $5,000 fine. IMSC also pleaded guilty on this date and was later sentenced to pay a $1,000 criminal fine.\u0022  (Source: International Materials Solutions Corporation. Case at 133.)  According to the Judgment Order in US v. International Materials Solutions, the fine was below guidelines because of the inability of the company to pay. (Source: US v. International Materials Solutions, Case No. 3:99-cr-008-WHR (S.D. Ohio), Judgment Order filed October 4, 1999.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, International Materials Solutions Corporation. Case at 133, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. International Materials Solutions Corporation, Case No. 3:99-cr-008-WHR (S.D. Ohio), Information filed on February 8, 1999, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/02-08-99imsc-info.pdf; Plea Agreement filed February 10, 1999, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/02-11-99imsc-plea-agree.pdf; Statement of Facts, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/02-10-99imsc-state-facts.pdf; Judgment Order filed October 4, 1999, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/09-1-99imsc-judgment.pdf.","Documents":""},{"Case ID":"ST-218","Case Cluster ":"International Materials Solutions Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Brazil","Year of Settlement":"1999","Month\/Day of Settlement (or Notes)":"02\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$5,000.00","Criminal Fine\/Penalty (US$) ":"$5,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 (June 2011): \u0022On February 8, 1999, the Department of Justice filed a two-count information in the Southern District of Ohio, charging International Materials Solutions Corporation (IMSC) and Thomas K. Qualey, IMSC\u0027s President, with one count of conspiring to violate the anti-bribery provisions of the FCPA and one count of bribing a foreign official. According to court documents, in 1995 and 1996, Qualey prepared and submitted bids on behalf of International Materials Solutions Corporation (IMSC) to sell forklifts to the Brazilian Air Force (BAF) and to service them. In order to secure these contracts, which were worth approximately $400,000, IMSC agreed to pay $67,000 in bribes to a Lieutenant Colonel in the BAF, who was stationed as a Foreign Liaison Officer in the United States. \/ Criminal Disposition: On February 10, 1999, Qualey pleaded guilty and was sentenced to four months home confinement and a $5,000 fine. IMSC also pleaded guilty on this date and was later sentenced to pay a $1,000 criminal fine.\u0022  (Source: International Materials Solutions Corporation. Case at 133.)  According to the Judgment Order in US v. International Materials Solutions, the fine was below guidelines because of the inability of the company to pay. (Source: US v. International Materials Solutions, Case No. 3:99-cr-008-WHR (S.D. Ohio), Judgment Order filed October 4, 1999.)  According to the Judgment in Mr. Qualey\u0027s case, \u0022The sentence departs from the guideline range: [due to] Criminal history over represents [sic] seriousness of past criminal conduct and likelihood of recidivism. Substantial assistance to foreign government.\u0022 (Source: US v. Thomas K. Qualey, Case No. 3:99-cr-008-WHR (S.D. Ohio), Judgment Order filed October 4, 1999.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, International Materials Solutions Corporation. Case at 133, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. International Materials Solutions Corporation, Case No. 3:99-cr-008-WHR (S.D. Ohio), Information filed on February 8, 1999, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/02-08-99imsc-info.pdf; Plea Agreement filed February 10, 1999, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/02-11-99imsc-plea-agree.pdf; Statement of Facts, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/02-10-99imsc-state-facts.pdf; Judgment Order filed October 4, 1999, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/09-1-99imsc-judgment.pdf; Thomas K. Quagley Plea Agreement filed on February 10, 1999, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/02-10-99qualey-plea-agree.pdf and Judgment (October 4, 1999), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/intl-materials\/09-01-99qualey-judgment.pdf","Documents":""},{"Case ID":"ST-219","Case Cluster ":"InVision Technologies, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China, Philippines, Thailand","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"12\/03","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$800,000.00","Criminal Fine\/Penalty (US$) ":"$800,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.15, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 InVision Technologies, Inc. at 100-101, location and time period of misconduct: Thailand (2002-2004), China (2002-2004), Philippines (2001-2002); company became aware of a high probability that its agents or distributors in Thailand, China and the Philippines had paid or offered to pay money to foreign officials or political parties in connection with transactions or proposed transactions for the sale by InVision of its airport security screening machines.  In 2005, SEC settled with GE InVision, InVision\u0027s corporate successor. David Pillor was InVision\u0027s senior vice president for sales and marketing. Resulting criminal enforcement actions: In Re InVision Technologies, Inc. (December 6, 2004); Civil enforcement actions: SEC v. David M. Pillor (N.D. Cal., August 15, 2006), SEC v. GE InVision, Inc. (N.D. Cal., February 14, 2005), In the Matter of GE InVision, Inc. (February 14, 2005)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 InVision Technologies, Inc. at 100-101, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; In Re Invision Technologies, Non-Prosecution Agreement of  December 3, 2004, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/invision-tech\/12-03-04invisiontech-agree.pdf; US Department of Justice Press Release, \u0022InVision Technologies, Inc. Enters into Agreement with the United States,\u0022 December 6, 2004, accessed at http:\/\/www.justice.gov\/opa\/pr\/2004\/December\/04_crm_780.htm","Documents":""},{"Case ID":"ST-220","Case Cluster ":"InVision Technologies, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, Philippines, Thailand","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"08\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$65,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$65,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.27","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Falsification of books and records, Aiding and abetting InVision\u0027s internal controls violations","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission\u0027s Litigation Release, the agency alleged that \u0022during the period from late 2001 through June 2004, InVision completed sales to airports in China, the Philippines, and Thailand. In the course of these transactions, Pillor received e-mail messages from his Asian regional sales manager that suggested that InVision\u0027s overseas sales agents and distributors intended to make improper payments or other gifts to foreign government officials, in violation of the FCPA. InVision subsequently paid invoices to its agents and distributors in China and the Philippines and improperly recorded the payments as legitimate business expenses.  InVision\u0027s FCPA violations occurred, in part, because the company lacked adequate internal controls to detect and prevent such conduct. For example, InVision\u0027s sales department provided only informal training about the FCPA to its employees and foreign agents. Similarly, the company\u0027s sales department failed to monitor its employees and foreign agents to ensure that they did not violate the requirements of the FCPA. As InVision\u0027s head of sales and a member of the company\u0027s board of directors, Pillor aided and abetted InVision\u0027s failure to establish adequate internal controls.\u0022  (Source: US Securities and Exchange Commission Litigation Release No. 19803 \/ August 15, 2006, SEC v. David M. Pillor, Case No. C-06-4906-WHA (N.D. Cal. filed Aug. 15, 2006), \u0022SEC Settles Charges Against Former InVision Technologies Senior Vice President for Sales and Marketing.\u0022)   According to the same Litigation Release, \u0022Simultaneous with the filing of the Commission\u0027s complaint, Pillor agreed, without admitting or denying the allegations, to pay a $65,000 civil penalty and to entry of a permanent injunction against future violations, in settlement of the matter.\u0022 (Source: Ibid.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 InVision Technologies, Inc. at 100-101, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Securities and Exchange Commission Litigation Release No. 19803 \/ August 15, 2006, SEC v. David M. Pillor, Case No. C-06-4906-WHA (N.D. Cal. filed Aug. 15, 2006), \u0022SEC Settles Charges Against Former InVision Technologies Senior Vice President for Sales and Marketing,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2006\/lr19803.htm.","Documents":""},{"Case ID":"ST-221","Case Cluster ":"InVision Technologies, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, Philippines, Thailand","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"02\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty ","Total Monetary Sanctions (US$)":"$1,117,703.57","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$589,000","Civil Prejudgment Interest (US$) ":"$28,703.57","Civil Fine \/ Penalty (US$)":"$500,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 InVision Technologies, Inc. at 100-101, location and time period of misconduct: Thailand (2002-2004), China (2002-2004), Philippines (2001-2002); company became aware of a high probability that its agents or distributors in Thailand, China and the Philippines had paid or offered to pay money to foreign officials or political parties in connection with transactions or proposed transactions for the sale by InVision of its airport security screening machines.  In 2005, SEC settled with GE InVision, InVision\u0027s corporate successor. David Pillor was InVision\u0027s senior vice president for sales and marketing. Resulting criminal enforcement actions: In Re InVision Technologies, Inc. (December 6, 2004); Civil enforcement actions: SEC v. David M. Pillor (N.D. Cal., August 15, 2006), SEC v. GE InVision, Inc. (N.D. Cal., February 14, 2005), In the Matter of GE InVision, Inc. (February 14, 2005) ","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 InVision Technologies, Inc. at 100-101, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Securities and Exchange Commission, Litigation Release No. 19078 \/ February 14, 2005, Securities and Exchange Commission v. GE InVision, Inc. (formerly known as InVision Technologies, Inc.), United States District Court for the Northern District of California, Civil Action No. C-05-0660 MEJ, \u0022SEC Settles Charges against InVision Technologies for $1.1 Million for Violations of the Foreign Corrupt Practices Act,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr19078.htm, and Complaint filed February 14, 2005, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/comp19078.pdf","Documents":""},{"Case ID":"ST-222","Case Cluster ":"Italy \/ COGIM case (Oil for Food case 15)","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Piacenza court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"05\/12","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$1,210,494.00","Criminal Fine\/Penalty (US$) ":"$129,094","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$1,081,400 ","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Criminal Code 322 bis","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Report on Italy, the case involved \u0022Alleged bribery of public officials to obtain contracts to supply medical equipment to the Iraqi Ministry of Health.\u0022 (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 70.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 70, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/47\/49377261.pdf  http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-223","Case Cluster ":"Italy \/ Libyan Arms Traffickers case","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Perugia court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"Libya","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"08\/07","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Confiscation","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of Foreign Officials, Sale of Military Weapons without Proper Registration with Italian Ministry of Defence, Engaging in Negotiations without Filing Proper Notifications (Criminal Code 110, 112, 81: Law 285\/1990; Law 895\/1967; Criminal Code 416, Criminal Code 110, 322-bis)","Offenses - Settled":"Foreign Bribery","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to the December 2011 OECD Phase 3 Report on Italy, two unnamed individual defendants were sanctioned through the Patteggiamento process for their misconduct relatedt o the Libyan Arms Traffickers Case.  The case involved approximately EUR 65 million in bribes. (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 65.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 65, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/47\/49377261.pdf    http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-224","Case Cluster ":"Italy \/ Libyan Arms Traffickers case","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Perugia court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"Libya","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"08\/07","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Confiscation","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of Foreign Officials, Sale of Military Weapons without Proper Registration with Italian Ministry of Defence, Engaging in Negotiations without Filing Proper Notifications (Criminal Code 110, 112, 81: Law 285\/1990; Law 895\/1967; Criminal Code 416, Criminal Code 110, 322-bis)","Offenses - Settled":"Foreign Bribery","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to the December 2011 OECD Phase 3 Report on Italy, two unnamed individual defendants were sanctioned through the Patteggiamento process for their misconduct relatedt o the Libyan Arms Traffickers Case.  The case involved approximately EUR 65 million in bribes. (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 65.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 65, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/47\/49377261.pdf    http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-225","Case Cluster ":"Italy \/ Oil Company Case","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Milan court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"Libya","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"03\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Confiscation","Total Monetary Sanctions (US$)":"$158,002.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$158,002","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Criminal Code 322 bis","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Report on Italy, the case involved \u0022Alleged bribery of Libyan public officials through an intermediary in order to obtain business in Libya\u0022 and bribe amount was EUR 14 million. (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 71.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 71, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/47\/49377261.pdf    http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-226","Case Cluster ":"Italy \/ Oil Company Case","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Milan court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"Libya","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"04\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Confiscation","Total Monetary Sanctions (US$)":"$1,588,430.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$1,588,430","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Criminal Code 322 bis and other [unspecified] offenses","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Report on Italy, the case involved \u0022Alleged bribery of Libyan public officials through an intermediary in order to obtain business in Libya\u0022 and bribe amount was EUR 14 million. (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 71.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 71, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/47\/49377261.pdf   http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-227","Case Cluster ":"Italy \/ Oil for Food Case 1 (compressor company)","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Milan Court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"03\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Unknown if ordered","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unspecified","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Criminal Code 322 bis","Offenses - Settled":"Criminal Code 322 bis","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Phase 3 Report on Italy, an unnamed individual defendant related to the  United Nations \u0022Oil for Food Case 1 [compressor company]\u0022 was sanctioned for foreign bribery and sentenced to one year imprisonment. (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 63.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/59\/47\/49377261.pdf         http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-228","Case Cluster ":"Italy \/ Pirelli Telecom Case","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Milan Court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"France","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$535,484.00","Criminal Fine\/Penalty (US$) ":"$535,484","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials (Criminal Code 322-bis)","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Report on Italy, in the Pirelli\/Telecom case, two legal persons - Pirelli and telecom Italia - Italy \u0022alleged bribery of French public officials to obtain business authorization, carried out in 33 total operations.\u0022  The total bribe amount given was \u0022approximately EUR 200 000.\u0022  (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 67.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 67, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/47\/49377261.pdf      http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-229","Case Cluster ":"Italy \/ Pirelli Telecom Case","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Milan Court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"France","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$535,484.00","Criminal Fine\/Penalty (US$) ":"$535,484","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials (Criminal Code 322-bis)","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Report on Italy, in the Pirelli\/Telecom case, two legal persons - Pirelli and telecom Italia - Italy \u0022alleged bribery of French public officials to obtain business authorization, carried out in 33 total operations.\u0022  The total bribe amount given was \u0022approximately EUR 200 000.\u0022  (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 67.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 67, accessed at http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-230","Case Cluster ":"Italy \/ Pirelli Telecom Case","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Perugia court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"France","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal, Civil","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Confiscation, Compensation for Civil Damages","Total Monetary Sanctions (US$)":"$200,806.50","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$133,871","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"$66,936","Other Civil Monetary Sanctions (Explanation)":"Compensation for civil damages","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Criminal Code 322 bis","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Report on Italy, in the Pirelli\/Telecom case, Unnamed Individuals 3 and 4 were sanctioned for foreign bribery.  The Date Crime Committed is noted as 2001-2005.  (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 68.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), accessed at http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-231","Case Cluster ":"Italy \/ Pirelli Telecom Case","Jurisdiction of Settlement":"Italy","Jurisdiction of Settlement \/ Enforcement Agency":"[Perugia court] - unspecified enforcement agency","Jurisdiction of Foreign Public Official(s) ":"France","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal, Civil","Legal Form of Settlement":"Patteggiamento","Monetary Sanctions  (Types)":"Criminal Confiscation, Compensation for Civil Damages","Total Monetary Sanctions (US$)":"$40,161.30","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$26,774","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"$13,387","Other Civil Monetary Sanctions (Explanation)":"Compensation for civil damages","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Criminal Code 322 bis","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the December 2011 OECD Report on Italy, in the Pirelli\/Telecom case, Unnamed Individuals 3 and 4 were sanctioned for foreign bribery.  The Date Crime Committed is noted as 2001-2005.  (Source: Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), at 68.)","Sources ":"Organisation for Economic Co-Operation and Development, Phase  3 Report on Implementing the OECD Anti-Bribery Convention in Italy (Adopted by the OECD Working Group on Bribery on December 16, 2011), accessed at http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Italyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-232","Case Cluster ":"ITT Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"02\/11","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$1,678,650.11","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,041,112","Civil Prejudgment Interest (US$) ":"$387,538.11","Civil Fine \/ Penalty (US$)":"$250,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 ITT Corporation, at 48:  Misconduct in China, 2001-2005; misconduct involved alleged payments to Chinese government officials by ITT\u0027s wholly-owned Chinese subsidiary, Nanjing Goulds Pumps Ltd. (NGP).   Securities and Exchange Commission complaint had alleged that approximately $200,000 in illicit payments to 32 different Chinese state-owned entities which generated over $4 million in sales to NGP, from which ITT realized improper profits of more than $1 million.  The complaint mentioned two involved projects: the Xiaolangdi Hydroelectric Power Plant on the Yellow River and the Three Gorges Dam infrastructure project. Payments disguised as increased commissions in NGP\u0027s books and records.  (See also, US Securities and Exchange Commission Litigation Release No. 20896 \/ February 11, 2009, SEC v. ITT Corporation, Civil Action No. 1:09-cv-00272 (RJL) (D.D.C. filed February 11, 2009.)","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 ITT Corporation, at 48;  US Securities and Exchange Commission Litigation Release No. 20896 \/ February 11, 2009, SEC v. ITT Corporation, Civil Action No. 1:09-cv-00272 (RJL) (D.D.C. filed Feb. 11, 2009), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr20896.htm; Texts of the Complaint, Consent agreement, and final judgment available at http:\/\/fcpa.shearman.com.","Documents":""},{"Case ID":"ST-233","Case Cluster ":"ITXC Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Rwanda, Senegal,Mali","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"09\/02","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$7,000.00","Criminal Fine\/Penalty (US$) ":"$7,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy, Bribery of foreign officials, Commercial bribery","Offenses - Settled":"Conspiracy, Bribery of foreign officials, Commercial bribery","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022Three former executives of ITXC Corporation, a global telecommunications company based in Princeton, NJ, have pleaded guilty to conspiring to violate the FCPA and the Travel Act in connection with a scheme to bribe government telecommunications officials in four African countries. ITXC was a publicly traded company that provided telecommunication services, primarily Voice Over Internet Protocol (VOIP) services, to carriers across the globe. In pleading, the defendants admitted that between September 1999 and October 2004, they conspired with each other and other former ITXC employees and officers to make corrupt payments totaling approximately $450,000 to employees of foreign state-owned and foreign-owned telecommunications carriers in Nigeria, Rwanda, Senegal, and Mali to obtain and retain contracts for ITXC. For example, in Nigeria, ITXC entered into a service agreement with and agreed to pay a consulting company headed by an official of NITEL, the state-owned Nigerian telecommunications authority, in exchange for assistance in obtaining agreements with other service providers in the country. Between November 2002 and May 2004, ITXC wire transferred approximately $166,541.31 to the Nigerian bank account of the foreign official\u0027s company.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-101.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-101, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Department of Justice Press Release, \u0022Former ITXC Corporation Executives Sentenced for Roles in Foreign Bribery Scheme,\u0022 September 2, 2008, accessed at  http:\/\/www.justice.gov\/opa\/pr\/2007\/July\/07_crm_556.html","Documents":""},{"Case ID":"ST-234","Case Cluster ":"ITXC Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Rwanda, Senegal, Mali","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/21","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$10,000.00","Criminal Fine\/Penalty (US$) ":"$10,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy, Bribery of foreign officials, Commercial bribery","Offenses - Settled":"Conspiracy, Bribery of foreign officials, Commercial bribery","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022Three former executives of ITXC Corporation, a global telecommunications company based in Princeton, NJ, have pleaded guilty to conspiring to violate the FCPA and the Travel Act in connection with a scheme to bribe government telecommunications officials in four African countries. ITXC was a publicly traded company that provided telecommunication services, primarily Voice Over Internet Protocol (VOIP) services, to carriers across the globe. In pleading, the defendants admitted that between September 1999 and October 2004, they conspired with each other and other former ITXC employees and officers to make corrupt payments totaling approximately $450,000 to employees of foreign state-owned and foreign-owned telecommunications carriers in Nigeria, Rwanda, Senegal, and Mali to obtain and retain contracts for ITXC. For example, in Nigeria, ITXC entered into a service agreement with and agreed to pay a consulting company headed by an official of NITEL, the state-owned Nigerian telecommunications authority, in exchange for assistance in obtaining agreements with other service providers in the country. Between November 2002 and May 2004, ITXC wire transferred approximately $166,541.31 to the Nigerian bank account of the foreign official\u0027s company.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-101.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-101, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Department of Justice Press Release, \u0022Former ITXC Corporation Executives Sentenced for Roles in Foreign Bribery Scheme,\u0022 September 2, 2008, accessed at  http:\/\/www.justice.gov\/opa\/pr\/2007\/July\/07_crm_556.html","Documents":""},{"Case ID":"ST-235","Case Cluster ":"ITXC Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Rwanda, Senegal, Mali","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"05\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, False Accounting Violations, Aiding and Abetting Falsification of Books and Records, Aiding and Abetting Internal Controls Violations","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022Three former executives of ITXC Corporation, a global telecommunications company based in Princeton, NJ, have pleaded guilty to conspiring to violate the FCPA and the Travel Act in connection with a scheme to bribe government telecommunications officials in four African countries. ITXC was a publicly traded company that provided telecommunication services, primarily Voice Over Internet Protocol (VOIP) services, to carriers across the globe. In pleading, the defendants admitted that between September 1999 and October 2004, they conspired with each other and other former ITXC employees and officers to make corrupt payments totaling approximately $450,000 to employees of foreign state-owned and foreign-owned telecommunications carriers in Nigeria, Rwanda, Senegal, and Mali to obtain and retain contracts for ITXC. For example, in Nigeria, ITXC entered into a service agreement with and agreed to pay a consulting company headed by an official of NITEL, the state-owned Nigerian telecommunications authority, in exchange for assistance in obtaining agreements with other service providers in the country. Between November 2002 and May 2004, ITXC wire transferred approximately $166,541.31 to the Nigerian bank account of the foreign official\u0027s company.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-101.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-102, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20556 \/ May 6, 2008, Securities and Exchange Commission v. Steven J. Ott and Roger Michael Young, Civil Action No. 06-4195 (GEB) (D.N.J.), Securities and Exchange Commission v. Yaw Osei Amoako Civil Action No. 05-4284 (GEB) (D.N.J.), \u0022Former Executives Of ITXC Corp. Settle Foreign Bribery Charges,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20556.htm","Documents":""},{"Case ID":"ST-236","Case Cluster ":"ITXC Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Rwanda, Senegal, Mali","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"09\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$7,500.00","Criminal Fine\/Penalty (US$) ":"$7,500","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Conspiracy, Bribery of foreign officials, Commercial bribery","Offenses - Settled":"Conspiracy, Bribery of foreign officials, Commercial bribery","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022Three former executives of ITXC Corporation, a global telecommunications company based in Princeton, NJ, have pleaded guilty to conspiring to violate the FCPA and the Travel Act in connection with a scheme to bribe government telecommunications officials in four African countries. ITXC was a publicly traded company that provided telecommunication services, primarily Voice Over Internet Protocol (VOIP) services, to carriers across the globe. In pleading, the defendants admitted that between September 1999 and October 2004, they conspired with each other and other former ITXC employees and officers to make corrupt payments totaling approximately $450,000 to employees of foreign state-owned and foreign-owned telecommunications carriers in Nigeria, Rwanda, Senegal, and Mali to obtain and retain contracts for ITXC. For example, in Nigeria, ITXC entered into a service agreement with and agreed to pay a consulting company headed by an official of NITEL, the state-owned Nigerian telecommunications authority, in exchange for assistance in obtaining agreements with other service providers in the country. Between November 2002 and May 2004, ITXC wire transferred approximately $166,541.31 to the Nigerian bank account of the foreign official?s company.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-101.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-101, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Department of Justice Press Release, \u0022Former ITXC Corporation Executives Sentenced for Roles in Foreign Bribery Scheme,\u0022 September 2, 2008, accessed at  http:\/\/www.justice.gov\/opa\/pr\/2007\/July\/07_crm_556.html","Documents":""},{"Case ID":"ST-237","Case Cluster ":"ITXC Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Rwanda, Senegal, Mali","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"05\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$188,453.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$150,411","Civil Prejudgment Interest (US$) ":"$38,042","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"","Offenses - Alleged":"Bribery of Foreign Officials, False Accounting Violations, Aiding and Abetting Falsification of Books and Records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"YES","Summary":"According to the June 2011 United States Report to the OECD, \u0022Three former executives of ITXC Corporation, a global telecommunications company based in Princeton, NJ, have pleaded guilty to conspiring to violate the FCPA and the Travel Act in connection with a scheme to bribe government telecommunications officials in four African countries. ITXC was a publicly traded company that provided telecommunication services, primarily Voice Over Internet Protocol (VOIP) services, to carriers across the globe. In pleading, the defendants admitted that between September 1999 and October 2004, they conspired with each other and other former ITXC employees and officers to make corrupt payments totaling approximately $450,000 to employees of foreign state-owned and foreign-owned telecommunications carriers in Nigeria, Rwanda, Senegal, and Mali to obtain and retain contracts for ITXC. For example, in Nigeria, ITXC entered into a service agreement with and agreed to pay a consulting company headed by an official of NITEL, the state-owned Nigerian telecommunications authority, in exchange for assistance in obtaining agreements with other service providers in the country. Between November 2002 and May 2004, ITXC wire transferred approximately $166,541.31 to the Nigerian bank account of the foreign official?s company.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-101.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ITXC Corporation Case Summary at 100-101, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. http:\/\/www.justice.gov\/opa\/pr\/2007\/July\/07_crm_556.html","Documents":""},{"Case ID":"ST-238","Case Cluster ":"Japan Settlement","Jurisdiction of Settlement":"Japan","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"Month and Day unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,600.00","Criminal Fine\/Penalty (US$) ":"$2,600","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the OECD December 2011 Phase 3 Report of Japan, the case \u0022involved the bribery of two foreign government officials by Defendant \u0027A,\u0027 a senior executive of a foreign subsidiary of a Japanese company, and Defendant \u0027B,\u0027 an employee of the same foreign subsidiary, in order to obtain favourable treatment in a foreign public procurement contracting process.  The bribes, which were in the form of material gifts, were approximately JPY 800 000 (USD 10 400). [footnote: The conversion of Japanese Yen (JPY) into US dollars (USD) throughout this report is based on the exchange rate on 14 September 2011.]  The company did not win the contract, the value of which is not specified.  Defendant \u0027A,\u0027 a Japanese national, was convicted and fined JPY 500 000 (USD 6 500).  Defendant \u0027B,\u0027 also a Japanese national, was convicted and fined JPY 200 000 (USD 2 600).  The defendants admitted guilt and were convicted on summary trial.  The facts that gave rise to to the case took place in 2004, and the convictions were obtained in 2007.\u0022  (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Japan,\u0022 December 2011, at 9.)","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Japan,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/51\/49377330.pdf     http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Japanphase3reportEN.pdf","Documents":""},{"Case ID":"ST-239","Case Cluster ":"Japan Settlement","Jurisdiction of Settlement":"Japan","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"Month and Day unspecified","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$6,500.00","Criminal Fine\/Penalty (US$) ":"$6,500","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the OECD December 2011 Phase 3 Report of Japan, the case \u0022involved the bribery of two foreign government officials by Defendant \u0027A,\u0027 a senior executive of a foreign subsidiary of a Japanese company, and Defendant \u0027B,\u0027 an employee of the same foreign subsidiary, in order to obtain favourable treatment in a foreign public procurement contracting process.  The bribes, which were in the form of material gifts, were approximately JPY 800 000 (USD 10 400). [footnote: The conversion of Japanese Yen (JPY) into US dollars (USD) throughout this report is based on the exchange rate on 14 September 2011.]  The company did not win the contract, the value of which is not specified.  Defendant \u0027A,\u0027 a Japanese national, was convicted and fined JPY 500 000 (USD 6 500).  Defendant \u0027B,\u0027 also a Japanese national, was convicted and fined JPY 200 000 (USD 2 600).  The defendants admitted guilt and were convicted on summary trial.  The facts that gave rise to to the case took place in 2004, and the convictions were obtained in 2007.\u0022  (Source: Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Japan,\u0022 December 2011, at 9.)","Sources ":"Organisation for Economic Co-Operation and Development, \u0022Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Japan,\u0022 December 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/51\/49377330.pdf","Documents":""},{"Case ID":"ST-240","Case Cluster ":"Johnson \u0026 Johnson","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Greece, Poland, Romania, Iraq (UN Oil-for-Food)","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"04\/08","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$21,400,000.00","Criminal Fine\/Penalty (US$) ":"$21,400,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Statement of Facts agreed to be Johnson \u0026 Johson as part of its Deferred Prosecution Agreement, J\u0026J engaged in misconduct with respect to the UN Oil-for-Food program and in Greece, Poland and Romania.  In Greece, DePuy Inc. (Delaware-registered) and DePuy International (wholly owned subsidiary) from 2001 to 2003, Greek Agent A was paid approximately EUR 7,987,540, and from 2003 through 2005, Greek Agent B was paid approximately EUR 7,303,754; significant portion of these payments were used to pay cash incentives to Greek health care workers at publicly-owned hospitals to induce them to buy J\u0026J products; from 2002-2006, in addition to the payments to the agents, approximately EUR500,000 was withdrawn by J\u0026J subsidiary Depuy Hellas employees to cover payments owed to the health care workers by the agents but not yet paid.  In Poland, Johnson \u0026 Johnson Poland Sp. z.o.o. (wholly owned subsidiary) entered into approximately 4,400 civil contracts between 2000 and 2006, for which the company paid Romanian health care workers of publicly-owned hospitals approximately $3.65 million, some of which were used to make improper payments. Between 2000 and through 2006, J\u0026J also made approximately 15,000 payment sto sponsor travel for publicly-employed Polish health care professionals, totaling approximately $7.6 million, a portion of which were improper.  In Romania, between 2005 and 2008, Johnson \u0026 Johnson d.o.o. (wholly-owned Romanian subsidiary) and its employees directly or indirectly authorized th epayment of $140,000 in incentives to publicly-owned Romanian health care professionals (most of whom are government employees) to induce the purchase of pharmaceuticals manufactured by J\u0026J subsidiaries and operating companies.  In Iraq, between 2000 and 2003, Janssen Pharmaceutica, NV (wholly owned subsidiary headquartered in Beerse, Belgium) and Cilag AG International (wholly owned subsidiary headquartered in Schaffhausen, Switzerland) were awarded 18 contracts for the sale of pharmaceuticals to the Iraqi Ministry of Health State Company for Marketing Drugs and Medical Appliances under the UN Oil for Food Program, with a total contract value of approximately $9.9 million, which generated approximately $6.1 million in profits. Janssen and Cilag secured thse contracts through the payment of approximately $857,387 in kickbacks to the government of Iraq; the kickbacks were paid to the government of Iraq through a Lebanon Agent and concealed from the United Nations by inflating Janssen and Cilag\u0027s contract prices by 10%. Among the relevant considerations listed in the DPA are: Johnson and Johnson\u0027s agreement to resolve related cases then being investigated by the SEC and the UK Serious Fraud Office (SFO) (para 4-i) and the possibility that were the DOJ to \u0022initiate a prosecution of J\u0026J or one of its operating companies and obtain conviction, instead of entering into this Agreement to defer prosecution, J\u0026J could be subject to exclusion from participation in federal health programs pursuant to 42 U.S.C. Section 1320a-7(a). (para 4-j). Also as outlined in the DPA, J\u0026J agreed to pay a monetary penalty as part of its settlement with the Department of Justice that was \u0022a 25 percent reduction off the bottom of the fine range.\u0022 (para 6) (Source:  Johnson \u0026 Johnson, Deferred Prosecution Agreement and Attachment A: Statement of Facts, filed in US v. Depuy, Inc. Case No. 1:11-cr-00099-JDB (D.D.C. April 8, 2011)).  The US Department of Justice Press Release on the case noted that \u0022The Justice Department acknowledges and expresses its appreciation for the significant assistance provided by the authorities of the 8th Ordinary Interrogation Department of the Athens Court of First Instance and the Athens Economic Crime Squad in Greece; the 5th Investigation Department of the Regional Prosecutor\u0027s Office in Radom, Poland; the Fraud Squad of the West Yorkshire Police Department in the United Kingdom; and the SEC\u0027s Division of Enforcement, as well as the coordination and cooperation with the authorities of the United Kingdom\u0027s Serious Fraud Office.\u0022 (Source: US Department of Justice Press Release, \u0022Johnson \u0026 Johnson Agrees to Pay $21.4 Million Criminal Penalty to Resolve Foreign Corrupt Practices Act and Oil for Food Investigations,\u0022 April 8, 2011.)","Sources ":"Johnson \u0026 Johnson, Deferred Prosecution Agreement and Attachment A: Statement of Facts, filed in US v. Depuy, Inc. Case No. 1:11-cr-00099-JDB (D.D.C. April 8, 2011), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/depuy-inc\/04-08-11depuy-dpa.pdf;  US Department of Justice Press Release, \u0022Johnson \u0026 Johnson Agrees to Pay $21.4 Million Criminal Penalty to Resolve Foreign Corrupt Practices Act and Oil for Food Investigations,\u0022 April 8, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/April\/11-crm-446.html;  US Securities and Exchange Commission, Litigation Release No. 21922 \/ April 8, 2011, \u0022Johnson and Johnson to pay more than $70 million in settled FCPA enforcement action,\u0022 Securities and Exchange Commission v. Johnson \u0026 Johnson, Civil Action No. 1: 11-CV-00686-EFH  (D.D.C., April 8, 2011).   See also Johnson \u0026 Johnson Press Release, \u0022Johnson \u0026 Johnson Announces Settlement with U.S. Department of Justice and U.S. Securities and Exchange Commission,\u0022 April 8, 2011, accessed at http:\/\/www.jnj.com\/connect\/news\/all\/johnson-johnson-announces-settlement-with-us-department-of-justice-and+us-securities-and-exchange-commission","Documents":""},{"Case ID":"ST-241","Case Cluster ":"Johnson \u0026 Johnson","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Greece, Poland, Romania, Iraq (UN Oil-for-Food)","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"04\/08","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$48,666,316.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$38,227,826","Civil Prejudgment Interest (US$) ":"$10,438,490","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Statement of Facts agreed to be Johnson \u0026 Johson as part of its Deferred Prosecution Agreement with the Department of Justice, J\u0026J engaged in misconduct with respect to the UN Oil-for-Food program and in Greece, Poland and Romania.  In Greece, DePuy Inc. (Delaware-registered) and dePuy International (wholly owned subsidiary) from 2001 to 2003, Greek Agent A was paid approximately EUR 7,987,540, a and from 2003 through 2005, Greek Agent B was paid approximately EUR 7,303,754; significant portion of these payments were used to pay cash incentives to Greek health care workers at publicly-owned hospitals to induce them to buy J\u0026J products; from 2002-2006, in addition to the payments to the agents, approximately EUR500,000 was withdrawn by J\u0026J subsidiary Depuy Hellas employees to cover payments owed to the health care workers by the agents but not yet paid.  In Poland, Johnson \u0026 Johnson Poland Sp. z.o.o. (wholly owned subsidiary) entered in to approximately 4,400 civil contracts between 2000 and 2006, for which the company paid Romanian health care workers of publicly-owned hospitals approximately $3.65 million, some of which were used to make improper payments. Between 2000 and through 2006, J\u0026J also made approximately 15,000 payment sto sponsor travel for publicly-employed Polish health care professionals, totaling approximately $7.6 million, a portion of which were improper.  In Romania, between 2005 and 2008, Johnson \u0026 Johnson d.o.o. (wholly-owned Romanian subsidiary) and its employees directly or indirectly authorized the payment of $140,000 in incentives to publicly-owned Romanian health care professionals (most of whom are government employees) to induce the purchase of pharmaceuticals manufactured by J\u0026J subsidiaries and operating companies.  In Iraq, between 2000 and 2003, Janssen Pharmaceutica, NV (wholly owned subsidiary headquartered in Beerse, Belgium) and Cilag AG International (wholly owned subsidiary headquartered in Schaffhausen, Switzerland) were awarded 18 contracts for the sale of pharmaceuticals to the Iraqi Ministry of Health State Company for Marketing Drugs and Medical Appliances under the UN Oil for Food Program, wht a total contract value of approximately $9.9 million, which generated approximately $6.1 million in profits. Janssen and Cilag secured thse contracts through the payment of approximately $857,387 in kickbacks to the government of Iraq; the kickbacks were paid to the government of Iraq through a Lebanon Agent and concealed from the United Nations by inflating Janssen and Cilag\u0027s contract prices by 10%. Among the relevant considerations listed in the DPA are: Johnson and Johnson\u0027s agreement to resolve related cases then being investigated by the SEC and the UK Serious Fraud Office (SFO) (para 4-i) and the possibility that were the DOJ to \u0022initiate a prosecution of J\u0026J or one of its operating companies and obtain conviction, instead of entering into this Agreement to defer prosecution, J\u0026J could be subject to exclusion from participation in federal health programs pursuant to 42 U.S.C. Section 1320a-7(a). (para 4-j). Also as outlined in the DPA, J\u0026J agreed to pay a monetary penalty as part of its settlement with the Department of Justice that was \u0022a 25 percent reduction off the bottom of the fine range.\u0022 (para 6) (Source:  Johnson \u0026 Johnson, Deferred Prosecution Agreement and Attachment A: Statement of Facts, filed in US v. Depuy, Inc. Case No. 1:11-cr-00099-JDB (D.D.C. April 8, 2011)).  SEC:  \u0022Without admitting or denying the SEC\u0027s allegations, J\u0026J has consented to the entry of a court order permanently enjoining it from future violations of Sections 30A, 13(b)(2)(A), and 13(b)(2)(B) of the Securities Exchange Act of 1934; ordering it to pay $38,227,826 in disgorgement and $10,438,490 in prejudgment interest; and ordering it to comply with certain undertakings regarding its FCPA compliance program.\u0022 (Source: US Securities and Exchange Commission, Litigation Release No. 21922 \/ April 8, 2011, \u0022Johnson and Johnson to pay more than $70 million in settled FCPA enforcement action,\u0022 Securities and Exchange Commission v. Johnson \u0026 Johnson, Civil Action No. 1: 11-CV-00686-EFH  (D.D.C., April 8, 2011), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr21922.htm.)  The US Department of Justice Press Release on the case noted that \u0022The Justice Department acknowledges and expresses its appreciation for the significant assistance provided by the authorities of the 8th Ordinary Interrogation Department of the Athens Court of First Instance and the Athens Economic Crime Squad in Greece; the 5th Investigation Department of the Regional Prosecutor\u0027s Office in Radom, Poland; the Fraud Squad of the West Yorkshire Police Department in the United Kingdom; and the SEC\u0027s Division of Enforcement, as well as the coordination and cooperation with the authorities of the United Kingdom\u0027s Serious Fraud Office.\u0022 (Source: US Department of Justice Press Release, \u0022Johnson \u0026 Johnson Agrees to Pay $21.4 Million Criminal Penalty to Resolve Foreign Corrupt Practices Act and Oil for Food Investigations,\u0022 April 8, 2011.)","Sources ":"US Securities and Exchange Commission, Litigation Release No. 21922 \/ April 8, 2011, \u0022Johnson and Johnson to pay more than $70 million in settled FCPA enforcement action,\u0022 Securities and Exchange Commission v. Johnson \u0026 Johnson, Civil Action No. 1: 11-CV-00686-EFH  (D.D.C., April 8, 2011); Johnson \u0026 Johnson, Deferred Prosecution Agreement and Attachment A: Statement of Facts, filed in US v. Depuy, Inc. Case No. 1:11-cr-00099-JDB (D.D.C. April 8, 2011), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/depuy-inc\/04-08-11depuy-dpa.pdf;  US Department of Justice Press Release, \u0022Johnson \u0026 Johnson Agrees to Pay $21.4 Million Criminal Penalty to Resolve Foreign Corrupt Practices Act and Oil for Food Investigations,\u0022 April 8, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/April\/11-crm-446.html.  See also Johnson \u0026 Johnson  Press Release, \u0022Johnson \u0026 Johnson Announces Settlement with U.S. Department of Justice and U.S. Securities and Exchange Commission,\u0022 April 8, 2011, accessed at http:\/\/www.jnj.com\/connect\/news\/all\/johnson-johnson-announces-settlement-with-us-department-of-justice-and+us-securities-and-exchange-commission http:\/\/www.investor.jnj.com\/releasedetail.cfm?releaseid=564971  and add the following link: http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr21922.htm","Documents":""},{"Case ID":"ST-244","Case Cluster ":"Julian Messent (PWS International Ltd.)","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Costa Rica","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"10\/26","Other Jurisdictions of Settlement":"Costa Rica","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Restitution","Total Monetary Sanctions (US$)":"$157,399.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$157,399","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$157,399","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Costa Rica","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 2","Offenses - Alleged":"Making or authorizing corrupt payments (section 1(1) of the Prevention of Corruption Act 1906)","Offenses - Settled":"Making or authorizing corrupt payments (section 1(1) of the Prevention of Corruption Act 1906)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office Press Release, on October 26, 2010, Julian Messent, former head of the Property (Americas) Division at London-based insurance bsiness PWS International Ltd., pleaded guilty at Southwark Court to two counts of making corrupt payments between February 1999 and 2002.  He was sentenced to 21 months\u0027 imprisonment and ordered to pay GBP 100,000 in compensation within 28 days to the Republic of Costa Rica or serve an additional 12 months imprisonment if he fails to do so. The corrupt payments were: (1) in 1999, a payment of $25,832.22 to Roxana Cordero Bogantes, the wife of Alvaro Alcuna, an agent of the Instituto Nacional de Seguros of the Republic of Costa Rica, and (2) in 2002, payment of $250,000 to Reska Financial Inc., a company associated with an agent of the Instituto Nacional de Seguros of the Republic of Costa Rica, namely Critobal Zawadski; both payments were as  inducment or reward for assisting in the appointment or retention of PWS International Limited as broker of the reinsurance contract known as \u0022U-500.\u0022  The Press Release also noted that between 1999 and 2002, Messent authorized 41 corrupt payments totalling $1,982,230.77 to Costa Rican officials, their wives and associated companies. This was a joint investigation by the SFO and the City of London Police.  Following elections in Costa Rica in 2002, officials in INS and ICE were replaced. Enquiries were made into the contract with PWS and the payments made unider it; the Foreign and Commonwealth Office referred the case to SFO in October 2005. (Source: UK Serious Fraud Office, \u0022Insurance Broker jailed for bribing Costa Rican officials,\u0022 October 26, 2010.)  The US Government cited the case of Julian Messent in its Response to ICE\u0027s [Instituto Costariccense de Electricidad\u0027s] Petition for Victim Status and Restitution, noting that in Messent\u0027s case, he had admitted that he authorized corrupt payments of almost $2 million to Costa Rican officials at ICE and the state insurance company, Instituto Nacional de Seguros, and that under the UK sentencing order, Messent was not required to pay restitution to ICE or Instituto Nacional de Seguros. Rather, he was ordered to pay money to the government of Costa Rica, something which Alcatel-Lucent had done in the US settlement cases. (Source: US v. Alcatel France S.A., et al Case No. 1:10-cr-20906-MGC and US v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907-MGC (S.D. Fla.), Government\u0027s Response to ICE\u0027s Petition for Victim Status and Restitution filed May 23, 2011).  ","Sources ":"United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf;  UK Serious Fraud Office Press Release, \u0022Insurance Broker jailed for bribing Costa Rican officials,\u0022 October 26, 2010, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2010\/insurance-broker-jailed-for-bribing-costa-rican-officials.aspx; US v. Alcatel France S.A., et al Case No. 1:10-cr-20906-MGC and US v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907-MGC (S.D. Fla.), Government\u0027s Response to ICE\u0027s Petition for Victim Status and Restitution filed May 23, 2011 (obtained via Pacer).  ","Documents":""},{"Case ID":"ST-245","Case Cluster ":"Kazakh Oil Mining","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Kazakhstan","Year of Settlement":"2003","Month\/Day of Settlement (or Notes)":"09\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Restitution","Total Monetary Sanctions (US$)":"$8,025,000.00","Criminal Fine\/Penalty (US$) ":"$25,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$8,000,000","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Subscribing to False Tax Returns, Tax Evasion","Offenses - Settled":"Subscribing to False Tax Returns, Tax Evasion","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On April 2, 2003, James H. Giffen, the Chairman of The Mercator Corporation (Mercator), a merchant bank with offices in New York and the Republic of Kazakhstan, was indicted in the Southern District of New York on charges that he made a series of illegal payments to senior Kazakh officials in connection with numerous oil deals in that country. According to court documents, Giffen allegedly made corrupt payments to senior Kazakh officials in connection with the following transactions in which Giffen represented the Republic of Kazakhstan: 1) Mobil Oil\u0027s 1996 purchase of a 25% share in the Tengiz oil field; (2) Mobil Oil\u0027s 1995 agreement to finance the processing and sale of gas condensate from the Karachaganak oil and gas field; (3) Amoco\u0027s 1997 purchase of a share in the Caspian Pipeline Consortium; (4) Texaco and other oil companies\u0027 purchase of a share in the Karachaganak oil and gas field in 1998; (5) Mobil and other oil companies\u0027 1998 purchase of exploration rights in the Kazakh portion of the Caspian Sea, and; (6) Phillips Petroleum\u0027s 1998 purchase of Caspian Sea exploration rights. [  ] According to the original indictment, Giffen and Mercator were advisors to the Kazakh government on strategic planning, development of foreign investment and the negotiation of priority investment projects relating to the exploration, development, production, transportation, and processing of oil and gas. During this period, Giffen had held the title of counselor to the President of Kazakhstan. According to the charges, Mobil oil agreed to pay the success fees owed by Kazakhstan to Giffen and Mercator, and out of those fees, Giffen made unlawful payments of $22 million dollars to secret Swiss accounts beneficially owned by two high level Kazakh officials.  In addition, according to the Indictment, between 1995 and 2000, Giffen caused approximately $70 million paid by various oil companies into escrow accounts in Switzerland in connection with the purchase of oil and gas rights in Kazakhstan to be diverted into secret Swiss bank accounts under his control. Giffen then used this money to make additional unlawful payments of approximately $55 million to the two senior officials of the Kazakh Government.  Also on April 2, 2003, J. Bryan Williams a senior executive at Mobil Oil, was charged in connection with a kickback and tax evasion scheme involving a related oil deal in Kazakhstan. According to court documents, Williams was sent by Mobil\u0027s Chairman to finalize the negotiations with Kazakhstan regarding Mobil\u0027s purchase for approximately $1 billion of a 25% interest in the Tengiz oil field in 1996. After the Tengiz deal closed, Mobil paid $41 million to a New York merchant bank that represented the Republic of Kazakhstan in the transaction. The merchant bank\u0027s Chairman kicked back $2 million of that payment to Williams, by transferring money through a secret Swiss bank account.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, The Mercator Corporation Case Summary at 104-106.)  According to the Press Release by the United States Attorney for the Southern District of New York, Swiss authorities provided \u0022outstanding cooperation\u0022 in the case.  (Source:  United States Attorney for the Southern District of New York, \u0022Former Mobil Executive Sentenced on Tax Evasion Charges in Connection with Kazakhstan Oil Transactions,\u0022 September 18, 2003.)  According to the Court Docket Report in the case, the ordered restitution was to be paid to the US Internal Revenue Services.  (Source:  US v. Williams, Case No. 03-cr-406 (SDNY), Court Docket Report retrieved January 15, 2012, via Pacer.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, The Mercator Corporation Case Summary at 104-106, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Williams, Case No. 03-cr-406-HB (SDNY), Superseding Indictment filed April 14, 2003, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/williamsjb\/04-14-03williams-supersed-indict.pdf; Superseding Information filed June 12, 2003, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/williamsjb\/06-12-03williams-supersed-info.pdf; Amended Judgment filed October 22, 2003, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/williamsjb\/04-02-03williams-judgment.pdf; Court Docket Report retrieved January 15, 2012, via Pacer.  United States Attorney for the Southern District of New York, \u0022Former Mobil Executive Sentenced on Tax Evasion Charges in Connection with Kazakhstan Oil Transactions,\u0022 September 18, 2003, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/williamsjb\/09-18-03williams-pressrelease.pdf. ","Documents":""},{"Case ID":"ST-246","Case Cluster ":"Kazakh Oil Mining","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Kazakhstan","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture of any interest held in specified bank accounts ","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"BOTA Foundation (see Summary for explanation)","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Commit Wire Fraud, Conspiracy to Commit Mail Fraud, Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering, Conspiracy to Defraud the United States by Impairing and Impeding Its Lawful Functions, Bribery of Foreign Officials, Wire Fraud, Mail fraud, International Money Laundering, Money Laundering, Obstructing the Enforcement of the Internal Revenue Service, Subscribing to False Tax Returns, Failure to Supply Information Regarding Foreign Bank Accounts on an Income Tax Return ","Offenses - Settled":"Failure to Supply Information Regarding Foreign Bank Accounts on an Income Tax Return ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On April 2, 2003, James H. Giffen, the Chairman of The Mercator Corporation (Mercator), a merchant bank with offices in New York and the Republic of Kazakhstan, was indicted in the Southern District of New York on charges that he made a series of illegal payments to senior Kazakh officials in connection with numerous oil deals in that country. According to court documents, Giffen allegedly made corrupt payments to senior Kazakh officials in connection with the following transactions in which Giffen represented the Republic of Kazakhstan: 1) Mobil Oil\u0027s 1996 purchase of a 25% share in the Tengiz oil field; (2) Mobil Oil\u0027s 1995 agreement to finance the processing and sale of gas condensate from the Karachaganak oil and gas field; (3) Amoco\u0027s 1997 purchase of a share in the Caspian Pipeline Consortium; (4) Texaco and other oil companies\u0027 purchase of a share in the Karachaganak oil and gas field in 1998; (5) Mobil and other oil companies\u0027 1998 purchase of exploration rights in the Kazakh portion of the Caspian Sea, and; (6) Phillips Petroleum\u0027s 1998 purchase of Caspian Sea exploration rights. [  ] According to the original indictment, Giffen and Mercator were advisors to the Kazakh government on strategic planning, development of foreign investment and the negotiation of priority investment projects relating to the exploration, development, production, transportation, and processing of oil and gas. During this period, Giffen had held the title of counselor to the President of Kazakhstan. According to the charges, Mobil oil agreed to pay the success fees owed by Kazakhstan to Giffen and Mercator, and out of those fees, Giffen made unlawful payments of $22 million dollars to secret Swiss accounts beneficially owned by two high level Kazakh officials.  In addition, according to the Indictment, between 1995 and 2000, Giffen caused approximately $70 million paid by various oil companies into escrow accounts in Switzerland in connection with the purchase of oil and gas rights in Kazakhstan to be diverted into secret Swiss bank accounts under his control. Giffen then used this money to make additional unlawful payments of approximately $55 million to the two senior officials of the Kazakh Government.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, The Mercator Corporation Case Summary at 104-106.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, The Mercator Corporation Case Summary at 104-106, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. James H. Giffen, Case No. 2:03-cr-404 (SDNY), Complaint filed March 28, 2003, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/giffen\/03-28-03giffen-complaint.pdf; Second Superseding Indictment filed August 4, 2004, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/giffen\/08-04-04giffen-second-superseding-indict.pdf; Plea Agreement dated August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/giffen\/08-06-10giffen-plea-agree.pdf; Judgment filed November 23, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/giffen\/11-23-10giffen-judgment.pdf","Documents":""},{"Case ID":"ST-247","Case Cluster ":"Kazakh Oil Mining","Jurisdiction of Settlement":"Kazakhstan","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Kazakhstan","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"05\/02","Other Jurisdictions of Settlement":"Switzerland, United States","Settlement with Individual or Legal Person?":"Other (In Rem Forfeiture) ","Type of Settlement":"Other","Legal Form of Settlement":"Memorandum of Understanding","Monetary Sanctions  (Types)":"Civil Asset Forfeiture","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"BOTA Foundation (see Summary for explanation)","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Forfeiture","Offenses - Settled":"Forfeiture","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"Pursuant to a 2007 Memorandum of Understanding among the Governments of Kazakhstan, Switzerland and the United States, approximately $84 mllion held on deposit in the account of Orel Capital Ltd. at Credit Agricole Indosuez in Geneva, Switzerland were transferred in July 1999 to an account in the name of the Treasury of the Ministry of Finance of the Republic of Kazakhstan at Pictet \u0026 Cie in Geneva, Switzerland.  The funds had been frozen by order of a Swiss examining magistrate and in the United States, a criminal indictment had been filed against James H. Giffen which included a criminal forfeiture allegation.  The MOU stipulated that the funds be used to establish and operate the BOTA Foundation which carries out social programs and whose operations are being overseen by the World Bank pursuant to a Service Agreement.  (Source:  Memorandum of Understanding Among the Governments of the United States of America, the Swiss Confederation, and the Republic of Kazakhstan (May 2007); Amended in 2008.)  Please note that the amount of forfeited and returned sums are noted on the Kazakh Oil Mining - US Settlement Bota Foundation entry only so as to avoid double counting of settlement sums.","Sources ":"Memorandum of Understanding by the Swiss Confederation, United States and the Republic of Kazakhstan (May 2007) and Annex 2 (Service Agreement for TDB BOTA Foundation among the International Bank for Reconstruction and Development and the Governments of the United States of America, the Swiss Confederation, and the Republic of Kazakhstan, accessed at http:\/\/www.state.gov\/documents\/organization\/108887.pdf.  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, The Mercator Corporation Case Summary at 104-106, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Approximately $84 Million, Case No. 2:07-cr-03559-LAP (SDNY), Verified Complaint for forfeiture in rem, filed May 3, 2007 and Final Order filed June 1, 2009 (both accessed via Pacer). ","Documents":""},{"Case ID":"ST-248","Case Cluster ":"Kazakh Oil Mining","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Kazakhstan","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"05\/02","Other Jurisdictions of Settlement":"Kazakhstan, United States","Settlement with Individual or Legal Person?":"Other (Confiscated Funds)","Type of Settlement":"Other","Legal Form of Settlement":"Memorandum of Understanding  ","Monetary Sanctions  (Types)":"Civil Confiscation","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"BOTA Foundation (see Summary for explanation)","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"Pursuant to a 2007 Memorandum of Understanding among the Governments of Kazakhstan, Switzerland and the United States, approximately $84 mllion held on deposit in the account of Orel Capital Ltd. at Credit Agricole Indosuez in Geneva, Switzerland were transferred in July 1999 to an account in the name of the Treasury of the Ministry of Finance of the Republic of Kazakhstan at Pictet \u0026 Cie in Geneva, Switzerland.  The funds had been frozen by order of a Swiss examining magistrate and in the United States, a criminal indictment had been filed against James H. Giffen and Mercator Corporation which included a criminal forfeiture allegation.  The MOU stipulated that the funds be used to establish and operate the BOTA Foundation which carries out social programs and whose operations are being overseen by the World Bank pursuant to a Service Agreement.  (Source:  Memorandum of Understanding Among the Governments of the United States of America, the Swiss Confederation, and the Republic of Kazakhstan (May 2007); Amended in 2008.)   Please note that the amount of forfeited and returned sums are noted on the Kazakh Oil Mining - US Bota Foundation entry only so as to avoid double counting of settlement sums.","Sources ":"Memorandum of Understanding by the Swiss Confederation, United States and the Republic of Kazakhstan (May 2007) and Annex 2 (Service Agreement for TDB BOTA Foundation among the International Bank for Reconstruction and Development and the Governments of the United States of America, the Swiss Confederation, and the Republic of Kazakhstan, accessed at http:\/\/www.state.gov\/documents\/organization\/108887.pdf.  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, The Mercator Corporation Case Summary at 104-105, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-249","Case Cluster ":"Kazakh Oil Mining","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Kazakhstan","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"05\/02","Other Jurisdictions of Settlement":"Kazakhstan, Switzerland","Settlement with Individual or Legal Person?":"Other (Confiscated Funds)","Type of Settlement":"Other","Legal Form of Settlement":"Memorandum of Understanding  ","Monetary Sanctions  (Types)":"Civil Confiscation","Total Monetary Sanctions (US$)":"$84,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"$84,000,000","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$84,000,000","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"BOTA Foundation (see Summary for explanation)","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"Pursuant to a 2007 Memorandum of Understanding among the Governments of Kazakhstan, Switzerland and the United States, approximately $84 mllion held on deposit in the account of Orel Capital Ltd. at Credit Agricole Indosuez in Geneva, Switzerland were transferred in July 1999 to an account in the name of the Treasury of the Ministry of Finance of the Republic of Kazakhstan at Pictet \u0026 Cie in Geneva, Switzerland.  The funds had been frozen by order of a Swiss examining magistrate and in the United States, a criminal indictment had been filed against James H. Giffen and Mercator Corporation which included a criminal forfeiture allegation.  The MOU stipulated that the funds be used to establish and operate the BOTA Foundation which carries out social programs and whose operations are being overseen by the World Bank pursuant to a Service Agreement.  (Source:  Memorandum of Understanding Among the Governments of the United States of America, the Swiss Confederation, and the Republic of Kazakhstan (May 2007); Amended in 2008.)   Please note that the amount of forfeited and returned sums are noted on the Kazakh Oil Mining - US Settlement Bota Foundation entry only so as to avoid double counting of settlement sums.","Sources ":"Memorandum of Understanding by the Swiss Confederation, United States and the Republic of Kazakhstan (May 2007) and Annex 2 (Service Agreement for TDB BOTA Foundation among the International Bank for Reconstruction and Development and the Governments of the United States of America, the Swiss Confederation, and the Republic of Kazakhstan, accessed at http:\/\/www.state.gov\/documents\/organization\/108887.pdf.  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, The Mercator Corporation Case Summary at 104-105, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-250","Case Cluster ":"Kazakh Oil Mining","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Kazakhstan","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine; Criminal forfeiture","Total Monetary Sanctions (US$)":"$32,000.00","Criminal Fine\/Penalty (US$) ":"$32,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"BOTA Foundation (see Summary for explanation)","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On April 2, 2003, James H. Giffen, the Chairman of The Mercator Corporation (Mercator), a merchant bank with offices in New York and the Republic of Kazakhstan, was indicted in the Southern District of New York on charges that he made a series of illegal payments to senior Kazakh officials in connection with numerous oil deals in that country. According to court documents, Giffen allegedly made corrupt payments to senior Kazakh officials in connection with the following transactions in which Giffen represented the Republic of Kazakhstan: 1) Mobil Oil\u0027s 1996 purchase of a 25% share in the Tengiz oil field; (2) Mobil Oil\u0027s 1995 agreement to finance the processing and sale of gas condensate from the Karachaganak oil and gas field; (3) Amoco\u0027s 1997 purchase of a share in the Caspian Pipeline Consortium; (4) Texaco and other oil companies\u0027 purchase of a share in the Karachaganak oil and gas field in 1998; (5) Mobil and other oil companies\u0027 1998 purchase of exploration rights in the Kazakh portion of the Caspian Sea, and; (6) Phillips Petroleum\u0027s 1998 purchase of Caspian Sea exploration rights.  Subsequently, on August 6, 2010, Mercator was charged with one count of violating the anti-bribery provisions of the FCPA in connection with the purchase of two snowmobiles in November 1999. These snowmobiles were later shipped to Kazakhstan for delivery to a senior Kazakh official.According to the original indictment, Giffen and Mercator were advisors to the Kazakh government on strategic planning, development of foreign investment and the negotiation of priority investment projects relating to the exploration, development, production, transportation, and processing of oil and gas. During this period, Giffen had held the title of counselor to the President of Kazakhstan. According to the charges, Mobil oil agreed to pay the success fees owed by Kazakhstan to Giffen and Mercator, and out of those fees, Giffen made unlawful payments of $22 million dollars to secret Swiss accounts beneficially owned by two high level Kazakh officials.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, The Mercator Corporation Case Summary at 104-106.)   Please note that the amount of forfeited and returned sums are noted on the Kazakh Oil Mining - US Settlement Bota Foundation entry only so as to avoid double counting of settlement sums.","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, The Mercator Corporation Case Summary at 104-106, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Mercator Corporation, Case No. 1:03-cr-404-WHP (S.D.N.Y.), Superseding Information filed August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/mercator\/08-06-10mercator-info.pdf; Plea Agreement filed August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/mercator\/08-06-10mercator-plea-agmt.pdf; Judgment filed November 23, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/mercator\/11-30-10mercator-judgment.pdf.  United States Attorney for the Southern District of New York Press Release, \u0022New York Merchant Bank Pleads Guilty to FCPA Violation; Bank Chairman Pleads Guilty to Failing to Disclose Control of Foreign Bank Account,\u0022 August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/giffen\/08-06-10giffen-press-plea-usao-sdny.pdf","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Kazakhstan_Oil_Switzerland_MOU-CH-US-KZ_BOTA_FDN_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Kazakhstan_Oil_Final_Order_Jun_1_2009.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Kazakhstan_Oil_%2484m_Verified_Complaint_May_3_2007.pdf"},{"Case ID":"ST-251","Case Cluster ":"Latin Node Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Honduras, Yemen","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"04\/07","Other Jurisdictions of Settlement":"[Yemen: investigation]","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,000,000.00","Criminal Fine\/Penalty (US$) ":"$2,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On March 23, 2009, Latin Node Inc. (LatiNode) was charged with one count of violating the anti-bribery provisions of the FCPA in connection with improper payment in Honduras and Yemen. According to court documents, LatiNode was a privately held Florida corporation that provided wholesale telecommunications services using Internet protocol technology in a number of countries throughout the world, including Honduras and Yemen.  On December 14, 2010, LatiNode\u0027s former CEO and Vice President for Business Development, Jorge Granados and Manuel Caceres, were indicted by a Grand Jury in the Southern District of Florida on 19 counts of conspiracy, violations of the FCPA, and money laundering. Subsequently, on December 17, 2010, Manuel Salvoch, LatiNode\u0027s former CFO, and Juan Pablo V. Vasquez, a former senior commercial executive at LatiNode, were each charged with one count of conspiracy to violate the anti-bribery provisions of the FCPA.\u0022  According to the Report, in Honduras, \u0022between September 2006 and June 2007, these executives paid or caused to be paid more than $500,000 in bribes to the Honduran officials. In all, according to court documents filed in the case against LatiNode, between March 2004 and June 2007, the company paid or caused to be paid approximately $1,099,889 in payments to third parties, knowing that some or all of those funds would be passed on as bribes to officials of Hondutel. In addition to the payments for the interconnection agreement, LatiNode admitted that these payments were also, in part, intended to secure reduced call termination rates for the company\u0027s traffic.  Each of these illicit payments originated from LatiNode\u0027s Miami bank account, and many of the payments were concealed by laundering the money through LatiNode subsidiaries in Guatemala and through accounts in Honduras controlled by Honduran government officials.\u0022  In Yemen, according to the same Report, \u0022LatiNode admitted that from approximately July 2005 through April 2006, the company made 17 payments totaling approximately $1,150,654 to a third-party consultant with the knowledge that some or all of the money would be passed on to Yemeni officials in exchange for favorable interconnection rates in Yemen. Each of these payments was also made from LatiNode\u0027s Miami bank account. Company e-mails indicated that company executives believed that potential recipients of these payments included Yemeni government officials.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30.)  According to the World Bank Anti-Corruption Authorities website, Yemen was investigating the case (Source:  Anti-Corruption Authorities, Yemeni Anti-Corruption Authority summary of work on Latin Node case, accessed on January 18, 2012 at http:\/\/www.acauthorities.org\/aca\/sucessstory\/case-no-09-20239cr-houck-0-50-wvan-against-latin-no-de-inc-company.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Latin Node, Inc., Case No. 1:09-cr-20239-PCH (S.D. Fla.), Information filed March 24, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/litton-applied\/03-23-09latinnode-info.pdf; Plea Agreement filed April 3, 2009, accessed at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/litton-applied\/04-03-09latinnode-plea-agree.pdf; Statement of Offense filed April 3, 2009 accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/litton-applied\/04-03-09latinnode-state-offense.pdf.  The World Bank, Anti-Corruption Authorities, Yemeni Anti-Corruption Authority summary of work on Latin Node case, accessed on January 18, 2012 at http:\/\/www.acauthorities.org\/aca\/sucessstory\/case-no-09-20239cr-houck-0-50-wvan-against-latin-no-de-inc-company.","Documents":""},{"Case ID":"ST-252","Case Cluster ":"Latin Node Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Honduras, Yemen","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"05\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to commit international money laundering, Bribery of foreign officials, International money laundering","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On March 23, 2009, Latin Node Inc. (LatiNode) was charged with one count of violating the anti-bribery provisions of the FCPA in connection with improper payment in Honduras and Yemen. According to court documents, LatiNode was a privately held Florida corporation that provided wholesale telecommunications services using Internet protocol technology in a number of countries throughout the world, including Honduras and Yemen.  On December 14, 2010, LatiNode\u0027s former CEO and Vice President for Business Development, Jorge Granados and Manuel Caceres, were indicted by a Grand Jury in the Southern District of Florida on 19 counts of conspiracy, violations of the FCPA, and money laundering. Subsequently, on December 17, 2010, Manuel Salvoch, LatiNode\u0027s former CFO, and Juan Pablo V. Vasquez, a former senior commercial executive at LatiNode, were each charged with one count of conspiracy to violate the anti-bribery provisions of the FCPA.\u0022  According to the Report, in Honduras, \u0022between September 2006 and June 2007, these executives paid or caused to be paid more than $500,000 in bribes to the Honduran officials. In all, according to court documents filed in the case against LatiNode, between March 2004 and June 2007, the company paid or caused to be paid approximately $1,099,889 in payments to third parties, knowing that some or all of those funds would be passed on as bribes to officials of Hondutel. In addition to the payments for the interconnection agreement, LatiNode admitted that these payments were also, in part, intended to secure reduced call termination rates for the company\u0027s traffic.  Each of these illicit payments originated from LatiNode\u0027s Miami bank account, and many of the payments were concealed by laundering the money through LatiNode subsidiaries in Guatemala and through accounts in Honduras controlled by Honduran government officials.\u0022  In Yemen, according to the same Report, \u0022LatiNode admitted that from approximately July 2005 through April 2006, the company made 17 payments totaling approximately $1,150,654 to a third-party consultant with the knowledge that some or all of the money would be passed on to Yemeni officials in exchange for favorable interconnection rates in Yemen. Each of these payments was also made from LatiNode\u0027s Miami bank account. Company e-mails indicated that company executives believed that potential recipients of these payments included Yemeni government officials.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Granados and Vasquez, Case No. 1:10-cr-20881 (S.D. Fla.), Indictment filed on December 21, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/granados-jorge\/12-21-10granados-indict.pdf; Plea Agreement filed May 19, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/granados-jorge\/05-19-11granados-plea.pdf; Judgment in a Criminal Case filed September 13, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/granados-jorge\/09-13-11granados-judgment.pdf","Documents":""},{"Case ID":"ST-253","Case Cluster ":"Latin Node Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Honduras, Yemen","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"01\/21","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$7,500.00","Criminal Fine\/Penalty (US$) ":"$7,500 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On March 23, 2009, Latin Node Inc. (LatiNode) was charged with one count of violating the anti-bribery provisions of the FCPA in connection with improper payment in Honduras and Yemen. According to court documents, LatiNode was a privately held Florida corporation that provided wholesale telecommunications services using Internet protocol technology in a number of countries throughout the world, including Honduras and Yemen.  On December 14, 2010, LatiNode\u0027s former CEO and Vice President for Business Development, Jorge Granados and Manuel Caceres, were indicted by a Grand Jury in the Southern District of Florida on 19 counts of conspiracy, violations of the FCPA, and money laundering. Subsequently, on December 17, 2010, Manuel Salvoch, LatiNode\u0027s former CFO, and Juan Pablo V. Vasquez, a former senior commercial executive at LatiNode, were each charged with one count of conspiracy to violate the anti-bribery provisions of the FCPA.\u0022  According to the Report, in Honduras, \u0022between September 2006 and June 2007, these executives paid or caused to be paid more than $500,000 in bribes to the Honduran officials. In all, according to court documents filed in the case against LatiNode, between March 2004 and June 2007, the company paid or caused to be paid approximately $1,099,889 in payments to third parties, knowing that some or all of those funds would be passed on as bribes to officials of Hondutel. In addition to the payments for the interconnection agreement, LatiNode admitted that these payments were also, in part, intended to secure reduced call termination rates for the company\u0027s traffic.  Each of these illicit payments originated from LatiNode\u0027s Miami bank account, and many of the payments were concealed by laundering the money through LatiNode subsidiaries in Guatemala and through accounts in Honduras controlled by Honduran government officials.\u0022  In Yemen, according to the same Report, \u0022LatiNode admitted that from approximately July 2005 through April 2006, the company made 17 payments totaling approximately $1,150,654 to a third-party consultant with the knowledge that some or all of the money would be passed on to Yemeni officials in exchange for favorable interconnection rates in Yemen. Each of these payments was also made from LatiNode\u0027s Miami bank account. Company e-mails indicated that company executives believed that potential recipients of these payments included Yemeni government officials.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Vasquez, Case No. 1:10-cr-20894 (S.D. Fla.), Judgment in a Criminal Case, filed April 25, 2012  (accessed via PACER); Information filed January 19, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vasquezjp\/12-17-10vasquez-juan-info.pdf; Plea Agreement filed January 21, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vasquezjp\/01-21-11vasquez-juan-plea.pdf; Statement of Offense filed January 21, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/vasquezjp\/1-21-11vasquez-juan-statement.pdf","Documents":""},{"Case ID":"ST-254","Case Cluster ":"Latin Node Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Honduras, Yemen","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"04\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None ","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to commit international money laundering, Bribery of foreign officials, International money laundering","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Judgment in Mr. Caceres\u0027 case, on April 24, 2012 he was sentenced to a prison term of twenty-three months; other than a $100 court assessment fee, no monetary sanctions were ordered in his case. (Source: US v. Caceres, Case No. 1:10-cr-20881 (S.D. Fla.), Judgment in a Criminal Case, April 24, 2012.)  According to the June 2011 United States Report to the OECD, \u0022On March 23, 2009, Latin Node Inc. (LatiNode) was charged with one count of violating the anti-bribery provisions of the FCPA in connection with improper payment in Honduras and Yemen. According to court documents, LatiNode was a privately held Florida corporation that provided wholesale telecommunications services using Internet protocol technology in a number of countries throughout the world, including Honduras and Yemen.  On December 14, 2010, LatiNode\u0027s former CEO and Vice President for Business Development, Jorge Granados and Manuel Caceres, were indicted by a Grand Jury in the Southern District of Florida on 19 counts of conspiracy, violations of the FCPA, and money laundering. Subsequently, on December 17, 2010, Manuel Salvoch, LatiNode\u0027s former CFO, and Juan Pablo V. Vasquez, a former senior commercial executive at LatiNode, were each charged with one count of conspiracy to violate the anti-bribery provisions of the FCPA.\u0022  According to the Report, in Honduras, \u0022between September 2006 and June 2007, these executives paid or caused to be paid more than $500,000 in bribes to the Honduran officials. In all, according to court documents filed in the case against LatiNode, between March 2004 and June 2007, the company paid or caused to be paid approximately $1,099,889 in payments to third parties, knowing that some or all of those funds would be passed on as bribes to officials of Hondutel. In addition to the payments for the interconnection agreement, LatiNode admitted that these payments were also, in part, intended to secure reduced call termination rates for the company\u0027s traffic.  Each of these illicit payments originated from LatiNode\u0027s Miami bank account, and many of the payments were concealed by laundering the money through LatiNode subsidiaries in Guatemala and through accounts in Honduras controlled by Honduran government officials.\u0022  In Yemen, according to the same Report, \u0022LatiNode admitted that from approximately July 2005 through April 2006, the company made 17 payments totaling approximately $1,150,654 to a third-party consultant with the knowledge that some or all of the money would be passed on to Yemeni officials in exchange for favorable interconnection rates in Yemen. Each of these payments was also made from LatiNode\u0027s Miami bank account. Company e-mails indicated that company executives believed that potential recipients of these payments included Yemeni government officials.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Granados, et al, Case No. 1:10-cr-20881 (S.D. Fla.), Indictment filed on December 21, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/granados-jorge\/12-21-10granados-indict.pdf; Plea Agreement filed May 20, 2011 and Judgment in a Criminal Case filed April 25, 2012, all accessed via PACER.  (Copy of Judgment can also be accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/cacercesj\/2012-04-25-cacercesj-judgment.pdf)","Documents":""},{"Case ID":"ST-255","Case Cluster ":"Latin Node Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Honduras, Yemen","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"01\/12","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea  ","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On March 23, 2009, Latin Node Inc. (LatiNode) was charged with one count of violating the anti-bribery provisions of the FCPA in connection with improper payment in Honduras and Yemen. According to court documents, LatiNode was a privately held Florida corporation that provided wholesale telecommunications services using Internet protocol technology in a number of countries throughout the world, including Honduras and Yemen.  On December 14, 2010, LatiNode\u0027s former CEO and Vice President for Business Development, Jorge Granados and Manuel Caceres, were indicted by a Grand Jury in the Southern District of Florida on 19 counts of conspiracy, violations of the FCPA, and money laundering. Subsequently, on December 17, 2010, Manuel Salvoch, LatiNode\u0027s former CFO, and Juan Pablo V. Vasquez, a former senior commercial executive at LatiNode, were each charged with one count of conspiracy to violate the anti-bribery provisions of the FCPA.\u0022  According to the Report, in Honduras, \u0022between September 2006 and June 2007, these executives paid or caused to be paid more than $500,000 in bribes to the Honduran officials. In all, according to court documents filed in the case against LatiNode, between March 2004 and June 2007, the company paid or caused to be paid approximately $1,099,889 in payments to third parties, knowing that some or all of those funds would be passed on as bribes to officials of Hondutel. In addition to the payments for the interconnection agreement, LatiNode admitted that these payments were also, in part, intended to secure reduced call termination rates for the company\u0027s traffic.  Each of these illicit payments originated from LatiNode\u0027s Miami bank account, and many of the payments were concealed by laundering the money through LatiNode subsidiaries in Guatemala and through accounts in Honduras controlled by Honduran government officials.\u0022  In Yemen, according to the same Report, \u0022LatiNode admitted that from approximately July 2005 through April 2006, the company made 17 payments totaling approximately $1,150,654 to a third-party consultant with the knowledge that some or all of the money would be passed on to Yemeni officials in exchange for favorable interconnection rates in Yemen. Each of these payments was also made from LatiNode?s Miami bank account. Company e-mails indicated that company executives believed that potential recipients of these payments included Yemeni government officials.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Latin Node, Inc. Case Summary at 29-30, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Manuel Salvoch, Case No. 1:10-cr-20893-PCH (S.D. Fla.), Judgment in a Criminal Case, filed June 8, 2012 (accessed via PACER); Information filed December 17, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/salvoch\/12-17-10salvoch-info.pdf; Plea Agreement dated January 12, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/salvoch\/01-12-11salvoch-plea.pdf; Statement of Offense dated January 12, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/salvoch\/01-12-11salvoch-statement.pdf.","Documents":""},{"Case ID":"ST-256","Case Cluster ":"Lesotho Highlands Water Project","Jurisdiction of Settlement":"Lesotho","Jurisdiction of Settlement \/ Enforcement Agency":"Director of Public Prosecutions","Jurisdiction of Foreign Public Official(s) ":"Lesotho","Year of Settlement":"2003","Month\/Day of Settlement (or Notes)":"10\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$62,266.50","Criminal Fine\/Penalty (US$) ":"$62,266.50","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$62,266.50","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the decision by the Lesotho High Court, Mr. DuPlooy, an intermediary for the Impreglio company, pleaded guilty to foreign bribery charges and was fined R500,000 in addition to receiving a prison term.  (Source: R v. Du Plooy, High Court of Lesotho, CRI\/T\/11\/1999.)  According to a presentation to the US Senate Foreign Relations Committee by Guido Penzhorn, SC, lead prosecutor in the Lesotho Highlands Water Projects case, \u0022In June 2003 one Du Plooy, the intermediary who acted on behalf of Impregilo of Italy, the lead partner of the consortium that built the main dam, pleaded guilty to bribing Mr Sole on behalf of Impregilo. In exchange for co-operation with the prosecution he was fined R500 000, coupled to a lengthy period of imprisonment which was conditionally suspended.\u0022   (Source:  Guido Penzhorn SC, Comments on the Current Lesotho Bribery Prosecutions, Presentation before the [U.S.] Senate Foreign Relations Committee, July 24, 2004.) Please note that June 1, 2003 was used as the date of currency conversion. ","Sources ":"R v. DuPlooy, High Court of Lesotho (CRI\/T\/111\/1999), October 17, 2003 sentencing date, accessed at http:\/\/www.lesotholii.org\/ls\/judgment\/high-court\/2003\/122; Guido Penzhorn SC, Comments on the Current Lesotho Bribery Prosecutions, Presentation before the [U.S.] Senate Foreign Relations Committee, July 24, 2004, accessed at http:\/\/www.odiousdebts.org\/odiousdebts\/publications\/SenatePaperJuly04.pdf. See also, LL Thesane and GH Penzhorn SC, \u0022Case Study: the lesotho bribery prosecutions,\u0022 presented at the Conference on the Protection and Optimization of Public Funds, the Cooperation between National and International Authorities, 14-16 May 2007, accessed at http:\/\/www1.worldbank.org\/finance\/star_site\/documents\/arw\/Lesotho_Highlands_EU_Anti_Fraud_Case_Study_Thetsane_Penzhorn_May_2007.pdf.  ","Documents":""},{"Case ID":"ST-257","Case Cluster ":"Lesotho Highlands Water Project","Jurisdiction of Settlement":"Lesotho","Jurisdiction of Settlement \/ Enforcement Agency":"Director of Public Prosecutions","Jurisdiction of Foreign Public Official(s) ":"Lesotho","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"02\/25","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,504,530.00","Criminal Fine\/Penalty (US$) ":"$1,504,530","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$1,504,530","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a presentation to the US Senate Foreign Relations Committee by Guido Penzhorn, SC, lead prosecutor in the Lesotho Highlands Water Projects case, \u0022On 25 February 2004 Schneider Electric SA (formerly Spie Batignolles), the multi-national French construction company involved in building the transfer tunnels, pleaded guilty to 16 counts of bribing Mr Sole. A fine of R10million was agreed with the prosecution and was paid.\u0022  (Source:  Guido Penzhorn SC, Comments on the Current Lesotho Bribery Prosecutions, Presentation before the [U.S.] Senate Foreign Relations Committee, July 24, 2004.)","Sources ":"Guido Penzhorn SC, Comments on the Current Lesotho Bribery Prosecutions, Presentation before the [U.S.] Senate Foreign Relations Committee, July 24, 2004, accessed at http:\/\/www.odiousdebts.org\/odiousdebts\/publications\/SenatePaperJuly04.pdf. See also, LL Thesane and GH Penzhorn SC, \u0022Case Study: the Lesotho bribery prosecutions,\u0022 presented at the Conference on the Protection and Optimization of Public Funds, the Cooperation between National and International Authorities, 14-16 May 2007, accessed at http:\/\/www1.worldbank.org\/finance\/star_site\/documents\/arw\/Lesotho_Highlands_EU_Anti_Fraud_Case_Study_Thetsane_Penzhorn_May_2007.pdf.  See also, Schneider Electric SA v. Director of Public Prosecutions (CRI\/APN\/751\/2003), accessed at  http:\/\/www.lesotholii.org\/ls\/judgment\/high-court\/2003\/150.","Documents":""},{"Case ID":"ST-258","Case Cluster ":"Litton Industries","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Central District of California","Jurisdiction of Foreign Public Official(s) ":"Taiwan, China; Greece","Year of Settlement":"1999","Month\/Day of Settlement (or Notes)":"06\/30","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Restitution, Investigation Costs","Total Monetary Sanctions (US$)":"$18,501,600.00","Criminal Fine\/Penalty (US$) ":"$16,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$737,000","Criminal Legal \/ Procedural Costs (US$)":"$1,264,600 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Defraud the Government (Litton Applied); Conspiracy to Defraud the Government, Causing False Statement to the US, Mail Fraud (Litton Systems Canada)","Offenses - Settled":"Conspiracy to Defraud the Government (Litton Applied); Conspiracy to Defraud the Government, Causing False Statement to the US, Mail Fraud (Litton Systems Canada)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Court Docket Report, pursuant to the E-Government Act, the final judgments are not available for public viewing. (Source: US v. Litton Applied Technologies, et al, Case No. 2:99-cr-00673 (C.D. Cal.), Docket Report retrieved via Pacer on October 4, 2011). The US Department of Justice website on FCPA Enforcement Actions lists the case but no documents.  (http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/litton-applied.html). According to the Court Docket Report in US v. Litton Applied et al, Litton Applied and Litton Systems were ordered to jointly pay $18.5 million, consisting of $16.5 million in fines, restitution of $737,000, Cost of Investigation of $1,263,000 and special assessment of $1,600.   The recipient of the restitution was not expressly stated.  According to the New York Times, the two Litton Industries units had \u0022agreed to pay $18.5 million to settle allegations of having made illegal payments to obtain defense business in Greece and Taiwan. [  ] The negotiated plea ends investigations of a $150 million deal to sell radar for F-16 fighter planes to Greece and $47 million in contracts to upgrade Taiwanese military aircraft. In both cases, the company was accused of paying private consultants for help in getting business. [  ] In the Taiwan case, prosecutors accused the Litton units of paying more than $4.3 million to Richard M. Hei, a retired Taiwanese Air Force major, for using his contacts to help secure contracts. [  ] In Greece, the Applied Technology division was alleged to have paid more than $12 million to four Greek agents for help in selling the F-16 radars in 1993. [  ] In both cases the companies were accused o hiding the payments from American regulators. Federal law does not ban the use of foreign consultants, but require the disclosure of any commissions that are promised or paid.\u0022 (Source: New York Times, \u00222 Litton Units Plead Guilty To Illegal Foreign Payments,\u0022 July 1, 1999.)","Sources ":"New York Times, \u00222 Litton Units Plead Guilty To Illegal Foreign Payments,\u0022 July 1, 1999, at http:\/\/www.nytimes.com\/1999\/07\/01\/business\/2-litton-units-plead-guilty-to-illegal-foreign-payments.html; [case listed but no documents on DOJ Fraud\/FCPA website]; US v. Litton Applied Technologies, Case No. 2:99-cr-00673 (C.D. Cal.), Docket Report retrieved via Pacer on October 4, 2011; New York Times, \u00222 Litton Units Plead Guilty To Illegal Foreign Payments,\u0022 July 1, 1999, accessed at http:\/\/www.nytimes.com\/1999\/07\/01\/business\/2-litton-units-plead-guilty-to-illegal-foreign-payments.html?pagewanted=print\u0026src=pm.","Documents":""},{"Case ID":"ST-155","Case Cluster ":"Fiat S.p.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"12\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$10,809,142.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$5,309,632","Civil Prejudgment Interest (US$) ":"$1,899,510","Civil Fine \/ Penalty (US$)":"$3,600,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release (December 22, 2008), the Commission \u0022filed Foreign Corrupt Practices Act books and records and internal controls charges against Fiat S.p.A. and CNH Global N.V. in the U.S. District Court for the District of Columbia. Fiat S.p.A., an Italian company, provides automobiles, trucks and commercial vehicles. CNH Global N.V., a majority-owned subsidiary of Fiat, provides agricultural and construction equipment. The Commission\u0027s complaint alleges that from 2000 through 2003, certain Fiat and CNH Global subsidiaries made approximately $4.3 million in kickback payments in connection with their sales of humanitarian goods to Iraq under the United Nations Oil for Food Program (the \u0022Program\u0022). The kickbacks were characterized as \u0022after sales service fees\u0022 (\u0022ASSFs\u0022), but no bona fide services were performed.\u0022  (Source: US Securities and Exchange Commission Litigation Release No. 20835 (December 22, 2008), Securities and Exchange Commission v. Fiat S.p.A. and CNH Global N.V., Civil Action No. 08 CV 0221 (D.D.C.) (CKK), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Fiat S.p.A. and CNH Global N.V. For Improper Payments to Iraq Under the U.N. Oil for Food Program ? Fiat Agrees to Pay Over $10 Million in Disgorgement, Interest, and Penalties.\u0022)","Sources ":"US Securities and Exchange Commission Litigation Release No. 20835 (December 22, 2008), Securities and Exchange Commission v. Fiat S.p.A. and CNH Global N.V., Civil Action No. 08 CV 0221 (D.D.C.) (CKK), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Fiat S.p.A. and CNH Global N.V. For Improper Payments to Iraq Under the U.N. Oil for Food Program -- Fiat Agrees to Pay Over $10 Million in Disgorgement, Interest, and Penalties,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20835.htm; Complaint filed December 22, 2008, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20835.pdf","Documents":""},{"Case ID":"ST-156","Case Cluster ":"Flowserve Corporation","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Rijksrecherche (Dutch Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/16","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$408,875.00","Criminal Fine\/Penalty (US$) ":"$121,569","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$287,306","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"","Offenses - Settled":"Sanctions legislation by paying kickbacks when implementing UN Oil-for-Food Programme","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Netherlands Phase 2 Report of the OECD Anti-Bribery Working Group (December 17, 2008): \u0022As of October 2008, no foreign bribery cases had been brought before the Dutch courts. Nevertheless, the prosecution authorities have concluded out-of-court transactions with seven companies for paying kickbacks in the context of the Oil-for-Food Programme in Iraq, although the offence charged was the violation of sanctions legislation and not the foreign bribery offence.\u0022 (para 2); \u0022 the Prosecution Department reports that it has concluded financial transactions (out of court settlements) with 7 companies for violating sanction legislation by paying kickbacks when implementing the Oil for Food Programme. Criminal gains have also been confiscated. In July 2008 a press release has been issued about these settlements. Together with the names of the companies (Alfasan International B.V., N.V. Organon, Flowserve B.V. , OPW Fluid Transfer Group Europe B.V., Prodetra B.V. Solvochem Holland B.V., Stet Holland B.V.) the settlements have been made public. For the following Oil-for-food transactions out-of-court settlements have been reached: 1. Alfasan International BV Woerden, fine: \u20ac 31.800,-- and confiscation \u20ac 10.183,55 2. NV Organon Oss, fine: \u20ac 381.602 3. Flowerserve bv te Etten-Leur, fine: \u20ac 76.274 and confiscation \u20ac 180.260 4. OPW Fluid Transfer Group Europe BV, Nieuw Vennep, fine \u20ac 57.204 and confiscation \u20ac 24.600 5. Prodetra bv, Wadinxveen, fine: 64.751 and confiscation \u20ac 34.485,95 6. Solvochem Holland bv, Rotterdam, fine \u20ac 136.000 and confiscation \u20ac 144.592 7. Stet Holland bv,Emmeloord, fine \u20ac 119.712 and confiscation \u20ac 54.458.\u0022 (Source: Ibid., at 14.)","Sources ":"OECD Anti-Bribery Working Group, The Netherlands Phase 2 Report (December 17, 2008), accessed at http:\/\/www.oecd.org\/dataoecd\/61\/59\/41919004.pdf; Melissa Lipman, \u0022Cos. Settle Dutch Probe Into Oil-For-Food For ?1.3M,\u0022 Law 360, July 16, 2008, accessed at http:\/\/www.law360.com\/articles\/62486\/cos-settle-dutch-probe-into-oil-for-food-for-1-3m (partial article, gives date of Dutch Public Prosecution Service press release); see also, US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Flowserve Corporation Case Summary at 83-84, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.","Documents":""},{"Case ID":"ST-158","Case Cluster ":"Flowserve Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"02\/21","Other Jurisdictions of Settlement":"Netherlands","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$4,000,000.00","Criminal Fine\/Penalty (US$) ":"$4,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud","Offenses - Settled":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD, \u0022On February 21, 2008, the Department of Justice and the SEC simultaneously filed a criminal information and a civil complaint against Flowserve Pompes SAS (Flowserve Pompes), and its parent company, Flowserve Corporation (Flowserve), in the U.S. District Court for the District of Columbia. The information charges that Flowserve Pompes engaged in a conspiracy to commit wire fraud and to violate the books and records provisions of the FCPA in connection with a scheme to pay kickbacks to the Iraqi government under the United Nations Oil for Food Program (OFFP). The SEC\u0027s civil complaint charges Flowserve with violating the books and records and internal controls provisions of the FCPA in connection with the same underlying conduct.  According to documents filed in the criminal and civil cases, the French and Dutch subsidiaries of Flowserve [ ] paid or promised to pay approximately $820,246 from 2001 to 2003 in connection with the sale of industrial equipment to the Iraqi government. Flowserve Pompes, Flowserve\u0027s French subsidiary, concealed illegal payments to the Iraqi government totaling $604,651 through a Jordanian entity that was its exclusive agent for Iraqi contracts. These payments were made to assist Flowserve Pompes in obtaining fifteen contracts for the sale of large-scale water pumps and spare parts for use in Iraqi oil refineries. Flowserve Pompes also agreed to, but did not ultimately make, an additional $173,758 in improper payments pursuant to four additional contracts, as delivery under these four contracts had not been completed by the time of the U.S. invasion of Iraq in March 2003. Senior officials at Flowserve Pompes, including its President, allegedly developed different false cover stories to conceal these kickback payments in the company\u0027s internal accounting records.  According to the SEC\u0027s complaint, Flowserve\u0027s Dutch Subsidiary, Flowserve B.V., also entered into one contract involving an improper kickback under the OFFP. Specifically, Flowserve B.V. paid $41,836 in kickbacks to Iraqi officials in order to obtain a contract to supply water pump spare parts to the Iraqi government-owned South Gas Company.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Flowserve Corporation Case Summary at 83-84.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Flowserve Corporation Case Summary at 83-84, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; US Department of Justice Press Release, \u0022Flowserve Corporation to Pay $4 Million Penalty for Kickback Payments to the Iraqi Government under the U.N. Oil for Food Program,\u0022 February 21, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/February\/08_crm_132.html; US v. Flowserve Pompes SAS, Case No. 1:08-cr-00035-RJL (D.D.C.), Information filed February 21, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/flowserve-sas\/02-21--08flowserve-inform.pdf and Deferred Prosecution Agreement (February 21, 2008), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/flowserve-sas\/02-21-08flowserve-deferred.pdf","Documents":""},{"Case ID":"ST-160","Case Cluster ":"General Electric Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"07\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$23,478,614.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$18,397,949","Civil Prejudgment Interest (US$) ":"$4,080,665","Civil Fine \/ Penalty (US$)":"$1,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD, \u0022On July 27, 2010, the SEC filed a settled civil action against General Electric Company (\u0022GE\u0022) and two GE subsidiaries (Ionics, Inc. (currently known as GE Ionics, Inc.) and Amersham plc (currently known as GE Healthcare Ltd.)  in the U.S. District Court for the District of Columbia. The SEC\u0027s complaint charged the companies with books and records and internal controls violations in connection with bribes paid to former Iraqi government officials under the United Nations Oil for Food Program (OFFP) by two GE subsidiaries and two other subsidiaries of public companies that have since been acquired by GE. [  ] According to the SEC\u0027s Complaint, from approximately 2000 to 2003, two GE subsidiaries, Marquette-Hellige (\u0022Marquette\u0022) and OEC-Medical Systems (Europa) AG (\u0022OEC-Medical\u0022), made approximately $2.04 million in kickback payments in the form of computer equipment, medical supplies, and services to the Iraqi Ministry of Health. [  ]  Two other current GE subsidiaries, Ionics S.r.l. and Nycomed Imaging AS made approximately $1.55 million in cash kickback payments under the OFFP prior to GE\u0027s acquisition of their parent companies.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, General Electric Company Case Summary at 47-48.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, General Electric Company Case Summary at 47-48, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; US Securities and Exchange Commission Litigation Release (July 27, 2010) at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21602.htm.","Documents":""},{"Case ID":"ST-161","Case Cluster ":"Germany \/ Company P","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"06\/26","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Administrative Offences Act","Monetary Sanctions  (Types)":"Fine","Total Monetary Sanctions (US$)":"$279,040.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"$279,040","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Section 30 OWiG in conjunction with sections 334 and 335 Criminal Code","Offenses - Settled":"Section 30 OWiG in conjunction with sections 334 and 335 Criminal Code","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to the March 2011 Germany Report to the OECD, \u0022Decision of Hildesheim Regional Court of 26 June 2009 pursuant to section 30 OWiG in conjunction with sections 334 and 335CC - against Company P. specialised in cleaning pipes -- Fine of EUR 200 000 (see Annual reports 2007-2008 and 2009 Lower Saxony (a) and Germany\u0027s reply to Phase 3 questionnaires), hereinafter Case \u0022Company P\u0022 (Source: Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at footnote 49.)","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf. http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Germanyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-162","Case Cluster ":"Germany \/ Hamburg-based Shipping Company","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Administrative Offences Act","Monetary Sanctions  (Types)":"Fine","Total Monetary Sanctions (US$)":"$47,675.40","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"$47,675.40","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Section 30 OWiG in connection with sections 299 and 400 Criminal Code","Offenses - Settled":"Section 30 OWiG in connection with sections 299 and 400 Criminal Code","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to the March 2011 Germany Phase 3 Report to the OECD, \u0022iii) Decision of the Hamburg Regional Court of 17 July 2008 pursuant to section 30 OWiG in conjunction with sections 299 and 300 CC- against a Hamburg based shipping company -- Fine of EUR 30 000 (see Germany\u0027s reply to Phase 3 questionnaires and Germany\u0027s reply to Phase 3 questionnaires Hamburg bb ? decision provided only in German), hereinafter Case \u0022Hamburg based shipping Company\u0022 (Source: Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at footnote 49.)","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf. http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Germanyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-163","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf. http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Germanyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-164","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.  http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Germanyphase3reportEN.pdf","Documents":""},{"Case ID":"ST-165","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-166","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-167","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"YES","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-168","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"YES","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-169","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-170","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-171","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-172","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-173","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-174","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-175","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-176","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-177","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-178","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-179","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-180","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-181","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-182","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-183","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-184","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-185","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-186","Case Cluster ":"Germany Agreed Sanctions Cases \/ Siemens Unnamed Individual Defendants","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-187","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #25","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-188","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #26","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-189","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #27","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-190","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #28","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-191","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #29","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-192","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #30","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-193","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #31","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-194","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #32","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-195","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #33","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-196","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #34","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for exemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-197","Case Cluster ":"Germany Agreed Sanctions Cases \/ Unnamed Individual Defendant #35","Jurisdiction of Settlement":"Germany","Jurisdiction of Settlement \/ Enforcement Agency":"Unspecified","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"","Month\/Day of Settlement (or Notes)":"Between 2005 and end 2010","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Arrangement under section 153a of the Criminal Code of Procedure","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown Amount","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Unspecified","Summary":"According to Germany\u0027s March 2011 Phase 3 Report by the OECD, \u0022From 2005 to end 2010, 69 individuals were sanctioned, of which 30 were criminally convicted, 35 were sanctioned under an arrangement under section 153a of the Criminal Code of Procedure [ ] and 4 were found liable in administrative proceedings.\u0022  (Source:  Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, at para 19.)   The Report also noted that of the 35 individuals agreed to arrangements under section 153a of the Criminal Code of Procedure, 24 of which (over two thirds pertained to the Siemens case.\u0022 (Source: Ibid., at para 39.)  According to the Report, \u0022individuals sanctioned under section 153a CCP [Code of Criminal Procedure] and in administrative proceedings were only sanctioned to paying fines. The amounts of fines were, in a majority of cases, within the lower range of fines available except for a few particularly aggravated cases involving senior executives. [ ] For instance, the size of fines ranges from EUR 1800 to a record amount of EUR 2.16 million.\u0022 (Source: Ibid., at para 20.)  According to the procedure of agreements under section 153a CCP, the Report notes that, \u0022individuals may be sanctioned un the context of the conditional exemption from prosecution by the public prosecutor [ ].  The condition for expemption, which must be agreed by both the court and the individual, may consist of the payment of a sum of money to the treasury or to a non-profit organisation.\u0022  (Source: Ibid., para 98.)  ","Sources ":"Organisation for Economic Co-operation and Development, Working Group on Bribery: 2010 Data on Enforcement of the Anti-Bribery Convention, accessed at http:\/\/www.oecd.org\/dataoecd\/47\/39\/47637707.pdf; Organisation for Economic Co-operation and Development, Directorate for Financial and Enterprise Affairs, \u0022Germany: Phase 3 Report on the Application of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the 2009 Revised Recommendation on Combating Bribery in International Business Transactions,\u0022 approved and adopted by the Working Group on Bribery in International Business Transactions on 17 March 2011, accessed at http:\/\/www.oecd.org\/dataoecd\/5\/45\/47416623.pdf.","Documents":""},{"Case ID":"ST-154","Case Cluster ":"Fiat S.p.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"12\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$7,000,000","Criminal Fine\/Penalty (US$) ":"$7,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD, \u0022On December 22, 2008, three subsidiaries of Fiat S.p.A. (Fiat), an Italian corporation based in Turin, Italy, were charged in the U.S. District Court for the District of Columbia in connection with a scheme to pay bribes to Iraqi government officials in order to win contracts under the U.N. Oil-for-Food Program (OFFP). Two Fiat subsidiaries, Iveco S.p.A. (Iveco) and CNH Italia S.p.A. (CNH Italia), were each charged with one count of conspiracy to commit wire fraud and to violate the books and records provisions of the FCPA. A third subsidiary, CNH France S.A. (CNH France), was charged with one count of conspiracy to commit wire fraud. The SEC simultaneously filed a civil complaint against Fiat and CNH Global N.V., alleging that Fiat and its subsidiaries violated the books and records and internal controls provisions of the FCPA in relation to the same conduct.  These charges stemmed from a series of improper payments made by Fiat to Iraqi government officials in order to obtain contracts with Iraqi ministries to provide industrial pumps, gears, and other equipment. According to court documents, between 2000 and 2002, Iveco, CNH Italia, and CNH France paid a total of approximately $4.4 million in kickbacks (referred to as \u0022after sales service fees\u0022 (ASSFs)) to the Iraqi government by inflating the price of contracts by 10 percent before submitting the contracts to the U.N. for approval, and concealed from the U.N. the fact that the price contained a kickback to the Iraqi government. Iveco and CNH Italia also inaccurately recorded the kickback payments as commissions and service fees for its agents in its books and records.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Fiat S.p.A. Case Summary at 73-74.)  Fiat settled the charges against its subsidiaries by entering a Deferred Prosecution Agreement with the Department of Justice that required the company to pay $7 million criminal penalty.  (Source: Ibid.)  According to the Statements of Facts accompanying the Deferred Prosecution Agreement:  \u0022Company X,\u0022 a Lebanese company, acted as both an agent and distributor for Iveco in connection with sales to the Iraqi government under the OFFP; and \u0022Company Y,\u0022 a United Arab Emirates company, acted as a conduit for payments to the Iraqi government under the OFFP.  (Source: In Re Fiat S.p.A., et al, Deferred Prosecution Agreement (December 20, 2008), paras 15 and 16.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Fiat S.p.A. Case Summary at 73-74, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; In Re: Fiat S.p.A., et. al; United States v. Iveco S.p.A.; United States v. CNH Italia S.p.A.; and United States v. CNH France S.A., Deferred Prosecution Agreement (December 22, 2008), accessed at http:\/\/www.justice.gov\/opa\/documents\/fiat-dpa.pdf; US Department of Justice Press Release, \u0022Fiat Agrees to $7 Million Fine in Connection with Payment of $4.4 Million in Kickbacks by Three Subsidiaries Under the U.N. Oil for Food Program,\u0022 December 22, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/December\/08-crm-1140.html","Documents":""},{"Case ID":"ST-157","Case Cluster ":"Flowserve Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"02\/21","Other Jurisdictions of Settlement":"Netherlands","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$6,574,225.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$2,720,861","Civil Prejudgment Interest (US$) ":"$853,364","Civil Fine \/ Penalty (US$)":"$3,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, the \u0022Commission today filed Foreign Corrupt Practices Act books and records and internal controls charges against Flowserve Corporation (\u0022Flowserve\u0022) in the U.S. District Court for the District of Columbia. Flowserve is a Texas-based manufacturer of pumps, valves, seals, and related automation and services to the power, oil, gas, and chemical industries. The Commission\u0027s complaint alleges that from 2001 through 2003, two of Flowserve\u0027s subsidiaries entered into a total of twenty contracts in which $646,488 in kickback payments were made and another $173,758 were authorized in connection with sales of industrial equipment to Iraqi government entities under the U.N. Oil for Food Program (the \u0022Program\u0022). The kickbacks were characterized as \u0022after-sales service fees\u0022 (\u0022ASSFs\u0022), but no bona fide services were performed. The Program was intended to provide humanitarian relief for the Iraqi population, which faced severe hardship under international trade sanctions. The Program allowed the Iraqi government to purchase humanitarian goods through a U.N. escrow account. The kickbacks paid by Flowserve\u0027s subsidiaries diverted funds out of the escrow account and into an Iraqi slush fund. The contracts submitted to the U.N. did not disclose that the illicit payments were included in the inflated contract prices. [  ] Flowserve, without admitting or denying the allegations in the Commission\u0027s complaint, consented to the entry of a final judgment permanently enjoining it from future violations of Sections 13(b)(2)(A) and 13(b)(2)(B) of the Securities Exchange Act of 1934, ordering it to disgorge $2,720,861, in profits, plus $853,364 in pre-judgment interest, and to pay a civil penalty of $3,000,000. Flowserve will also pay a $4,000,000 fine pursuant to a deferred prosecution agreement with the U.S. Department of Justice, Fraud Section. Flowserve B.V. will enter into a criminal disposition with the Dutch Public Prosecutor pursuant to which it will pay a fine.\u0022 (Source: US Securities and Exchange Commission Litigation Release No. 20461 \/ February 21, 2008, Securities and Exchange Commission v. Flowserve Corporation, Civil Action No. 08 CV 00294 (D.D.C.) (EGS), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Flowserve Corporation For Improper Payments to Iraq Under the U.N. Oil for Food Program ? Company Agrees to Pay Over $6.5 Million in Civil Penalties, Disgorgement of Profits, and Prejudgment Interest.\u0022)","Sources ":"US Securities and Exchange Commission Litigation Release No. 20461 \/ February 21, 2008, Securities and Exchange Commission v. Flowserve Corporation, Civil Action No. 08 CV 00294 (D.D.C.) (EGS), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Flowserve Corporation For Improper Payments to Iraq Under the U.N. Oil for Food Program -- Company Agrees to Pay Over $6.5 Million in Civil Penalties, Disgorgement of Profits, and Prejudgment Interest,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20461.htm; Complaint filed February 21, 2008, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20461.pdf","Documents":""},{"Case ID":"ST-159","Case Cluster ":"Flowserve Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"02\/21","Other Jurisdictions of Settlement":"Netherlands","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$4,000,000.00","Criminal Fine\/Penalty (US$) ":"$4,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud","Offenses - Settled":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD, \u0022On February 21, 2008, the Department of Justice and the SEC simultaneously filed a criminal information and a civil complaint against Flowserve Pompes SAS (Flowserve Pompes), and its parent company, Flowserve Corporation (Flowserve), in the U.S. District Court for the District of Columbia. The information charges that Flowserve Pompes engaged in a conspiracy to commit wire fraud and to violate the books and records provisions of the FCPA in connection with a scheme to pay kickbacks to the Iraqi government under the United Nations Oil for Food Program (OFFP). The SEC\u0027s civil complaint charges Flowserve with violating the books and records and internal controls provisions of the FCPA in connection with the same underlying conduct.  According to documents filed in the criminal and civil cases, the French and Dutch subsidiaries of Flowserve [ ] paid or promised to pay approximately $820,246 from 2001 to 2003 in connection with the sale of industrial equipment to the Iraqi government. Flowserve Pompes, Flowserve\u0027s French subsidiary, concealed illegal payments to the Iraqi government totaling $604,651 through a Jordanian entity that was its exclusive agent for Iraqi contracts. These payments were made to assist Flowserve Pompes in obtaining fifteen contracts for the sale of large-scale water pumps and spare parts for use in Iraqi oil refineries. Flowserve Pompes also agreed to, but did not ultimately make, an additional $173,758 in improper payments pursuant to four additional contracts, as delivery under these four contracts had not been completed by the time of the U.S. invasion of Iraq in March 2003. Senior officials at Flowserve Pompes, including its President, allegedly developed different false cover stories to conceal these kickback payments in the company\u0027s internal accounting records.  According to the SEC\u0027s complaint, Flowserve\u0027s Dutch Subsidiary, Flowserve B.V., also entered into one contract involving an improper kickback under the OFFP. Specifically, Flowserve B.V. paid $41,836 in kickbacks to Iraqi officials in order to obtain a contract to supply water pump spare parts to the Iraqi government-owned South Gas Company.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Flowserve Corporation Case Summary at 83-84.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Flowserve Corporation Case Summary at 83-84, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; US Department of Justice Press Release, \u0022Flowserve Corporation to Pay $4 Million Penalty for Kickback Payments to the Iraqi Government under the U.N. Oil for Food Program,\u0022 February 21, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/February\/08_crm_132.html; US v. Flowserve Pompes SAS, Case No. 1:08-cr-00035-RJL (D.D.C.), Information filed February 21, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/flowserve-sas\/02-21--08flowserve-inform.pdf and Deferred Prosecution Agreement (February 21, 2008), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/flowserve-sas\/02-21-08flowserve-deferred.pdf","Documents":""},{"Case ID":"ST-198","Case Cluster ":"HealthSouth Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"04\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$500.00","Criminal Fine\/Penalty (US$) ":"$500","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"False Statements to the FBI (18 USC Section 1001)","Offenses - Settled":"False Statements to the FBI (18 USC Section 1001)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022Vincent Nico, former Vice President of HealthSouth Corporation, has been charged with wire fraud related to contracts with a hospital in Saudi Arabia.  Nico, 47, of Palm Harbor, Florida, has agreed to plead guilty to the wire fraud charge contained in a criminal information that was filed at U.S. District Court in Birmingham, Alabama. In addition, former HealthSouth Executive Vice President Thomas Carman, 52, of Birmingham, has agreed to plead guilty to a separate criminal information charging him with making a false statement to the FBI. [  ] HealthSouth was a corporation organized under the laws of the State of Delaware with its headquarters in Birmingham, Alabama. [ ] The charges against Nico and Carman stem from HealthSouth\u0027s agreement to provide staffing and management services for a 450-bed hospital in Saudi Arabia. Under HealthSouth\u0027s contract with a Saudi foundation which built and owned the hospital, HealthSouth was to receive $10 million annually over a five-year term.  According to the criminal informations, the Saudi foundation\u0027s director general solicited a $1 million payment from HealthSouth, ostensibly as a \u0022finders fee.\u0022  Against the advice of counsel, HealthSouth allegedly agreed to pay the Saudi foundation\u0027s director general the sum of $500,000 per year for a five-year period in return for his agreement to execute the contract on behalf of the Saudi foundation. In order to conceal the true nature of the scheme, HealthSouth officers, including Nico and Carman, allegedly arranged for the foundation\u0027s director general to execute a bogus consulting contract with a HealthSouth-affiliated entity in Australia. Until the scheme was detected in 2003, HealthSouth paid the amounts due under this phony consulting contract by wiring them to Australia, where they were subsequently wired to the foundation\u0027s director general in Saudi Arabia, according to the charges. The HealthSouth officers allegedly undertook this conduct despite the fact that they had been specifically advised beforehand by an attorney retained by HealthSouth that such conduct would amount to a violation of federal criminal law.  The criminal information against Nico charges that he violated his duty of honest services to HealthSouth by accepting a kickback from the foundation\u0027s director general whereby Nico received $125,000 per year from the $500,000 paid to the foundation\u0027s director general. Under this agreement, Nico received a total of $375,000 in undisclosed payments. In addition, Nico received $631,502 from HealthSouth as payment of a bonus he demanded based his claim that he had performed exemplary service for the company in securing and maintaining the contract with the Saudi foundation, and that he had not received any compensation for that service. Nico has agreed to forfeit $1,005,602, the total amount he received from the foundation\u0027s director general and as payment of the bonus from HealthSouth.  The criminal information against Carman charges that he made a false statement to the FBI when he claimed during an interview that the consulting contract with the foundation\u0027s director general was intended to be a legitimate arrangement under which real services were to be provided.\u0022 (Source:  US Department of Justice Press Release, \u0022Former HealthSouth Officers Charged in Fraud Conspiracy involving Saudi Hospitals,\u0022 March 2, 2004.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, HealthSouth Corporation Case Summary at 122-123, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Carman, Case No. 2:04-cr-00093-LSC-JEO (N.D. Ala.), Information filed March 2, 2004, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/carman\/03-02-04carman-info.pdf;  Plea Agreeement filed March 21, 2004, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/carman\/03-02-04carman-plea-agmt.pdf; Judgment dated August 3, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/carman\/08-03-05carman-judgment.pdf.  US Department of Justice Press Release, \u0022Former HealthSouth Officers Charged in Fraud Conspiracy involving Saudi Hospitals,\u0022 March 2, 2004, accessed at http:\/\/www.justice.gov\/opa\/pr\/2004\/March\/04_crm_131.htm","Documents":""},{"Case ID":"ST-199","Case Cluster ":"HealthSouth Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"04\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Forfeiture","Total Monetary Sanctions (US$)":"$1,256,502.00","Criminal Fine\/Penalty (US$) ":"$250,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$1,006,502","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Wire Fraud","Offenses - Settled":"Wire Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD, \u0022In March and July 2004, the Department of Justice filed charges against four HealthSouth executives in connection with an alleged scheme to bribe the director general of a Saudi Arabian foundation in furtherance of HealthSouth\u0027s effort to secure an agreement to provide staffing and management services for a 450-bed hospital in Saudi Arabia. Under the contract that HealthSouth eventually executed with the Saudi Arabian foundation, HealthSouth was to receive $10 million annually over a five-year term.  On July 1, 2004, the Department indicted Robert E. Thomson, President and COO of HealthSouth\u0027s in-patient division, and James C. Reilly, the Group Vice President of Legal Services for Health South, in the Northern District of Alabama. According to the indictment, the Saudi Arabian foundation\u0027s director general solicited a $1 million payment from HealthSouth, ostensibly as a \u0022finder\u0027s fee.\u0022  Against the advice of counsel, HealthSouth allegedly agreed to pay the Saudi Arabian foundation\u0027s director general the sum of $500,000 per year for a five-year period in return for his agreement to execute the contract on behalf of the Saudi Arabian foundation. In order to conceal the true nature of the scheme, HealthSouth officers, including Thomson and Reilly, allegedly arranged for the Saudi Arabian foundation\u0027s director general to execute a bogus consulting contract with a HealthSouth-affiliated entity in Australia. Until the scheme was detected in 2003, HealthSouth paid the amounts due under this phony consulting contract by wiring them to Australia, where they were subsequently wired to the foundation\u0027s director general in Saudi Arabia, according to the indictment. The HealthSouth officers allegedly undertook this conduct despite the fact that they had been specifically advised beforehand by an attorney retained by HealthSouth that such conduct would amountto a violation of federal criminal law.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, HealthSouth Corporation Case Summary at 122-123.)  According to Nico\u0027s Plea Agreement, \u0022The Defendant hereby agrees to surrender to the United States of America the sum of $1,006,502 pursuant to Title 18, United States Code. Section 981 (a)(1)(C), and Title 28, UnitedStates Code, Section 2461(e), as property constituting or derived from proceeds traceable to the violation of Title 18, United States Code, Section 1343.\u0022  (Source:  US v. Nico, Case No.  2:04-cr-00092-SLB-JEO (N.D. Ala.), Plea Agreement filed March 2, 2004.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, HealthSouth Corporation Case Summary at 122-123, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  U.S. v. Vincent Nico, Case No. 2:04-cr-00092-SLB-JEO (N.D. Ala.), Information filed Mar 2, 2004, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nico\/03-02-04nico-info.pdf; Plea Agreement filed March 2, 2004, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nico\/03-02-04nico-plea-agmt.pdf; Judgment filed June 9, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/nico\/06-09-05nico-judgment.pdf","Documents":""},{"Case ID":"ST-200","Case Cluster ":"Helmerich \u0026 Payne, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Argentina, Venezuela","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"07\/30","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,000,000.00","Criminal Fine\/Penalty (US$) ":"$1,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"$0","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"Accrording to the June 2011 Report to the OECD, \u0022On July 30, 2009 Helmerich \u0026 Payne (H\u0026P) entered into a non-prosecution agreement with the Department of Justice and the SEC initiated a settled administrative proceeding against H\u0026P. These enforcement actions stemmed from a series of improper payments by H\u0026P to government officials in Argentina and Venezuela in violation of the FCPA. [ ] The improper payments were made to officials of the Argentine and Venezuelan customs services, both government agencies, made in order to import and export goods that were not within regulations, to import goods that could not lawfully be imported, and to evade higher duties and taxes on the goods. From 2004 through 2008, H\u0026P Argentina paid Argentine customs officials approximately $166,000, which allowed it to avoid more than an estimated $186,000 in expenses it would have otherwise incurred if it had properly imported and exported the equipment and materials. In addition, from 2003 through 2008, H\u0026P Venezuela made corrupt payments to Venezuelan customs officials totaling approximately $19,673, which allowed it to avoid more than an estimated $134,000 in expenses it would have otherwise incurred if it had properly imported and exported the equipment and materials. H\u0026P and its subsidiaries then falsely, or at least misleadingly, described these improper payments in H\u0026P\u0027s books and records.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Helmerich \u0026 Payne, Inc. Case Summary at 62-63.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Helmerich \u0026 Payne, Inc. Case Summary at 62-63, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  In Re Helmerich \u0026 Payne, Inc., Nonprosecution Agreement (July 29, 2009), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/helmerich-payne\/06-29-09helmerich-agree.pdf; US Department of Justice Press Release, \u0022Helmerich \u0026 Payne Agrees to Pay $1 Million Penalty to Resolve Allegations of Foreign Bribery in South America,\u0022 July 30, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/July\/09-crm-741.html.","Documents":""},{"Case ID":"ST-201","Case Cluster ":"Helmerich \u0026 Payne, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina, Venezuela","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"07\/30","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Pre-judgment Interest","Total Monetary Sanctions (US$)":"$375,681.22","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$320,604","Civil Prejudgment Interest (US$) ":"$55,077.22","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"$0","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"Accrording to the June 2011 Report to the OECD, \u0022On July 30, 2009 Helmerich \u0026 Payne (H\u0026P) entered into a non-prosecution agreement with the Department of Justice and the SEC initiated a settled administrative proceeding against H\u0026P. These enforcement actions stemmed from a series of improper payments by H\u0026P to government officials in Argentina and Venezuela in violation of the FCPA. [ ] The improper payments were made to officials of the Argentine and Venezuelan customs services, both government agencies, made in order to import and export goods that were not within regulations, to import goods that could not lawfully be imported, and to evade higher duties and taxes on the goods. From 2004 through 2008, H\u0026P Argentina paid Argentine customs officials approximately $166,000, which allowed it to avoid more than an estimated $186,000 in expenses it would have otherwise incurred if it had properly imported and exported the equipment and materials. In addition, from 2003 through 2008, H\u0026P Venezuela made corrupt payments to Venezuelan customs officials totaling approximately $19,673, which allowed it to avoid more than an estimated $134,000 in expenses it would have otherwise incurred if it had properly imported and exported the equipment and materials. H\u0026P and its subsidiaries then falsely, or at least misleadingly, described these improper payments in H\u0026P\u0027s books and records.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Helmerich \u0026 Payne, Inc. Case Summary at 62-63.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Helmerich \u0026 Payne, Inc. Case Summary at 62-63, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; US Securities and Exchange Commission, In the Matter of Helmerich \u0026 Payne, Inc., Administrative Proceedings File No. 3-13565, Order Instituting Cease-and-Desist Proceedings, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2009\/34-60400.pdf","Documents":""},{"Case ID":"ST-203","Case Cluster ":"Immucor, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Italy","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"09\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission\u0027s Litigation Release in SEC v. Gioacchino De Chirico, on September 28, 2007, the Securities and Exchange Commission \u0022announced the filing of a settled civil action against Gioacchino De Chirico, Chief Executive Officer of Immucor, Inc., for violating Section 13(b)(5) of the Exchange Act and Rule 13b2-1, and for aiding and abetting violations of Sections 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act. The Commission\u0027s complaint, filed in the United States District Court of the Northern District of Georgia, alleges that in April 2004, Immucor paid \u20ac13,500 (Euros) [US$16,119] to the director of a public hospital in Milan, Italy as a quid pro quo for the hospital director favoring Immucor in selecting contracts for supplies and equipment. The complaint further alleges that De Chirico approved an invoice that falsely described the \u20ac13,500 payment as a consulting fee for services in connection with opportunities in Switzerland -- work De Chirico knew the hospital director had never performed.With the filing of the Commission\u0027s action, De Chirico has agreed, without admitting or denying the allegations in the Commission\u0027s complaint, to the entry of a final judgment ordering him to pay a civil penalty of $30,000. Separately, Immucor and De Chirico consented to a Commission cease-and-desist order related to the same events, without admitting or denying the Commission\u0027s findings. (Exchange Act Release No. 56558).\u0022 (Source: SEC Litigation Release No. 20316, SEC v. Giaocchino De Chirico, Case No. 1:07-cv-2367 (N.D. Ga., September 28, 2007)  The SEC had alleged that the payment request had been submitted by Immucor\u0027s local sales agent who asked that it be paid to a Swiss bank account for the benefit of the hospital director (para 5); in accordance with the sales agent\u0027s earlier agreement with the hospital director\u0027s request to assist him in avoiding Italian taxes, De Chirico authorized that the EUR 13,500 payment be made through Immucor\u0027s German subsidiary, Immucor Medizinische Diagnostik GmbH. (para 6) (Source:  In the Matter of Immucor, Inc. and Gioacchino de Chirico, Order Instituting Cease and Desist Proceedings, Administrative Proceeding File No. 3-12846.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Immucor, Inc. Case Summary at 94-95, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  SEC v. Gioacchino De Chirico, Case No. 1:07-cv-2367 (N.D. GA), Complaint filed September 28, 2007, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2007\/comp20316.pdf; US Securities and Exchange Commission Litigation Release No. 20316, SEC v. De Chirico, http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20316.htm; In Re: Immucor, Inc. and Gioacchino De Chirico, Order Instituting Cease and Desist Proceedings (September 27, 2007), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2007\/34-56558.pdf.","Documents":""},{"Case ID":"ST-204","Case Cluster ":"Immucor, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Italy","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"09\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$30,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$30,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"False accounting violations, Aiding and abetting internal controls violations, Aiding and abetting falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission\u0027s Litigation Release in SEC v. Gioacchino De Chirico, on September 28, 2007, the Securities and Exchange Commission \u0022announced the filing of a settled civil action against Gioacchino De Chirico, Chief Executive Officer of Immucor, Inc., for violating Section 13(b)(5) of the Exchange Act and Rule 13b2-1, and for aiding and abetting violations of Sections 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act. The Commission\u0027s complaint, filed in the United States District Court of the Northern District of Georgia, alleges that in April 2004, Immucor paid \u20ac13,500 (Euros) [US$16,119] to the director of a public hospital in Milan, Italy as a quid pro quo for the hospital director favoring Immucor in selecting contracts for supplies and equipment. The complaint further alleges that De Chirico approved an invoice that falsely described the \u20ac13,500 payment as a consulting fee for services in connection with opportunities in Switzerland -- work De Chirico knew the hospital director had never performed.With the filing of the Commission\u0027s action, De Chirico has agreed, without admitting or denying the allegations in the Commission\u0027s complaint, to the entry of a final judgment ordering him to pay a civil penalty of $30,000. Separately, Immucor and De Chirico consented to a Commission cease-and-desist order related to the same events, without admitting or denying the Commission\u0027s findings. (Exchange Act Release No. 56558).\u0022 (Source: SEC Litigation Release No. 20316, SEC v. Giaocchino De Chirico, Case No. 1:07-cv-2367 (N.D. Ga., September 28, 2007)  The SEC had alleged that the payment request had been submitted by Immucor\u0027s local sales agent who asked that it be paid to a Swiss bank account for the benefit of the hospital director (para 5); in accordance with the sales agent\u0027s earlier agreement with the hospital director\u0027s request to assist him in avoiding Italian taxes, De Chirico authorized that the EUR 13,500 payment be made through Immucor\u0027s German subsidiary, Immucor Medizinische Diagnostik GmbH. (para 6) (Source:  In the Matter of Immucor, Inc. and Gioacchino de Chirico, Order Instituting Cease and Desist Proceedings, Administrative Proceeding File No. 3-12846.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Immucor, Inc. Case Summary at 94-95, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  SEC v. Gioacchino De Chirico, Case No. 1:07-cv-2367 (N.D. GA), Complaint filed September 28, 2007, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2007\/comp20316.pdf; US Securities and Exchange Commission Litigation Release No. 20316, SEC v. De Chirico, http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20316.htm; SEC Release No. 56558, In Re: Immucor, Inc. and Gioacchino De Chirico, Cease and Desist Order (September 27, 2007), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2007\/34-56558.pdf.","Documents":""},{"Case ID":"ST-206","Case Cluster ":"Ingersoll - Rand Company Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"10\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$4,220,987.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,710,034","Civil Prejudgment Interest (US$) ":"$560,953","Civil Fine \/ Penalty (US$)":"$1,950,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, on October 31, 2007, the Commission \u0022filed Foreign Corrupt Practices Act books and records and internal controls charges against Ingersoll-Rand Company Ltd., a New Jersey-based industrial equipment company, in the U.S. District Court for the District of Columbia. The Commission\u0027s complaint alleges that from 2000 through 2003, four of Ingersoll-Rand\u0027s subsidiaries entered into contracts in which $963,148 in kickback payments were made and $544,697 in additional payments were authorized in connection with sales of humanitarian goods to Iraq under the U.N. Oil for Food Program (the \u0022Program\u0022). The kickbacks were characterized as \u0022after-sales service fees\u0022 (\u0022ASSFs\u0022), but no bona fide services were performed. The Program was intended to provide humanitarian relief for the Iraqi population, which faced severe hardship under international trade sanctions. It allowed the Iraqi government to purchase humanitarian goods through a U.N. escrow account. The kickbacks paid by Ingersoll-Rand\u0027s subsidiaries and third parties diverted funds out of the escrow account and into an Iraqi slush fund. The contracts submitted to the U.N. did not disclose that the illicit payments were included in the inflated contract prices. The complaint also alleges that $8,000 in \u0022pocket money\u0022 and travel expenses were paid to Iraqi government officials in connection with a trip to Italy.\u0022  (Source: US Securities and Exchange Commission, Litigation Release No. 20353 \/ October 31, 2007, Securities and Exchange Commission v. Ingersoll-Rand Company Ltd., Civil Action No. 107- CV- 01955 (D.D.C.) (JDB), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Ingersoll-Rand Company Ltd. For Improper Payments to Iraq Under the U.N. Oil for Food Program - - Company Agrees to Pay Over $4.2 Million and to Make Certain Undertakings Regarding its Foreign Corrupt Practices Act Compliance Program.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Ingersoll-Rand Company Limited  Case Summary at 92-93, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 20353 \/ October 31, 2007, Securities and Exchange Commission v. Ingersoll-Rand Company Ltd., Civil Action No. 107- CV- 01955 (D.D.C.) (JDB), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Ingersoll-Rand Company Ltd. For Improper Payments to Iraq Under the U.N. Oil for Food Program - - Company Agrees to Pay Over $4.2 Million and to Make Certain Undertakings Regarding its Foreign Corrupt Practices Act Compliance Program,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20353.htm","Documents":""},{"Case ID":"ST-205","Case Cluster ":"Ingersoll - Rand Company Limited","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"10\/31","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,500,000.00","Criminal Fine\/Penalty (US$) ":"$2,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to falsify books and records","Offenses - Settled":"Conspiracy to falsify books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On October 31, 2007, the Department of Justice filed criminal charges against two subsidiaries of Ingersoll-Rand Company Limited (Ingersoll-Rand), in connection with payments made by these and other subsidiaries to obtain contracts administered by the United Nations Oil for Food Program (OFFP). On the same day, the SEC filed a settled civil complaint against Ingersoll-Rand, charging it with violations of the internal controls and books and records provisions of the FCPA arising out of the same underlying conduct.According to court documents, between October 2000 and August 2003, employees of three subsidiaries, one unnamed, Ingersoll-Rand Italiana, and Thermo King Ireland Limited, made $963,148 in kickback payments to the Iraqi government, and promised an additional $544,697, in exchange for contracts to provide road construction equipment, air compressors and parts, and refrigerated trucks under the OFFP. In order to both pay for and conceal these kickbacks, the subsidiaries inflated the price of contracts by approximately 10 percent before submitting them to the U.N. for approval. The subsidiaries never revealed to the U.N. the fact that the contract prices contained a kickback to the Iraqi government.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Ingersoll-Rand Company Limited Case Summary at 92-93.)  Ingersoll-Rand, on behalf of itself and its subsidiaries, entered into Deferred Prosecution Agreement with the Department of Justice and agreed to pay a criminal fine of $2.5 million.  (Source: US v. Ingersoll-Rand Italiana SpA, Case No. 1:07-cr-00296-RJL (D.D.C.), Deferred Prosecution Agreement filed November 14, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/ingerand-italiana\/11-17-07ingersollrand-def-agree.pdf.","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Ingersoll-Rand Company Limited Case Summary at 92-93, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Thermo-King Ireland Limited, Case No. 1:07-cr-00296-RJL (D.D.C.), Notice of Filing of Deferred Prosecution Agreement (as to Ingersoll-Rand Company Limited), filed November 14, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/thermoking-ireland\/11-14-07thermo-king-ingersoll-dpa.pdf; Attachment A: Statement of Offenses, filed November 14, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/ingerand-italiana\/10-30-07ingersollrand-statement.pdf","Documents":""},{"Case ID":"ST-103","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$7,265,080.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$5,981,693","Civil Prejudgment Interest (US$) ":"$1,283,387","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission Litigation Release, the Commission \u0022filed a settled enforcement action on November 4, 2010, in the U.S. District Court for the District of Columbia charging Transocean Inc. (\u0022Transocean\u0022), an international provider of offshore drilling services and equipment to oil companies throughout the world, with violations of the anti-bribery, books and records, and internal controls provisions of the Foreign Corrupt Practices Act (\u0022FCPA\u0022). Transocean has agreed to pay disgorgement, interest, and a civil penalty totaling $7,265,080 to settle the charges.  The SEC\u0027s complaint alleges that: From at least 2002 through 2007, Transocean made illicit payments through its customs agents to Nigerian government officials to extend the temporary importation status of its drilling rigs, to obtain false paperwork associated with its drilling rigs, and obtain inward clearance authorizations for its rigs and a bond registration. In addition, Transocean made illicit payments through Panalpina World Transport Holding Ltd.\u0027s Pancourier express courier service to Nigerian government officials to expedite the import of various goods, equipment and materials into Nigeria. In most instances, customs duties for these items were not paid by either Panalpina or Transocean. Transocean also made illicit payments through Panalpina to Nigerian government officials to expedite the delivery of medicine and other materials into Nigeria. Transocean\u0027s total gains from the conduct were approximately $5,981,693.\u0022  (Source:  US Securities and Exchange Commission, Litigation Release No. 21725 \/ November 4, 2010, Securities \u0026 Exchange Commission v. Transocean Inc., Civil Action No. 1:10-CV-01891 (JDB) (D.D.C.), \u0022SEC Charges Transocean for Bribery Scheme in Nigeria - Transocean to Pay Disgorgement and Civil Penalties of $7,265,080.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21725 \/ November 4, 2010, Securities \u0026 Exchange Commission v. Transocean Inc., Civil Action No. 1:10-CV-01891 (JDB) (D.D.C.), \u0022SEC Charges Transocean for Bribery Scheme in Nigeria - Transocean to Pay Disgorgement and Civil Penalties of $7,265,080,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21725.htm; Complaint filed November 4, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21725.pdf","Documents":""},{"Case ID":"ST-104","Case Cluster ":"Bribery of a Senior Iraqi Police Official","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"08\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign official ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Bribery of a Senior Iraqi Police Official, at 105: Salam admitted that in January 2006, while working as a civilian translator for a U.S. army subcontractor, he offered a senior Iraqi police official $60,000 in exchange for the official\u0027s assistance via official use of his position with the Iraqi police force to coordinate the purchase of 1,000 armored vests and a sophisticated map printer for approximately $1 million by the multinational Civilian Police Assistance Training Team (CPATT), an organization designed to train the Iraqi police and border guard in Iraq.  Salam admiited that he later made final arangements with an undercover agent of the Office of the Special Inspector General for Iraq Reconstruction who was posing as a procurement officer for CPATT, that he offered a separate $28,000 to $35,000 \u0022gift\u0022 to the agent to process the contracts.  Salam pleaded guilty on August 4, 2006 and was sentenced on February 2, 2007 to 36 months\u0027 imprisonment, 24 months\u0027 supervised release and 250 hours\u0027 community service.  According to the Complaint in the case, Mr. Salam is a US citizen. (Sources: US v. Faheem Mousa Salam, Case No. 1:06-cr-00157-RJL (D.D.C.), Complaint filed June 7, 2006 and Judgment in a Criminal Case filed February 7, 2007.)","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Bribery of a Senior Iraqi Police Official, at 105, accessed at http:\/\/www.justice.gov\/opa\/pr\/2006\/August\/06_crm_500.html; US v. Faheem Mousa Salam, Case No. 1:06-cr-00157-RJL (D.D.C.), Complaint fileed June 7, 2006 and Judgment in a Criminal Case filed February 7, 2007.","Documents":""},{"Case ID":"ST-105","Case Cluster ":"Bribery of and by World Bank Officials","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice ","Jurisdiction of Foreign Public Official(s) ":"Kenya, Ethiopia, World Bank","Year of Settlement":"2002","Month\/Day of Settlement (or Notes)":"02\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Restitution","Total Monetary Sanctions (US$)":"$133,000.00","Criminal Fine\/Penalty (US$) ":"$6,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$127,000","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$127,000","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Former Employer (World Bank)","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to commit wire fraud, Bribery of foreign officials","Offenses - Settled":"Conspiracy to commit wire fraud, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD, \u0022In 2002, the Department of Justice charged two World Bank officials, Ramendra Basu, a national of India, and Gautam Sengupta, with conspiring to steer World Bank contracts to certain consultants in exchange for kickbacks. According to court documents, the two defendants conspired with a Swedish consultant and others to use their official positions with the World Bank to steer World Bank contracts in Ethiopia and Kenya to certain Swedish companies in exchange for approximately $127,000 in kickbacks. In addition, the defendants admitted that in January 1999, they received a request for a $50,000 bribe from a Kenyan government official working on a Project Implementation Unit involved in a World Bank-financed project, which was to be paid by the Swedish consultant. Collectively, Basu and Sengupta forwarded this request to the Swedish consultant and passed along related bank account information, despite knowing that the payment was meant to corruptly influence an act or decision of the foreign official in his official capacity, in violation of the anti-bribery provisions of the FCPA. [  ]  Sengupta pleaded guilty on February 13, 2002, and was sentenced in 2006, Sengupta to two months\u0027 imprisonment and one year of supervised release, which was to include four months of home confinement. Sengupta was also sentenced to pay a criminal fine of $3,000.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of and by World Bank Officials Case Summary, at 125-126.)  According to Mr. Sengupta\u0027s Plea Agreement, \u0022III. RESTITUTION \/ 5. Pursuant to 18 U.S.C. \u00a7 3663 (a)(3), the defendant and the government agree that the amount of loss in this case is $127,000 and the defendant agrees to pay full restitution of this amount for all damage that resulted from his violations of the statutes listed in Section I herein. The United States and the Defendant agree that the Defendant has made such restitution, and The World Bank, Mr. Sengupta\u0027s former employer, has represented to the Department of Justice that it has no further claim against the defendant.\u0022 (Source: US v. Gautam Sengupta, Case No. 1:02-cr-040-RWR (D.D.C.), Plea Agreement filed January 30, 2002.)  According to the Judgment, Mr. Sengupta was ordered to pay $6,000 in criminal fines. (Source: US v. Gautam Sengupta, Case No. 1:02-cr-040-RWR (D.D.C.), Judgment filed in a criminal case, February 15, 2006.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of and by World Bank Officials Case Summary, at 125-126, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Department of Justice Press Release, \u0022Former World Bank Employee Sentenced for Taking Kickbacks and Assisting in the Bribery of a Foreign Official,\u0022 April 25, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/April\/08-crm-341.html; US v. Gautam Sengupta, Case No. 1:02-cr-040-RWR (D.D.C.), Plea Agreement filed January 30, 2002, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/sengupta\/01-30-02sengupta-plea-agree.pdf; Judgment filed February 15, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/sengupta\/02-15-06sengupta-judgment.pdf.","Documents":""},{"Case ID":"ST-106","Case Cluster ":"Bribery of and by World Bank Officials","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Kenya, Ethiopia, World Bank","Year of Settlement":"2002","Month\/Day of Settlement (or Notes)":"12\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to commit wire fraud, Bribery of foreign officials","Offenses - Settled":"Conspiracy to commit wire fraud, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD, \u0022In 2002, the Department of Justice charged two World Bank officials, Ramendra Basu, a national of India, and Gautam Sengupta, with conspiring to steer World Bank contracts to certain consultants in exchange for kickbacks. According to court documents, the two defendants conspired with a Swedish consultant and others to use their official positions with the World Bank to steer World Bank contracts in Ethiopia and Kenya to certain Swedish companies in exchange for approximately $127,000 in kickbacks. In addition, the defendants admitted that in January 1999, they received a request for a $50,000 bribe from a Kenyan government official working on a Project Implementation Unit involved in a World Bank-financed project, which was to be paid by the Swedish consultant. Collectively, Basu and Sengupta forwarded this request to the Swedish consultant and passed along related bank account information, despite knowing that the payment was meant to corruptly influence an act or decision of the foreign official in his official capacity, in violation of the anti-bribery provisions of the FCPA.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of and by World Bank Officials Case Summary, at 125-126.)  According to the Judgment in Mr. Basu\u0027s case, no monetary penalty was assessed. (Source: US v. Ramendra Basu, Case No. 1:02-cr-00475-RWR (D.D.C.), Judgment in a criminal case, filed May 30, 2008.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of and by World Bank Officials Case Summary, at 125-126, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Ramendra Basu, Case No. 1:02-cr-00475-RWR (D.D.C.), Judgment in a criminal case, filed May 30, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/basu\/05-03-08basu-judgment.pdf","Documents":""},{"Case ID":"ST-107","Case Cluster ":"Bribery of Liberian Officials for False Accreditation of Academic Institutions","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Liberia","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"03\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to commit wire and mail fraud, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to commit wire and mail fraud, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"No (Education License)","Summary":"According to the June 2011 United States Report to the OECD, \u0022In a superseding information filed on March 20, 2006, Richard John Novak was charged with one count of bribery in violation of the FCPA and an additional count of conspiracy to bribe foreign officials, to commit mail fraud, and to commit wire fraud. These charges stemmed from a series of bribe payments, in excess of $43,000, which were made to several Liberian officials in order to obtain accreditation from Liberia for Saint Regis University, Robertstown University, and James Monroe University, and to induce Liberian officials to issue letters and other documents to third parties falsely representing that Saint Regis University was properly accredited by Liberia. These \u0022online universities\u0022 were in fact part of an online \u0022diploma mill scheme,\u0022 and they provided no legitimate educational services and had no legitimate academic accreditation. According to court documents, between October 2002 and September 2004, approximately $19,200 was wired from an account in the State of Washington controlled by Novak\u0027s co-defendants, Dixie Ellen Randock and Steven Karl Randock, Sr., to a bank account in Maryland in the name of the Liberian Consul. These corrupt payments benefited officials of the Liberian Embassy in Washington, D.C., the Director of National Commission of Higher Education of Liberia, and the Director General of Higher Education of Liberia.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Liberian Officials for False Accreditation of Academic Institutions Case Summary at 119-120.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Liberian Officials for False Accreditation of Academic Institutions Case Summary at 119-120,  accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Richard John Novak, Case No. 2:05-cr-180-LRJ (E.D. Wash.), Superseding Indictment filed March 20, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/novakr\/03-20-06novak-supersede-info.pdf; Plea Agreement filed March 20, 2006, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/novakr\/03-20-06novak-plea-agree.pdf; Judgment in a Criminal Case, October 2, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/novakr\/10-02-08novak-judgment.pdf.","Documents":""},{"Case ID":"ST-108","Case Cluster ":"Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Haiti","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"05\/15","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$36,375.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$36,375","Criminal Restitution \/ Reparation (US$)":"$0","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Conspiracy to Commit Money Laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 4, 2009, two former executives of a Florida-based telecommunications company, the president of a Florida-based intermediary company, and two former Haitian government officials were charged in an indictment for their alleged roles in a foreign bribery, wire fraud, and money laundering scheme that lasted from at least November 2001 through March 2005. Joel Esquenazi, the former president of the telecommunications company; Carlos Rodriguez, the former executive vice-president of the telecommunications company; Marguerite Grandison, the former president of Telecom Consulting Services Corp.; Robert Antoine, a former director of international relations at the Republic of Haiti\u0027s state-owned national telecommunications company, Telecommunications D\u0027Haiti (Haiti Teleco); and Jean Rene Duperval, another former director of international relations at Haiti Teleco, were charged in connection with a scheme whereby the telecommunications company paid more than $800,000 to shell companies, including Grandison\u0027s Telecom Consulting Services Corp., to be used for bribes to foreign officials of Haiti Teleco. The purpose of these bribes was to obtain various business advantages from the Haitian officials for the telecommunications company, including issuing preferred telecommunications rates, reducing the number of minutes for which payment was owed, and giving a variety of credits toward owed sums, as well as to defraud the Republic of Haiti of revenue.Previously, on April 22, 2009, Juan Diaz, the president of J.D. Locator Services Inc., a Florida-based intermediary, and Antonio Perez, the former controller of the Florida-based telecommunications company, were charged in connection with their roles in the alleged foreign bribery scheme. According to court documents, from 1998 to 2003, Diaz and Perez conspired to make \u0022side payments\u0022 totaling $1 million to the Haitian government officials through a shell company belonging to Diaz, all on behalf of the Florida-based telecommunications company.On February 1, 2010, Jean Fourcand, the president of Fourcand Enterprises, Inc., another intermediary company, was charged in a one-count criminal information with engaging in monetary transactions involving property derived from the scheme to bribe the former Haitian government officials. Specifically, between November 2001 and August 2002, Fourcand received funds originating from this and other U.S. telecommunications companies for the benefit of Robert Antoine. A portion of these funds came in the form of a check from J.D. Locator Services Inc., and a portion of these funds were used to engage in a real estate transaction that benefitted Antoine.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco) Case Summary at 51-52.)   ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco) Case Summary at 51-52, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Perez, Case No. 1:09-cr-20347-JEM (S.D. Fla.), Information filed April 22, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pereza\/04-22-09perez-info.pdf; Plea Agreement filed April 27, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pereza\/04-27-09perez-plea-agree.pdf; Factual Agreement filed April 27, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pereza\/04-27-08perez-fact-agree.pdf.  ","Documents":""},{"Case ID":"ST-109","Case Cluster ":"Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Haiti","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"02\/19","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture, Criminal Restitution","Total Monetary Sanctions (US$)":"$18,500.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$18,500","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Money Laundering","Offenses - Settled":"Money Laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 4, 2009, two former executives of a Florida-based telecommunications company, the president of a Florida-based intermediary company, and two former Haitian government officials were charged in an indictment for their alleged roles in a foreign bribery, wire fraud, and money laundering scheme that lasted from at least November 2001 through March 2005. Joel Esquenazi, the former president of the telecommunications company; Carlos Rodriguez, the former executive vice-president of the telecommunications company; Marguerite Grandison, the former president of Telecom Consulting Services Corp.; Robert Antoine, a former director of international relations at the Republic of Haiti?s state-owned national telecommunications company, Telecommunications D\u0027Haiti (Haiti Teleco); and Jean Rene Duperval, another former director of international relations at Haiti Teleco, were charged in connection with a scheme whereby the telecommunications company paid more than $800,000 to shell companies, including Grandison\u0027s Telecom Consulting Services Corp., to be used for bribes to foreign officials of Haiti Teleco. The purpose of these bribes was to obtain various business advantages from the Haitian officials for the telecommunications company, including issuing preferred telecommunications rates, reducing the number of minutes for which payment was owed, and giving a variety of credits toward owed sums, as well as to defraud the Republic of Haiti of revenue.Previously, on April 22, 2009, Juan Diaz, the president of J.D. Locator Services Inc., a Florida-based intermediary, and Antonio Perez, the former controller of the Florida-based telecommunications company, were charged in connection with their roles in the alleged foreign bribery scheme. According to court documents, from 1998 to 2003, Diaz and Perez conspired to make \u0022side payments\u0022 totaling $1 million to the Haitian government officials through a shell company belonging to Diaz, all on behalf of the Florida-based telecommunications company.On February 1, 2010, Jean Fourcand, the president of Fourcand Enterprises, Inc., another intermediary company, was charged in a one-count criminal information with engaging in monetary transactions involving property derived from the scheme to bribe the former Haitian government officials. Specifically, between November 2001 and August 2002, Fourcand received funds originating from this and other U.S. telecommunications companies for the benefit of Robert Antoine. A portion of these funds came in the form of a check from J.D. Locator Services Inc., and a portion of these funds were used to engage in a real estate transaction that benefitted Antoine.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco) Case Summary at 51-52.)   According to the Amended Judgment in US v. Esquenazi, Esquenazi, Rodriguez, Perez, Fourcand and Antoine were ordered joint and severally liable for $2.2 million in restitution.  (Source: US v. Esquenazi, Case No. 1:09-cr-20210-JEM (S.D. Fla.), Amended Judgment filed November 3, 2011, accessed via Pacer.)  Esquenazi and Rodriguez were sentenced following their convictions; hence there is no entry on their cases and the restitution sum is noted only in the Perez entry as to avoid double counting of the sum. ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco) Case Summary at 51-52, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; US v. Jean Fourcand, Case No. 1:10-cr-20062-JEM (S.D. Fla.), Information filed February 1, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/fourcandj\/02-01-10fourcand-info.pdf; Plea Agreement filed February 19, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/fourcandj\/02-19-10fourcand-plea-agree.pdf; Factual Agreement filed February 19, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/fourcandj\/02-19-10fourcand-agree.pdf; Judgment filed May 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/fourcandj\/05-06-10fourcand-judgment.pdf","Documents":""},{"Case ID":"ST-111","Case Cluster ":"Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Haiti","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"02\/08","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$955,596.69","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$955,596.69","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Commit Money Laundering","Offenses - Settled":"Conspiracy to Commit  Money Laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"In July 2012, as part of his February 8, 2012 plea agreement filed in US v. Patrick Joseph, Mr. Joseph, was sentenced on one one count conspiracy to commit money laundering and forfeited $955,596.69 in criminal proceeds.  (Source: US v. Joseph, Case No. 1:09-cr-21010-JEM (S.D. Fla.), Plea Agreement filed February 8, 2012; Order of Forfeiture filed on July 6, 2012 and Judgment filed July 10, 2012.)  According to the Superseding Indictment in the same case, Mr. Joseph had been the Director General of Haiti Teleco from 2001-2003, and had allegedly conspired with others to conceal bribery proceeds.  (Source: US v. Cruz, et al, Case No. 1:09-cr-21010-JEM (S.D. Fla.), Superseding Indictment filed July 13, 2011.)","Sources ":"US v. Joseph, Case No. 1:09-cr-21010-JEM (S.D. Fla.), Plea Agreement filed February 8, 2012, accessed at http:\/\/www.fcpablog.com\/blog\/2012\/2\/9\/haiti-telco-official-pleads-guilty.html; Order of Forfeiture filed on July 6, 2012 and Judgment filed July 10, 2012 oth accessed via PACER; US v. Cruz, et al, Case No. 1:09-cr-21010-JEM (S.D. Fla.), Superseding Indictment filed July 13, 2011, accessed via PACER.","Documents":""},{"Case ID":"ST-112","Case Cluster ":"Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Haiti","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/12","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture, Criminal Restitution","Total Monetary Sanctions (US$)":"$3,432,980.39","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$1,580,771","Criminal Restitution \/ Reparation (US$)":"$1,852,209","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution ordered but recipient unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Commit Money Laundering","Offenses - Settled":"Conspiracy to Commit Money Laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On December 4, 2009, two former executives of a Florida-based telecommunications company, the president of a Florida-based intermediary company, and two former Haitian government officials were charged in an indictment for their alleged roles in a foreign bribery, wire fraud, and money laundering scheme that lasted from at least November 2001 through March 2005. Joel Esquenazi, the former president of the telecommunications company; Carlos Rodriguez, the former executive vice-president of the telecommunications company; Marguerite Grandison, the former president of Telecom Consulting Services Corp.; Robert Antoine, a former director of international relations at the Republic of Haiti\u0027s state-owned national telecommunications company, Telecommunications D\u0027Haiti (Haiti Teleco); and Jean Rene Duperval, another former director of international relations at Haiti Teleco, were charged in connection with a scheme whereby the telecommunications company paid more than $800,000 to shell companies, including Grandison\u0027s Telecom Consulting Services Corp., to be used for bribes to foreign officials of Haiti Teleco. The purpose of these bribes was to obtain various business advantages from the Haitian officials for the telecommunications company, including issuing preferred telecommunications rates, reducing the number of minutes for which payment was owed, and giving a variety of credits toward owed sums, as well as to defraud the Republic of Haiti of revenue.Previously, on April 22, 2009, Juan Diaz, the president of J.D. Locator Services Inc., a Florida-based intermediary, and Antonio Perez, the former controller of the Florida-based telecommunications company, were charged in connection with their roles in the alleged foreign bribery scheme. According to court documents, from 1998 to 2003, Diaz and Perez conspired to make \u0022side payments\u0022 totaling $1 million to the Haitian government officials through a shell company belonging to Diaz, all on behalf of the Florida-based telecommunications company.On February 1, 2010, Jean Fourcand, the president of Fourcand Enterprises, Inc., another intermediary company, was charged in a one-count criminal information with engaging in monetary transactions involving property derived from the scheme to bribe the former Haitian government officials. Specifically, between November 2001 and August 2002, Fourcand received funds originating from this and other U.S. telecommunications companies for the benefit of Robert Antoine. A portion of these funds came in the form of a check from J.D. Locator Services Inc., and a portion of these funds were used to engage in a real estate transaction that benefitted Antoine.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco) Case Summary at 51-52.)   According to the Amended Judgment in US v. Esquenazi, Esquenazi, Rodriguez, Perez, Fourcand and Antoine were ordered joint and severally liable for $2.2 million in restitution.  (Source: US v. Esquenazi, Case No. 1:09-cr-20210-JEM (S.D. Fla.), Amended Judgment filed November 3, 2011, accessed via Pacer.)  Esquenazi and Rodriguez were sentenced following their convictions; hence there is no entry on their cases and the restitution sum is noted only in the Perez entry as to avoid double counting of the sum. ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bribery of Officials at Telecommunications D\u0027Haiti (Haiti Teleco) Case Summary at 51-52, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf;  US v. Esquenazi et al (including Robert Antoine), Case No. 1:09-cr-21010-MGC (S.D. Fla.), Indictment filed December 8, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/esquenazij\/12-08-09esquenazi-indict.pdf; Plea Agreement filed March 12, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/antione\/03-12-10antoine-plea.pdf;  Factual Agreement filed March 12, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/antione\/03-12-10antoine-agree.pdf; Judgment filed June 10, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/antione\/06-01-10antoine-judgment.pdf.  US Department of Justice Press Release, \u0022Former Haitian Government Official Sentenced to Prison for His Role in Money Laundering Conspiracy Related to Foreign Bribery Scheme,\u0022 June 2, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/June\/10-crm-639.html","Documents":""},{"Case ID":"ST-113","Case Cluster ":"Bristow Group, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria ","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"09\/26","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"No (Tax) ","Summary":"According to the June 2011 US Report to the OECD on the Enforcement of the Anti-Bribery Convention, \u0022On September 26, 2007, the SEC instituted administrative proceedings against Bristow Group Inc., [ ]  for violations of the FCPA. The SEC\u0027s administrative order alleged that Bristow violated the anti-bribery, internal controls, and books and records provisions of the FCPA as a consequence of the actions of two of its subsidiaries in Nigeria.  According to the SEC\u0027s administrative filing, since at least 2003 and through approximately the end of 2004, Bristow Group\u0027s Nigerian affiliate, Pan African Airlines Nigeria Ltd. (PAAN), made improper payments totaling $423,000 to employees of the governments of two Nigerian states to influence them to improperly reduce the amount of expatriate employment taxes payable by PAAN to the respective Nigerian state governments. At the end of each year, PAAN was subject to an expatriate \u0022Pay As You Earn\u0022 (PAYE) tax, which was assessed on the salaries of PAAN employees by the government of each Nigerian state where PAAN operated. PAAN then negotiated with government tax officials to lower the amount assessed. In each instance, the PAYE tax demand amount was lowered and a separate cash payment for the tax officials was negotiated. Once PAAN paid the state government and the tax officials, each state government provided PAAN with a receipt reflecting only the amount payable to the state government. All together, PAAN secured an $854,000 reduction in its PAYE tax liability in exchange for these improper payments.\r\nDuring that same time period, Bristow Group underreported PAAN and another Bristow Group Nigerian affiliate\u0027s payroll expenses to certain Nigerian state governments. As a result, Bristow Group\u0027s periodic reports filed with the SEC did not accurately reflect certain of the company\u0027s payroll-related expenses. Accordingly, the SEC\u0027s administrative order found that during this time period, Bristow Group had both lacked sufficient internal accounting controls and mischaracterized the payments as legitimate payroll expenses on its books and records.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bristow Group Inc.Case,  at 96-97.)  According to the SEC Administrative Proceedings file, Bristow settled the charges by consenting to a cease and desist order; no monetary penalty was ordered. (Source: Securities and Exchange Commission, Administrative Proceeding File No. 3-12833, In the Matter of Bristow Group Inc., September 26, 2007, Order Instituting Cease and Desist Proceedings)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bristol Group Inc. Case Summary, at 96-97, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; Securities and Exchange Commission, Administrative Proceeding File No. 3-12833, In the Matter of Bristow Group Inc., September 26, 2007, Order Instituting Cease and Desist Proceedings, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2007\/34-56533.pdf","Documents":""},{"Case ID":"ST-115","Case Cluster ":"CBRN Ltd.","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Crown Prosecution Service","Jurisdiction of Foreign Public Official(s) ":"Uganda","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"08\/23","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea  ","Monetary Sanctions  (Types)":"Unknown if ordered","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown   ","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unknown","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Section 1 of the Prevention of Corruption Act 1906 (bribery)","Offenses - Settled":"Section 1 of the Prevention of Corruption Act 1906 (bribery)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the United Kingdom\u0027s August 2011 Report to the OECD, \u0022City of London Police - Guilty plea to bribery sets legal landmark \/ The first UK prosecution of a foreign bribery offence was heard in August 2008. The Managing Director of a UK-based company was found guilty of making corrupt payments to foreign officials. A Ugandan Government official who received the payment was arrested in London and also convicted.\u0022  (Source: United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011).)  According to the City of London Police Press Release, Neils Jorgen Tobiasen, 65, from Denmark, pleaded guilty at Southwark Crown Court to making corrupt payments.  Tobiasen, financial director of CBRN Team Ltd, will be sentenced at a later date. Tobiasen was charged under Section 1 of the Prevention of Corruption Act 1906.\u0022 (Source:  City of London Police Press Release, \u0022Guilty plea to bribery sets legal landmark \/ The government welcomed the first successful prosecution by the City of London Police?s Overseas Anti-Corruption Unit,\u0022 August 23, 2008.)","Sources ":"United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf; City of London Police Press Release, \u0022Guilty plea to bribery sets legal landmark \/ The government welcomed the first successful prosecution by the City of London Police\u0027s Overseas Anti-Corruption Unit,\u0022 August 23, 2008, accessed at http:\/\/www.cityoflondon.police.uk\/CityPolice\/Departments\/ECD\/anticorruptionunit\/guiltypleatobribery.htm, and which gives link to Michael Peel, \u0022Guilty plea to bribery sets legal landmark,\u0022 Financial Times, August 23, 2008, accessed at http:\/\/www.ft.com\/intl\/cms\/s\/0\/ff993ec6-70ad-11dd-b514-0000779fd18c.html#axzz1hsufXAJV","Documents":""},{"Case ID":"ST-116","Case Cluster ":"Central Asia American Enterprise Fund","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"United Kingdom","Year of Settlement":"2002","Month\/Day of Settlement (or Notes)":"09\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Restitution","Total Monetary Sanctions (US$)":"$300,000.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$300,000","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$300,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction; Restitution","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Government Program Fraud, Wire Fraud, Conspiracy to Commit Fraud ","Offenses - Settled":"Government Program Fraud, Wire Fraud, Conspiracy to Commit Fraud ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Plea Agreement and Statement of Facts in US v. Richard G. Pitchford, Pitchford was the vice president and country manager in Turkmenistan for the US Government-funded Central Asia American Enterprise Fund (CAAEF).  In addition to theft from the fund by using a kick-back scheme, Pitchford admitted to engaging in a scheme to ensure that a British company would win the bid on a CAAEF funded project and that the British company\u0027s bid was inflated by 15% or $200K and Pitchford worked to ensure that the British company won the bid even though he knew that all or some of the inflated amount would be paid to a British official with the UK Department of Trade and Industry.  As part of Pitchford\u0027s restitution, he was ordered to forfeit amounts in two New York brokerage accounts and a yacht that he had denied owning.  Some of the kickback funds in the Pitchford case were funneled through a BVI shell company (K.P.H., Inc.) formed by a CAAEF consultant with whom Pitchford conspired and a Swiss legal entity (Melioservice) formed by the UK official and used as a \u0022commission\u0022 agent.  The plea agreement noted that the US Department of Justice\u0027s Fraud Section which prosecuted the case would recommend to the court that Pitchford receive the maximum applicable reduction in sentencing for his plea and that the government would not seek an upward departure from applicable sentencing guidelines.  Moreover, if Pitchford complied with all the conditions of his plea agreement, the government agreed to file a departure motion in his sentencing. (Source: US v. Pitchford, Case No. 1:02-cr-365 (D.D.C.), Plea Agreement and Statement of Facts filed September 13, 2002 and Information filed September 3, 2002). Patrick Dickey, a co-conspirator pleaded guilty to non-FCPA charges and was ordered to pay $300K in restitution to the United States. (Source: U.S. Agency for International Development Press Release, \u0022Investigation of International Fradulent Conspiracy Results in Incarceration for Two Co-Conspirators,\u0022 November 27, 2002.)  ","Sources ":"US v. Patrick Dickey, Case No. 1:02-cr-00369-RCL (D.D.C.), Court Docket Report accessed via Pacer (the documents are not accessible by Pacer).  US v. Richard G. Pitchford, Case No. 1:02-cr-365 (D.D.C.), Information filed September 3, 2002; Plea Agreement and Statement of Facts filed September 13, 2002;  U.S. Agency for International Development Press Release, \u0022Investigation of International Fradulent Conspiracy Results in Incarceration for Two Co-Conspirators,\u0022 November 27, 2002, all accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pitchford.html","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Dickey_DOJ_Court_Docket_Report.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Richard_Pitchford_Sentencing_USAID_Nov_27_2002_0.pdf"},{"Case ID":"ST-117","Case Cluster ":"Central Asia American Enterprise Fund","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"United Kingdom","Year of Settlement":"2002","Month\/Day of Settlement (or Notes)":"09\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Restitution, Criminal Forfeiture","Total Monetary Sanctions (US$)":"$400,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown value of accounts and yacht","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$400,000","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$400,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction; Restitution","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of Foreign Official, Government Program Fraud, Conspiracy to Commit Fraud","Offenses - Settled":"Bribery of Foreign Official, Government Program Fraud, Conspiracy to Commit Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Plea Agreement and Statement of Facts in US v. Richard G. Pitchford, Pitchford was the vice president and country manager in Turkmenistan for the US Government-funded Central Asia American Enterprise Fund (CAAEF).  In addition to theft from the fund by using a kick-back scheme, Pitchford admitted to engaging in a scheme to ensure that a British company would win the bid on a CAAEF funded project and that the British company\u0027s bid was inflated by 15% or $200K and Pitchford worked to ensure that the British company won the bid even though he knew that all or some of the inflated amount would be paid to a British official with the UK Department of Trade and Industry.  As part of Pitchford\u0027s restitution, he was ordered to forfeit amounts in two New York brokerage accounts and a yacht that he had denied owning.  Some of the kickback funds in the Pitchford case were funneled through a British Virgin Islands shell company (K.P.H., Inc.) formed by a CAAEF consultant with whom Pitchford conspired and a Swiss legal entity (Melioservice) formed by the UK official and used as a \u0022commission\u0022 agent.  The plea agreement noted that the US Department of Justice\u0027s Fraud Section which prosecuted the case would recommend to the court that Pitchford receive the maximum applicable reduction in sentencing for his plea and that the government would not seek an upward departure from applicable sentencing guidelines.  Moreover, if Pitchford complied with all the conditions of his plea agreement, the government agreed to file a departure motion in his sentencing. Pitchford also agreed to pay $400,000 in restitution to the United States and to forfeit funds in two asset management accounts, in addition to a yacht in which that he denied having any interest. (Source: US v. Pitchford, Case No. 1:02-cr-365 (D.D.C.), Plea Agreement and Statement of Facts filed September 13, 2002 and Information filed September 3, 2002). Patrick Dickey, a co-conspirator pleaded guilty to non-FCPA charges and was ordered to pay $300K in restitution to the United States. (Source: U.S. Agency for International Development Press Release, \u0022Investigation of International Fradulent Conspiracy Results in Incarceration for Two Co-Conspirators,\u0022 November 27, 2002.)  ","Sources ":"US v. Richard G. Pitchford, Case No. 1:02-cr-365 (D.D.C.), Information filed September 3, 2002, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pitchford\/09-03-02pitchford-info.pdf; Plea Agreement filed September 13, 2002, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pitchford\/09-13-02pitchford-plea-agree.pdf; and Statement of Facts filed September 13, 2002, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pitchford\/09-13-02pitchford-state-facts.pdf;  U.S. Agency for International Development Press Release, \u0022Investigation of International Fradulent Conspiracy Results in Incarceration for Two Co-Conspirators,\u0022 November 27, 2002, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pitchford\/11-27-02pitchford-pressrelease.pdf","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Richard_Pitchford_Information_Sep_3_2002.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Richard_Pitchford_Plea_Agreement_Sep_13_2002.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Richard_Pitchford_Statement_Of_Facts_Sep_13_2002.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Richard_Pitchford_Sentencing_USAID_Nov_27_2002.pdf"},{"Case ID":"ST-118","Case Cluster ":"Chevron Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Treasury (Office of Foreign Assets Control)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food) ","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"11\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Settlement agreement","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$2,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$2,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Iraqi Sanctions Regulations (31 C.F.R. part 575)","Offenses - Settled":"Wire Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a press release by the United States Attorney for the Southern District of New York, on November 14, 2007, the United States Attorney for the Southern District of New York, the District Attorney for New York County, and the Department of the Treasury\u0027s Office of Foreign Assets Control (\u0022OFAC\u0022), \u0022announced an agreement (\u0022the Agreement\u0022) resolving the criminal and civil regulatory liabilities of CHEVRON CORPORATION and its subsidiaries (\u0022CHEVRON\u0022) relating to CHEVRON?s procurement of Iraqi oil under the United Nations Oil-for-Food Program. According to the Agreement, CHEVRON obtained Iraqi oil under the Program from third parties that paid secret, illegal surcharges to the former government of Iraq, in violation of United States wire fraud statutes and administrative regulations that prohibited transactions with the former Government of Iraq. Pursuant to the Agreement, CHEVRON will make the following payments totaling $27,000,000: (1) forfeiture of $20,000,000 to the U.S. Attorney\u0027s Office for the Southern District of New York (\u0022SDNY\u0022), which will seek to transfer that money to the Development Fund of Iraq (established on May 21, 2003, by United Nations Security Council Resolution 1483) to be paid as restitution for the benefit of the people of Iraq; (2) $5,000,000 to the New York County District Attorney\u0027s Office (\u0022DANY\u0022) to be distributed as DANY shall deem appropriate; and (3) $2,000,000 to OFAC in settlement of civil penalties. In a separate agreement, CHEVRON agreed to pay an additional monetary penalty of $3,000,000 to the Securities and Exchange Commission (\u0022SEC\u0022), and to pay disgorgement of $25,000,000, which will be satisfied by their payments to SDNY and DANY.\u0022 (Source: United States Attorney for the Southern District of New York Press Release, \u0022Chevron Corproation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007.)  The Press Release also noted that, \u0022This case is one of many that are the result of an unprecedented, wide-ranging criminal investigation into the United Nations Oil-for-Food Program. [  ] To date, the investigation has produced cases against 12 individuals and 7 entities (including CHEVRON) -- of which 6 individuals and 2 entities pleaded guilty, 1 individual was found guilty at trial, and 2 entities reached agreements with SDNY. The remaining cases are pending. Also as a result of the investigation, over $47.5 million in criminal proceeds has been forfeited or has been agreed to be forfeited to SDNY; SDNY will seek to transfer these funds to the Development Fund of Iraq as restitution for the benefit of the people of Iraq.\u0022 (Source: Ibid.)  Resulting ciminal cases: US v. Chevron Corporation (S.D.N.Y., November 14, 2007) and New York v. Chevron Corporation (New York County, November 14, 2007)","Sources ":"United States Attorney for the Southern District of New York Press Release, \u0022Chevron Corporation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/November07\/chevronagreementpr.pdf; Chevron Corporation Non-Prosecution Agreement dated November 8, 2007, accessed at  http:\/\/judiciary.house.gov\/hearings\/pdf\/deferredprosecution\/Chevron071108.pdf.","Documents":""},{"Case ID":"ST-119","Case Cluster ":"Chevron Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"New York County District Attorney\u0027s Office","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food) ","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"11\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$5,000,000.00","Criminal Fine\/Penalty (US$) ":"$5,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2 ","Offenses - Alleged":"Wire Fraud","Offenses - Settled":"Wire Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a press release by the United States Attorney for the Southern District of New York, on November 14, 2007, the United States Attorney for the Southern District of New York, the District Attorney for New York County, and the Department of the Treasury\u0027s Office of Foreign Assets Control (\u0022OFAC\u0022), \u0022announced an agreement (\u0022the Agreement\u0022) resolving the criminal and civil regulatory liabilities of CHEVRON CORPORATION and its subsidiaries (\u0022CHEVRON\u0022) relating to CHEVRON\u0027s procurement of Iraqi oil under the United Nations Oil-for-Food Program. According to the Agreement, CHEVRON obtained Iraqi oil under the Program from third parties that paid secret, illegal surcharges to the former government of Iraq, in violation of United States wire fraud statutes and administrative regulations that prohibited transactions with the former Government of Iraq. Pursuant to the Agreement, CHEVRON will make the following payments totaling $27,000,000: (1) forfeiture of $20,000,000 to the U.S. Attorney\u0027s Office for the Southern District of New York (\u0022SDNY\u0022), which will seek to transfer that money to the Development Fund of Iraq (established on May 21, 2003, by United Nations Security Council Resolution 1483) to be paid as restitution for the benefit of the people of Iraq; (2) $5,000,000 to the New York County District Attorney\u0027s Office (\u0022DANY\u0022) to be distributed as DANY shall deem appropriate; and (3) $2,000,000 to OFAC in settlement of civil penalties. In a separate agreement, CHEVRON agreed to pay an additional monetary penalty of $3,000,000 to the Securities and Exchange Commission (\u0022SEC\u0022), and to pay disgorgement of $25,000,000, which will be satisfied by their payments to SDNY and DANY.\u0022 (Source: United States Attorney for the Southern District of New York Press Release, \u0022Chevron Corproation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007.)  The Press Release also noted that, \u0022This case is one of many that are the result of an unprecedented, wide-ranging criminal investigation into the United Nations Oil-for-Food Program. [  ] To date, the investigation has produced cases against 12 individuals and 7 entities (including CHEVRON) -- of which 6 individuals and 2 entities pleaded guilty, 1 individual was found guilty at trial, and 2 entities reached agreements with SDNY. The remaining cases are pending. Also as a result of the investigation, over $47.5 million in criminal proceeds has been forfeited or has been agreed to be forfeited to SDNY; SDNY will seek to transfer these funds to the Development Fund of Iraq as restitution for the benefit of the people of Iraq.\u0022 (Source: Ibid.)  Resulting ciminal cases: US v. Chevron Corporation (S.D.N.Y., November 14, 2007) and New York v. Chevron Corporation (New York County, November 14, 2007)","Sources ":"United States Attorney for the Southern District of New York Press Release, \u0022Chevron Corporation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/November07\/chevronagreementpr.pdf;  Chevron Corporation Non-Prosecution Agreement dated November 8, 2007, accessed at  http:\/\/judiciary.house.gov\/hearings\/pdf\/deferredprosecution\/Chevron071108.pdf","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Chevron_SDNY_Non-Prosecution_Agreement_2007.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Chevron_SDNY_Agreement_PR_Mar_7_2008.pdf"},{"Case ID":"ST-120","Case Cluster ":"Chevron Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"11\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Civil Penalty","Total Monetary Sanctions (US$)":"$3,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"$3,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Internal controls violations","Offenses - Settled":"No admission or denial of alleged offeses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a press release by the United States Attorney for the Southern District of New York, on November 14, 2007, the United States Attorney for the Southern District of New York, the District Attorney for New York County, and the Department of the Treasury\u0027s Office of Foreign Assets Control (\u0022OFAC\u0022), \u0022announced an agreement (\u0022the Agreement\u0022) resolving the criminal and civil regulatory liabilities of CHEVRON CORPORATION and its subsidiaries (\u0022CHEVRON\u0022) relating to CHEVRON\u0027s procurement of Iraqi oil under the United Nations Oil-for-Food Program. According to the Agreement, CHEVRON obtained Iraqi oil under the Program from third parties that paid secret, illegal surcharges to the former government of Iraq, in violation of United States wire fraud statutes and administrative regulations that prohibited transactions with the former Government of Iraq. Pursuant to the Agreement, CHEVRON will make the following payments totaling $27,000,000: (1) forfeiture of $20,000,000 to the U.S. Attorney\u0027s Office for the Southern District of New York (\u0022SDNY\u0022), which will seek to transfer that money to the Development Fund of Iraq (established on May 21, 2003, by United Nations Security Council Resolution 1483) to be paid as restitution for the benefit of the people of Iraq; (2) $5,000,000 to the New York County District Attorney\u0027s Office (\u0022DANY\u0022) to be distributed as DANY shall deem appropriate; and (3) $2,000,000 to OFAC in settlement of civil penalties. In a separate agreement, CHEVRON agreed to pay an additional monetary penalty of $3,000,000 to the Securities and Exchange Commission (\u0022SEC\u0022), and to pay disgorgement of $25,000,000, which will be satisfied by their payments to SDNY and DANY.\u0022 (Source: United States Attorney for the Southern District of New York Press Release, \u0022Chevron Corproation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007.)  The Press Release also noted that, \u0022This case is one of many that are the result of an unprecedented, wide-ranging criminal investigation into the United Nations Oil-for-Food Program. [  ] To date, the investigation has produced cases against 12 individuals and 7 entities (including CHEVRON) -- of which 6 individuals and 2 entities pleaded guilty, 1 individual was found guilty at trial, and 2 entities reached agreements with SDNY. The remaining cases are pending. Also as a result of the investigation, over $47.5 million in criminal proceeds has been forfeited or has been agreed to be forfeited to SDNY; SDNY will seek to transfer these funds to the Development Fund of Iraq as restitution for the benefit of the people of Iraq.\u0022 (Source: Ibid.)  ","Sources ":"United States Attorney for the Southern District of New York Press Release, \u0022Chevron Corporation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/November07\/chevronagreementpr.pdf; US v. Chevron Corporation, Non-Prosecution Agreement filed November 14, 2007, accessed at http:\/\/fcpa.shearman.com\/files\/a6f\/a6f9b06a5abb243a2c37f89af684cbfc.pdf?i=4ae86429c8e9a2d374783fd18138bb2d; US Securities and Exchange Commission v. Chevron Corporation, Case No. 1:07-cv-10299-SHS (S.D.N.Y.), Complaint filed on November 14, 2007 and Final Judgment filed on November 20, 2007, accessed at www.fcpa.shearman.com; SEC Litigation Release No. 20363 \/ November 14, 2007, accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20363.htm","Documents":""},{"Case ID":"ST-121","Case Cluster ":"Chevron Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food) ","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"11\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Penalties, Criminal Forfeiture","Total Monetary Sanctions (US$)":"$20,000,000.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$20,000,000","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$20,000,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Iraq via Development Fund for Iraq","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Wire Fraud","Offenses - Settled":"Wire Fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a press release by the United States Attorney for the Southern District of New York, on November 14, 2007, the United States Attorney for the Southern District of New York, the District Attorney for New York County, and the Department of the Treasury\u0027s Office of Foreign Assets Control (\u0022OFAC\u0022), \u0022announced an agreement (\u0022the Agreement\u0022) resolving the criminal and civil regulatory liabilities of CHEVRON CORPORATION and its subsidiaries (\u0022CHEVRON\u0022) relating to CHEVRON\u0027s procurement of Iraqi oil under the United Nations Oil-for-Food Program. According to the Agreement, CHEVRON obtained Iraqi oil under the Program from third parties that paid secret, illegal surcharges to the former government of Iraq, in violation of United States wire fraud statutes and administrative regulations that prohibited transactions with the former Government of Iraq. Pursuant to the Agreement, CHEVRON will make the following payments totaling $27,000,000: (1) forfeiture of $20,000,000 to the U.S. Attorney\u0027s Office for the Southern District of New York (\u0022SDNY\u0022), which will seek to transfer that money to the Development Fund of Iraq (established on May 21, 2003, by United Nations Security Council Resolution 1483) to be paid as restitution for the benefit of the people of Iraq; (2) $5,000,000 to the New York County District Attorney\u0027s Office (\u0022DANY\u0022) to be distributed as DANY shall deem appropriate; and (3) $2,000,000 to OFAC in settlement of civil penalties. In a separate agreement, CHEVRON agreed to pay an additional monetary penalty of $3,000,000 to the Securities and Exchange Commission (\u0022SEC\u0022), and to pay disgorgement of $25,000,000, which will be satisfied by their payments to SDNY and DANY.\u0022 (Source: United States Attorney for the Southern District of New York Press Release, \u0022Chevron Corporation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007.)  The Press Release also noted that, \u0022This case is one of many that are the result of an unprecedented, wide-ranging criminal investigation into the United Nations Oil-for-Food Program. [  ] To date, the investigation has produced cases against 12 individuals and 7 entities (including CHEVRON) -- of which 6 individuals and 2 entities pleaded guilty, 1 individual was found guilty at trial, and 2 entities reached agreements with SDNY. The remaining cases are pending. Also as a result of the investigation, over $47.5 million in criminal proceeds has been forfeited or has been agreed to be forfeited to SDNY; SDNY will seek to transfer these funds to the Development Fund of Iraq as restitution for the benefit of the people of Iraq.\u0022 (Source: Ibid.)  Resulting ciminal cases: US v. Chevron Corporation (S.D.N.Y., November 14, 2007) and New York v. Chevron Corporation (New York County, November 14, 2007)  ","Sources ":"United States Attorney for the Southern District of New York Press Release, \u0022Chevron Corporation Agrees to Pay $30 Million in Oil-for-Food Settlement,\u0022 November 14, 2007, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/November07\/chevronagreementpr.pdf;  Chevron Corporation Non-Prosecution Agreement dated November 8, 2007, accessed at  http:\/\/judiciary.house.gov\/hearings\/pdf\/deferredprosecution\/Chevron071108.pdf","Documents":""},{"Case ID":"ST-122","Case Cluster ":"Chiquita Brands International, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Colombia","Year of Settlement":"2001","Month\/Day of Settlement (or Notes)":"10\/03","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order ","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$100,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$100,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission Litigation Release, on October 3, 2007, the agency announced that it had filed a settled complaint against Chiquita Brands, alleging that the company had violated the books and records and internal controls provisions of the FCPA as a result of the conduct of its Colombian subsidiary, C.I. Bananos de Exportaction, S.A (Banadex).  The SEC had alleged that Banadex\u0027s chief administrative officer authorized the company\u0027s customs broker, as well as Banadex\u0027s security officer and controller, to make a corrupt payment of $30,000 to local customs officials to secure the renewal of the port facility\u0027s license. The SEC also alleged that Banadex\u0027s books and records incorrectly identified the two installment payments, made in 1996 and 1997.  Without admitting or denying the Commission\u0027s findings, Chiquita consented to the entry of an order that requires Chiquita to cease and desist from violating those provisions. The Commission also filed a settled complaint in federal court seeking entry of a consent order requiring Chiquita to pay a $100,000 civil penalty. Chiquita settled the action without admitting or denying the Commission\u0027s allegations.   (Source:  US Securities and Exchange Commission Litigation Release No. 17169 \/ October 3, 2001, SEC v. Chiquita Brands International, Inc., Civ. Action No. 1:01CV02079 (D.D.C.) (filed October 3, 2001), \u0022SEC Settles Case against Chiquita Brands International, Inc.\u0022)  \r\n","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Chiquita Brands International, Inc. Case,  at 128-129, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; US Securities and Exchange Commission, Admin Proceedings File No. 3-10613, In the Matter of Chiquita Brands International, Inc., October 3, 2001, accessed at http:\/\/www.sec.gov\/litigation\/admin\/34-44902.htm; ","Documents":""},{"Case ID":"ST-123","Case Cluster ":"Comverse Technologies Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Greece","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"04\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,200,000.00","Criminal Fine\/Penalty (US$) ":"$1,200,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Falsification of books and records","Offenses - Settled":"Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Statement of Facts attached to the Non-Prosecution Agreement involving Comverse Technology Inc. (\u0022CTI\u0022), Comverse, Inc. and the subsidiaries of Comverse, Inc. (collectively referred to as \u0022Comverse\u0022), Comverse Ltd. is a wholly-owned subsidiary of Comverse, Inc. was an Israeli company based in Tel Aviv, Israel.   From in or around 2000 to in or around 2006, Comverse Ltd. paid Agent G monthly retainer fees of $5,000 or $5,500 per month and also commissions on purchase orders he helped to obtain for Comverse Ltd.  Agent G would keep 15% of the total commission, and the remaining 85% was used to make improper payments.  In or around early 2003, certain employees of the Europe, Middle East, and Africa (\u0022EMEA\u0022) division of Comverse Ltd, directed Agent C to set up a shell company and corresponding bank account in Cyprus, Agent G was told that the shell company would be used to make cash payments to sernior executives of one of Comverse Ltd\u0027s Greek private customers. In or around February 2003, with the assistance of a Cypriot lawyer, Agent G caused Corporation H to be incorporated in Cyprus and bank accounts to be opened in Cyprus in the name of Corporation H.  Corporation H had no offices or employees and was later described by Agent G as \u0022purely a money laundering operation.\u0022  Using a fake invoice scheme, money was transferred from Comverse Ltd.\u0027s bank account in Isael to one of Coporation H\u0027s Cyprus bank accounts. Then the money would be withdrawn by Agent G or an employee and carried to directly to a Greek private customer or customers in Italy. Between 2003 and 2006, Comverse Ltd. made approximately $536,000 in cash payments to Corporation H with the intent that the money would be passed onto individuals connected to the Hellenic Telecommunications Organization S.A. (\u0022OTE\u0022), a telecommunications provider controlled and partially owned by the Greek government, and included payments to employees of OTE\u0027s subsidiaries Cosmote, Cosmofon, and Cosmorom, in order to obtain purchase orders from those companies for Comverse Ltd. products and services, resulting in approximately $1,250,000 in adjusted operating income. (para 24) (In Re: Comverse Technology, Inc., Non-Prosecution Agreement and Statement of Facts, April 6, 2011).  The company also settled SEC charges by agreeing to pay $1,249,614 disgorgement and $358,887 in prejudgment interest, without admitting or denying the allegations the SEC\u0027s allegations.  In the Complaint filed in SEC v. Comverse Technologies, SEC had alleged that the Cypriot entity which funnelled the improper paymens was called Fintron Enterprises Ltd. (para 12), and that the payments resulted in contracts worth approximately $10 million in revenues and ill-gotten gains of approximately $1.2 million.  (Source:  SEC v. Comverse Technology, Inc., Case No. 11:cv-1704-LDW (E.D.N.Y.), Complaint filed on April 7, 2011 and Litigation release No. 21920, April 7, 2011).","Sources ":"In Re: Comverse Technologies, Inc., Non-Prosecution Agreement and Statement of Facts, April 6, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/rae-comverse\/04-06-11comverse-npa.pdf; US Department of Justice Press Release, \u0022Comverse Technology INC. Agrees to Pay $1.2 Million Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 April 7, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/April\/11-crm-438.html; Securities and Exchange Commission v. Comverse Technology, Inc., Case No. 11-CV-1704-LDW (E.D.N.Y. filed April 7, 2011), Litigation Release No. 21920 (April 7, 2011), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr21920.htm and Complaint at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp21920.pdf.\r\n","Documents":""},{"Case ID":"ST-124","Case Cluster ":"Comverse Technologies Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Greece","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"04\/07","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Conduct-based Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profit, Prejudgment Interest","Total Monetary Sanctions (US$)":"$1,608,501.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,249,614","Civil Prejudgment Interest (US$) ":"$358,887","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Statement of Facts attached to the Non-Prosecution Agreement involving Comverse Technology Inc. (\u0022CTI\u0022), Comverse, Inc. and the subsidiaries of Comverse, Inc. (collectively referred to as \u0022Comverse\u0022), Comverse Ltd. is a wholly-owned subsidiary of Comverse, Inc. was an Israeli company based in Tel Aviv, Israel.   From in or around 2000 to in or around 2006, Converse Ltd. paid Agent G monthly retainer fees of $5,000 or $5,500 per month and also commissions on purchase orders he helped to obtain for Comverse Ltd.  Agent G would keep 15% of the total commission, and the remaining 85% was used to make improper payments.  In or around early 2003, certain employees of the Europe, Middle East, and Africa (\u0022EMEA\u0022) division of Comverse ltd, directed Agent C to set up a shell company and corresponding bank account in Cyprus, Agent G was told that the shell company would be used to make cash payments to sernior executives of one of Comverse Ltd\u0027s Greek private customers. In or around February 2003, with the assistance of a Cypriot lawyer, Agent G caused Corporation H to be incorporated in Cyprus and bank accounts to be opened in Cyprus in the name of Corporation H.  Corporation H had no offices or employees and was later described by Agent G as \u0022purely a money laundering operation.\u0022  Using a fake invoice scheme, money was transferred from Comverse Ltd.\u0027s bank account in Isael to one of Coporation H\u0027s Cyprus bank accounts. Then the money would be withdrawn by Agent G or an employee and carried to directly to a Greek private customer or customers in Italy. Between 2003 and 2006, Comverse Ltd. made approximately $536,000 in cash payments to Corporation H with the intent that the money would be passed onto individuals connected to the Hellenic Telecommunications Organization S.A. (\u0022OTE\u0022), a telecommunications provider controlled and partially owned by the Greek government, and included payments to employees of OTE\u0027s subsidiaries Cosmote, Cosmofon, and Cosmorom, in order to obtain purchase orders from those companies for Comverse Ltd. products and services, resulting in approximately $1,250,000 in adjusted operating income. (para 24) (In Re: Comverse Technology, Inc., Non-Prosecution Agreement and Statement of Facts, April 6, 2011).  In the Complaint filed in SEC v. Comverse Technologies, SEC had alleged that the Cypriot entity which funnelled the improper paymens was called Fintron Enterprises Ltd. (para 12), and that the payments resulted in contracts worth approximately $10 million in revenues and ill-gotten gains of approximately $1.2 million.  (Source:  SEC v. Comverse Technology, Inc., Case No. 11:cv-1704-LDW (E.D.N.Y.), Complaint filed on April 7, 2011 and Litigation release No. 21920, April 7, 2011)","Sources ":"In Re: Comverse Technologies, Inc., Non-Prosecution Agreement and Statement of Facts, April 6, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/rae-comverse\/04-06-11comverse-npa.pdf; US Department of Justice Press Release, \u0022Comverse Technology Inc. Agrees to Pay $1.2 Million Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 April 7, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/April\/11-crm-438.html; Securities and Exchange Commission v. Comverse Technology, Inc., Case No. 11-CV-1704-LDW (E.D.N.Y. filed April 7, 2011), Litigation Release No. 21920 (April 7, 2011), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr21920.htm and Complaint at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp21920.pdf.\r\n","Documents":""},{"Case ID":"ST-125","Case Cluster ":"Control Components, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China, Malaysia, South Korea, India, Romania, Brazil, United Arab Emirates (total over 36 countries - both private and public bribery)","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"07\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$18,200,000.00","Criminal Fine\/Penalty (US$) ":"$18,200,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.21, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art, 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to commit commercial bribery, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to commit commercial bribery, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On July 22, 2009, Control Components, Inc. (CCI), a Rancho Santa Margarita, California-based company, was charged in a three count criminal information with violations of the FCPA and the Travel Act, stemming from a decade-long scheme to secure contracts in approximately 36 countries by paying bribes to officials and employees of various foreign state-owned companies as well as foreign and domestic private companies. Previously, two former executives of CCI, Mario Covino and Richard Morlok, were each charged with one count of conspiracy to bribe foreign officials in violation of the FCPA (on December 17, 2008 and January 7, 2009, respectively). On April 9, 2009, a grand jury in the Central District of California returned an indictment against six additional former CCI executives for their alleged roles in this bribery scheme.  According to court documents, from 2003 through 2007, CCI, a manufacturer of service control valves for use in the nuclear, oil and gas, and power generation industries, made approximately 236 corrupt payments to officers and employees of foreign state-owned and private companies in more than 30 countries. Sales from these corrupt payments resulted in net profits to the company of approximately $46.5 million.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Control Components, Inc. Case Summary, at 64-65.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Control Componets, Inc. Case Summary, at 64-65, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Control Components, Inc., Case No. 09-cr-00162-JVS (C.D. Cal., July 22, 2009), Information filed on July 22, 2009 and Plea Agreement and Statement of Facts dated July 22, 2009; Company press release dated July 31, 2009; Court Docket report as of August 28, 2009; IMI (parent company) news release of August 27, 2009.  All documents accessed at FCPA website of Shearman and Sterling, at http:\/\/fcpa.shearman.com\/index.php (US v. Control Components, Inc. case summary page); udgment filed July 31, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/control-inc\/07-31-09cci-judgment.pdf","Documents":""},{"Case ID":"ST-126","Case Cluster ":"Control Systems Specialists, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Brazil","Year of Settlement":"1998","Month\/Day of Settlement (or Notes)":"10\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,500.00","Criminal Fine\/Penalty (US$) ":"$1,500","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.15, Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials; Bribery of foreign officials, Bribery of US officials","Offenses - Settled":"Conspiracy to bribe foreign officials; Bribery of foreign officials, Bribery of US officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD on the Enforcement of the Anti-Bribery Convention, \u0022On August 19, 1998, the Department of Justice filed a three-count information against Control Systems Specialist, Inc. (CSS) and its President, Darrold Richard Crites, charging both with conspiring to bribe foreign officials, as well as bribing both foreign and U.S. public officials. CSS, an Ohio corporation, was engaged in the business of buying and repairing surplus military equipment for resale. According to court documents, in 1994, CSS and Crites bid on a contract to supply refurbished military equipment to the Brazilian Aeronautical Commission. In order to win this contract, between November 1994 and December 1995, CSS and Crites made more than 21 bribe payments to a Brazilian Air Force Lt. Colonel, who was authorized to purchase military equipment on behalf of the Brazilian government. These bribe payments ultimately totaled more than $250,000. In addition, CSS and Crites paid approximately $66,000 to a U.S. Air Force officer to provide CSS with confidential information that helped the contracts with the Brazilian government. As a result of these bribe payments, CSS was awarded the contract with the Brazilian Air Force, which was ultimately worth more than $670,000.\r\nCriminal Disposition:\r\nCSS and Crites each pleaded guilty before Judge Walter H. Rice on October 15, 1998, and were subsequently sentenced on March 8, 1999. Defendant Crites was sentenced to 3 years\u0027 probation, including 6 months\u0027 home confinement. CSS was fined $1,500.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Control Systems Specialist, Inc. Case at 134.).  According to the Court Docket Report, the fine was $500 per each count. (Source: US v. Control Systems Specialist, Inc. and Darrold Richard Crites, Case No. 3:98-cr-073 (S.D. Ohio), Court Docket Report accessed at http:\/\/fcpa.shearman.com\/files\/6dc\/6dc8985e0fb5fd5bf9a9385bc162bb79.pdf?i=c5b5c161b6598bf223e61ed0033c2711.","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31,2011, Control Systems Specialist, Inc. Case at 134, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf;  US v. Control Systems Specialist, Inc. and Darrold Richard Crites, Case No. 3:98-cr-073 (S.D. Ohio), Information filed on August 19, 1998, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/control-inc\/08-19-98css-info.pdf; Plea Agreement filed October 15, 1998, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/control-inc\/10-15-98css-plea-agree.pdf; US v. Control Systems Specialist, Inc. and Darrold Richard Crites, Case No. 3:98-cr-073 (S.D. Ohio), Court Docket Report accessed at http:\/\/fcpa.shearman.com\/files\/6dc\/6dc8985e0fb5fd5bf9a9385bc162bb79.pdf?i=c5b5c161b6598bf223e61ed0033c2711.","Documents":""},{"Case ID":"ST-127","Case Cluster ":"Control Systems Specialists, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Brazil","Year of Settlement":"1998","Month\/Day of Settlement (or Notes)":"10\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea ","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.15","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to bribe foreign officials; Bribery of foreign officials, Bribery of US officials","Offenses - Settled":"Conspiracy to bribe foreign officials; Bribery of foreign officials, Bribery of US officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD on the Enforcement of the Anti-Bribery Convention, \u0022On August 19, 1998, the Department of Justice filed a three-count information against Control Systems Specialist, Inc. (CSS) and its President, Darrold Richard Crites, charging both with conspiring to bribe foreign officials, as well as bribing both foreign and U.S. public officials. CSS, an Ohio corporation, was engaged in the business of buying and repairing surplus military equipment for resale. According to court documents, in 1994, CSS and Crites bid on a contract to supply refurbished military equipment to the Brazilian Aeronautical Commission. In order to win this contract, between November 1994 and December 1995, CSS and Crites made more than 21 bribe payments to a Brazilian Air Force Lt. Colonel, who was authorized to purchase military equipment on behalf of the Brazilian government. These bribe payments ultimately totaled more than $250,000. In addition, CSS and Crites paid approximately $66,000 to a U.S. Air Force officer to provide CSS with confidential information that helped the contracts with the Brazilian government. As a result of these bribe payments, CSS was awarded the contract with the Brazilian Air Force, which was ultimately worth more than $670,000.\r\nCriminal Disposition:\r\nCSS and Crites each pleaded guilty before Judge Walter H. Rice on October 15, 1998, and were subsequently sentenced on March 8, 1999. Defendant Crites was sentenced to 3 years\u0027 probation, including 6 months\u0027 home confinement. CSS was fined $1,500.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Control Systems Specialist, Inc. Case at 134.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31,2011, Control Systems Specialist, Inc. Case at 134, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf;  US v. Control Systems Specialist, Inc. and Darrold Richard Crites, Case No. 3:98-cr-073 (S.D. Ohio), Information filed on August 19, 1998, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/control-inc\/08-19-98css-info.pdf; Plea Agreement filed October 15, 1998, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/control-inc\/10-15-98css-plea-agree.pdf; US v. Control Systems Specialist, Inc. and Darrold Richard Crites, Case No. 3:98-cr-073 (S.D. Ohio), Court Docket Report accessed at http:\/\/fcpa.shearman.com\/files\/6dc\/6dc8985e0fb5fd5bf9a9385bc162bb79.pdf?i=c5b5c161b6598bf223e61ed0033c2711.","Documents":""},{"Case ID":"ST-128","Case Cluster ":"Con-Way, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Philippines","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"08\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$300,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$300,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Con-Way Inc. at 58-59: Time period of misconduct in Philippines, 2000-2003; SEC complaint alleged that Con-Way\u0027s Philippine subsidiary, Emery Transnational, (1) made approximately $244,000 in improper payments to foreign officials of the Philippines Bureau of Customs and the Philippine Economic Zone Area, that the payments were made to induce these foreign officials to violate customs regulations, settle customs disputes, and reduce or not enforce otherwise legitimate fines; (2) $173,000 in improper payments to officials at fourteen state-owned airlines that conducted business in the Philippines, to induce airline officials to improperly reserve space for Emery Transnational on airplanes, to fasely under-weigh shipments, and to improperly consolidate multiple shipments into a single shipment, resulting in lower shipping charges.  Resulting civil\/administrative enforcement actions: SEC v. Con-Way Inc., Case No. 1:08-cv-01478-EGS (D.D.C.), Complaint filed August 27, 2008; In the Matter of Con-Way Inc. (August 27, 2008).  According to the US Securities and Exchange Commission Litigation Release, \u0022Without admitting or denying the allegations in the Commission?s complaint, Con-way agreed to pay a $300,000 civil penalty.\u0022  (Source: \r\nUS Securities and Exchange Commission, Litigation Release No. 20690 \/ August 27, 2008, Securities and Exchange Commission v. Con-way Inc., Civil Action No. 1:08-CV-01478 (D.D.C.) (EGS), \u0022SEC Files Settled Enforcement Action Charging Con-way Inc. with Violations of the Foreign Corrupt Practices Act.\u0022)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Con-Way Inc. at 58-59, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Securities and Exchange Commission, Litigation Release No. 20690 \/ August 27, 2008, Securities and Exchange Commission v. Con-way Inc., Civil Action No. 1:08-CV-01478 (D.D.C.) (EGS), \u0022SEC Files Settled Enforcement Action Charging Con-way Inc. with Violations of the Foreign Corrupt Practices Act,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20690.htm; US Securities and Exchange Commission v. Con-Way Inc., Case No. 1:08-cv-01478-EGS (D.D.C.), Complaint filed August 27, 2008, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20690.pdf","Documents":""},{"Case ID":"ST-129","Case Cluster ":"Daimler AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China, Croatia, Egypt, Greece, Hungary, Indonesia, Iraq (UN Oil-for-Food), Ivory Coast, Latvia, Nigeria, Russia, Serbia and Montenegro, Thailand, Turkey, Turkmenistan, Uzbekistan, Vietnam and other unspecified countries (at least 22 countries)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"04\/01","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits","Total Monetary Sanctions (US$)":"$91,432,867.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$91,432,867","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offeses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Press Release, the Commission \u0022today announced a settlement with Daimler AG for violations of the Foreign Corrupt Practices Act (FCPA), alleging that the Stuttgart, Germany-based automobile manufacturer engaged in a repeated and systematic practice of paying bribes to foreign government officials to secure business in Asia, Africa, Eastern Europe and the Middle East.  Daimler agreed to pay $91.4 million in disgorgement to settle the SEC\u0027s charges and pay $93.6 million in fines to settle charges in separate criminal proceedings announced today by the U.S. Department of Justice.\r\n\r\nThe SEC alleges that Daimler paid at least $56 million in improper payments over a period of more than 10 years. The payments involved more than 200 transactions in at least 22 countries. Daimler earned $1.9 billion in revenue and at least $90 million in illegal profits through these tainted sales transactions, which involved at least 6,300 commercial vehicles and 500 passenger cars. Daimler also paid kickbacks to Iraqi ministries in connection with direct and indirect sales of motor vehicles and spare parts under the United Nations Oil for Food Program. [  ]   The SEC\u0027s complaint, filed in U.S. District Court for the District of Columbia, alleges that Daimler used bribes to further government sales in such countries as Russia, China, Vietnam, Nigeria, Hungary, Latvia, Croatia, and Bosnia. Among other means, Daimler used dozens of ledger accounts, known internally as \u0022interne Fremdkonten\u0022 or \u0022internal third party accounts\u0022 to maintain credit balances for the benefit of government officials. These credit balances were controlled by Daimler subsidiaries or outside third parties, including foreign government officials or Daimler\u0027s dealers, distributors or other agents who were at times used as intermediaries to make payments to foreign government officials. The accounts were funded through several bogus pricing mechanisms, such as \u0022price surcharges,\u0022 \u0022price inclusions,\u0022 or excessive commissions. Daimler also used artificial discounts or rebates on sales contracts to effectuate bribes. In those instances, all or a portion of the discount was kicked back through a ledger account to a foreign government official, rather than credited to the purchasing government customer.\u0022 (Source:  US Securities and Exchange Commission Press Release, \u0022SEC Charges Daimler AG with Global Bribery,\u0022 April 1, 2010.)\r\n\r\n","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31,2011, Daimler AG Case Summary at 49-50, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf;  US Securities and Exchange Commission Press Release, \u0022SEC Charges Daimler AG with Global Bribery,\u0022 April 1, 2010, accessed at http:\/\/www.sec.gov\/news\/press\/2010\/2010-51.htm; Complaint assigned March 22, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp-pr2010-51.pdf","Documents":""},{"Case ID":"ST-130","Case Cluster ":"Daimler AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China, Croatia, Egypt, Greece, Hungary, Indonesia, Iraq (UN Oil-for-Food), Ivory Coast, Latvia, Nigeria, Russia, Serbia and Montenegro, Thailand, Turkey, Turkmenistan, Uzbekistan, Vietnam and other unspecified countries (at least 22 countries)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"04\/01","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$37,220,000.00","Criminal Fine\/Penalty (US$) ":"$37,220,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to falsify books and records, Falsification of books and records","Offenses - Settled":"Conspiray to falsify books and records, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to DOJ Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Daimler AG, at 24-25:  Case involved Daimler AG and three subsidiaries:  DaimlerChrysler Automotive Russia SAO (DCAR), Daimler Export and Trade Finance GmbH (ETF), and DaimlerChrysler China Ltd. (DCCL).  Misconduct alleged (1) hundreds of  improper payments worth tens of millions of dollars by Daimler AG and its subsidiaries to foreign officials in at least 22 countries - including China, Croatia, Egypt, Greece, Hungary, Indonesia, Iraq, Ivory Coast, Latvia, Nigeria, Russia, Serbia and Montenegro, Thailand, Turkey, Turkmenistan, Uzbekistan, Vietnam and others - to assist in securing contracts with government customers for the purchase of Daimler vehicles.  (2) Daimler AG admitted that it agreed to pay kickbacks to former Iraqi government in connection with contracts to sell vehicles to Iraq under the UN\u0027s Oil-for-Food program.  Time period of conduct is 1998-2008. The contracts were valued in the hundreds of millions of dollars.  According to Daimler AG\u0027s Deferred Prosecution Agreement, the company agreed to pay a fine of $93.6 million; the parties agreed that any fines agreed to and\/or ordered against Daimler\u0027s subsidiaries would be deducted from that amount.  (Source: US v. Daimler AG, Case No. 1:10-cr-063-RJL (D.D.C.), Deferred Prosecution Agreement filed March 24, 2010.)  DaimlerChrysler Automotive Russia SAO agreed to pay $27.26 million in criminal fine and Daimler Export and Trade Finance agreed to pay $29.12 million in criminal fine.  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31,2011, Daimler AG Case Summary at 49-50.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31,2011, Daimler AG Case Summary at 49-50, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Daimler AG, at 24-25, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US v. Daimler AG, et al, Case No. 1:10-cr-00063-RJL (D.D.C.), United States\u0027 Sentencing Memorandum filed March 24, 2010 and Information filed Mar. 22, 2010, both accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/daimler-ag.html and Deferred Prosecution Agreement and Statement of Facts filed March 24, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/daimler\/03-24-10daimlerag-agree.pdf; ,US Department of Justice Press Release, \u0022Daimler AG and Three Subsidiaries Resolve Foreign Corrupt Practices Act Investigation and Agree to Pay $93.6 Million in Criminal Penalties,\u0022 April 1, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/April\/10-crm-360.html (accessed September 14, 2011). ","Documents":""},{"Case ID":"ST-131","Case Cluster ":"Daimler AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement ","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials; Bribery of foreign officials ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to DOJ Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Daimler AG, at 24-25:  Case involved Daimler AG and three subsidiaries:  DaimlerChrysler Automotive Russia SAO (DCAR), Daimler Export and Trade Finance GmbH (ETF), and DaimlerChrysler China Ltd. (DCCL).  Misconduct alleged (1) hundreds of  improper payments worth tens of millions of dollars by Daimler AG and its subsidiaries to foreign officials in at least 22 countries - including China, Croatia, Egypt, Greece, Hungary, Indonesia, Iraq, Ivory Coast, Latvia, Nigeria, Russia, Serbia and Montenegro, Thailand, Turkey, Turkmenistan, Uzbekistan, Vietnam and others - to assist in securing contracts with government customers for the purchase of Daimler vehicles.  (2) Daimler AG admitted that it agreed to pay kickbacks to former Iraqi government in connection with contracts to sell vehicles to Iraq under the UN\u0027s Oil-for-Food program.  Time period of conduct is 1998-2008. The contracts were valued in the hundreds of millions of dollars.  According to DaimlerChrysler China Ltd\u0027s Deferred Prosecution Agreement, in light of the parent company Daimler AG\u0027s payment of $93.6 million in criminal fines (offset by fines ordered against its Russian and Export and Trade Finance subsidiaries), no separate monetary fine was imposed against its China subsidiary.  (Source: US v. DaimlerChrysler China Ltd., Case No. 1:10-cr-066-RJL (D.D.C.), Deferred Prosecution Agreement filed March 24, 2010.)  ","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Daimler AG, at 24-25, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US v. Daimler AG, et al, Case No. 1:10-cr-00063-RJL (D.D.C.), Deferred Prosecution Agreement and Statement of Facts filed March 24, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/daimler\/03-24-10daimlerag-agree.pdf; US Department of Justice Press Release, \u0022Daimler AG and Three Subsidiaries Resolve Foreign Corrupt Practices Act Investigation and Agree to Pay $93.6 Million in Criminal Penalties,\u0022 April 1, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/April\/10-crm-360.html (accessed September 14, 2011). US v. DaimlerChrysler China Ltd., Case No. 1:10-cr-066-RJL (D.D.C.), Deferred Prosecution Agreement filed March 24, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/daimler\/03-24-10daimlerchina-prosecution.pdf","Documents":""},{"Case ID":"ST-132","Case Cluster ":"Daimler AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Croatia","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$29,120,000.00","Criminal Fine\/Penalty (US$) ":"$29,120,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials; Bribery of foreign officials ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to DOJ Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Daimler AG, at 24-25:  Case involved Daimler AG and three subsidiaries:  DaimlerChrysler Automotive Russia SAO (DCAR), Daimler Export and Trade Finance GmbH (ETF), and DaimlerChrysler China Ltd. (DCCL). Misconduct alleged (1) hundreds of  improper payments worth tens of millions of dollars by Daimler AG and its subsidiaries to foreign officials in at least 22 countries - including China, Croatia, Egypt, Greece, Hungary, Indonesia, Iraq, Ivory Coast, Latvia, Nigeria, Russia, Serbia and Montenegro, Thailand, Turkey, Turkmenistan, Uzbekistan, Vietnam and others - to assist in securing contracts with government customers for the purchase of Daimler vehicles.  (2) Daimler AG admitted that it agreed to pay kickbacks to former Iraqi government in connection with contracts to sell vehicles to Iraq under the UN\u0027s Oil-for-Food program.  Time period of conduct is 1998-2008. The contracts were valued in the hundreds of millions of dollars.  According to the Plea Agreements and the Amended Jugment filed in US v. Daimler Export and Trade Finance GmbH, the Daimler subsidiary agreed to and was ordered to pay $29.12 million in criminal fines.  (Sources:  US v. Daimler Export and Trade Finance GmbH, Case No. 1:10-cr-65-RJL (D.D.C.), Plea Agreement filed March 24, 2010 and Amended Judgment filed April 6, 2010.)","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Daimler AG, at 24-25, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.  US v. Daimler Export and Trade Finance GmbH, Case No. 1:10-cr-65-RJL (D.D.C.), Plea Agreement filed March 24, 2010, accessed at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/daimler\/03-24-10daimlerexp-plea.pdf and Amended Judgment filed April 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/daimler\/04-06-10daimlerexp-amend.pdf. See also, US Department of Justice Press Release, \u0022Daimler AG and Three Subsidiaries Resolve Foreign Corrupt Practices Act Investigation and Agree to Pay $93.6 Million in Criminal Penalties,\u0022 April 1, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/April\/10-crm-360.html and US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31,2011, Daimler AG Case Summary at 49-50","Documents":""},{"Case ID":"ST-133","Case Cluster ":"Daimler AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Russia","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$27,360,000.00","Criminal Fine\/Penalty (US$) ":"$27,360,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials; Bribery of foreign officials ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to DOJ Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Daimler AG, at 24-25:  Case involved Daimler AG and three subsidiaries:  DaimlerChrysler Automotive Russia SAO (DCAR), Daimler Export and Trade Finance GmbH (ETF), and DaimlerChrysler China Ltd. (DCCL).  Misconduct alleged (1) hundreds of  improper payments worth tens of millions of dollars by Daimler AG and its subsidiaries to foreign officials in at least 22 countries - including China, Croatia, Egypt, Greece, Hungary, Indonesia, Iraq, Ivory Coast, Latvia, Nigeria, Russia, Serbia and Montenegro, Thailand, Turkey, Turkmenistan, Uzbekistan, Vietnam and others - to assist in securing contracts with government customers for the purchase of Daimler vehicles.  (2) Daimler AG admitted that it agreed to pay kickbacks to former Iraqi government in connection with contracts to sell vehicles to Iraq under the UN\u0027s Oil-for-Food program.  Time period of conduct is 1998-2008. The contracts were valued in the hundreds of millions of dollars.  According to the Amended Judgment in US v. DaimlerChrysler Automotive Russia SAO, the Daimler subsidiary ordered to pay $27.36 million in criminal fine.  (Sources: US v. DaimlerChrysler Automotive Russia SAO, Case No. 1:10-cr-64 (D.D.C.), Plea Agreement filed March 24, 2010, and Amended Judgment filed April 6, 2010.)","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Daimler AG, at 24-25, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf;  US Department of Justice Press Release, \u0022Daimler AG and Three Subsidiaries Resolve Foreign Corrupt Practices Act Investigation and Agree to Pay $93.6 Million in Criminal Penalties,\u0022 April 1, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/April\/10-crm-360.html (accessed September 14, 2011).  US v. DaimlerChrysler Automotive Russia SAO, Case No. 1:10-cr-64 (D.D.C.), Plea Agreement filed March 24, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/daimler\/03-24-10daimlerrussia-plea.pdf and Amended Judgment filed April 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/daimler\/04-06-10daimlerrussia-amend.pdf.  See also, US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31,2011, Daimler AG Case Summary at 49-50, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf","Documents":""},{"Case ID":"ST-134","Case Cluster ":"Data Systems and Solutions, LLC","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Lithuania","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"06\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$8,820,000.00","Criminal Fine\/Penalty (US$) ":"$8,820,000 ","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Bribery of foreign officials, Conspiracy to bribe foreign officials","Offenses - Settled":"Bribery of foreign officials, Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022Data Systems \u0026 Solutions LLC (DS\u0026S), a company based in Reston, Va., that provides design, installation, maintenance and other services at nuclear and fossil fuel power plants, has agreed to pay an $8.82 million criminal penalty to resolve violations of the Foreign Corrupt Practices Act (FCPA) [  ]  The department filed a two-count criminal information today in the Eastern District of Virginia charging DS\u0026S with conspiring to violate, and violating, the FCPA\u0027s anti-bribery provisions.  According to court documents, DS\u0026S paid bribes to officials employed by the Ignalina Nuclear Power Plant, a state-owned nuclear power plant in Lithuania, to secure contracts to perform services for the plant.  To disguise the scheme, the bribes were funneled through several subcontractors located in the United States and abroad.  The subcontractors, in turn, made repeated payments to high-level officials at Ignalina via check or wire transfer.  \r\nThe department also filed today a deferred prosecution agreement with DS\u0026S.  Under the terms of the agreement, the department will defer prosecution of DS\u0026S for two years.\u0022 (Source: US Department of Justice Press Release, \u0022Data Systems \u0026 Solutions LLC Resolves Foreign Corrupt Practices Act Violations and Agrees to Pay $8.82 Million Criminal Penalty,\u0022 June 18, 2012.)  According to the Information filed in the case, \u0022Subcontractor C\u0022 was a shell company was a shell company incorporated in the US and was used to funnel bribe payments (para 12), including to the officials\u0027 bank accounts in the U.S. (para 16b) (Source: US v. Data Systems \u0026 Solutions LLC, Case No. 1:12-cr-262 (E.D.Va.), Information filed June 18, 2012.)\r\n","Sources ":"US Department of Justice Press Release, \u0022Data Systems \u0026 Solutions LLC Resolves Foreign Corrupt Practices Act Violations and Agrees to Pay $8.82 Million Criminal Penalty,\u0022 June 18, 2012, accessed at http:\/\/www.justice.gov\/opa\/pr\/2012\/June\/12-crm-768.html; US v. Data Systems \u0026 Solutions LLC, Case No. 1:12-cr-00262 (E.D. Va.), Information filed June 18, 2012 and Deferred Prosecution Agreement filed June 18, 2012, both accessed via PACER.","Documents":""},{"Case ID":"ST-135","Case Cluster ":"David Chalmers\/ Bayoil","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"08\/17","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Restitution","Total Monetary Sanctions (US$)":"$9,016,151.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$9,016,151","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$9,016,151","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Iraq via Development Fund for Iraq","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Multiple counts of conspiracy to commit wire fraud, violations of sanctions","Offenses - Settled":"Conspiracy to commit wire fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a press release by the United States Attorney for the Southern District of New York, \u0022David B. Chalmers, Jr. [ ] and two corporations that he operated -- BAYOIL (USA), INC. [  ] BAYOIL SUPPLY \u0026 TRADING LIMITED, a Bahamian company with principal offices in Nassau, Bahamas (collectively, the \u0022BAYOIL COMPANIES\u0022). CHALMERS and the BAYOIL COMPANIES each pleaded guilty today before United States District Judge DENNY CHIN to participating in a scheme to pay illegal surcharges to the former Government of Iraq in connection with the purchase of crude oil in the United Nations Oil-for-Food Program between mid-2000 and 2003. Judge CHIN also accepted earlier today the guilty plea of LUDMIL DIONISSIEV to related smuggling charges. DIONISSIEV worked with CHALMERS and the BAYOIL COMPANIES during the course of this scheme to purchase Iraqi oil. CHALMERS and the BAYOIL COMPANIES each pleaded guilty to participating in a conspiracy to commit wire fraud related to the payment of secret illegal surcharge payments to the former Government of Iraq.\u0022  (Source: United States Attorney for the Southern District of New York, \u0022U.S. Announces Four Guilty Pleas in Oil-for-Food Case,\u0022 August 17, 2007.)  According to the Restitution Order, on March 18, 2008, Mr. Chalmers and the Bayoil companies were ordered joint and severally liable for payment of restitution in the amount of $9,016,151.40 and the defendants were ordered to pay this sum \u0022in restitution to the Development Fund for Iraq, in care of Ambassador Srood Najib.\u0022 (Source: US v. David Chalmers, et al, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Order of Restitution filed March 25, 2008.).  Please note that the restitution figure has been included only in the company entry so as to avoid double-counting. ","Sources ":"US v. David B. Chalmers, Jr., Bayoil (USA) Inc., and Bayoil Supply \u0026 Trading Limited, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Order of Restitution filed on March 25, 2008; United States Attorney Southern District of New York Press Release, \u0022U.S. Announces Four Guilty Pleas in Oil-for-Food Case,\u0022 August 17, 2007, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/August07\/chalmersdionissievbayoiloilforfoodpleaspr.pdf.","Documents":""},{"Case ID":"ST-136","Case Cluster ":"David Chalmers\/ Bayoil","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"08\/17","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Restitution","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$0","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Iraq via Development Fund for Iraq (see Summary for explanation)","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Multiple counts of conspiracy to commit wire fraud, violations of sanctions","Offenses - Settled":"Conspiracy to commit wire fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a press release by the United States Attorney for the Southern District of New York, \u0022David B. Chalmers, Jr. [ ] and two corporations that he operated -- BAYOIL (USA), INC. [  ] BAYOIL SUPPLY \u0026 TRADING LIMITED, a Bahamian company with principal offices in Nassau, Bahamas (collectively, the \u0022BAYOIL COMPANIES\u0022). CHALMERS and the BAYOIL COMPANIES each pleaded guilty today before United States District Judge DENNY CHIN to participating in a scheme to pay illegal surcharges to the former Government of Iraq in connection with the purchase of crude oil in the United Nations Oil-for-Food Program between mid-2000 and 2003. Judge CHIN also accepted earlier today the guilty plea of LUDMIL DIONISSIEV to related smuggling charges. DIONISSIEV worked with CHALMERS and the BAYOIL COMPANIES during the course of this scheme to purchase Iraqi oil. CHALMERS and the BAYOIL COMPANIES each pleaded guilty to participating in a conspiracy to commit wire fraud related to the payment of secret illegal surcharge payments to the former Government of Iraq.\u0022  (Source: United States Attorney for the Southern District of New York, \u0022U.S. Announces Four Guilty Pleas in Oil-for-Food Case,\u0022 August 17, 2007.)  According to the Restitution Order, on March 18, 2008, Mr. Chalmers and the Bayoil companies were ordered joint and severally liable for payment of restitution in the amount of $9,016,151.40 and the defendants were ordered to pay this sum \u0022in restitution to the Development Fund for Iraq, in care of Ambassador Srood Najib.\u0022 (Source: US v. David Chalmers, et al, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Order of Restitution filed March 25, 2008.)  Please note that the restitution figure has been included only in the company entry so as to avoid double-counting.  ","Sources ":"US v. David B. Chalmers, Jr., Bayoil (USA) Inc., and Bayoil Supply \u0026 Trading Limited, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Order of Restitution filed on March 25, 2008; United States Attorney Southern District of New York Press Release, \u0022U.S. Announces Four Guilty Pleas in Oil-for-Food Case,\u0022 August 17, 2007, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/August07\/chalmersdionissievbayoiloilforfoodpleaspr.pdf.","Documents":""},{"Case ID":"ST-137","Case Cluster ":"David Chalmers\/ Bayoil","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"08\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$5,000.00","Criminal Fine\/Penalty (US$) ":"$5,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Multiple counts of conspiracy to commit wire fraud, violations of sanctions, smuggling of goods","Offenses - Settled":"Smuggling of goods","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a press release by the United States Attorney for the Southern District of New York, \u0022David B. Chalmers, Jr. [ ] and two corporations that he operated -- BAYOIL (USA), INC. [  ] BAYOIL SUPPLY \u0026 TRADING LIMITED, a Bahamian company with principal offices in Nassau, Bahamas (collectively, the \u0022BAYOIL COMPANIES\u0022). CHALMERS and the BAYOIL COMPANIES each pleaded guilty today before United States District Judge DENNY CHIN to participating in a scheme to pay illegal surcharges to the former Government of Iraq in connection with the purchase of crude oil in the United Nations Oil-for-Food Program between mid-2000 and 2003. Judge CHIN also accepted earlier today the guilty plea of LUDMIL DIONISSIEV to related smuggling charges. DIONISSIEV worked with CHALMERS and the BAYOIL COMPANIES during the course of this scheme to purchase Iraqi oil. CHALMERS and the BAYOIL COMPANIES each pleaded guilty to participating in a conspiracy to commit wire fraud related to the payment of secret illegal surcharge payments to the former Government of Iraq.\u0022  (Source: United States Attorney for the Southern District of New York, \u0022U.S. Announces Four Guilty Pleas in Oil-for-Food Case,\u0022 August 17, 2007.)  According to the Court Docket Report in US v. Chalmers, et al, Dionissiev paid the $5,000 fine on December 17, 2007. (Source: US v. Chalmers, et al Case No. 1:05-cr-00059-DC (S.D.N.Y.), Court Docket Report as of October 26, 2011.) ","Sources ":"US v. David B. Chalmers, Jr., Bayoil (USA) Inc., and Bayoil Supply \u0026 Trading Limited, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Order of Restitution filed on March 25, 2008; http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/March08\/chalmersetalsentencingpr.pdf.  United States Attorney Southern District of New York Press Release, \u0022U.S. Announces Four Guilty Pleas in Oil-for-Food Case,\u0022 August 17, 2007, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/August07\/chalmersdionissievbayoiloilforfoodpleaspr.pdf; US v. Chalmers, et al, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Court Docket Report as of October 26, 2011 (accessed via Pacer).","Documents":""},{"Case ID":"ST-138","Case Cluster ":"Delta Pine \u0026 Land Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Turkey","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"07\/25","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order ","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$300,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$300,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2 ","Offenses - Alleged":"Bribery of Foreign Officials (Turk Deltapine); Internal controls violations (Delta \u0026 Pine); Falsification of books and records (Delta \u0026 Pine)","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"No (Certification) ","Summary":"According to the US Securities and Exchange Commission Litigation Release in the case, on July 25 and July 26, 2007, the Commission filed two settled enforcement proceedings charging Delta \u0026 Pine Land Company, engaged in the production and marketing of cottonseed, and its subsidiary, Turk Deltapine, inc., with FCPA violations.  Delta Pine and Turk Deltapine consented to both actions without admitting or denying the allegations.  In both the July 25 US District Court complaint and the July 26 SEC Administrative Order, the Commission had charged that from 2001 through 2006, Turk Deltapine made payments of approximately $43,000 to officials of the Turkish Ministry of Agricultural and Rural Affairs in order to obtain governmental reports and certifications that were necessary for Turk Deltapine to obtain, retain, and operate its businesses in Turkey. In the federal lawsuit, Delta \u0026 Pine and Turk Deltapine agreed to the entry of a final judgment requiring them to pay jointly and severally a $300,000 penalty.  (Source:  SEC Litigation Release No. 20214 (July 26, 2007), CORRECTED, SEC v. Delta \u0026 Pine Land Company and Turk Deltapine, inc., Case No. 1:07-cv-01352 (RWR) (D.D.C.), Complaint filed July 25, 2007).","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Delta Pine \u0026 Land Company at 84-85, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf;  SEC v. Delta \u0026 Pine Land Company and Turk Deltapine, Inc., No. 1:07-cv-01352, (D.D.C. 2007): Administrative Proceeding No. 3-12712, Litigation Release No. 20214 (July 26, 2007); Final Judgment filed August 22, 2007 - all SEC enforcement action related documents accessed at www.fcpa.shearman.com, case entry SEC v. Delta \u0026 Pine Land Company and Turk Deltapine.","Documents":""},{"Case ID":"ST-139","Case Cluster ":"Deutsche Telekom AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Montenegro","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"12\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$4,360,000.00","Criminal Fine\/Penalty (US$) ":"$4,360,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Falsification of Books and Records","Offenses - Settled":"Falsification of Books and Records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022Magyar Telekom Plc., a Hungarian telecommunications company, and Deutsche Telekom AG, a German telecommunications company and majority owner of Magyar Telekom, have agreed to pay a combined $63.9 million criminal penalty to resolve a Foreign Corrupt Practices Act (FCPA) investigation into activities by Magyar Telekom and its subsidiaries in Macedonia and Montenegro. [ ]  The department filed a criminal information against Magyar Telekom and a two-year deferred prosecution agreement in U.S. District Court for the Eastern District of Virginia today.   The three-count information charges Magyar Telekom with one count of violating the anti-bribery provision of the FCPA and two counts of violating the books and records provisions of the FCPA.   At the time of the charged conduct, Magyar Telekom\u0027s American Depository Receipts (ADRs) traded on the New York Stock Exchange (NYSE).   As part of the deferred prosecution agreement, Magyar Telekom agreed to pay a $59.6 million penalty for its illegal activity [  ]    \r\n\r\nAccording to court documents, Magyar Telekom\u0027s scheme in Macedonia stemmed from potential legal changes being made to the telecommunications market in that country.    In early 2005, the Macedonian government tried to liberalize the Macedonian telecommunications market in a way that Magyar Telekom deemed detrimental to its Macedonian subsidiary, Makedonski Telekommunikacii AD Skopje (MakTel).   Throughout the late winter and spring of 2005, Magyar Telekom executives, with the help of Greek intermediaries, lobbied Macedonian government officials to prevent the implementation of the new telecommunications laws and regulations. [ ]  According to court documents, in order to secure the benefits in the protocol of cooperation, the Magyar Telekom executives engaged in a course of conduct with consultants, intermediaries and other third parties, including through sham consultancy contracts with entities owned and controlled by a Greek intermediary, to pay \u20ac4.875 (approximately $6 million) under circumstances in which they knew, or were aware of a high probability that circumstances existed in which, all or part of such payment would be passed on to Macedonian officials.   The sham contracts were recorded as legitimate on MakTel\u0027s books and records, which were consolidated into Magyar Telekom\u0027s financials.   Deutsche Telekom, which owned approximately 60 percent of Magyar Telekom, reported in the results of Magyar Telekom\u0027s operations in its consolidated financial statements.    \r\n\r\n Additionally, the criminal information charges Magyar Telekom with falsifying its books and records in regard to its activity in Montenegro.   According to the court filing, Magyar Telekom made improper payments in connection with its acquisition of a state-owned telecommunications company in Montenegro.   These payments were documented on Magyar Telekom\u0027s books and records through the execution of four bogus contracts.   For example, two of the contracts were backdated and concealed the true counterparties, and no legitimate services were provided under the contracts even though the contracts were for \u20ac4.47 million.\r\n\r\nThe department today also entered into a two-year non-prosecution agreement with Magyar Telekom\u0027s parent company, Deutsche Telekom, for its failure to keep books and records that accurately detailed the activities of Magyar Telekom.   Deutsche Telekom, which is headquartered in Germany, agreed to pay a $4.36 million penalty in connection with the inaccurate books and records.\u0022  (Source: US Department of Justice Press Release, Magyar Telekom and Deutsche Telekom Resolve Foreign Corrupt Practices Act Investigation and Agree to Pay Nearly $64 Million in Combined Criminal Penalties,\u0022 December 29, 2011.)","Sources ":"US Department of Justice, In Re: Deutsche Telekom AG, Non-Prosecution Agreeement dated December 29, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/deutsche-telekom\/2011-12-29-deustche-telekom-npa.pdf; US Department of Justice Press Release, Magyar Telekom and Deutsche Telekom Resolve Foreign Corrupt Practices Act Investigation and Agree to Pay Nearly $64 Million in Combined Criminal Penalties,\u0022 December 29, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/December\/11-crm-1714.html","Documents":""},{"Case ID":"ST-140","Case Cluster ":"Deutsche Telekom AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Macedonia and Montenegro","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"12\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$31,200,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$31,200,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, Falsification of Books and Records","Offenses - Settled":"No Admission or Denial of Allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, on December 29, 2011, the Commission \u0022charged the largest telecommunications provider in Hungary and three of its former top executives with bribing government and political party officials in Macedonia and Montenegro to win business and shut out competition in the telecommunications industry. The SEC alleges that three senior executives at Magyar Telekom Plc. orchestrated, approved, and executed a plan to bribe Macedonian officials in 2005 and 2006 to prevent the introduction of a new competitor and gain other regulatory benefits. Magyar Telekom\u0027s subsidiaries in Macedonia made illegal payments of approximately $6 million under the guise of bogus consulting and marketing contracts. The same executives orchestrated a second scheme in 2005 in Montenegro related to Magyar Telekom\u0027s acquisition of the state-owned telecommunications company there. Magyar Telekom paid approximately $9 million through four sham contracts to funnel money to government officials in Montenegro. Magyar Telekom\u0027s parent company Deutsche Telekom AG also is charged with books and records and internal controls violations of the Foreign Corrupt Practices Act (FCPA).\u0022 (Source:  US Securities and Exchange Commission, Litigation Release No. 22213 \/ December 29, 2011, SEC v. Magyar Telekom Plc. and Deutsche Telekom AG, Case No. 11 civ 9646 (S.D.N.Y.) and SEC v. Straub, et al., Case No. 11 civ 9645 (S.D.N.Y.), \u0022SEC Charges Magyar Telekom and Former Executives with Bribing Officials in Macedonia and Montenegro.\u0022)\r\n\r\n","Sources ":"US Securities and Exchange Commission, Litigation Release No. 22213 \/ December 29, 2011, SEC v. Magyar Telekom Plc. and Deutsche Telekom AG, Case No. 11 civ 9646 (S.D.N.Y.) and SEC v. Straub, et al., Case No. 11 civ 9645 (S.D.N.Y.), \u0022SEC Charges Magyar Telekom and Former Executives with Bribing Officials in Macedonia and Montenegro,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr22213.htm; Complaint in SEC v. Magyar Telekom plc and Deutsche Telekom AG, Case No. 1:11-cv-9646 (S.D.N.Y.. December 29, 2011), accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp22213-co.pdf","Documents":""},{"Case ID":"ST-141","Case Cluster ":"Deutsche Telekom AG","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Montenegro","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"12\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$59,600,000.00","Criminal Fine\/Penalty (US$) ":"$59,600,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022Magyar Telekom Plc., a Hungarian telecommunications company, and Deutsche Telekom AG, a German telecommunications company and majority owner of Magyar Telekom, have agreed to pay a combined $63.9 million criminal penalty to resolve a Foreign Corrupt Practices Act (FCPA) investigation into activities by Magyar Telekom and its subsidiaries in Macedonia and Montenegro. [ ]  The department filed a criminal information against Magyar Telekom and a two-year deferred prosecution agreement in U.S. District Court for the Eastern District of Virginia today.   The three-count information charges Magyar Telekom with one count of violating the anti-bribery provision of the FCPA and two counts of violating the books and records provisions of the FCPA.   At the time of the charged conduct, Magyar Telekom\u0027s American Depository Receipts (ADRs) traded on the New York Stock Exchange (NYSE).   As part of the deferred prosecution agreement, Magyar Telekom agreed to pay a $59.6 million penalty for its illegal activity [  ]    \r\n\r\nAccording to court documents, Magyar Telekom\u0027s scheme in Macedonia stemmed from potential legal changes being made to the telecommunications market in that country.    In early 2005, the Macedonian government tried to liberalize the Macedonian telecommunications market in a way that Magyar Telekom deemed detrimental to its Macedonian subsidiary, Makedonski Telekommunikacii AD Skopje (MakTel).   Throughout the late winter and spring of 2005, Magyar Telekom executives, with the help of Greek intermediaries, lobbied Macedonian government officials to prevent the implementation of the new telecommunications laws and regulations. [ ]  According to court documents, in order to secure the benefits in the protocol of cooperation, the Magyar Telekom executives engaged in a course of conduct with consultants, intermediaries and other third parties, including through sham consultancy contracts with entities owned and controlled by a Greek intermediary, to pay \u20ac4.875 (approximately $6 million) under circumstances in which they knew, or were aware of a high probability that circumstances existed in which, all or part of such payment would be passed on to Macedonian officials.   The sham contracts were recorded as legitimate on MakTel\u0027s books and records, which were consolidated into Magyar Telekom?s financials.   Deutsche Telekom, which owned approximately 60 percent of Magyar Telekom, reported in the results of Magyar Telekom\u0027s operations in its consolidated financial statements.    \r\n\r\n Additionally, the criminal information charges Magyar Telekom with falsifying its books and records in regard to its activity in Montenegro.   According to the court filing, Magyar Telekom made improper payments in connection with its acquisition of a state-owned telecommunications company in Montenegro.   These payments were documented on Magyar Telekom\u0027s books and records through the execution of four bogus contracts.   For example, two of the contracts were backdated and concealed the true counterparties, and no legitimate services were provided under the contracts even though the contracts were for \u20ac4.47 million.\r\n\r\nThe department today also entered into a two-year non-prosecution agreement with Magyar Telekom\u0027s parent company, Deutsche Telekom, for its failure to keep books and records that accurately detailed the activities of Magyar Telekom.   Deutsche Telekom, which is headquartered in Germany, agreed to pay a $4.36 million penalty in connection with the inaccurate books and records. [ ]  Significant assistance was provided by the FBI Washington Field Office?s dedicated FCPA squad, the SEC Division of Enforcement, the Criminal Division\u0027s Office of International Affairs and international legal partners in Switzerland, Germany, Greece, Hungary and the Republic of Macedonia. (Source: US Department of Justice Press Release, Magyar Telekom and Deutsche Telekom Resolve Foreign Corrupt Practices Act Investigation and Agree to Pay Nearly $64 Million in Combined Criminal Penalties,\u0022 December 29, 2011.)","Sources ":"US v. Magyar Telecom, Plc, Case No. 1:11-cr-00597 (E.D. Va.), Information filed December 29, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/magyar-telekom\/2011-12-29-information-magyar-telekom.pdf; Deferred Prosecution Agreement filed December 29, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/magyar-telekom\/2011-12-29-dpa-magyar.pdf.  US Department of Justice, In Re: Deutsche Telekom AG, Non-Prosecution Agreeement dated December 29, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/deutsche-telekom\/2011-12-29-deustche-telekom-npa.pdf; US Department of Justice Press Release, Magyar Telekom and Deutsche Telekom Resolve Foreign Corrupt Practices Act Investigation and Agree to Pay Nearly $64 Million in Combined Criminal Penalties,\u0022 December 29, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/December\/11-crm-1714.html","Documents":""},{"Case ID":"ST-142","Case Cluster ":"Diageo plc","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Thailand, India, South Korea","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"07\/27","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$16,373,820.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$11,306,081","Civil Prejudgment Interest (US$) ":"$2,067,739","Civil Fine \/ Penalty (US$)":"$3,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records ","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"No (Customs, Tax)","Summary":"According to a US Securities and Exchange Commission Press Release, \u0022According to the SEC\u0027s order instituting settled administrative proceedings against Diageo, the company made more than $1.7 million in illicit payments to hundreds of government officials in India from 2003 to mid-2009. The officials were responsible for purchasing or authorizing the sale of its beverages in India, and increased sales from these payments yielded more than $11 million in profit for the company.  The SEC found that from 2004 to mid-2008, Diageo paid approximately $12,000 per month -- totaling nearly $600,000 -- to retain the consulting services of a Thai government and political party official. This official lobbied other high-ranking Thai government officials extensively on Diageo?s behalf in connection with pending multi-million dollar tax and customs disputes, contributing to Diageo\u0027s receipt of certain favorable decisions by the Thai government.  According to the SEC\u0027s order, Diageo paid 100 million in Korean currency (more than $86,000 in U.S. dollars) to a customs official in South Korea as a reward for his role in the government\u0027s decision to grant Diageo significant tax rebates. Diageo also improperly paid travel and entertainment expenses for South Korean customs and other government officials involved in these tax negotiations. Separately, Diageo routinely made hundreds of gift payments to South Korean military officials in order to obtain and retain liquor business. [  ] Without admitting or denying the findings, Diageo agreed to cease and desist from further violations and pay $11,306,081 in disgorgement, prejudgment interest of $2,067,739, and a financial penalty of $3 million.\u0022 (Source: US Securities and Exchange Commission Press Release, \u0022SEC Charges Liquor Giant Diageo with FCPA Violations,\u0022 July 27, 2011.)","Sources ":"US Securities and Exchange Commission Press Release, \u0022SEC Charges Liquor Giant Diageo with FCPA Violations,\u0022 July 27, 2011, accessed at http:\/\/www.sec.gov\/news\/press\/2011\/2011-158.htm; In the Matter of Diageo plc, SEC Administrative Proceeding File No. 3-14490, \u0022Order Instituting Cease-and-Desist Proceedings,\u0022 July 27, 2011, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2011\/34-64978.pdf","Documents":""},{"Case ID":"ST-143","Case Cluster ":"Diagnostic Products Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China ","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"05\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$2,788,622.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$2,038,727","Civil Prejudgment Interest (US$) ":"$749,895","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations  ","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Diagnostic Products Corporation, at 109-110:  From late 1991 through December 2002, DPC (Tianjin) Co., Ltd., a subsidiary of Diagnostics Product Corporation paid approximately $1.6 million in bribes in the form of illegal \u0022commissions\u0022 to physicians and lab personnel employed at government-owned hospitals in China in exchange for agreements that the hospitals would obtain DPC Tianjin\u0027s products and services. In most cases, bribes were paid in cash. The \u0022commissions,\u0022 typically between 3 percent and 10 percent of sales, allowed DPC Tianjin to earn approximately $2 million in profits from the sales. DPC Tianjin pleaded guilty to violating the FCPA and paid criminal fine of $2 million; to resolve SEC charges, DPC agreed to the issuance of an order to cease-and-desist from future violations and to disgorge $2,038,727 and $749,895 in prejudgment interest to the SEC.  Resulting Criminal Enforcement Actions: US v. DPC (Tianjin) Co., Ltd. (C.D. Cal., May 20, 2005); Resulting Civil\/Administrative Enforcement Action: In the Matter of Diagnostic Products Corporation (May 20, 2005).","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Diagnostic Products Corporation, at 109-110, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; In the Matter of Diagnostic Products Corporation, US Securities and Exchange Commission, Administrative Proceeding File No. 3-11933, Order Instituting Cease and Desist Proceedings, May 20, 2005, accessed at http:\/\/www.sec.gov\/litigation\/admin\/34-51724.pdf","Documents":""},{"Case ID":"ST-144","Case Cluster ":"Diagnostic Products Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China ","Year of Settlement":"2005","Month\/Day of Settlement (or Notes)":"05\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,000,000.00","Criminal Fine\/Penalty (US$) ":"$2,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Diagnostic Products Corporation, at 109-110:  From late 1991 through December 2002, DPC (Tianjin) Co., Ltd., a subsidiary of Diagnostics Product Corporation paid approximately $1.6 million in bribes in the form of illegal \u0022commissions\u0022 to physicians and lab personnel employed at government-owned hospitals in China in exchange for agreements that the hospitals would obtain DPC Tianjin\u0027s products and services. In most cases, bribes were paid in cash. The \u0022commissions,\u0022 typically between 3 percent and 10 percent of sales, allowed DPC Tianjin to earn approximately $2 million in profits from the sales. DPC Tianjin pleaded guilty to violating the FCPA and paid criminal fine of $2 million; to resolve SEC charges, DPC agreed to the issuance of an order to cease-and-desist from future violations and to disgorge $2,038,727 and $749,895 in prejudgment interest to the SEC.  Resulting Criminal Enforcement Actions: US v. DPC (Tianjin) Co., Ltd. (C.D. Cal., May 20, 2005); Resulting Civil\/Administrative Enforcement Action: In the Matter of Diagnostic Products Corporation (May 20, 2005).","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Diagnostic Products Corporation, at 109-110, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.  US v. DPC (Tianjin), Case No. 05-cr-482 (C.D. Cal.), Information filed on May 20, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/dpc-tianjin\/05-20-05dpc-tianjin-info.pdf; Plea Agreement filed on May 20, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/dpc-tianjin\/05-19-05dpc-tianjin-plea-agree.pdf; Judgment filed June 21, 2005, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/dpc-tianjin\/06-23-05dpc-tianjin-judge.pdf","Documents":""},{"Case ID":"ST-145","Case Cluster ":"Dow Chemical Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"India","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"02\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$325,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$325,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"No (Registration and Inspection) ","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Dow Chemical Company, at 96:  (1) DE-Nocil, a subsidiary of Dow, made approximately $200,000 in improper payments to Indian government officials, including $39,700 to an official in India\u0027s Central Insecticides Board to expedite the registration of three DE-Nocil products. DE-Nocil made $435,000 in profits because of the accelerated registration, $329,295 of which went to Dow. (2) DE-Nocil payment of approximately $87,400 in small ($100 or less) payments to state-level agricultural inspectors to keep them from interfering in the sale of DE-Nocil products. (3) DE-Nocil payments to sales tax officials and customs officials, as well as improper gifts, travel, and entertainment to other government officials ($19,000), totalling more than $70,000.  To resolve SEC charges, Dow Chemical agreed to cease-and-desist order and pay $325,000 in civil penalties.  Resulting Civil\/Administrative Enforcement Actions: SEC v. Dow Chemical Company (D.D.C., February 13, 2007); In the Matter of Dow Chemical Company (February 13, 2007), which noted that payments to Central Insecticides Board official was through use of consultants and unrelated companies (para 5); and the third set of improper payments included  $11,800 to sales tax officials; $3,700 to excise tax officials; and $1,500 to customs officials. (para 10)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Dow Chemical Company, at 96, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; In the Matter of Dow Chemical Company, Administrative Proceeding File No. 3-12567, Order Instituting Cease-and-Desist Proceedings (February 13, 2007), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2007\/34-55281.pdf; SEC v. The Dow Chemical Company, Case No. 07-cv-0336 (D.D.C.), Consent of the Dow Chemical Company filed March 5, 2007, accessed at http:\/\/fcpa.shearman.com\/files\/e3a\/e3a9b7ff98db69bdcf91a57abb71ad9b.pdf?i=350f24b2193e00eee96548107c6882d6.  ","Documents":""},{"Case ID":"ST-146","Case Cluster ":"El Paso Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"02\/07","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Civil Penalty","Total Monetary Sanctions (US$)":"$2,250,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$2,250,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Faliure to Maintain Books and Records, Internal Controls Violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, the Commission filed a settled complaint on February 7, 2007, which alleged \u0022that from approximately June 2001 through June 2002, El Paso, and its predecessor in-interest The Coastal Corporation, indirectly made approximately $5.5 million in illegal surcharge payments to Iraq in connection with its purchases of crude oil from third parties under the U.N. Oil for Food Program. The Program was intended to provide humanitarian relief for the Iraqi population, which faced severe hardship under international trade sanctions. However, beginning in August 2000, officials of Iraqi State Oil Marketing Organization, began demanding illegal kickbacks. The kickbacks were made in the form of surcharges, and were sent to Iraqi-controlled accounts at banks in Jordan and Lebanon. [  ]  El Paso, without admitting or denying the allegations in the Commission\u0027s complaint, consented to the entry of a final judgment permanently enjoining it from future violations of Sections 13(b)(2)(A) and 13(b)(2)(B) of the Securities Exchange Act of 1934, ordering it to disgorge $5,482,363 in profits, and to pay a civil penalty of $2,250,000. El Paso will satisfy its disgorgement obligation by forfeiting $5,482,363 pursuant to a non-prosecution agreement with the U.S. Attorney\u0027s Office for the Southern District of New York.\u0022 (Source: US Securities and Exchange Commission Litigation Release No. 19991 \/ February 7, 2007, Securities and Exchange Commission v. El Paso Corporation, Civil Action No. 07CV00899 (S.D.N.Y.), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against El Paso Corporation For Improper Payments to Iraq Under the U.N. Oil for Food Program - - Company Agrees to Pay $7.7 Million.\u0022)  Please note that the Disgorgement penalty has not been noted in this entry as it is already noted in the El Paso criminal case settlement. \r\n\r\n","Sources ":"US Securities and Exchange Commission Litigation Release No. 19991 \/ February 7, 2007, Securities and Exchange Commission v. El Paso Corporation, Civil Action No. 07CV00899 (S.D.N.Y.), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against El Paso Corporation For Improper Payments to Iraq Under the U.N. Oil for Food Program - - Company Agrees to Pay $7.7 Million,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr19991.htm; Complaint filed February 7, 2007, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2007\/comp19991.pdf","Documents":""},{"Case ID":"ST-147","Case Cluster ":"El Paso Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Iraq (\u0022UN Oil-for-Food\u0022)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"02\/05","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$5,482,363.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$5,482,363 ","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$5,482,363","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Iraq via Development Fund for Iraq","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to Defraud the United States, Wire Fraud","Offenses - Settled":"Failure to Maintain Internal Controls","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to El Paso Corporation\u0027s Non-Prosecution Agreement with the United States Attorney for the Southern District of New York, following the merger between El Paso Corporation and The Costal Corporation, \u0022EL PASO purchased Iraqi oil from third-party intermediaries and\/or allocation holders.  Although EL PASO took steps designed to prevent the purchase of Iraqi oil from third parties on which illegal surcharges had been paid, such procedures proved inadequate.  The United States Government has represented to EL PASO that records maintained by the former Government of Iraq and its agents demonstrate that, from June 2001 until May 2002, EL PASO purchased Iraqi oil for which third-party intermediaries and\/or allocation holders paid approximately $5.48 million in illegal surcharges to the former Government of Iraq.  These surcharge payments were not deposited into the Oil-for-Food Program\u0027s escrow account, which was established to purchase humanitarian goods for the Iraqi people. [ ] It is the intent of the United States Attorney\u0027s Office for the Southern District of New York to seek the transfer of these funds to the Development Fund for Iraq [ ] to be used as restitution to the Iraqi people as the intended beneficiaries of the proceeds of all Iraqi oil pursuant to the United Nations Oil-for-Food Program.\u0022  (Source: In Re: El Paso Corporation, Non-Prosecution Agreement with the United States Attorney for the Southern District of New York, Department of Justice, February 5, 2007.)","Sources ":"In Re: El Paso Corporation, Non-Prosecution Agreement with the United States Attorney for the Southern District of New York, February 5, 2007, accessed at http:\/\/fcpa.shearman.com\/files\/82c\/82c7a6a47d469bdfa8a7c6d82bf03737.pdf?i=dfef6d9305307bf27b828e9290194bef; United States Attorney for the Southern District of New York Press Release, \u0022Texas Oil Executive and Two Corporations Sentenced on Charges Involving a Scheme to Pay Secret Kickbacks to the Former Government of Saddam Hussein,\u0022 March 7, 2008, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/March08\/chalmersetalsentencingpr.pdf","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/El_Paso_SDNY_Non-Prosecution_Agreement_Feb_2007.pdf"},{"Case ID":"ST-148","Case Cluster ":"El Paso Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Southern District of New York","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"10\/01","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Restitution","Total Monetary Sanctions (US$)":"$11,023,245.91","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$11,023,245.91","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$11,023,245.91","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Iraq via Development Fund for Iraq","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to commit wire fraud, Wire Fraud and others","Offenses - Settled":"Conspiracy to commit wire fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Court Docket Report in US v. Wyatt, on October 1, 2007, Mr. Wyatt,  charged with numerous misconduct related to the UN Oil-for-Food Programme a co-defendant in the case, changed his plea during mid-trial to a plea of guilty to one count conspiracy to commit wire fraud; on November 28, 2007, he was ordered to pay $11,023,245.91 in restitution (Source:  US v. Wyatt, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Court Docket Report retrieved January 5, 2012.)  According to the US Government\u0027s Sentencing Memorandum, \u0022In light of Wyatt\u0027s conduct, the parties have agreed in the Plea Agreement that Wyatt should forfeit $11,023,245.91.  That is the total value of: [1] the SOMO satellite communications services that Wyatt paid for (approximately $3,400,000), see supra; [2] the Phase 8 surcharge payment that Wyatt caused to be paid (220,000 Euros - approximately $200,000), see supra; and [3] the surcharge payments made in connection with the Phase 9-12 Nafta and Mednafta oil allocations (approximately $7,423,246). In the Government?s view, an appropriate representative of the people of Iraq for these purposes is the Development Fund for Iraq (\u0022DFI\u0022), an entity that has, according to published reports, received more than 2 billion dollars on behalf of the Iraqi people, and which has used the funds at its disposal to, among other things, buy wheat for the Iraqi people, and to improve the country\u0027s now-damaged electrical infrastructure. In connection with this matter, the United States Attorney\u0027s Office will work to transfer any funds forfeited by Wyatt to the DFI.\u0022  The Government\u0027s Sentencing Memorandum also noted that Mr. Wyatt used Cypriot \u0022Front Companies\u0022 in carrying out his misconduct. (US v. Wyatt, Case No. 1:05-cr-59-DC (S.D.N.Y.), Government Sentencing Memorandum filed November 26, 2007.)","Sources ":"United States Attorney Southern District of New York Press Release, \u0022U.S. Announces Four Guilty Pleas in Oil-for-Food Case,\u0022 August 17, 2007, accessed at http:\/\/www.justice.gov\/usao\/nys\/pressreleases\/November07\/wyattsentencingpr.pdf; US v. Wyatt, Case No. 1:05-cr-00059-DC (S.D.N.Y.), Court Docket Report as of January 4, 2012 and Government Sentencing Memorandum filed November 26, 2007 (accessed via Pacer).","Documents":""},{"Case ID":"ST-149","Case Cluster ":"Electronic Data Systems Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"India","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"09\/25","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$490,902.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$358,800","Civil Prejudgment Interest (US$) ":"$132,102","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Disclosure violations, Regulation violations ","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Electronic Data Systems Corporation, at 81-82: Misconduct in India, 2001-2003; EDS\u0027s former Indian subsidiary, A.T. Kearney Ltd. - India (ATKI) alleged to have made at least $720,000 in illicit payments to high-level employees of two Indian state-owned enterprises threatened in order to retain business with those enterprises; ATKI made the payments at the direction of Srninivasan, ATKI\u0027s president, after the officials of the state-owned enterprises threatened to cancel the contracts with ATKI. These bribes allowed EDS to recognize over $7.5 million in revenue from the Indian companies\u0027 contracts after ATKI began paying the bribes.  Settlement amounts: $70,000 civil penalty (Srinivasan), $358,800 disgorgement and $132,102 prejudgment interest (EDS \/ ATKI-related penalties).  Resulting civil enforcement\/administrative actions:  In the Matter of Electronic Data Systems Corporation (September 25, 2007); SEC v. Chandramowli Srinivasan (D.D.C., September 25, 2007).","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Electronic Data Systems Corporation, at 81-82, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; SEC v. Chandramowli Srinivasan, case summary and related documents at http:\/\/fcpa.shearman.com\/?mode=form\u0026id=221; In the Matter of Electronic Data Systems Corporation, Administrative Proceedings, File No. 3-12825, Order Instituting Cease and Desist Proceedings (September 25, 2007), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2007\/34-56519.pdf.","Documents":""},{"Case ID":"ST-150","Case Cluster ":"Electronic Data Systems Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"India","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"09\/25","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$70,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$70,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, False accounting violations","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Electronic Data Systems Corporation, at 81-82: Misconduct in India, 2001-2003; EDS\u0027s former Indian subsidiary, A.T. Kearney Ltd. - India (ATKI) alleged to have made at least $720,000 in illicit payments to high-level employees of two Indian state-owned enterprises threatened in order to retain business with those enterprises; ATKI made the payments at the direction of Srninivasan, ATKI\u0027s president, after the officials of the state-owned enterprises threatened to cancel the contracts with ATKI. These bribes allowed EDS to recognize over $7.5 million in revenue from the Indian companies\u0027 contracts after ATKI began paying the bribes.  Settlement amounts: $70,000 civil penalty (Srinivasan), $358,800 disgorgement and $132,102 prejudgment interest (EDS \/ ATKI-related penalties).  Resulting civil enforcement\/administrative actions:  In the Matter of Electronic Data Systems Corporation (September 25, 2007); SEC v. Chandramowli Srinivasan (D.D.C., September 25, 2007).","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Electronic Data Systems Corporation, at 81-82, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; SEC v. Chandramowli Srinivasan, case summary and related documents at http:\/\/fcpa.shearman.com\/?mode=form\u0026id=221; In the Matter of Electronic Data Systems Corporation, Administrative Proceedings, File No. 3-12825, Order Instituting Cease and Desist Proceedings (September 25, 2007), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2007\/34-56519.pdf.","Documents":""},{"Case ID":"ST-151","Case Cluster ":"Faro Technologies, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"06\/05","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,100,000.00","Criminal Fine\/Penalty (US$) ":"$1,100,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records","Offenses - Settled":"Bribery of foreign official ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to DOJ Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Faro Technologies, at 35-37:  Time period of misconduct in China was 2003-2006.  Faro Technologies is a Florida-based company that develops and markets portable computerized measurement devices and software.  SEC complaint stated that Oscar H. Meza, the company\u0027s Vice-President for Asia-Pacific Sales and Director of Asia-Pacific Sales for Faro.  According to the Statement of Facts, Faro began direct sales of its products in China through its subsidiary, Faro China, based in Shanghai.  On several occasions, Meza authorized other Faro employees to make corrupt payments directly to employees of state-owned or controlled entities in China to secure business for Faro.  Meza authorized total of $444,492 in corrupt payments which allowed Faro to secure contracts worth approximately $4.5 - $4.9 million in sales an $1.4 million in net profits. Use of intermediary and shell company to funnel\/disguise bribe payments. DOJ: Criminal fine of $1.1 million (Faro); Civil: Disgorgement of $1.85 million (Faro); Civil Penalty of $30K (Meza), and Disgorgement and Prejudgment interest of $26,707 (Meza).  Related Criminal Enforcement Actions: In Re Faro Technologies Inc. (June 5, 2008); Civil Administrative \/ Enforcement Actions: SEC v. Oscar H. Meza (D.D.C., August 28, 2009), In the Matter of Faro Technologies, Inc. (June 5, 2008). ","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Faro Technologies, Inc. at 35-36, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Department of Justice Press Release, \u0022Faro Technologies Inc. Agrees to Pay $1.1 Million Penalty and Enter Non-Prosecution Agreement for FCPA Violations,\u0022 accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/June\/08-crm-505.html (accessed September 15, 2011).","Documents":""},{"Case ID":"ST-152","Case Cluster ":"Faro Technologies, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"06\/05","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$1,850,943.32","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,411,306","Civil Prejudgment Interest (US$) ":"$439,637","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to DOJ Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Faro Technologies, at 35-37:  Time period of misconduct in China was 2003-2006.  Faro Technologies is a Florida-based company that develops and markets portable computerized measurement devices and software.  SEC complaint stated that Oscar H. Meza, the company\u0027s Vice-President for Asia-Pacific Sales and Director of Asia-Pacific Sales for Faro.  According to the Statement of Facts, Faro began direct sales of its products in China through its subsidiary, Faro China, based in Shanghai.  On several occasions, Meza authorized other Faro employees to make corrupt payments directly to employees of state-owned or controlled entities in China to secure business for Faro.  Meza authorized total of $444,492 in corrupt payments which allowed Faro to secure contracts worth approximately $4.5 - $4.9 million in sales an $1.4 million in net profits. Use of intermediary and shell company to funnel\/disguise bribe payments. DOJ: Criminal fine of $1.1 million (Faro); Civil: Disgorgement of $1.85 million (Faro; encompassing $1,411,306 disgorgement and $439,637.32 prejudgment interest); Civil Penalty of $30K (Meza), and Disgorgement and Prejudgment interest of $26,707 (Meza).  Related Criminal Enforcement Actions: In Re Faro Technologies Inc. (June 5, 2008); Civil Administrative \/ Enforcement Actions: SEC v. Oscar H. Meza (D.D.C., August 28, 2009), In the Matter of Faro Technologies, Inc. (June 5, 2008). ","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Faro Technologies, Inc. at 35-36, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Securities and Exchange Commission, In the Matter of Faro Technologies, Inc., Administrative Proceeding File No. 3-13059 (June 5, 2008), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2008\/34-57933.pdf","Documents":""},{"Case ID":"ST-153","Case Cluster ":"Faro Technologies, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"08\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$56,707.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$26,707","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$30,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art, 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, False accounting, False statements to accountants, Aiding and abetting Faro\u0027s bribery of foreign officials, Aiding and abetting Faro\u0027s internal controls violations, Aiding and abetting Faro\u0027s falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, \u0022On August 28, 2009, the Securities and Exchange Commission filed a settled enforcement action in the United States District Court for the District of Columbia against Oscar H. Meza, formerly the Director of Asia-Pacific Sales for Faro Technologies, Inc. (\u0022Faro\u0022), a software development and manufacturing company. The Commission\u0027s complaint alleges that Meza authorized bribery payments to employees of Chinese state-owned companies in order to obtain contracts, and that in order to conceal the bribes Meza instructed that account entries be altered. The Commission charged Meza with violations of the anti-bribery, books and records and internal control provisions of the Foreign Corrupt Practices Act (\u0022FCPA\u0022), and with aiding and abetting Faro\u0027s violations of the anti-bribery, books and records and internal control provisions of the FCPA.  The Commission\u0027s complaint alleges that beginning in 2004, Meza authorized a former employee of Faro\u0027s subsidiary, Faro Shanghai Co., Ltd. (\u0022Faro-China\u0022), to make the improper payments. The complaint alleges that Meza\u0027s actions resulted in Faro-China\u0027s payment of $444,492 in bribes during the period 2004 through 2006, generating approximately $4.5 million in sales and approximately $1.4 million in net profit.  Without admitting or denying the allegations in the complaint, Meza has consented to the entry of a final judgment permanently enjoining him from violating Sections 30A and 13(b)(5) of the Securities Exchange Act of 1934 (\u0022Exchange Act\u0022) and Exchange Act Rule 13b2-1, and from aiding and abetting violations of Sections 30A, 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act. The final judgment also orders that Meza pay a $30,000 civil penalty, as well as $26,707 in disgorgement and prejudgment interest.\u0022 (Source: US Securities and Exchange Commission Litigation Release No. 21190 \/ August 28, 2009, SECURITIES AND EXCHANGE COMMISSION v. OSCAR H. MEZA, Civil Action No. 1:09-CV-01648 (D.D.C.) (Filed August 28, 2009), \u0022SEC SUES FORMER SALES EXECUTIVE FOR FOREIGN BRIBERY.\u0022)  Please note that the Litigation Release did not provide a breakdown of the figure for disgorgement and prejudgment interest; the amount was therefore recorded under disgorgement. \r\n","Sources ":"US Securities and Exchange Commission Litigation Release No. 21190 \/ August 28, 2009, SECURITIES AND EXCHANGE COMMISSION v. OSCAR H. MEZA, Civil Action No. 1:09-CV-01648 (D.D.C.) (Filed August 28, 2009), \u0022SEC SUES FORMER SALES EXECUTIVE FOR FOREIGN BRIBERY,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21190.htm, and Complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp21190.pdf\r\n","Documents":""},{"Case ID":"ST-53","Case Cluster ":"BAE Systems plc","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Czech Republic, Hungary, Saudi Arabia","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"03\/01","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$400,000,000.00","Criminal Fine\/Penalty (US$) ":"$400,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to defraud the United States by impairing and impeding its lawful functions, Conspiracy to make false statements; Conspiracy to violate the Arms Export Control Act and International Traffic in Arms Regulations  ","Offenses - Settled":"Conspiracy to defraud the United States by impairing and impeding its lawful functions, Conspiracy to make false statements; Conspiracy to violate the Arms Export Control Act and International Traffic in Arms Regulations  ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On February 4, 2010, BAE Systems plc (BAES), a multinational defense contractor with headquarters in the United Kingdom, was charged in a one-count criminal information with conspiracy to defraud the United States by impairing and impeding its lawful functions, to make false statements about its FCPA compliance program, and to violate the Arms Export Control Act (AECA) and International Traffic in Arms Regulations (ITAR). These charges alleged that from 2000 to 2002, BAES represented to various U.S. government agencies, including the Departments of Defense and Justice, that it would create and implement policies and procedures to ensure its compliance with the anti-bribery provisions of the FCPA, as well as similar, foreign laws implementing the Organisation for Economic Co-operation and Development (OECD) Anti-bribery Convention.  In pleading guilty, BAES acknowledged that, despite its representations to the U.S. government to the contrary, BAES knowingly and willfully failed to create sufficient compliance mechanisms to ensure compliance with these legal prohibitions on foreign bribery. More specifically, BAES admitted that it regularly used and encouraged the establishment of shell companies and third party intermediaries to assist in securing sales of defense articles. BAES admitted that, from May 2001 onward, it made a series of substantial payments to these shell companies and third party intermediaries that were not subjected to the degree of scrutiny and review to which BAES told the U.S. government the payments would be subjected, even though BAES was aware there was a high probability that part of some of the payments would be used to ensure that BAES was favored in foreign government decisions regarding the purchase of defense articles. In addition, BAES admitted that, as part of the conspiracy, it knowingly and willfully failed to identify commissions paid to third parties for assistance in soliciting, promoting or otherwise securing sales of defense articles, in violation of the AECA and ITAR.\u0022 (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, BAE Systems Plc Case Summary at 50-51.)  According to the US Department of Justice Press Release, the DOJ acknowledged the assistance of the UK\u0027s Serious Fraud Office in its investigation. (Source: US Department of Justice Press Release, \u0022BAE Systems PLC Pleads Guilty and Ordered to Pay $400 Million Criminal Fine,\u0022 March 1, 2010.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, BAE Systems Plc Case Summary at 50-51, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US v. BAE Systems plc, Case No. 1:10-cr-0035-JDB (D.D.C.),  Information filed February 4,2 010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/bae-system\/02-01-10baesystems-info.pdf; Plea Agreement filed March 1, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/bae-system\/03-01-10baesystems-plea-agree.pdf3; United States Government Sentencing Memorandum filed February 22, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/bae-system\/02-22-10baesystems-memo.pdf; US Department of Justice Press Release, \u0022BAE Systems PLC Pleads Guilty and Ordered to Pay $400 Million Criminal Fine,\u0022 March 1, 2010, accessed at www.justice.gov\/opa\/pr\/2010\/March\/10-crm-209.html","Documents":""},{"Case ID":"ST-54","Case Cluster ":"BAE Systems plc","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of State","Jurisdiction of Foreign Public Official(s) ":"Czech Republic, Hungary, Saudi Arabia, Chile, Indonesia, South Africa and many others (unnamed)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"05\/16","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent Agreement","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$79,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$79,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Violations of Arms Export Control Act and International Traffic in Arms Regulations (Failure to Register as a Broker, Failure to Obtain Written Approval for Brokering, Failure to File Annual Broker Reports, Causing Unauthorized Brokering, Failure to Disclose Payments, Failure to Maintain Records)","Offenses - Settled":"Violations of Arms Export Control Act and International Traffic in Arms Regulations (Failure to Register as a Broker, Failure to Obtain Written Approval for Brokering, Failure to File Annual Broker Reports, Causing Unauthorized Brokering, Failure to Disclose Payments, Failure to Maintain Records)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of State Consent Agreement, on May 16, 2011, BAE Systems plc entered into an agreement with the State Department \u0022to settle 2,591 violations of the Arms Control Export Act and International Traffic in Arms Regulations in connection with the unauthorized brokering of U.S. defense articles and services, failure to register as a broker, failure to file annual broker reports, causing unauthorized brokering, failure to report the payment of fees or commissions, and failure to maintain records involving ITAR-controlled transactions.  As part of the Consent Agreement, the company was assessed $79 million in civil penalties, with $10 million possibly suspended upon implementation of remedial measures.  (Source: US Department of State, BAE Systems plc, Consent Agreement signed May 16, 2011.) The Statement Department\u0027s May 2011 Proposed Charging Letter included a Summary of Investigation, which noted misconduct related to activities in more than a dozen jurisdictions.  (Source: US Department of State, BAE Systems plc, Proposed Charging Letter, May [ ] 2011.)","Sources ":"US Department of State, BAE Systems, Plc. Proposed Charging Letter, May [ ]  2011, accessed at  http:\/\/www.pmddtc.state.gov\/compliance\/consent_agreements\/pdf\/BAES_PCL.pdf; Consent Agreement signed May 16, 2011, accessed at http:\/\/www.pmddtc.state.gov\/compliance\/consent_agreements\/pdf\/BAES_CA.pdf;  Order entered into on May 16, 2011, accessed at http:\/\/www.pmddtc.state.gov\/compliance\/consent_agreements\/pdf\/BAES_Order%20.pdf.","Documents":""},{"Case ID":"ST-55","Case Cluster ":"Baker Hughes Incorporated","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Indonesia, Kazakhstan","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"04\/11","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea (BHSI), Deferred Prosecution Agreement (Baker Hughes)","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$11,000,000.00","Criminal Fine\/Penalty (US$) ":"$11,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials (Baker Hughes, BHSI), Conspiracy to falsify books and records (Baker Hughes, BHSI), Bribery of foreign officials (BHSI), Falsification of books and records (BHSI)","Offenses - Settled":"Conspiracy to bribe foreign officials (Baker Hughes, BHSI), Conspiracy to falsify books and records (Baker Hughes, BHSI), Bribery of foreign officials (BHSI), Falsification of books and records (BHSI)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice press release, as part of the plea and deferred prosecution agreements, it was agreed that Baker Hughes Services international (BHSI) would pay a criminal fine of $11 million, serve a three-year term of organizational probation and adopt a comprehensive anti-bribery compliance program. In a related matter, Baker Hughes reached a settlement of a complaint filed by the Securities and Exchange Commission under which it agreed to pay $10 million in civil penalties and more than $24 million in disgorgement of all profits it earned in connection with the Karachaganak project, including prejudgment interest. The $44 million in combined fines and penalties is the largest monetary sanction ever imposed in an FCPA case.\u0022 (Source: US Department of Justice Press Release, \u0022Baker Hughes Subsidiary Pleads Guilty to Bribing Kazakh Official and  Agrees to Pay $11 Million Criminal Fine as Part of Largest Combined Sanction Ever Imposed in FCPA Case,\u0022 April 26, 2007).  As summarized in the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Baker Hughes Incorporated, at 92-94, \u0022According to the plea agreements, Baker Hughes and BHSI violated the FCPA by paying approximately $4.1 million in bribes to an intermediary, knowing that the intermediary would transfer all or part of the corrupt payments to an official of Kazakhoil, the state-owned oil company,\u0022 and in 2007, the SEC filed civil complaints against Baker Hughes and BHSI\u0027s Business Development Manager, Roy Fearnley with FCPA violations in the same bribery scheme. In 2001, the SEC had filed civil complaints against two former employees of Baker Hughes, a partner in an Indonesian accounting firm, and a partner of the accounting firm KPMG Siddarharta Siddharta \u0026 Harsono. (Source: US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Baker Hughes Incorporated, at 92-94, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf","Sources ":"US Department of Justice Press Release, \u0022Baker Hughes Subsidiary Pleads Guilty to Bribing Kazakh Official and  Agrees to Pay $11 Million Criminal Fine as Part of Largest Combined Sanction Ever Imposed in FCPA Case,\u0022 April 26, 2007, accessed at http:\/\/www.justice.gov\/opa\/pr\/2007\/April\/07_crm_296.html (accessed on September 14, 2011); US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Baker Hughes Incorporated, at 92-94, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.","Documents":""},{"Case ID":"ST-56","Case Cluster ":"Baker Hughes Incorporated","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia, Kazakhstan, India, Brazil","Year of Settlement":"2001","Month\/Day of Settlement (or Notes)":"09\/12","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, False accounting, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Administrative Proceeding File, \u0022In March 1999, Baker Hughes\u0027 CFO and its Controller authorized an illegal payment, through KPMG, its agent in Indonesia, to a local government official in Indonesia. Baker Hughes, through its CFO and Controller, directed that this improper payment be made while knowing or aware that KPMG would pass all or part of the payment along to a foreign government official for the purpose of influencing the official\u0027s decision affecting the business of Baker Hughes. This improper payment was made in violation of the Foreign Corrupt Practices Act (\u0022FCPA\u0022). In addition, in 1998 and 1995, senior managers at Baker Hughes authorized payments to Baker Hughes\u0027 agents in India and Brazil, respectively, without making an adequate inquiry as to whether the agents might give all or part of the payments to foreign government officials in violation of the FCPA. Baker Hughes improperly recorded all three transactions in its books and records as routine business expenditures. In addition to its false books and records, Baker Hughes also failed to devise and maintain an adequate system of internal accounting controls to detect and prevent improper payments to foreign government officials and to provide reasonable assurance that transactions were recorded as necessary to permit the preparation of financial statements in conformity with Generally Accepted Accounting Principles.\u0022  (Source:  US Securities and Exchange Commission, In the Matter of Baker Hughes, Inc., Administrative Proceeding File No. 3-10572 [September 12, 2001].)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Baker Hughes Incorporated Case Summary at 106-107, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, In the Matter of Baker Hughes, Inc., Administrative Proceeding File No. 3-10572 (September 12, 2001), accessed at http:\/\/www.sec.gov\/litigation\/admin\/34-44784.htm","Documents":""},{"Case ID":"ST-57","Case Cluster ":"Baker Hughes Incorporated","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia","Year of Settlement":"2001","Month\/Day of Settlement (or Notes)":"09\/11","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Aiding and abetting Baker Hughes\u0027 internal controls violations, Aiding and abetting Baker Hughes\u0027 falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Tax)","Summary":"According to a Litigation Release by the US Securities and Exchange Commission, on September 11, 2001, the SEC and the Department of Justice jointly filed a complaint which \u0022alleges that in 1999, Harsono authorized KPMG-SSH personnel to bribe an Indonesian tax official on behalf of one of KPMG-SSH\u0027s clients, PT Eastman Christensen (\u0022PTEC\u0022), an Indonesian company beneficially owned by Baker Hughes Incorporated (\u0022Baker Hughes\u0022). KPMG-SSH agreed to make the illicit payment to influence the Indonesian tax official to reduce a tax assessment for PTEC from $3.2 million to $270,000. Harsono advised KPMG-SSH personnel that if Baker Hughes represented directly to KPMG-SSH, not through PTEC, that it wanted KPMG-SSH to make the illicit payment, KPMG-SSH would be willing to pay the Indonesian tax official. To conceal the improper payment, Harsono agreed with KPMG-SSH personnel that KPMG-SSH should generate an invoice that would include money for the payment to the Indonesian tax official and for KPMG-SSH\u0027s fees for services rendered. The false invoice, although purporting to be for professional services rendered, in reality represented $75,000 to be paid to an Indonesian tax official, and the remainder for KPMG-SSH\u0027s actual fees and applicable taxes. After receiving the invoice, PTEC paid KPMG-SSH $143,000 and improperly entered the transaction on its books and records as payment for professional services rendered. On March 23, 1999, PTEC received a tax assessment of approximately $270,000 from the Indonesian government, almost $3 million lower than the original assessment.\u0022  (Source: US Securities and Exchange Commission Litigation Release No. 17127 \/ September 12, 2001, UNITED STATES OF AMERICA AND SECURITIES AND EXCHANGE COMMISSION v. KPMG SIDDHARTA SIDDHARTA \u0026 HARSONO AND SONNY HARSONO, Civil Action No. H-01-3105 (S.D. Tex.) (filed September 11, 2001), \u0022SEC AND DEPARTMENT OF JUSTICE FILE FIRST-EVER JOINT CIVIL ACTION AGAINST KPMG SIDDHARTA SIDDHARTA \u0026 HARSONO AND ITS PARTNER SONNY HARSONO FOR AUTHORIZING THE PAYMENT OF A BRIBE IN INDONESIA.\u0022)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Baker Hughes Incorporated Case Summary at 106-107, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 17127 \/ September 12, 2001, UNITED STATES OF AMERICA AND SECURITIES AND EXCHANGE COMMISSION v. KPMG SIDDHARTA SIDDHARTA \u0026 HARSONO AND SONNY HARSONO, Civil Action No. H-01-3105 (S.D. Tex.) (filed September 11, 2001), \u0022SEC AND DEPARTMENT OF JUSTICE FILE FIRST-EVER JOINT CIVIL ACTION AGAINST KPMG SIDDHARTA SIDDHARTA \u0026 HARSONO AND ITS PARTNER SONNY HARSONO FOR AUTHORIZING THE PAYMENT OF A BRIBE IN INDONESIA,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr17127.htm","Documents":""},{"Case ID":"ST-58","Case Cluster ":"Baker Hughes Incorporated","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Indonesia, Kazakhstan, Angola, Nigeria, Russia, Uzbekistan","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"04\/11","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty ","Total Monetary Sanctions (US$)":"$33,078,015.41","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$19,944,778","Civil Prejudgment Interest (US$) ":"$3,133,237","Civil Fine \/ Penalty (US$)":"$10,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8, Art. 9","Offenses - Alleged":"Bribery of foreign officials, False accounting, Internal controls violations, Falsification of books and records ","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the April 26, 2007 US Securities and Exchange Commission Press Release, \u0022The Securities and Exchange Commission today announced the filing of a settled enforcement action charging Baker Hughes Incorporated, a Houston, Texas-based global provider of oil field products and services, with violations of the Foreign Corrupt Practices Act (FCPA). Baker Hughes has agreed to pay more than $23 million in disgorgement and prejudgment interest for these violations and to pay a civil penalty of $10 million for violating a 2001 Commission cease-and-desist Order prohibiting violations of the books and records and internal controls provisions of the FCPA.  [  ] The SEC\u0027s complaint alleges that Baker Hughes paid approximately $5.2 million to two agents while knowing that some or all of the money was intended to bribe government officials, specifically officials of State-owned companies, in Kazakhstan. The complaint alleges that one agent was hired in September 2000 on the understanding that Kazakhoil, Kazakhstan\u0027s national oil company at that time, had demanded that the agent be hired to influence senior level employees of Kazakhoil to approve the award of business to the company. [  ] Baker Hughes, the complaint alleges, paid the agent $4.1 million to its bank account in London but received no identifiable services from the agent. The complaint also alleges that in 1998 Baker Hughes retained a second agent in connection with the award of a large chemical contract with KazTransOil, the national oil transportation operator of Kazakhstan. Between 1998 and 1999, Baker Hughes paid over $1 million to the agent\u0027s Swiss bank account, despite a company employee knowing by December 1998 that the agent\u0027s representative was a high-ranking executive of KazTransOil.  The SEC\u0027s complaint against Baker Hughes also alleges violations of the books and records and internal controls provisions of the FCPA in Nigeria, Angola, Indonesia, Russia, Uzbekistan and Kazakhstan.  [  ] The [SEC] staff also acknowledges the help provided, in the form of mutual legal assistance, by the Isle of Man Financial Supervision Commission, HM Procureur (Attorney General) for Guernsey, and by the authorities of the United Kingdom and Switzerland.\u0022  (Source:  US Securities and Exchange Commission Press Release, \u0022SEC Charges Baker Hughes With Foreign Bribery and With Violating 2001 Commission Cease-and-Desist Order \/ Baker Hughes Subsidiary Pleads Guilty to Three Felony Charges in Criminal Action Filed by Department of Justice; Criminal Fines, Civil Penalties and Disgorgement of Illicit Profits Total More Than $44 Million,\u0022 April 26, 2007.)  According to the April 26, 2007 Press Release by the US Securities and Exchange Commission, \u0022the SEC also charged Roy Fearnley, a former business development manager for Baker Hughes, with violating and aiding and abetting violations of the FCPA.\u0022  (Source:  US Securities and Exchange Commission Press Release, \u0022SEC Charges Baker Hughes With Foreign Bribery and With Violating 2001 Commission Cease-and-Desist Order \/ Baker Hughes Subsidiary Pleads Guilty to Three Felony Charges in Criminal Action Filed by Department of Justice; Criminal Fines, Civil Penalties and Disgorgement of Illicit Profits Total More Than $44 Million,\u0022 April 26, 2007.)  According to the Shearman and Sterling FCPA Digest, the case is noteworthy for its jurisdictional reach, as Mr. Fearnley was a British citizen residing in Kazakhstan.  According to the Default Judgment Order in his case, Mr. Fearnley did not respond to the complaint, and on January 26, 2010, was ordered to pay $5,000 in disgorgement of profits and $7,635.51 in prejudgment interest.  As Mr. Fearnley\u0027s case was not a settlement, the monetary penalty was not included in the total for this case. (Source: Shearman and Sterling, FCPA Digest, \u0022SEC vs. Baker Hughes Incorporated and Roy Fearnley, accessed at http:\/\/fcpa.shearman.com\/index.php; SEC v. Defendant Incorporated and Roy Fearnley, Case No. 4-07-cv-1408 (S.D. Tex.), Default Judgment filed January 26, 2010, also accessed at http:\/\/fcpa.shearman.com.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Baker Hughes Incorporated Case Summary at 106-107, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   US Securities and Exchange Commission Press Release, \u0022SEC Charges Baker Hughes With Foreign Bribery and With Violating 2001 Commission Cease-and-Desist Order \/ Baker Hughes Subsidiary Pleads Guilty to Three Felony Charges in Criminal Action Filed by Department of Justice; Criminal Fines, Civil Penalties and Disgorgement of Illicit Profits Total More Than $44 Million,\u0022 April 26, 2007, accessed at http:\/\/www.sec.gov\/news\/press\/2007\/2007-77.htm;  Shearman and Sterling, FCPA Digest, \u0022SEC vs. Baker Hughes Incorporated and Roy Fearnley, accessed at http:\/\/fcpa.shearman.com\/index.php; SEC v. Defendant Incorporated and Roy Fearnley, Case No. 4-07-cv-1408 (S.D. Tex.), Default Judgment filed January 26, 2010, also accessed at http:\/\/fcpa.shearman.com.)","Documents":""},{"Case ID":"ST-59","Case Cluster ":"Balfour Beatty plc","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Egypt","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"10\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Civil Recovery Order (Proceeds of Crime Act)","Monetary Sanctions  (Types)":"Civil Recovery Order, Legal Costs","Total Monetary Sanctions (US$)":"$3,983,920.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$3,983,920","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"Unspecified amount (Legal Costs)","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Irregular payments relating to a contract","Offenses - Settled":"Inaccurate business records (Section 221 Companies Act 1985)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Serious Fraud Office Press Release, in April 2008 the SFO obtained the power to issue civil recovery orders under the Proceeds of Crime Act 2002, under which the SFO can recover property obtained by unlawful conduct. The October 8, 2009 SFO press release noted that \u0022These provisions do not require a specific offence to be established against any particular company or individual, merely tht the property sought is the proceeds of unlawful conduct.\u0022 Balfour Beatty brought the payment irregularities to the attention of the SFO; the payments occurred within a subsidiary entity [name not mentioned in the press release] during the construction of The Bibliotheca Project in Alexandria, Egypt, completed in 2001; the project was undertaken by a Balfour Beatty subsidiary in a joint venture with an Egyptian company.  In a Consent Order agreed to on October 6, 2008 before the High Court, Balfour Beatty agreed to a settlement payment of GBP 2.25 million together with a contribution towards the costs of the Civil Recovery Order proceedings. (Source: UK Serious Fraud Office, \u0022Balfour Beatty plc,\u0022 October 6, 2008, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2008\/balfour-beatty-plc.aspx).  Balfour Beatty plc also announced the settlement in a statement released on October 8, 2008: \u0022Balfour Beatty reaches full settlement of issues relating to Bibliotheca Alexandrina [sic] project,\u0022 accessed at http:\/\/www.balfourbeatty.com\/index.asp?pageid=42\u0026newsid=173.","Sources ":"UK Serious Fraud Office Press Release, \u0022Balfour Beatty plc: Serious Fraud Office successfully obtains first ever Civil Recovery Order involving major plc.,\u0022 October 6, 2008, accessed at http:\/\/www.sfo.gov.uk\/press-room\/press-release-archive\/press-releases-2008\/balfour-beatty-plc.aspx; Balfour Beatty plc company statement, \u0022Balfour Beatty reaches full settlement of issues relating to Bibliotheca Alexandrina [sic] project,\u0022 October 8, 2008, accessed at http:\/\/www.balfourbeatty.com\/index.asp?pageid=42\u0026newsid=173.  See also, United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf","Documents":""},{"Case ID":"ST-60","Case Cluster ":"Ball Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"03\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$300,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$300,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the June 2011 United States Report to the OECD, Ball Corporation, \u0022entered into a settlement with the SEC pertaining to the company\u0027s alleged violations of the books and records and internal controls provisions of the FCPA.  According to the SEC\u0027s cease-and-desist order, after Ball acquired an Argentine company, Fornamental, S.A. in March 2006, certain accounting personnel at Ball learned that Fornamental employees may have made questionable payments and caused other compliance problems before the acquisition. Despite learning of these payments after the acquisition, Ball failed to take sufficient action to ensure that such activities did not recur at Fornamental. Within months of Ball\u0027s acquisition of Fornamental, two Fornamental executives, the then-Fornamental President and then-Fornamental Vice President of Institutional Affairs - authorized improper payments to Argentine officials. Specifically, in the period between July 2006 and October 2007, Fornamental\u0027s senior officers authorized at least ten unlawful payments totaling approximately $106,749 to Argentine government officials. These payments were intended to induce government custom officials to circumvent Argentine laws prohibiting the importation of prohibited used machinery, equipment and parts and also to secure the exportation of raw materials at reduced tariffs.Fornamental\u0027s bribes were funneled through a third party customs agent, who often included the bribes on invoices sent to the company. The bribes often appeared on the invoices as separate line items described inaccurately as \u0022fees for customs assistance \u0022customs advisory services,\u0022 \u0022verification charge,\u0022 or simply \u0022fees.\u0022  According to the SEC\u0027s order, the true nature of these payments was then mischaracterized as ordinary business expenses on Fornamental\u0027s books and records.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Ball Corporation Case Summary, at 19-20.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Ball Corporation Case Summary, at 19-20, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  In the Matter of Ball Corporation, Order Instituting Cease and Desist Proceedings, Administrative Proceeding File No. 3-14305 (March 24, 2011), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2011\/34-64123.pdf","Documents":""},{"Case ID":"ST-61","Case Cluster ":"BellSouth Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nicaragua","Year of Settlement":"2002","Month\/Day of Settlement (or Notes)":"01\/15","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$150,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$150,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Internal controls violations; Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 US Report to the OECD on the Enforcement of the Anti-Bribery Convention, \u0022On January 15, 2002, the SEC filed two settled enforcement actions against BellSouth Corporation, charging that two of the company\u0027s subsidiaries had engaged in violations of the internal controls and books and records provisions of the FCPA. According to the SEC\u0027s Complaint, between September 1997 and August 2000, former senior management of BellSouth\u0027s Venezuelan subsidiary, Telcel, C.A. (Telcel), authorized payments totaling approximately $10.8 million to six offshore companies and improperly recorded the disbursements in Telcel\u0027s books and records, based on fictitious invoices, as bona fide services. Telcel\u0027s internal controls failed to detect the unsubstantiated payments for a period of at least two years. As an additional consequence of this control deficiency, the Complaint alleged that BellSouth was unable to reconstruct the circumstances or purpose of the Telcel payments, or determine the identity of their ultimate recipients. Telcel was Venezuela\u0027s leading wireless provider, contributing more revenue to BellSouth\u0027s Latin American Group segment than any other Latin American BellSouth operation. In addition, the SEC charged that between October 1998 and June 1999, BellSouth\u0027s Nicaraguan subsidiary, Telefonia Celular de Nicaragua, S.A.\u0027s (Telefonia), improperly recorded payments to the wife of the Nicaraguan legislator who was the chairman of the Nicaraguan legislative committee with oversight of Nicaraguan telecommunications.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, BellSouth Corporation Case,  at 127-128.)  According to the SEC Administrative Proceeding File, the agency issued a Cease and Desist Order enjoining the company from future violations. (Source:  Securities and Exchange Commission, Administrative Proceeding File No. 3-10678, In re: Matter of BellSouth Corporation, January 15, 2002.)  According to the Final Judgment issued against the company, BellSouth was ordered to pay $150,000 in civil penalties. (Source: SEC v. BellSouth Corporation, Case No. 1:02-cv-00113 (N.D. Ga.), Final Judgment and Other Relief Order filed January 24, 2002.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, BellSouth Corporation Case,  at 127-128, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; Securities and Exchange Commission, Administrative Proceeding File No. 3-10678, In re: Matter of BellSouth Corporation, January 15, 2002, accessed at http:\/\/www.sec.gov\/litigation\/admin\/34-45279.htm; SEC v. BellSouth Corporation, Case No. 1:02-cv-00113 (N.D. Ga.), Final Judgment and Other Relief Order filed January 24, 2002, Court Docket Report; actual text of the Judgment not able to be accessed via Pacer.)","Documents":""},{"Case ID":"ST-62","Case Cluster ":"Bid-Rigging in the International Market for Marine Hose","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Argentina, Brazil, Ecuador, Mexico, Venezuela","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"12\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$80,000.00","Criminal Fine\/Penalty (US$) ":"$80,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to violate the Sherman Antitrust Act, Conspiracy to bribe foreign officials ","Offenses - Settled":"Conspiracy to violate the Sherman Antitrust Act, Conspiracy to bribe foreign officials ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Mr. Hioki, the former general manager of his company\u0027s Industrial Engineered Products Department in Tokyo, Japan was charged for his role in a conspiracy to rig bids, fix prices and allocate market shares of marine hose in the US market and for his role in approving deals and corrupt payments and steps to conceal the improper payments via local sales agents in Latin America to employees of government-owned enterprises with which Mr. Hioki\u0027s company sought to do business.  From January 2004 through 2007, Mr. Hioki and others made more than $1 million in corrupt payments to foreign government officials in Latin America to secure or retain business. On December 10, 2008, Mr. Hioki became the ninth individual to plead guilty in the marine hose bid-rigging investigation and the first individual to plead guilty in the investigation of the FCPA conspiracy.  He was sentenced to 24 months\u0027 imprisonment and a criminal fine of $80,000, following the Department of Justice Antitrust Division\u0027s establishe practice of negotiating agreed-to-dispositions.  (Source: US Report to the OECD,  Bid-Rigging in the International Market for Marine Hose Case Summary, at 74-75.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Bid-Rigging in the International Market for Marine Hose Case,  at 74-75, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Hisao Mioki, Case No. 4:08-cr-795 (S.D. Tex.), Criminal Information filed December 8, 2008, accessed at  http:\/\/www.justice.gov\/atr\/cases\/f240400\/240474.pdf; Plea Agreement filed December 10, 2008, accessed at http:\/\/www.justice.gov\/atr\/cases\/f243700\/243716.pdf","Documents":""},{"Case ID":"ST-63","Case Cluster ":"Biomet, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Argentina, Brazil, China","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"03\/26","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$17,280,000.00","Criminal Fine\/Penalty (US$) ":"$17,280,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials, Books and records provisions","Offenses - Settled":"Conspiracy to bribe foreign officials, Bribery of foreign officials, Books and records provisions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022According to the criminal information filed today in U.S. District Court in the District of Columbia in connection with the agreement, Biomet, its subsidiaries, employees and agents made various improper payments from approximately 2000 to 2008 to publicly-employed health care providers in Argentina, Brazil and China to secure lucrative business with hospitals.   During this time, more than $1.5 million in direct and indirect corrupt payments were made.   In addition, at the end of each fiscal year, Biomet, its executives, employees and agents falsely recorded the payments on its books and records as \u0022commissions,\u0022 \u0022royalties,\u0022 \u0022consulting fees\u0022 and \u0022scientific incentives\u0022 to conceal the true nature of the payments.\u0022  (Source: US Department of Justice Press Release, \u0022Third Medical Device Company Resolves Foreign Corrupt Practices Act Investigation,\u0022 March 26, 2012.)","Sources ":"US Department of Justice Press Release, \u0022Third Medical Device Company Resolves Foreign Corrupt Practices Act Investigation,\u0022 March 26, 2012, accessed at http:\/\/www.justice.gov\/opa\/pr\/2012\/March\/12-crm-373.html; US v. Biomet, Inc., Case No. 1:12-cr-080 (D.D.C.), Information filed March 26, 2012, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/biomet\/2012-03-26-biomet-information.pdf; Deferred Prosecution Agreement dated March 26, 2012, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/biomet\/2012-03-26-biomet-dpa.pdf","Documents":""},{"Case ID":"ST-64","Case Cluster ":"Biomet, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina, Brazil, China","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"03\/26","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$5,575,731.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$4,432,998","Civil Prejudgment Interest (US$) ":"$1,142,733","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Books and records provisions","Offenses - Settled":"Bribery of foreign officials, Books and records provisions","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Complaint, Biomet and four of its subsidiaries paid bribes to public doctors employed by public hospitals and agencies in Argentina, Brazil and China. (Source: US SEC v. Biomet, Inc., Case No. 1:12-cv-00454 (D.D.C.), Complaint filed March 26, 2012.)  According to the SEC Press Release, \u0022According to the SEC\u0027s complaint filed in federal court in Washington D.C., employees of Biomet Argentina SA paid kickbacks as high as 15 to 20 percent of each sale to publicly-employed doctors in Argentina. Phony invoices were used to justify the payments, and the bribes were falsely recorded as \u0022consulting fees\u0022 or \u0022commissions\u0022 in Biomet\u0027s books and records. [  ] The SEC alleges that Biomet\u0027s U.S. subsidiary Biomet International used a distributor to bribe publicly-employed doctors in Brazil by paying them as much as 10 to 20 percent of the value of their medical device purchases. [  ] two additional subsidiaries - Biomet China and Scandimed AB - sold medical devices through a distributor in China who provided publicly-employed doctors with money and travel in exchange for their purchases of Biomet products.\u0022 (Source: US Securities and Exchange Commission Press Release 2012-50, \u0022SEC Charges Medical Device Company Biomet with Foreign Bribery,\u0022 March 26, 2012.)","Sources ":"US Securities and Exchange Commission Press Release 2012-50, \u0022SEC Charges Medical Device Company Biomet with Foreign Bribery,\u0022 March 26, 2012, accessed at http:\/\/www.sec.gov\/news\/press\/2012\/2012-50.htm; US SEC v. Biomet, Inc. Case No. 1:12-cv-00454 (D.D.C.), Complaint filed March 26, 2012, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp22306.pdf","Documents":""},{"Case ID":"ST-65","Case Cluster ":"BizJet International Sales and Support, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico, Panama","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"03\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$11,800,000.00","Criminal Fine\/Penalty (US$) ":"$11,800,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials  ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022 BizJet paid bribes to officials employed by the Mexican Policia Federal Preventiva, the Mexican Coordinacion General de Transportes Aereos Presidenciales, the air fleet for the Gobierno del Estado de Sinaloa, the air fleet for the Gobierno del Estado de Sonora and the Republica de Panama Autoridad Aeronautica Civil.  In many instances, BizJet paid the bribes directly to the foreign officials.  In other instances, BizJet funneled the bribes through a shell company owned and operated by a BizJet sales manager.  BizJet executives orchestrated, authorized and approved the unlawful payments.\u0022  (Source: US Department of Justice Press Release, \u0022Bizjet International Sales and Support Inc., Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $11.8 Million Criminal Penalty,\u0022 March 14, 2012.)  According to the Statement of Facts agreed to by the company as part of its Deferred Prosecution Agreement, \u0022Shell Company A\u0022 was owned by BizJet\u0027s Sales Manager and operated out of his personal residence in Van Nuys, California (para 7); Shell Company A \u0022operated under the pretense\u0022 of supplying aircraft maintenance, repair and overhaul services  but in fact was used in the conspiracy by BizJet executives and sales manager to make unlawful payments to foreign officials via its bank account in California. (para 18) (Source: US v. BizJet International Sales and Support, Inc., Case No. 4:12-cr-00061 (N.D. Okla.), Deferred Prosecution Agreement and Statement of Facts filed March 14, 2012.)","Sources ":"US v. BizJet International Sales and Support, Inc., Case No. 4:12-cr-00061 (N.D. Okla.), Deferred Prosecution Agreement and Statement of Facts filed March 14, 2012, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/bizjet\/2012-03-14-bizjet-deferred-prosecution-agreement.pdf; US Department of Justice Press Release, \u0022Bizjet International Sales and Support Inc., Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $11.8 Million Criminal Penalty,\u0022 March 14, 2012, accessed at http:\/\/www.justice.gov\/opa\/pr\/2012\/March\/12-crm-321.html","Documents":""},{"Case ID":"ST-66","Case Cluster ":"BizJet International Sales and Support, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"03\/14","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"As part of the US settlements with the BizJet company, \u0022BizJet\u0027s indirect parent company, Lufthansa Technik AG, itself a German provider of aircraft-related services, entered into an agreement with the department in connection with the unlawful payments by BizJet and its directors, officers, employees and agents.  The department has agreed not to prosecute Lufthansa Technik provided that Lufthansa Technik satisfies its obligations under the agreement for a period of three years.  Those obligations include ongoing cooperation and the continued implementation of rigorous internal controls. (Source: US Department of Justice Press Release, \u0022Bizjet International Sales and Support Inc., Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $11.8 Million Criminal Penalty,\u0022 March 14, 2012.)  According to Luftansa Technik\u0027s Non-Prosecution Agreement with the Department of Justice, Luftansa \u0022admits, accepts, and acknowledges responsibility for the conduct of its subsidiary set forth in the Statement of Facts contained in the Deferred Prosecution Agreement between the Department and BizJet\u0022 (Source: Non-Prosecution Agreement between Department of Justice and Luftansa Technik A.G., December 21, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/lufthansa-technik\/2011-12-21-lufthansa-npa.pdf.) ","Sources ":"US Department of Justice Press Release, \u0022Bizjet International Sales and Support Inc., Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $11.8 Million Criminal Penalty,\u0022 March 14, 2012, accessed at http:\/\/www.justice.gov\/opa\/pr\/2012\/March\/12-crm-321.html; Non-Prosecution Agreement between Department of Justice and Luftansa Technik A.G., December 21, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/lufthansa-technik\/2011-12-21-lufthansa-npa.pdf.) ","Documents":""},{"Case ID":"ST-67","Case Cluster ":"BJ Services Company","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Argentina","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"03\/10","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.15, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the June 2011, US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022:  \u0022On March 10, 2004, the SEC instituted settled administrative proceedings against BJ Services Company (BJ Services), for violations of the anti-bribery, internal controls, and books and records provisions of the FCPA. According to the SEC\u0027s filing, during 2001, BJ Services, through its wholly owned Argentinean subsidiary B.J. Services, S.A. (\u0022BJSA\u0022), made illegal or questionable payments, totaling approximately 72,000 pesos to Argentinean customs officials. Further, from 1998 through April 2002 certain undocumented or improperly characterized payments were made totaling approximately 151,000 pesos. In certain instances, entries were made in BJSA\u0027s books and records to conceal the payments. During the same period, BJ Services experienced certain breaches in the existing accounting policies, controls and procedures in certain areas of its Latin American Region.\u0022 (Source: BJ Services Case Summary at 124.)  Please note that as part of the Cease-and-Desist order proceedings, BJ Services Company did not admit or deny the SEC\u0027s findings.  (Source: US Securities and Exchange Commission, In the Matter of BJ Services Company, Administrative File No. 3-11427, March 10, 2004.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, BJ Services Company, at 124, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf; US Securities and Exchange Commission, In the Matter of BJ Services Company, Administrative File No. 3-11427, March 10, 2004, accessed at http:\/\/www.sec.gov\/litigation\/admin\/34-49390.htm.","Documents":""},{"Case ID":"ST-68","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"09\/03","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Restitution","Total Monetary Sanctions (US$)":"$10,800,000.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$10,800,000","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$10,800,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to Former Employer (unspecified)","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to commit wire fraud","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to commit wire fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  According to the Plea Agreement, Stanley, a US citizen, \u0022agrees to pay restitution to the victim(s) of Count 2 of the Information [Conspiracy to commit mail and wire fraud]. The Defendant stipulates and agrees that as a result of his criminal conduct the victim, his former employer, incurred a monetary loss of $10.8 million. The Defendant and the United States agree to recommend that the Court order restitution of $10.8 million.\u0022 (Source: US v. Stanley, Case No. 4:08-cr-597 (S.D. Tex.), Plea Agreement filed September 3, 2008, para 7.)  According to the US Department of Justice Press Release, \u0022Significant assistance was provided by the SEC\u0027s Division of Enforcement and by the authorities in France, Italy, Switzerland and the United Kingdom.\u0022 (Source: US Department of Justice Press Release, \u0022Former Officer and Director of Global Engineering and Construction Company Pleads Guilty to Foreign Bribery and Kickback Charges,\u0022 September 3, 2008.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   US v. Albert Jackson Stanley, Case No. 4:08-cr-597 (S.D. Tex.), Information filed on August 29, 2008 and unsealed on September 3, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/stanleya\/08-29-08stanley-info.pdf;  Plea Agreement filed September 3, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/stanleya\/09-03-08stanley-plea-agree.pdf; and Court Docket Report retrieved on February 27, 2012 (via PACER).  See also, US Department of Justice Press Release, \u0022Former Officer and Director of Global Engineering and Construction Company Pleads Guilty to Foreign Bribery and Kickback Charges,\u0022 September 3, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/September\/08-crm-772.html","Documents":""},{"Case ID":"ST-69","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"Nigeria","Jurisdiction of Settlement \/ Enforcement Agency":"Economic and Financial Crimes Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/20","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine, Disgorgement","Total Monetary Sanctions (US$)":"$32,500,000.00","Criminal Fine\/Penalty (US$) ":"$30,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"$2,500,000 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$32,500,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Unknown (Bribery offenses related to the Bonny Island Natural Gas Bribe Scheme) ","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a Press Release by the ENI company, its subsidiary Snamprogetti Netherlands BV entered into a settlement and non-prosecution agreement with the Nigerian authorities to resolve an investigation into the activities of Snamprogetti, as member of the TSKJ consortium, in connection with contracts to build liquid natural [gas] faciltiies on Bonny Island, Nigeria.  According to the company press release, \u0022Pursuant to the agreement, Snamprogetti Netherlands B.V. agreed to the payment of a criminal penalty of $30 million and of $2.5 million as reimbursement for legal costs and expenses incurred by the Nigerian authorities. The Federal Government of Nigeria agreed to dismiss all charges against Snamprogetti Netherlands BV and to renounce to any civil claims and criminal charges in any jurisdiction.\u0022   (Source: ENI\/Saipem company Press Release, \u0022Snamprogetti Netherlands BV enters agreement with Federal Government of Nigeria,\u0022 December 20, 2010.)  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.  However, on December 22, 2010, the Nigerian Attorney General and Minister of Justice stated at a media briefing that the total sum of $170.8 million had been paid by foreign companies, including Technip, to settle bribery charges and\/or allegations and that the sums represented fines and disgorgement of profits.  (Source: 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010.)","Sources ":"2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010, provided to the study by the Nigerian Economic and Financial Crimes Commission. ENI Company Press Release, \u0022Snamprogetti Netherlands BV enters agreement with Federal Government of Nigeria,\u0022 December 20, 2010, accessed at http:\/\/www.saipem.com\/site\/download.jsp?idDocument=2013\u0026instance=2.  For details on United States settlement in the case, please see: US v. Snamprogetti Netherlands BV, Case No. 4:10-cr-00460 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts, filed July 7, 2010, accessed at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/snamprogetti\/07-07-10snamprogetti-dpa.pdf","Documents":""},{"Case ID":"ST-70","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"09\/03","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"None","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7, Art. 8","Offenses - Alleged":"Bribery of Foreign Officials, False Accounting, Aiding and Abetting Halliburton\u0027s Internal Controls Violations, Aiding and Abetting Halliburton\u0027s Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  The US Securities and Exchange Commission Litigation Release noted the assistance of foreign authorities in the case. (Source:  US Securities and Exchange Commission Litigation Release No. 20897A \/ February 11, 2009, Securities and Exchange Commission v. Halliburton Company and KBR, Inc., 4:09-CV-399, S.D. Tex. (Houston), \u0022SEC Charges KBR, Inc. with Foreign Bribery; Charges Halliburton Co. and KBR, Inc. with Related Accounting Violations -- Companies to Pay Disgorgement of $177 Million; KBR Subsidiary to Pay Criminal Fines of $402 Million; Total Payments to be $579 Million.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20897A \/ February 11, 2009, Securities and Exchange Commission v. Halliburton Company and KBR, Inc., 4:09-CV-399, S.D. Tex. (Houston), \u0022SEC Charges KBR, Inc. with Foreign Bribery; Charges Halliburton Co. and KBR, Inc. with Related Accounting Violations -- Companies to Pay Disgorgement of $177 Million; KBR Subsidiary to Pay Criminal Fines of $402 Million; Total Payments to be $579 Million,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr20897a.htm; Complaint filed September 3, 2008, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20700.pdf.","Documents":""},{"Case ID":"ST-71","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"03\/11","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Forfeiture ","Total Monetary Sanctions (US$)":"$148,989,568.67","Criminal Fine\/Penalty (US$) ":"$25,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$148,964,568.67","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  According to the US Department of Justice Press Release, \u0022Significant assistance was provided by [ ] the authorities in France, Italy, Switzerland and the United Kingdom, including in particular the Crown Prosecution Service, the Serious Fraud Office\u0027s International Assistance and Anti-Corruption Units, the London Metropolitan Police and the City of London Police in the United Kingdom.\u0022 (Source: US Department of Justice Press Release, \u0022UK Solicitor Pleads Guilty for Role in Bribing Nigerian Government Officials as Part of KBR Joint Venture Scheme,\u0022 March 11, 2011.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  U.S. v. Jeffrey Tesler and Wojciech J. Chodan, Case No. 09-cr-098 (S.D. Tex.), Indictment filed Feburary 17, 2009, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tesler\/tesler-indict.pdf; Plea Agreement filed March 11, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tesler\/tesler_plea_agmt.pdf and Court Docket Report retrieved on February 27, 2012 (via PACER).  US Department of Justice Press Release, \u0022UK Solicitor Pleads Guilty for Role in Bribing Nigerian Government Officials as Part of KBR Joint Venture Scheme,\u0022 March 11, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/March\/11-crm-313.html.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Tesler_Chodan_DOJ_Indictment_Feb_17_2009.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Tesler_DOJ_Plea_Agreement_Mar_11_2011.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Tesler_Plea_Agreement_DOJ_Press_Release_Mar_11_2011.pdf"},{"Case ID":"ST-72","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"Nigeria","Jurisdiction of Settlement \/ Enforcement Agency":"Economic and Financial Crimes Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"January","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution agreement","Monetary Sanctions  (Types)":"Criminal Fine, Disgorgement","Total Monetary Sanctions (US$)":"$28,500,000.00","Criminal Fine\/Penalty (US$) ":"$28,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$28,500,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Unknown (Bribery offenses related to the Bonny Island Natural Gas Bribe Scheme) ","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the JGC Corporation\u0027s January 31, 2011 Notice of Loss and Revisions of Earnings Forecasts for Fiscal Year Ending March 31, 2011, JGC reached a settlement with the Nigerian authorities in January 2011. No other details were noted in the company\u0027s notice. (Source: JGC Corporation\u0027s January 31, 2011 Notice of Loss and Revisions of Earnings Forecasts for Fiscal Year Ending March 31, 2011.)  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.  However, on December 22, 2010, the Nigerian Attorney General and Minister of Justice stated at a media briefing that the total sum of $170.8 million had been paid by foreign companies to settle bribery charges and\/or allegations and that the sums represented fines and disgorgement of profits.  (Source: 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010.)","Sources ":"Nigeria Settlement: 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010, provided to the study by the Nigerian Economic and Financial Crimes Commission. JGC Corporation\u0027s January 31, 2011 Notice of Loss and Revisions of Earnings Forecasts for Fiscal Year Ending March 31, 2011, accessed at http:\/\/www.jgc.co.jp\/en\/06ir\/pdf\/financial_statements_summary\/fy10\/fy10_3rdqtr_revision.pdf; US Settlement: US v. JGC Corporation,  Case No. 4:11-cr-00260 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts filed April 6, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/jgc-corp\/04-6-11jgc-corp-dpa.pdf.","Documents":""},{"Case ID":"ST-73","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2013","Month\/Day of Settlement (or Notes)":"04\/06","Other Jurisdictions of Settlement":"Nigeria","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$218,800,000.00","Criminal Fine\/Penalty (US$) ":"$218,800,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Aiding and Abetting the Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Aiding and Abetting the Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  The US Department of Justice Press Release noted that \u0022Significant assistance was provided by [ ] authorities in France, Italy, Switzerland and the United Kingdom.\u0022 (Source: US Department of Justice Press Release, \u0022JGC Corporation Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay a $218.8 Million Criminal Penalty,\u0022 April 6, 2011.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   US v. JGC Corporation, Case No. 4:11-cr-260 (S.D. Tex.), Information filed April 6, 2011, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/jgc-corp\/04-6-11jgc-corp-info.pdf; Deferred Prosecution Agreement filed April 6, 2011, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/jgc-corp\/04-6-11jgc-corp-dpa.pdf; US Department of Justice Press Release, \u0022JGC Corporation Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay a $218.8 Million Criminal Penalty,\u0022 April 6, 2011, accessed at www.justice.gov\/opa\/pr\/2011\/April\/11-crm-431.html.","Documents":""},{"Case ID":"ST-75","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"02\/11","Other Jurisdictions of Settlement":"Nigeria","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits","Total Monetary Sanctions (US$)":"$177,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$177,000,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials (KBR), Internal controls violations (Halliburton), Falsification of books and records (Halliburton), False accounting (KBR), Aiding and Abetting Halliburton\u0027s Internal Controls Violations (KBR), Aiding and Abetting Halliburton\u0027s Falsification of Books and Records (KBR)","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 20897 \/ February 11, 2009, Securities and Exchange Commission v. Halliburton Company, 4:09-CV-399, S.D. Tex. (Houston), \u0022SEC Charges KBR, Inc. with Foreign Bribery; Charges Halliburton Co. and KBR, Inc. with Related Accounting Violations ? Companies to Pay Disgorgement of $177 Million; KBR Subsidiary to Pay Criminal Fines of $402 Million; Total Payments to be $579 Million,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr20897.htm; Complaint filed February 11, 2009, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp20897.pdf","Documents":""},{"Case ID":"ST-76","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"Nigeria","Jurisdiction of Settlement \/ Enforcement Agency":"Economic and Financial Crimes Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"10\/21","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution agreement","Monetary Sanctions  (Types)":"Criminal Fine, Disgorgement, Procedural costs","Total Monetary Sanctions (US$)":"$35,000,000.00","Criminal Fine\/Penalty (US$) ":"$32,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"$2,500,000 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$35,000,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Unknown (Bribery offenses related to the Bonny Island Natural Gas Bribe Scheme) ","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Halliburton Company Press Release: \u0022Pursuant to this agreement [with Federal Government of Nigeria (FGN)], all lawsuits and charges against KBR and Halliburton corporate entities and associated persons have been withdrawn, The FGN agreed not to bring any further criminal charges or civil claims against those entities or persons, and Halliburton agreed to pay US$32.5 million to the FGN and to pay an additional US$2.5 million for FGN\u0027s attorneys\u0027 fees and other expenses. Among other provisions, Halliburton agreed to provide reasonable assistance in the FGN\u0027s effort to recover amounts frozen in a Swiss bank account of a former TSKJ agent and affirmed a continuing commitment with regard to corporate governance. Any charges related to this settlement will be reflected in discontinued operations.\u0022  (Source: Halliburton Company Press Release, \u0022Halliburton Confirms Agreement to Settle with Federal Government of Nigeria,\u0022 December 21, 2010.)   Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.  However, on December 22, 2010, the Nigerian Attorney General and Minister of Justice stated at a media briefing that the total sum of $170.8 million had been paid by foreign companies, including Halliburton, to settle bribery charges and\/or allegations and that the sums represented fines and disgorgement of profits.  (Source: 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010.)","Sources ":"2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010, provided to the study by the Nigerian Economic and Financial Crimes Commission.  Halliburton Company Press Release, \u0022Halliburton Confirms Agreement to Settle with Federal Government of Nigeria,\u0022 December 21, 2010, accessed at www.halliburton.com\/public\/news\/pubsdata\/press_release\/2010\/corpnws_12212010.html.","Documents":""},{"Case ID":"ST-77","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"02\/11","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$402,000,000.00","Criminal Fine\/Penalty (US$) ":"$402,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  The US Department of Justice Press Release noted that \u0022Significant assistance was provided by [  ] authorities in France, Italy, Switzerland and the United Kingdom.\u0022  (Source: US Department of Justice Press Release, \u0022Kellogg Brown \u0026 Root LLC Pleads Guilty to Foreign Bribery Charges and Agrees to Pay $402 Million Criminal Fine,\u0022 February 11, 2009.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US. v. Kellogg, Brown \u0026 Root LLC, Case No. 4:09-cr-071 (S.D. Tex.), Information filed February 6, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/kelloggb\/02-06-09kbr-info.pdf; Plea Agreement filed February 11, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/kelloggb\/02-11-09kbr-plea-agree.pdf; Judgment filed February 12, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/kelloggb\/02-12-09kbr-judgment.pdf.  US Department of Justice Press Release, \u0022Kellogg Brown \u0026 Root LLC Pleads Guilty to Foreign Bribery Charges and Agrees to Pay $402 Million Criminal Fine,\u0022 February 11, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/February\/09-crm-112.html","Documents":""},{"Case ID":"ST-78","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"07\/07","Other Jurisdictions of Settlement":"Nigeria","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$240,000,000.00","Criminal Fine\/Penalty (US$) ":"$240,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials, Aiding and Abetting the Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials, Aiding and Abetting the Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  The US Department of Justice Press Release noted that \u0022Significant assistance was provided by [  ] authorities in France, Italy, Switzerland and the United Kingdom.\u0022  (Source: US Department of Justice Press Release, \u0022Snamprogetti Netherlands B.V. Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $240 Million Criminal Penalty, $1.28 Billion in Total Penalties Obtained to Date for Scheme to Bribe Nigerian Government Officials to Obtain Contracts,\u0022 July 7, 2010.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Snamprogretti Netherlands BV, Case No. 4:10-cr-460 (S.D. Tex, 2010), Information filed July 7, 2010, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/snamprogetti\/07-07-10snamprogetti-info.pdf; Deferred Prosecution Agreement filed July 7, 2010, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/snamprogetti\/07-07-10snamprogetti-dpa.pdf.  US Department of Justice Press Release, \u0022Snamprogetti Netherlands B.V. Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $240 Million Criminal Penalty, $1.28 Billion in Total Penalties Obtained to Date for Scheme to Bribe Nigerian Government Officials to Obtain Contracts,\u0022 July 7, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/July\/10-crm-780.html","Documents":""},{"Case ID":"ST-79","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"07\/07","Other Jurisdictions of Settlement":"Nigeria","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits","Total Monetary Sanctions (US$)":"$125,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$125,000,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  According to the SEC Litigation Release, \u0022The SEC acknowledges the assistance of the U.S. Department of Justice, Fraud Section; the Federal Bureau of Investigation; and foreign authorities in Europe, Asia, Africa and the Americas.\u0022  (Source: US Securities and Exchange Commission Litigation Release No. 21588 \/ July 7, 2010, Securities and Exchange Commission v. ENI, S.p.A. and Snamprogetti Netherlands, B.V., Case No. 4:10-cv-02414, S.D. Tex. (Houston), \u0022SEC Charges Snamprogetti Netherlands, B.V. with Foreign Bribery and Related Accounting Violations and ENI, S.p.A. with Books and Records and Internal Controls Violations -- ENI and Snamprogetti to Pay Jointly $125 Million in Disgorgement; Snamprogetti Also to Pay a Criminal Penalty of $240 Million.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 21588 \/ July 7, 2010, Securities and Exchange Commission v. ENI, S.p.A. and Snamprogetti Netherlands, B.V., Case No. 4:10-cv-02414, S.D. Tex. (Houston), \u0022SEC Charges Snamprogetti Netherlands, B.V. with Foreign Bribery and Related Accounting Violations and ENI, S.p.A. with Books and Records and Internal Controls Violations -- ENI and Snamprogetti to Pay Jointly $125 Million in Disgorgement; Snamprogetti Also to Pay a Criminal Penalty of $240 Million,\u0022 accessed at www.sec.gov\/litigation\/litreleases\/2010\/lr21588.htm; Complaint filed July 7, 2010, accessed at www.sec.gov\/litigation\/complaints\/2010\/comp-pr2010-119.pdf.","Documents":""},{"Case ID":"ST-80","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"06\/28","Other Jurisdictions of Settlement":"Nigeria","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$240,000,000.00","Criminal Fine\/Penalty (US$) ":"$240,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  The US Department of Justice Press Release noted \u0022Significant assistance was provided by [ ] authorities in France, Italy, Switzerland and the United Kingdom.\u0022  (Source:  US Department of Justice Press Release, \u0022Technip S.A. Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $240 Million Criminal Penalty,\u0022 June 28, 2010.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Technip S.A., Case No. 4:10-cr-439 (S.D. Tex.), Information filed on June 28, 2010, accessed at ww.justice.gov\/criminal\/fraud\/fcpa\/cases\/technip-sa\/06-28-10-technip-%20information.pdf; Deferred Prosecution Agreement filed June 28, 2010, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/technip-sa\/06-28-10-technip-agreement.pdf. US Department of Justice Press Release, \u0022Technip S.A. Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay $240 Million Criminal Penalty,\u0022 June 28, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/June\/10-crm-751.html","Documents":""},{"Case ID":"ST-81","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"06\/28","Other Jurisdictions of Settlement":"Nigeria","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$98,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$98,000,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  According to the US Securities and Exchange Commission Litigation Release, the $98 million represents disgorgement of profits and prejudgment interest; the breakdown in amounts was not given. Also according to the Litigation Release, \u0022The Commission acknowledges the assistance of [ ] foreign authorities in Europe, Asia, Africa and the Americas.\u0022  (Source: US Securities and Exchange Commission Litigation Release No. 21578 \/ June 28, 2010, Securities and Exchange Commission v. Technip, Case No. 4:10-cv-02289, S.D. Tex. (Houston), \u0022SEC Charges Technip with Foreign Bribery and Related Accounting Violations -- Technip to Pay $98 Million in Disgorgement and Prejudgment Interest; Company Also to Pay a Criminal Penalty of $240 Million.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission Litigation Release No. 21578 \/ June 28, 2010, Securities and Exchange Commission v. Technip, Case No. 4:10-cv-02289, S.D. Tex. (Houston), \u0022SEC Charges Technip with Foreign Bribery and Related Accounting Violations -- Technip to Pay $98 Million in Disgorgement and Prejudgment Interest; Company Also to Pay a Criminal Penalty of $240 Million,\u0022 accessed at www.sec.gov\/litigation\/litreleases\/2010\/lr21578.htm; Complaint filed June 28, 2010, accessed at www.sec.gov\/litigation\/complaints\/2010\/comp-pr2010-110.pdf","Documents":""},{"Case ID":"ST-82","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"Nigeria","Jurisdiction of Settlement \/ Enforcement Agency":"Economic and Financial Crimes Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"Month and Day unspecified","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution agreement","Monetary Sanctions  (Types)":"Criminal Fine, Disgorgement","Total Monetary Sanctions (US$)":"$30,000,000.00","Criminal Fine\/Penalty (US$) ":"$30,000,000","Criminal Fine \/ Penalty (Explanation)":"Please note that the December 22, 2010 press briefing by the Nigerian Attorney General noted that $170.8 million had been paid in total by companies and individuals; no specific figure was given as to Technip. The press statement noted that the sums had been paid by the companies as fines and disgorgement but no breakdown was given.  The total amount for Technip is from a secondary source; as it was unknown what portion of the sums constituted fines or disgorgement. ","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$30,000,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Unknown (Bribery offenses related to the Bonny Island Natural Gas Bribe Scheme) ","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to secondary sources (including Marcus Cohen, David Elesinmogun \u0026 Obumneme Egwuatu, \u0022Will Nigeria Take Another Bite?,\u0022 FCPA Blog, August 4, 2011), Technip agreed to pay $30 million to Nigerian authorities as part of its settlement agreement.  For background on the US Foreign Corrupt Practices Act case and settlement with Technip, S.A. related to the Bonny Island natural gas project in Nigeria, please see US v. Technip S.A., Case No. 4:10-cr-00439 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts, filed June 28, 2010 and Technip S.A. Company Statement, \u0022Technip confirms resolution of DOJ and SEC investigation into TSKJ Nigeria,\u0022 June 28, 2010.  Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.  However, on December 22, 2010, the Nigerian Attorney General and Minister of Justice stated at a media briefing that the total sum of $170.8 million had been paid by foreign companies, including Technip, to settle bribery charges and\/or allegations and that the sums represented fines and disgorgement of profits.  (Source: 2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010.)","Sources ":"2010 Ministerial Media Briefing on the Activities of the Federal Ministry of Justice, by Mr. Mohammed Bello Adoke, SAN, Attorney General and Minister of Justice, Annual Press Briefing, 22 December 2010, provided to the study by the Nigerian Economic and Financial Crimes Commission.  Marcus Cohen, David Elesinmodun \u0026 Obumneme Egwuatu, \u0022Will Nigeria Take Another Bite?,\u0022 FCPA Blog, August 4, 2011, accessed at http:\/\/www.fcpablog.com\/blog\/tag\/shell; US v. Technip S.A., Case No. 4:10-cr-00439 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts, filed June 28, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/technip-sa\/06-28-10-technip-agreement.pdf; Technip S.A. Company Statement, \u0022Technip confirms resolution of DOJ and SEC investigation into TSKJ Nigeria,\u0022 June 28, 2010, accessed at http:\/\/www.technip.com\/en\/press\/technip-confirms-resolution-doj-and-sec-investigation-tskj-nigeria","Documents":""},{"Case ID":"ST-83","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/06","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Forfeiture","Total Monetary Sanctions (US$)":"$746,885.00","Criminal Fine\/Penalty (US$) ":"$20,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$726,885","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7, Art. 8","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 Report by the United States to the OECD, \u0022From 1995-2004, Kellogg Brown \u0026 Root Inc. (KBR), Technip S.A. (Technip), Snamprogetti Netherlands B.V. (Snamprogetti), and JGC were each part of the TSKJ joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were part of a four-company joint venture that was awarded four EPC contracts by Nigeria LNG Ltd. (NLNG), which is 49 percent owned by the government-owned Nigerian National Petroleum Corporation (NNPC). These contracts, which were valued at more than $6 billion, were for the construction of LNG facilities on Bonny Island. In exchange for being awarded these EPC contracts, the joint-venture partners used two agents to pay bribes totaled in excess of $182 million to a range of Nigerian government officials, including officials of the executive branch of the Nigerian government and officials at NNPC and NLNG.\u0022 (Source:  Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19.)  The US Department of Justice Press Release on Chodan\u0027s Plea Agreement noted that \u0022Significant assistance was provided by [ ] by authorities in France, Italy, Switzerland and the United Kingdom, including in particular the Crown Prosecution Service, the Serious Fraud Office?s International Assistance and Anti-Corruption Units, the London Metropolitan Police and the City of London Police.\u0022 (Source: US Department of Justice Press Release, \u0022UK Citizen Pleads Guilty to Conspiring to Bribe Nigerian Government Officials to Obtain Lucrative Contracts as Part of KBR Joint Venture Scheme,\u0022 December 6, 2010.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bonny Island Liquefied Gas Bribe Scheme Case Summary at 17-19, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Jeffrey Tesler and Wojciech J. Chodan, Case No. 09-cr-098 (S.D. Tex.), Indictment filed Feburary 17, 2009, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tesler\/tesler-indict.pdf; Plea Agreement filed December 6, 2010, accessesd at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/chodan\/12-06-10chodan-plea.pdf and Court Docket Report retrieved on February 27, 2012 (via PACER).  US Department of Justice Press Release, \u0022UK Citizen Pleads Guilty to Conspiring to Bribe Nigerian Government Officials to Obtain Lucrative Contracts as Part of KBR Joint Venture Scheme,\u0022 December 6, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/December\/10-crm-1391.html","Documents":""},{"Case ID":"ST-84","Case Cluster ":"Bonny Island Liquefied Natural Gas Bribe Scheme","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"01\/17","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$54,600,000.00","Criminal Fine\/Penalty (US$) ":"$54,600,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to Bribe Foreign Officials, Aiding and Abetting the Bribery of Foreign Officials","Offenses - Settled":"Conspiracy to Bribe Foreign Officials, Aiding and Abetting the Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022The department filed a deferred prosecution agreement and a criminal information today against Marubeni in U.S. District Court for the Southern District of Texas. The two-count information charges Marubeni with one count of conspiracy and one count of aiding and abetting violations of the FCPA. Marubeni is a Japanese trading company headquartered in Tokyo.  According to court documents, Marubeni was hired as an agent by the four-company TSKJ joint venture to help TSKJ obtain and retain EPC contracts to build liquefied natural gas (LNG) facilities on Bonny Island, Nigeria, by offering to pay and paying bribes to Nigerian government officials, among other means. TSKJ was comprised of Technip S.A., Snamprogetti Netherlands B.V., Kellogg Brown \u0026 Root Inc. (KBR) and JGC Corporation. Between 1995 and 2004, TSKJ was awarded four EPC contracts, valued at more than $6 billion, by Nigeria LNG Ltd. to build the LNG facilities on Bonny Island. The government-owned Nigerian National Petroleum Corporation was the largest shareholder of NLNG, owning 49 percent of the company. According to court documents, to assist in obtaining and retaining the EPC contracts, the joint venture hired two agents -- Marubeni and Jeffrey Tesler, a U.K. solicitor -- to pay bribes to a wide range of Nigerian government officials. The joint venture hired Tesler as a consultant to pay bribes to high-level Nigerian government officials, including top-level executive branch officials, and hired Marubeni to pay bribes to lower-level Nigerian government officials. At crucial junctures preceding the award of EPC contracts, a number of co-conspirators, including on two occasions an employee of Marubeni, met with successive holders of a top-level office in the executive branch of the Nigerian government to ask the office holders to designate a representative with whom TSKJ should negotiate bribes to Nigerian government officials. TSKJ paid approximately $132 million to a Gibraltar corporation controlled by Tesler and $51 million to Marubeni during the course of the bribery scheme and intended for these payments to be used, in part, for bribes to Nigerian government officials. [ ] Significant assistance was provided by authorities in France, Italy, Switzerland and the United Kingdom.\u0022  (Source:  US Department of Justice Press Release, \u0022Marubeni Corporation Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay a $54.6 Million Criminal Penalty,\u0022 January 17, 2012.)","Sources ":"US v. Marubeni Corporation, Case No. 4:12-cr-00022 (S.D. Tex.), Information filed January 17, 2012, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/marubeni\/2012-01-17-marubeni-information.pdf and Deferred Prosecution Agreement filed January 17, 2012, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/marubeni\/2012-01-17-marubeni-dpa.pdf.  US Department of Justice Press Release, \u0022Marubeni Corporation Resolves Foreign Corrupt Practices Act Investigation and Agrees to Pay a $54.6 Million Criminal Penalty,\u0022 January 17, 2012, accessed at http:\/\/www.justice.gov\/opa\/pr\/2012\/January\/12-crm-060.html; Marubeni Corporation Statement, \u0022Settlement with the U.S. Department of Justice regarding the Nigeria LNG Project,\u0022 January 18, 2012, accessed at http:\/\/www.marubeni.com\/news\/2012\/120118e.html","Documents":""},{"Case ID":"ST-85","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Gabon, Angola, Equatorial Guinea","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$5,858,165.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$2,694,405","Civil Prejudgment Interest (US$) ":"$1,063,760","Civil Fine \/ Penalty (US$)":"$2,100,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission Litigation Release, on November 3, 2010, the Commission \u0022charged GlobalSantaFe Corp. (GSF) (c\/k\/a Transocean Worldwide Inc.) with bribery and other violations of the Foreign Corrupt Practices Act (FCPA). According to the SEC?s complaint, filed today in federal district court in Washington, D.C., from approximately January 2002 through July 2007, GSF made illegal payments to officials of the Nigerian Customs Service (NCS), through companies acting as customs brokers for GSF. In November 2007, GSF, an oil and gas drilling services company, merged with a subsidiary of Transocean Inc. In December 2008, the listed company became Transocean Ltd. [  ]  The SEC alleges that GSF [GlobalSantaFe Corp], through its customs brokers, made other suspicious payments, some characterized as \u0022interventions,\u0022 to Nigerian customs officials. In addition, GSF similarly made a number of suspicious payments to government officials in Gabon, Angola, and Equatorial Guinea. These payments were described on invoices as, for example, \u0022customs vacation,\u0022 \u0022customs escort,\u0022 \u0022costs extra police to obtain visa,\u0022 \u0022official dues,\u0022 and \u0022authorities fees.\u0022  None of the payments were accurately reflected in GSF\u0027s books and records, nor was GSF\u0027s system of internal accounting controls adequate at the time to detect and prevent these illegal payments.  Without admitting or denying the SEC\u0027s allegations, GSF has consented to the entry of a court order permanently enjoining it from violating the anti-bribery and record keeping and internal controls provisions in Section 30A and Sections 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act. GSF also consented to the entry of a court order requiring GSF to pay disgorgement of $2,694,405, prejudgment interest of $1,063,760, and a civil penalty of $2.1 million.\u0022 (Source:  US Securities and Exchange Commission, Litigation Release No. 21724 \/ November 4, 2010, Securities and Exchange Commission v. GlobalSantaFe Corp., Civil Action No. 1:10-CV-01890 (RMC) (D.D.C.), \u0022SEC Charges GlobalSantaFe with Bribery and other  FCPA Violations.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21724 \/ November 4, 2010, Securities and Exchange Commission v. GlobalSantaFe Corp., Civil Action No. 1:10-CV-01890 (RMC) (D.D.C.), \u0022SEC Charges GlobalSantaFe with Bribery and other  FCPA Violations,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21724.htm; Complaint filed November 4, 2010,  accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21724.pdf","Documents":""},{"Case ID":"ST-86","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"Nigeria","Jurisdiction of Settlement \/ Enforcement Agency":"Economic and Financial Crimes Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"01\/28","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution agreement  ","Monetary Sanctions  (Types)":"Criminal Fine, Disgorgement","Total Monetary Sanctions (US$)":"$2,500,000.00","Criminal Fine\/Penalty (US$) ":"$2,500,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$2,500,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Unknown (Bribery offenses)","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to a filing by the Noble Corporation with the US Securities and Exchange Commission, \u0022Nigerian Customs Matter \/  In November 2010, Noble-Swiss reached a settlement with the U.S. Department of Justice and the Securities and Exchange Commission in connection with their investigation under the United States Foreign Corrupt Practices Act of certain reimbursement payments made by its Nigerian affiliate to customs agents in Nigeria. In January 2011, the Nigerian Economic and Financial Crimes Commission and the Nigerian Attorney General Office initiated an investigation into these same activities. A subsidiary of Noble-Swiss has resolved this matter through the execution of a non-prosecution agreement dated January 28, 2011. Pursuant to this agreement, the subsidiary will pay $2.5 million to resolve all charges and claims of the Nigerian government.\u0022 (Source:  Noble Corporation, SEC Form 8-K, January 31, 2011.)  ","Sources ":"Noble Corporation, \u0022Form 8-K Report of Noble Corporation,\u0022 filed with the US Securities \u0026 Exchange Commission, January 31, 2011, accessed at www.sec.gov\/Archives\/edgar\/data\/1169055\/000095012311006909\/h79316e8vk.htm.","Documents":""},{"Case ID":"ST-87","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Nigeria","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,590,000.00","Criminal Fine\/Penalty (US$) ":"$2,590,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Department of Justice Press Release, on November 4, 2010, \u0022the department and Noble Corporation, a Swiss corporation, reached an agreement in which Noble Corporation admitted that it had paid approximately $74,000 to a Nigerian freight forwarding agent, acknowledged that certain employees knew that some of the payments would be passed on as bribes to Nigerian customs officials, and admitted that the company falsely recorded the bribe payments as legitimate business expenses in its corporate books, records and accounts.  As part of the non-prosecution agreement entered into with the government, Noble will pay a $2.59 million criminal penalty. The non-prosecution agreement recognizes Noble\u0027s early voluntary disclosure, thorough self-investigation of the underlying conduct, full cooperation with the department and extensive remedial measures undertaken by the company. As a result of these factors, among others, the department agreed not to prosecute Noble or its subsidiaries for the bribe payments, provided that Noble satisfies its ongoing obligations under the agreement.\u0022 (Source:  US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   US Department of Justice, In Re: Noble Corporation, Non-Prosecution Agreement dated November 4, 2010, accessed at  www.justice.gov\/criminal\/fraud\/fcpa\/cases\/noble-corp\/11-04-10noble-corp-npa.pdf; US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010, accessed at www.justice.gov\/opa\/pr\/2010\/November\/10-crm-1251.html","Documents":""},{"Case ID":"ST-88","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Nigeria","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$5,576,998.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$4,294,933","Civil Prejudgment Interest (US$) ":"$1,282,065","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission Litigation Release, on November 4, 2010, the Commission \u0022announced a settlement with Noble Corporation (Noble) for violations of the Foreign Corrupt Practices Act (FCPA). The SEC alleged that Noble, an offshore drilling contractor headquartered in Switzerland with an office in Sugarland, Texas, made improper payments through its custom agents to officials of the Nigeria Customs Service to obtain permits and permit extensions necessary for operating offshore oil rigs in Nigeria. As part of the settlement, Noble will pay $5,576,998 in disgorgement and prejudgment interest.  [ ]   The Commission\u0027s complaint, filed today in federal court in Houston, alleges that from January 2003 through May 2007, Noble authorized payments by its Nigerian subsidiary to its customs agent, believing that the agent would give portions of the payments to Nigerian government officials to induce them to grant temporary importation permits (TIPs) and TIP extensions for Noble\u0027s drilling rigs. Although Noble was required to move its rigs out of Nigeria when TIPs and any extensions had expired, it did not do so in order to avoid the costs of moving the rigs, the potential loss of profits, and the break in performance of rigs under contract. Noble used the customs agents to submit false documents to Nigerian Customs Service showing export and re-import of its drilling rigs when in fact the rigs never moved. Noble paid its customs agents to present these false documents to the Nigeria Customs Service (NCS) and, through the customs agents, made improper payments to officials of the NCS to process the false documents and issue new TIPS. Noble obtained eight TIPs with false documentation.\u0022 (Source:  US Securities and Exchange Commission, Litigation Release No. 21728\/ November 4, 2010, Securities and Exchange Commission v. Noble Corporation, Case No. 4:10-cv-4336 (S.D. Tex.), \u0022SEC Charges Noble with FCPA Violations.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21728\/ November 4, 2010, Securities and Exchange Commission v. Noble Corporation, Case No. 4:10-cv-4336 (S.D. Tex.), \u0022SEC Charges Noble with FCPA Violations,\u0022  accessed at www.sec.gov\/litigation\/litreleases\/2010\/lr21728.htm; Complaint filed November 4, 2010, accessed at www.sec.gov\/litigation\/complaints\/2010\/comp21728. ","Documents":""},{"Case ID":"ST-89","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"02\/24","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$35,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$35,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Aiding and Abetting Noble Corporation\u0027s violations of the anti-bribery, books and records, and internal controls provisions; Internal Controls and False Records violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to a Press Release by the US Securities and Exchange Commission, the agency had filed a complaint against Thomas F. O\u0027Rourke, former controller and head of internal audit at Noble Corporation, along with two other company executives whom the agency alleged perpetrated a scheme to bribe Nigerian customs officials to grant new temporary permits illegally and \u0022favorably exercise or abuse their discretion to grant permit extensions.\u0022  The press release noted that \u0022Noble Corporation was charged with FCPA violations as part of a sweep of the oil services industry in late 2010. The company cooperated with investigators and agreed to pay more than $8 million to settle civil and criminal cases.\u0022  (Source:  US Securities and Exchange Commission Press Release, \u0022SEC Charges Three Oil Services Executives with Bribing Customs Officials in Nigeria,\u0022 February 24, 2012.)","Sources ":"US Securities and Exchange Commission Press Release, \u0022SEC Charges Three Oil Services Executives with Bribing Customs Officials in Nigeria,\u0022 February 24, 2012, accessed at http:\/\/www.sec.gov\/news\/press\/2012\/2012-32.htm and complaint filed in US v. Thomas F. O\u0027Rourke (S.D. Tex), case number not provided, acccessed at http:\/\/www.sec.gov\/litigation\/complaints\/2012\/comp-pr2012-32-1.pdf","Documents":""},{"Case ID":"ST-90","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Angola, Azerbaijan, Brazil, Kazakhstan, Nigeria, Russia, Turkmenistan, and other unspecified countries","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$70,560,000.00","Criminal Fine\/Penalty (US$) ":"$70,560,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to falsify books and records, Conspiracy to aiding and abetting falsification of books and records","Offenses - Settled":"Conspiracy to falsify books and records, Conspiracy to aiding and abetting falsification of books and records","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Department of Justice Press Release dated November 14, 2010, \u0022In documents filed in U.S. District Court for the Southern District of Texas, Panalpina World Transport (Holding) Ltd., a global freight forwarding and logistics services firm based in Basel, Switzerland, and its U.S.-based subsidiary, Panalpina Inc., admitted that the companies, through subsidiaries and affiliates (collectively \u0022Panalpina\u0022), engaged in a scheme to pay bribes to numerous foreign officials on behalf of many of its customers in the oil and gas industry. They did so in order to circumvent local rules and regulations relating to the import of goods and materials into numerous foreign jurisdictions. Panalpina admitted that between 2002 and 2007, it paid thousands of bribes totaling at least $27 million to foreign officials in at least seven countries, including Angola, Azerbaijan, Brazil, Kazakhstan, Nigeria, Russia and Turkmenistan. Also today, Panalpina\u0027s customers, including Shell Nigeria Exploration and Production Company Ltd. (SNEPCO), Transocean Inc. and Tidewater Marine International Inc., admitted that the companies approved of or condoned the payment of bribes on their behalf in Nigeria and falsely recorded the bribe payments made on their behalf as legitimate business expenses in their corporate books, records and accounts.  As part of the agreed resolution, the department today filed a criminal information charging Panalpina World Transport with conspiring to violate and violating the anti-bribery provisions of the FCPA. The department and Panalpina World Transport agreed to resolve the charges by entering into a deferred prosecution agreement. The department also filed a criminal information charging Panalpina Inc. with conspiring to violate the books and records provisions of the FCPA and with aiding and abetting certain customers in violating the books and records provisions of the FCPA. Panalpina Inc. has agreed to plead guilty to the charges. The agreements require the payment of a $70.56 million criminal penalty.\u0022 (Source:  US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties; SEC and Companies Agree to Civil Disgorgement and Penalties of Approximately $80 Million,\u0022 November 4, 2010.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Panalpina Inc., Case No. 4:10-cr-00765 (S.D. Tex.), Information filed November 4, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/panalpina-inc\/11-04-10panalpina-info.pdf;  Plea Agreement filed November 4, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/panalpina-inc\/11-04-10panalpina-plea.pdf; Judgmetn filed December 16, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/panalpina-inc\/12-16-10panalpina-judgment.pdf.  US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties; SEC and Companies Agree to Civil Disgorgement and Penalties of Approximately $80 Million,\u0022 November 4, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/November\/10-crm-1251.html.","Documents":""},{"Case ID":"ST-91","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Angola, Brazil, Kazakhstan, Nigeria, Russia, and other unspecified countries","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits","Total Monetary Sanctions (US$)":"$11,329,369.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$11,329,369","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations, Aiding and abetting the bribery of foreign officials, Aiding and abetting the falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission Litigation Release, on November 4, 2010, the Commission \u0022charged the U.S. subsidiary of Panalpina World Transport (Holding) Ltd. (PWT), a global freight forwarding and logistics services provider based in Basel, Switzerland, with violating the Foreign Corrupt Practices Act (FCPA) by bribing foreign officials around the world on behalf of its customers. The SEC\u0027s complaint, filed in federal district court in Houston, alleges that from 2002 through 2007 Panalpina, Inc. (Panalpina), in concert with other PWT subsidiaries and affiliates (Panalpina Group), bribed government officials in countries including Nigeria, Angola, Brazil, Russia, and Kazakhstan. The bribes were paid by Panalpina to obtain preferential customs, duties, and import treatment for its customers in connection with international freight shipments. Although PWT, Panalpina, and the Panalpina Group are not issuers for purposes of the FCPA, many of their customers are. By paying bribes on behalf of issuers, Panalpina both violated and aided and abetted violations of the FCPA.  To settle the SEC\u0027s charges, Panalpina will pay $11,329,369. [ ]  The complaint alleges that although the bribery schemes varied, most shared several similarities. The customers often used Panalpina or other Panalpina Group companies to ship goods internationally or sought Panalpina\u0027s assistance in obtaining customs or logistics services in the country to which goods were shipped. For various reasons --including delayed departures, insufficient or incorrect documentation, the nature of the goods being shipped and imported, or the refusal of local government officials to provide services without unofficial payments -- Panalpina\u0027s customers sometimes faced delays in importing goods. In other cases, Panalpina\u0027s customers sought to avoid local customs duties or inspection requirements or otherwise sought to import goods in circumvention of local law. In order to secure the importation of goods under these circumstances, Panalpina\u0027s customers often authorized Panalpina and other Panalpina Group companies to bribe foreign officials.  The complaint further alleges that Panalpina Group companies invoiced Panalpina\u0027s customers for the bribes. The invoices, which contained both legitimate and illegitimate charges, concealed the bribes by inaccurately referring to them as \u0022local processing,\u0022 \u0022special intervention,\u0022 \u0022special handing,\u0022 and other seemingly legitimate fees. Without admitting or denying the SEC\u0027s allegations, Panalpina consented to the entry of a final judgment ordering disgorgement and permanently enjoining it from violating the FCPA\u0027s anti-bribery provisions and aiding and abetting violations of the FCPA\u0027s books and records and internal controls provisions. These provisions are codified as Sections 30A, 13(b)(2)(A), and 13(b)(2)(B) of the Securities Exchange Act of 1934. The proposed settlement is subject to court approval.","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21727 \/ November 4, 2010, SEC v. Panalpina, Inc., Civil Action No. 4:10-cv-4334 (S.D. Texas, November 4, 2010), \u0022SEC Charges Panalpina with Violating Foreign Corrupt Practices Act,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21727.htm; Complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21727.pdf","Documents":""},{"Case ID":"ST-92","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"India, Mexico, Venezuela","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/07","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$32,625,000.00","Criminal Fine\/Penalty (US$) ":"$32,625,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to aiding and abetting falsification of books and records, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to aiding and abetting falsification of books and records, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to a US Department of Justice Press Release, in \u0022documents filed in U.S. District Court for the Southern District of Texas, Pride International Inc., a Houston-based corporation, and Pride Forasol S.A.S., a wholly owned French subsidiary of Pride International (collectively \u0022Pride\u0022), admitted that Pride paid a total of approximately $800,000 in bribes directly and indirectly to government officials in Venezuela, India and Mexico. According to court documents, the bribes were paid to extend drilling contracts for three rigs operating offshore in Venezuela; to secure a favorable administrative judicial decision relating to a customs dispute for a rig imported into India; and to avoid the payment of customs duties and penalties relating to a rig and equipment operating in Mexico. During the course of the investigation, Pride provided information and substantially assisted in the investigation of Panalpina.  Pride International was charged in a criminal information filed today with conspiring to violate the anti-bribery and books and records provisions of the FCPA; violating the anti-bribery provisions of the FCPA; and violating the books and records provisions of the FCPA. The department and Pride International agreed to resolve the charges by entering into a deferred prosecution agreement. The department also filed a criminal information charging Pride Forasol with conspiring to violate the anti-bribery provisions of the FCPA; violating the anti-bribery provisions of the FCPA; and aiding and abetting the violation of the books and records provisions of the FCPA. Pride Forasol has agreed to plead guilty to the charges. The agreements require the payment of a $32.625 million criminal penalty.\u0022 (Source: US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010.)  According to the Judgment in US v. Pride Forasol S.A.S., Case No. 4:10-cr-771 (S.D. Tex.), filed December 7, 2010, Pride Forsol was ordered to pay $32,625,000 in crimina penalties. ","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. United States v. Pride Forasol S.A.S. Case No. 4:10-cr-771 (S.D.Tex.), Criminal Information filed November 4, 2010, accessed at  www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pride-forasol\/11-04-10pride-forasol-info.pdf; Plea Agreement accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pride-forasol\/12-07-10pride-forasol-plea-agree.pdf; Judgment of December 7, 2010, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pride-forasol\/11-04-10pride-forasol-judgement.pdf.  US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/November\/10-crm-1251.html","Documents":""},{"Case ID":"ST-93","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Venezuela,  India, Mexico","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Aiding and abetting falsification of books and records","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Aiding and abetting falsification of books and records","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to a US Department of Justice Press Release, in \u0022documents filed in U.S. District Court for the Southern District of Texas, Pride International Inc., a Houston-based corporation, and Pride Forasol S.A.S., a wholly owned French subsidiary of Pride International (collectively \u0022Pride\u0022), admitted that Pride paid a total of approximately $800,000 in bribes directly and indirectly to government officials in Venezuela, India and Mexico. According to court documents, the bribes were paid to extend drilling contracts for three rigs operating offshore in Venezuela; to secure a favorable administrative judicial decision relating to a customs dispute for a rig imported into India; and to avoid the payment of customs duties and penalties relating to a rig and equipment operating in Mexico. During the course of the investigation, Pride provided information and substantially assisted in the investigation of Panalpina.  Pride International was charged in a criminal information filed today with conspiring to violate the anti-bribery and books and records provisions of the FCPA; violating the anti-bribery provisions of the FCPA; and violating the books and records provisions of the FCPA. The department and Pride International agreed to resolve the charges by entering into a deferred prosecution agreement. The department also filed a criminal information charging Pride Forasol with conspiring to violate the anti-bribery provisions of the FCPA; violating the anti-bribery provisions of the FCPA; and aiding and abetting the violation of the books and records provisions of the FCPA. Pride Forasol has agreed to plead guilty to the charges. The agreements require the payment of a $32.625 million criminal penalty.\u0022 (Source: US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010.)  According to the Deferred Prosecution Agreement in the case, \u0022Finally, the parties agree that any criminal penalty that might be imposed by the Court on, or otherwise paid by, Pride Forasol in connection with its guilty plea and plea agreement entered into simultaneously herewith will be deducted from the $32,625,000 fine contemplated by this Agreement.\u0022  (US v. Pride International, Inc. Case No. 4:10-cr-00766 (S.D. Tex.), Deferred Prosecution Agreeement, para 9.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Pride International, Inc., Case No. 4:10-cr-766 (S.D. Tex.), Criminal Information filed November 4, Nov 2010, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pride-intl\/11-04-10pride-intl-info.pdf; Deferred Prosecution Agreement, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/pride-intl\/11-04-10pride-intl-dpa.pdf.  US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/November\/10-crm-1251.html","Documents":""},{"Case ID":"ST-94","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Venezuela, India, Mexico, Kazakhstan, Saudi Arabia, the Republic of the Congo, and Libya","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$23,529,718.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$19,341,870","Civil Prejudgment Interest (US$) ":"$4,187,848","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission Litigation Release, on November 4, 2010, the Commission \u0022charged one of the world\u0027s largest offshore drilling companies with violating the Foreign Corrupt Practices Act (FCPA) by paying approximately $2 million to foreign officials in eight countries. The SEC\u0027s complaint, filed in federal district court in Houston, alleges that from 2001 through 2006 Pride International, Inc. and its subsidiaries bribed government officials in Venezuela, India, Mexico, Kazakhstan, Nigeria, Saudi Arabia, the Republic of the Congo, and Libya. The bribery schemes allowed Pride and its subsidiaries to extend drilling contracts, obtain the release of drilling rigs and other equipment from customs officials, reduce customs duties, extend the temporary importation status of drilling rigs, lower various tax assessments, and obtain other improper benefits.  [ ]  According to the SEC\u0027s complaint, from 2003 through 2005, Pride\u0027s former Venezuela country manager authorized bribes totaling approximately $384,000 to an official of Venezuela\u0027s state-owned oil company to secure extensions of three drilling contracts. In addition, the country manager authorized a bribe of approximately $30,000 to an employee of Venezuela\u0027s state-owned oil company to secure the payment of receivables. The SEC alleges that in 2003 a French subsidiary of Pride paid three bribes totaling approximately $500,000, believing that the funds would be given to an Indian judge to influence customs litigation relating to the importation of a drilling rig. According to the complaint, a Pride employee in the U.S. had knowledge of the payments at the time they were made.  The complaint alleges that in 2004 a former Pride vice president authorized a $10,000 bribe to a Mexican customs official in return for favorable treatment regarding customs deficiencies identified during an inspection of a supply boat. The SEC\u0027s complaint also alleges that from 2001 through 2006 numerous improper payments made by Pride subsidiaries operating in Mexico, Kazakhstan, Nigeria, Saudi Arabia, the Republic of the Congo, and Libya were not correctly recorded in those subsidiaries\u0027 books and records. As a result, the complaint alleges that Pride failed to make and keep accurate books and records and failed to devise and maintain appropriate internal controls.\u0022 (Source:  US Securities and Exchange Commission, Litigation Release No. 21726 \/ November 4, 2010, SEC v. Pride International, Inc., Civil Action No. 4:10-cv-4335 (S.D. Texas, November 4, 2010), \u0022SEC Charges Pride International with Violating the Foreign Corrupt Practices Act.\u0022)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Securities and Exchange Commission, Litigation Release No. 21726 \/ November 4, 2010, SEC v. Pride International, Inc., Civil Action No. 4:10-cv-4335 (S.D. Texas, November 4, 2010), \u0022SEC Charges Pride International with Violating the Foreign Corrupt Practices Act,\u0022 accessed at www.sec.gov\/litigation\/litreleases\/2010\/lr21726.htm; Complaint accessed at www.sec.gov\/litigation\/complaints\/2010\/comp21726.pdf.","Documents":""},{"Case ID":"ST-95","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Mexico, Venezuela","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/09","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Final Judgment","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$40,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$40,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art, 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations, Aiding and abetting Pride\u0027s falsification of books and records, Aiding and abetting of Pride\u0027s internal controls violations, False representation to accountants","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission Litigation Release, on December 11, 2009, the Commission charged Mr. Benton, Pride\u0027s former vice president for the Western Hemisphere Operations, alleging that in December 2004, Benton authorized the bribery of a Mexican customs official in return for favorable treatment regarding customs deficiencies identified during an inspection of a supply boat. The complaint further alleges that Benton had knowledge of a second bribe paid to a different Mexican customs official that same month. It is also alleged that from approximately 2003 to 2005, a manager of a Pride subsidiary in Venezuela authorized the bribery of an official of Venezuela\u0027s state-owned oil company in order to secure extensions of three drilling contracts. Benton, in an effort to conceal these payments, redacted references to bribery in an action plan responding to an internal audit report and signed two false certifications in connection with audits and reviews of Pride\u0027s financial statements denying any knowledge of bribery.\u0022 (Source:  US securities and Exchange Commission, Litigation Release No. 21335 \/ December 14, 2009, SEC v. Bobby Benton, Civil Action No. 4:09-CV-03963 (S.D. Texas, December 11, 2009), \u0022SEC Charges Former Officer of Pride International with Violating the Foreign Corrupt Practices Act,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21335.htm.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Securities and Exchange Commission, Litigation Release No. 21726 \/ November 4, 2010, SEC v. Pride International, Inc., Civil Action No. 4:10-cv-4335 (S.D. Texas, November 4, 2010), \u0022SEC Charges Pride International with Violating the Foreign Corrupt Practices Act,\u0022 accessed at www.sec.gov\/litigation\/litreleases\/2010\/lr21726.htm; US securities and Exchange Commission, Litigation Release No. 21335 \/ December 14, 2009, SEC v. Bobby Benton, Civil Action No. 4:09-CV-03963 (S.D. Texas, December 11, 2009), \u0022SEC Charges Former Officer of Pride International with Violating the Foreign Corrupt Practices Act,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21335.htm; Complaint filed December 11, 2009, accessed at www.sec.gov\/litigation\/complaints\/2009\/comp21335.pdf","Documents":""},{"Case ID":"ST-96","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Venezuela","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/09","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$25,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$25,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations, Aiding and Abetting Pride\u0027s bribery of foreign officials, Aiding and Abetting Pride\u0027s falsification of books and records, Aiding and Abetting Pride\u0027s internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission Litigation Release, \u0022On August 5, 2010, the Securities and Exchange Commission charged a former employee of Pride International, Inc. (Pride) with violations relating to bribes paid to foreign officials in Venezuela. The Commission\u0027s complaint names Joe Summers of John Day, Oregon, Pride\u0027s former Venezuela Country Manager.  The complaint alleges that from approximately 2003 to 2005, Summers authorized or allowed payments totaling approximately $384,000 to third-party companies believing that all or a portion of the funds would be given to an official of Venezuela\u0027s state-owned oil company in order to secure extensions of three drilling contracts. The complaint further alleges that Summers authorized the payment of approximately $30,000 to a third party believing that all or a portion of the funds would be given to an employee of Venezuela\u0027s state-owned oil company in order to obtain the payment of receivables.\u0022 (Source: US Securities and Exchange Commission, Litigation Release No. 21617 \/ August 5, 2010, SEC v. Joe Summers, Civil Action No. 4:10-cv-02786 (S.D. Texas, August 5, 2010), \u0022SEC Charges Former Employee of Pride International with Violating the Foreign Corrupt Practices Act.\u0022) ","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Securities and Exchange Commission, Litigation Release No. 21726 \/ November 4, 2010, SEC v. Pride International, Inc., Civil Action No. 4:10-cv-4335 (S.D. Texas, November 4, 2010), \u0022SEC Charges Pride International with Violating the Foreign Corrupt Practices Act,\u0022 accessed at www.sec.gov\/litigation\/litreleases\/2010\/lr21726.htm; US Securities and Exchange Commission, Litigation Release No. 21617 \/ August 5, 2010, SEC v. Joe Summers, Civil Action No. 4:10-cv-02786 (S.D. Texas, August 5, 2010), \u0022SEC Charges Former Employee of Pride International with Violating the Foreign Corrupt Practices Act,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21617.htm; Complaint filed August 5, 2010, accessed at www.sec.gov\/litigation\/complaints\/2010\/comp21617.pdf","Documents":""},{"Case ID":"ST-97","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"[Nigeria - secondary source]","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$18,149,459.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$14,153,536","Civil Prejudgment Interest (US$) ":"$3,995,923","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Securities and Exchange Commission Order Instituting Cease and Desist Proceedings, \u0022This matter concerns violations of the anti-bribery provisions of the Foreign Corrupt Practices Act (\u0022FCPA\u0022) by Respondent [Shell Nigeria Exploration and Production Company] and the record keeping and internal controls provisions of the FCPA by Respondent Shell. From September 2002 through November 2005, SIEP [Shell International Exploration and Production, Inc.], on behalf of Shell, authorized the reimbursement or continued use of services provided by a company acting as a customs broker that involved suspicious payments of approximately $3.5 million to officials of the Nigerian Customs Service in order to obtain preferential treatment during the customs process for the purpose of assisting Shell in obtaining or retaining business in Nigeria on Shell\u0027s Bonga Project. As a result of these payments, Shell profited in the amount of approximately $14 million. None of the improper payments was accurately reflected in Shell\u0027s books and records, nor was Shell\u0027s system of internal accounting controls adequate at the time to detect and prevent these suspicious payments.\u0022  (Source:  In Re: Royal Dutch Shell plc and Shell Nigeria Exploration and Production Company, US Securities and Exchange Commission Order Instituting Cease and Desist Proceedings, Administrative Proceeding File No. 3-14107, November 4, 2010, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2010\/34-63243.pdf.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  In Re: Royal Dutch Shell plc and Shell Nigeria Exploration and Production Company, US Securities and Exchange Commission Order Instituting Cease and Desist Proceedings, Administrative Proceeding File No. 3-14107, November 4, 2010, accessed at http:\/\/www.sec.gov\/litigation\/admin\/2010\/34-63243.pdf","Documents":""},{"Case ID":"ST-98","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"[Nigeria - secondary source]","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$30,000,000.00","Criminal Fine\/Penalty (US$) ":"$30,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Aiding and abetting falsification of books and records","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Aiding and abetting falsification of books and records","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Department of Justice Press Release, on November 4, 2010, \u0022A criminal information was also filed today charging SNEPCO, a Nigerian subsidiary of Royal Dutch Shell plc (collectively \u0022Shell\u0022), with conspiring to violate the anti-bribery and books and records provisions of the FCPA, and with aiding and abetting a violation of the books and records provisions. Royal Dutch Shell is the owner of a global group of energy and petrochemicals companies. The charges relate to approximately $2 million SNEPCO paid to its subcontractors with the knowledge that some or all of the money would be paid as bribes to Nigerian customs officials by Panalpina to import materials and equipment into Nigeria. To resolve the matter, the department and Shell have entered into a deferred prosecution agreement that requires, among other things, SNEPCO to pay a $30 million criminal penalty.\u0022  (Source:  US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  United States v. Shell Nigeria Exploration and Production Company Ltd, Case No. 4:10-cr-767 (S.D. Tex.), Information filed November 4, 2010, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/snepco\/11-04-10snepco-info.pdf; Deferred Prosecution Agreement filed November 4, 2010, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/cases\/snepco\/11-04-10snepco-dpa.pdf; US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/November\/10-crm-1251.html","Documents":""},{"Case ID":"ST-99","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Azerbaijan, Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$8,321,362.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$7,223,216.00","Civil Prejudgment Interest (US$) ":"$881,146","Civil Fine \/ Penalty (US$)":"$217,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"No (Customs, Tax)","Summary":"According to the US Securities and Exchange Commission Litigation Release, on November 4, 2010, the Commission \u0022charged New Orleans-based shipping company Tidewater Inc. with violating the Foreign Corrupt Practices Act (FCPA) for paying bribes to foreign government officials in Azerbaijan disguised as payments for legitimate services. Tidewater is also charged with authorizing improper payments to customs officials in Nigeria that were inaccurately recorded as legitimate expenses in the Company\u0027s books and records. The SEC alleges that Tidewater, directly or through its subsidiaries and agents, paid $160,000 in bribes to foreign government officials in Azerbaijan in 2001, 2003 and 2005 in order to influence acts and decisions by Azeri tax officials to resolve local audits in favor of a Tidewater subsidiary. The SEC further alleges that from January 2002 through March 2007, Tidewater, through a subsidiary, reimbursed approximately $1.6 million to its customs broker in Nigeria used to make improper payments to local Nigerian customs officials. These improper payments were made in order to induce the Nigerian officials to disregard regulatory requirements in Nigeria relating to the temporary importation of Tidewater\u0027s vessels into Nigerian waters. Tidewater improperly recorded these payments as legitimate expenses in its books and records.\u0022 (Source:  US Securities and Exchange Commission, Litigation Release No. 21729 \/ November 4, 2010, Securities and Exchange Commission v. Tidewater Inc., Civil Action No. 2:10-CV-04180 (U.S. District Court for the Eastern District of Louisiana).)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21729 \/ November 4, 2010, Securities and Exchange Commission v. Tidewater Inc., Civil Action No. 2:10-cv-04180 (U.S. District Court for the Eastern District of Louisiana), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21729.htm; Complaint filed November 4, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21729.pdf","Documents":""},{"Case ID":"ST-100","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Azerbaijan, Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$7,350,000.00","Criminal Fine\/Penalty (US$) ":"$7,350,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Falsification of books and records","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to falsify books and records, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"No (Customs, Tax)","Summary":"According to the US Department of Justice Press Release, on November 4, 2010, the Department \u0022filed a criminal information charging Tidewater Marine International Inc., a Cayman Island subsidiary of Tidewater Inc. (collectively \u0022Tidewater\u0022), with conspiring to violate the anti-bribery and books and records provisions of the FCPA, and with violating the books and records provisions of the FCPA. Tidewater Inc. is a global operator of offshore service and supply vessels for energy exploration headquartered in New Orleans. The charges filed against Tidewater Marine relate to approximately $160,000 in bribes paid through its employees and agents to tax inspectors in Azerbaijan to improperly secure favorable tax assessments and approximately $1.6 million in bribes paid through Panalpina to Nigerian customs officials to induce the officials to disregard Nigerian customs regulations relating to the importation of vessels into Nigerian waters. To resolve the matter, the department and Tidewater have entered into a deferred prosecution agreement that requires, among other things, Tidewater Marine to pay a $7.35 million criminal penalty.\u0022 (Source:  US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Tidewater Marine International Inc., Case No. 4:10-cr-00770 (S.D. Tex.), Information filed November 4, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tidewater-intl\/11-04-10tidewater-info.pdf; Deferred Prosecution Agreement filed November 4, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tidewater-intl\/11-04-10tidewater-dpa.pdf.  US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/November\/10-crm-1251.html","Documents":""},{"Case ID":"ST-101","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"Nigeria","Jurisdiction of Settlement \/ Enforcement Agency":"Economic and Financial Crimes Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"03\/03","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Unspecified","Total Monetary Sanctions (US$)":"$6,300,000.00","Criminal Fine\/Penalty (US$) ":"$6,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"$300,000 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$6,300,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Improper payments","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to Tidwater Inc.\u0027s March 3, 2011 Form 8-K filed with the US Securities and Exchange Commission, pursuant to a settlement agreement announced that day, Tidewater agreed to settle allegations that the Nigerian affiliate of a Swiss-based freight forwarder had made improper payments to government officials in Nigeria on behalf of Tidewater\u0027s foreign subsidiaries.  The Nigerian investigation revolved around the same 2007 conduct detailed in Tidewater\u0027s settlements with the US Department of Justice and the Securities and Exchange Commission. Tidewater agreed to pay $6 million to the Government of Nigeria and an additional $300,000 for the Government of Nigeria\u0027s attorneys and other expenses. (Source:  Technip Inc., SEC Form 8-K filed March 3, 2011.)  Tidewater\u0027s settlements with the US Department of Justice and the Securities and Exchange Commission are detailed in: US v. Tidewater Marine International, Inc., Case No. 4:10-cr-00770 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts filed November 4, 2010; and US Securities and Exchange Commission, Litigation Release No. 21729 (November 4, 2010), in SEC v. Tidewater, Inc., Case No. 2:10-cv-04180 (E.D. La.), Complaint filed November 4, 2010.   Please note that the settlement agreement with the Nigerian government is confidential and not publicly available.","Sources ":"Tidewater, Inc., US Securities and Exchange Commission Form 8-K filed March 3, 2011, at http:\/\/www.sec.gov\/Archives\/edgar\/data\/98222\/000119312511055141\/d8k.htm; US v. Tidewater Marine International, Inc., Case No. 4:10-cr-00770 (S.D. Tex.), Deferred Prosecution Agreement and Statement of Facts filed November 4, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/tidewater-intl\/11-04-10tidewater-dpa.pdf; US Securities and Exchange Commission, Litigation Release No. 21729 (November 4, 2010), in SEC v. Tidewater, Inc., Case No. 2:10-cv-04180 (E.D. La.), Complaint filed November 4, 2010, both accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21729.htm and http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21729.pdf.","Documents":""},{"Case ID":"ST-102","Case Cluster ":"Bribery by Oil Services and Freight Forwarding Companies","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"11\/04","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$13,440,000.00","Criminal Fine\/Penalty (US$) ":"$13,440,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to falsify books and records, Conspiracy to aiding and abetting falsification of books and records","Offenses - Settled":"Conspiracy to falsify books and records, Conspiracy to aiding and abetting falsification of books and records","Public Procurement Contract \/ SOE Involved?":"No (Customs)","Summary":"According to the US Department of Justice Press Release, \u0022Transocean Inc., a Caymans Island subsidiary of Transocean Ltd. (collectively \u0022Transocean\u0022), was charged today in a criminal information with conspiring to violate the anti-bribery and books and records provisions of the FCPA; violating the anti-bribery provision of the FCPA; and aiding and abetting the violation of the books and records provisions of the FCPA. Transocean Ltd. is a global provider of offshore oil drilling services and equipment based in Vernier, Switzerland. The charges relate to approximately $90,000 in bribes paid by Transocean Inc.\u0027s freight forwarding agents in Nigeria to Nigerian customs officials to circumvent Nigerian customs regulations regarding the import of goods and materials and the import of Transocean\u0027s deep-water oil rigs into Nigerian waters. The department and Transocean have agreed to enter into a deferred prosecution agreement that requires, among other things, Transocean Inc. to pay a $13.44 million criminal penalty.\u0022 (Source: US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010.)","Sources ":"Report by the United States to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions\u0022 (June 2011), Bribery by Oil Services and Freight Forwarding Companies Case Summary at 32-37, accessed at  http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Transocean Inc., Case No. 4:10-cr-00768 (S.D. Tex.), Information filed November 4, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/transocean-inc\/11-04-10transocean-info.pdf; Deferred Prosecution Agreement filed November 4, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/transocean-inc\/11-04-10transocean-dpa.pdf.  US Department of Justice Press Release, \u0022Oil Services Companies and a Freight Forwarding Company Agree to Resolve Foreign Bribery Investigations and to Pay More Than $156 Million in Criminal Penalties,\u0022 November 4, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/November\/10-crm-1251.html","Documents":""},{"Case ID":"ST-1","Case Cluster ":"AB Volvo","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"03\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$12,602,649.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"NA","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$7,299,208","Civil Prejudgment Interest (US$) ":"$1,303,441","Civil Fine \/ Penalty (US$)":"$4,000,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal controls violations, Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On March 20, 2008, AB Volvo, a Swedish company, entered into a deferred prosecution agreement with the Department of Justice and a settlement agreement with the SEC in connection with payments made by two of its subsidiaries to obtain contracts administered by the United Nations Oil for Food Program (OFFP). The subsidiaries, Renault Trucks SAS (Renault Trucks) and Volvo Construction Equipment AB (VCE), were charged in separate conspiracies to commit wire fraud and violate the books and records provision of the FCPA.According to the court documents, between November 2000 and April 2003, employees and agents of Renault Trucks paid a total of approximately $5 million in kickbacks to the Iraqi government for a total of approximately $61 million worth of contracts with various Iraqi ministries. To pay the kickbacks, Renault Trucks inflated the price of contracts by approximately 10 percent before submitting them to the U.N. for approval and concealed from the U.N. the fact that the contract prices contained a kickback to the Iraqi government. In some cases, Renault Trucks paid inflated prices to companies that outfitted the chassis and cabs produced by Renault Trucks. Those companies then used the excess funds to pay the kickbacks to the Iraqi government on behalf of Renault Trucks.  Between December 2000 and January 2003, Volvo Construction Equipment International AB (VCEI), the predecessor to VCE, and its distributors were awarded a total of approximately $13.8 million worth of contracts. During the same time period, employees, agents and distributors of VCEI paid a total of approximately $1.3 million in kickbacks to the Iraqi government by inflating the price of contracts by approximately 10 percent before submitting them to the U.N. for approval. Similar to Renault Trucks, VCE concealed from the U.N. the fact that the contract prices contained a kickback to the Iraqi government.\u0022  (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, AB Volvo Case Summary at 82-83.)   AB Volvo\u0027s settlement agreement with the US SEC is summarized in the SEC Litigation Release No. 20504 \/ March 20, 2008. ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, AB Volvo Case Summary at 82-83, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 20504 \/ March 20, 2008, Securities \u0026 Exchange Commission v. AB Volvo, Civil Action No. 08 CV 00473 (D.D.C.) (JB), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against AB Volvo For Improper Payments to Iraq Under the U.N. Oil for Food Program -- Company Agrees to Pay Over $12.6 Million in Civil Penalties, Disgorgement of Profits, and Interest,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20504.htm; SEC Complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20504.pdf.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/AB%20Volvo_SEC_Litigation_Release_Mar_20_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/AB_Volvo_SEC_Complaint_Mar_20_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/AB_Volvo_Settlement_DOJ_PR_Mar_8_2008_1.pdf"},{"Case ID":"ST-2","Case Cluster ":"AB Volvo","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"03\/20","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$7,000,000.00","Criminal Fine\/Penalty (US$) ":"$7,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud","Offenses - Settled":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On March 20, 2008, AB Volvo, a Swedish company, entered into a deferred prosecution agreement with the Department of Justice and a settlement agreement with the SEC in connection with payments made by two of its subsidiaries to obtain contracts administered by the United Nations Oil for Food Program (OFFP). The subsidiaries, Renault Trucks SAS (Renault Trucks) and Volvo Construction Equipment AB (VCE), were charged in separate conspiracies to commit wire fraud and violate the books and records provision of the FCPA.  According to the court documents, between November 2000 and April 2003, employees and agents of Renault Trucks paid a total of approximately $5 million in kickbacks to the Iraqi government for a total of approximately $61 million worth of contracts with various Iraqi ministries. To pay the kickbacks, Renault Trucks inflated the price of contracts by approximately 10 percent before submitting them to the U.N. for approval and concealed from the U.N. the fact that the contract prices contained a kickback to the Iraqi government. In some cases, Renault Trucks paid inflated prices to companies that outfitted the chassis and cabs produced by Renault Trucks. Those companies then used the excess funds to pay the kickbacks to the Iraqi government on behalf of Renault Trucks.Between December 2000 and January 2003, Volvo Construction Equipment International AB (VCEI), the predecessor to VCE, and its distributors were awarded a total of approximately $13.8 million worth of contracts. During the same time period, employees, agents and distributors of VCEI paid a total of approximately $1.3 million in kickbacks to the Iraqi government by inflating the price of contracts by approximately 10 percent before submitting them to the U.N. for approval. Similar to Renault Trucks, VCE concealed from the U.N. the fact that the contract prices contained a kickback to the Iraqi government.  Criminal Case Disposition:  To resolve its criminal liability in connection with this bribery scheme, AB Volvo, on behalf of itself and its subsidiaries, entered into a three-year deferred prosecution agreement with the Department, whereby AB Volvo agreed to pay a criminal fine of $7 million.\u0022 (Source:  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, AB Volvo Case Summary at 82-83.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, AB Volvo Case Summary at 82-83, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Volvo Construction Equipment, AB, Case No. 08-CR-069-RJL (D.D.C.), Information filed on March 20, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/volvo-ab\/03-20-08volvo-info.pdf;  US v. Renault Trucks SAS, Case No. 08-CR-068-RJL (D.D.C.), Information filed on March 20, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/renault-trucks\/03-20-08renault-trucks-info.pdf;  In Re: AB Volvo et al, US Department of Justice, Deferred Prosecution Agreement and Statement of Facts, filed March 20, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/volvo-ab\/03-18-08volvo-dpa.pdf.  US Department of Justice Press Release, \u0022AB Volvo to Pay $7 Million Penalty for Kickback Payments to the Iraqi Government under the U.N. Oil for Food Program,\u0022 March 20, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/March\/08_crm_220.html. ","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/AB_Volvo_Deferred_Prosecution_Agreement_Mar_18_2008_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/AB_Volvo_Renault_Trucks_Information_March_20_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/AB_Volvo_Settlement_DOJ_PR_Mar_8_2008_0.pdf"},{"Case ID":"ST-3","Case Cluster ":"ABB Ltd. (Matter #15)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico, Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"09\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, in 2005 ABB Ltd. self-reported to the US authorities that its Texan subsidiary ABB Inc. (which did business as ABB Network Management) may have made corrupt payments to public officials in Mexico to obtain contracts with the Comision Federal de Electricidad, a Mexican state-owned utility company.  The bribe payments were allegedly funnelled through a Mexican company that ABB NM hired, as well as through a company controlled by its representatives.  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39.)  According to the Plea Agreement, the Department of Justice recommended as part of the sentence, \u0022Fine. Assuming ABB Inc. accepts responsibility as explained above, the parties will recommend the imposition of a fine in the amount of $28,500,000 payable to the Clerk of the Court for the United States District Court for the Southern District of Texas.\u0022 (Source: US v. ABB Inc., Case No. 4:10-cr-00664 (S.D. Tex.), Plea Agreement filed September 29, 2010, para 10.)  According to the Judgement in the case, ABB Inc. was fined $17,100,000. (Source: US v. ABB Inc., Case No. 4:10-cr-00664 (S.D. Tex.), Judgment in a Criminal Case, filed October 1, 2010.)   According to the Deferred Prosecution Agreement in US v. ABB Ltd. (Parent company), \u0022ABB Ltd agrees to pay a total monetary penalty in the amount of $30,420,000, or the bottom of the applicable combined Sentencing Guidelines fine range for ABB Inc. and ABB Ltd - Jordan. ABB Ltd will pay $28,500,000 on behalf of ABB Inc. in connection with ABB Inc.\u0027s guilty plea and $1,920,000 on behalf of ABB Ltd - Jordan.\u0022  (US v. ABB Ltd., Case No. 4_10-cr-00665 (S.D. Tex.), Deferred Prosecution Agreement filed September 29, 2010.)  The US Department of Justice press release stated that ABB Ltd. resolved the cases involving its two subsidiaries by agreeing to pay $19 million in fines. (Source: US Department of Justice Press Release, \u0022ABB Ltd and Two Subsidiaries Resolve Foreign Corrupt Practices Act Investigation and Will Pay $19 Million in Criminal Penalties,\u0022 September 29, 2010.)  Please note that the settlement amounts in this entry are $0 as the amounts have been recorded in the appropriate entries for the subsidiaries.","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. ABB Inc., Case No. 4:10-cr-00664 (S.D. Tex.), Plea Agreement and Statement of Facts filed September 29, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/09-29-10abbinc-plea.pdf; US v. ABB Ltd., Case No. 4:10-cr-00665 (S.D. Tex.), Deferred Prosecution Agreement filed September 29, 2010, accessed at www.fcpa.shearman.com;  US Department of Justice Press Release, \u0022ABB Ltd and Two Subsidiaries Resolve Foreign Corrupt Practices Act Investigation and Will Pay $19 Million in Criminal Penalties,\u0022 September 29, 2010.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Ltd_Deferred_Prosecution_Agreement_Sep_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Settlement_DOJ_PR_Sep_29_2010.pdf"},{"Case ID":"ST-4","Case Cluster ":"ABB Ltd. (Matter #15)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Mexico, Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"09\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$39,314,262.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$17,141,474","Civil Prejudgment Interest (US$) ":"$5,662,788","Civil Fine \/ Penalty (US$)":"$16,510,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Books and records violations, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Litigation Release by the Securities and Exchange Commission, \u0022The SEC alleges that ABB, through its subsidiaries, paid bribes to government officials in Mexico to obtain business with government owned power companies, and paid kickbacks to the former regime in Iraq to obtain contracts under the United Nations Oil for Food Program. As alleged in the complaint, ABB\u0027s subsidiaries made at least $2.7 million in illicit payments in these schemes to obtain contracts that generated more than $100 million in revenues for ABB.  In the Mexican bribery scheme, the SEC alleges that from 1999 through 2004, ABB Network Management (\u0022ABB NM\u0022), a business unit within ABB\u0027s U.S. subsidiary, ABB, Inc., bribed officials in Mexico to obtain and retain business with two government owned electric utilities, Comision Federal de Electricidad (\u0022CFE\u0022) and Luz y Fuerza del Centro (\u0022LyFZ\u0022). [  ]  The SEC further alleges that from approximately 2000 to 2004 ABB participated in the United Nations Oil for Food Program (the \u0022Program\u0022). [  ]  According to the complaint, ABB participated in the Program through six subsidiaries: ABB Near East Trading Ltd. (\u0022ABB Jordan\u0022), ABB Automation, ABB Industrie AC Machines and ABB Solyvent-Ventec (collectively referred to as \u0022ABB France\u0022), ABB AG (\u0022ABB Austria\u0022), and ABB Elektrik Sanayi AS (\u0022ABB Turkey\u0022). The SEC alleges that these subsidiaries developed various schemes to pay secret kickbacks to Iraq to obtain contracts under the Program. ABB\u0027s Jordanian subsidiary acted as a conduit for other ABB subsidiaries by making the kickback payments on their behalf. Some of the kickbacks were made in the form of bank guarantees and cash payments. ABB improperly recorded the kickbacks on its books as legitimate payments for after sales services, consultation costs, and commissions.\u0022 (Source:  US Securities \u0026 Exchange Commission, Litigation Release No. 21673 \/ September 29, 2010, U.S. Securities and Exchange Commission v. ABB Ltd, Civil Action No. 1:10-CV-01648 (DDC) (PLF), \u0022SEC Charges ABB for Bribery Schemes in Mexico and Iraq - ABB to Pay $39 Million in Disgorgement and Civil Penalties.\u0022)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Securities \u0026 Exchange Commission, Litigation Release No. 21673 \/ September 29, 2010, U.S. Securities and Exchange Commission v. ABB Ltd, Civil Action No. 1:10-CV-01648 (DDC) (PLF), \u0022SEC Charges ABB for Bribery Schemes in Mexico and Iraq - ABB to Pay $39 Million in Disgorgement and Civil Penalties,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21673.htm; US v. ABB Ltd., Case No. 1:10-cv-01648-PLF (D.D.C.), Complaint filed on September 29, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp-pr2010-175.pdf","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_SEC_Litigation_Release_Sep_29_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_SEC_Complaint_Sep_29_2010.pdf"},{"Case ID":"ST-5","Case Cluster ":"ABB Ltd. (Matter #15)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico, Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"09\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$17,100,000.00","Criminal Fine\/Penalty (US$) ":"$17,100,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials, Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, in 2005 ABB Ltd. self-reported to the US authorities that its Texan subsidiary ABB Inc. (which did business as ABB Network Management) may have made corrupt payment sto public officials in Mexico to obtain contracts with the Comision Federal de Electricidad, a Mexican state-owned utility company.  The bribe payments were allegedly funnelled through a Mexican company that ABB NM hired, as well as through a company controlled by its representatives.  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39.)  According to the Plea Agreement, the Department of Justice recommended as part of the sentence, \u0022Fine. Assuming ABB Inc. accepts responsibility as explained above, the parties will recommend the imposition of a fine in the amount of $28,500,000 payable to the Clerk of the Court for the United States District Court for the Southern District of Texas.\u0022 (Source: US v. ABB Inc., Case No. 4:10-cr-00664 (S.D. Tex.), Plea Agreement filed September 29, 2010, para 10.)  According to the Judgement in the case, ABB Inc. was fined $17,100,000. (Source: US v. ABB Inc., Case No. 4:10-cr-00664 (S.D. Tex.), Judgment in a Criminal Case, filed October 1, 2010.)   According to the Deferred Prosecution Agreement in US v. ABB Ltd. (Parent company), \u0022ABB Ltd agrees to pay a total monetary penalty in the amount of $30,420,000, or the bottom of the applicable combined Sentencing Guidelines fine range for ABB Inc. and ABB Ltd - Jordan. ABB Ltd will pay $28,500,000 on behalf of ABB Inc. in connection with ABB Inc.\u0027s guilty plea and $1,920,000 on behalf of ABB Ltd - Jordan.\u0022  (US v. ABB Ltd., Case No. 4_10-cr-00665 (S.D. Tex.), Deferred Prosecution Agreement filed September 29, 2010.)  The US Department of Justice press release stated that ABB Ltd. resolved the cases involving its two subsidiaries by agreeing to pay $19 million in fines. (Source: US Department of Justice Press Release, \u0022ABB Ltd and Two Subsidiaries Resolve Foreign Corrupt Practices Act Investigation and Will Pay $19 Million in Criminal Penalties,\u0022 September 29, 2010.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. ABB Inc., Case No. 4:10-cr-00664 (S.D. Tex.), Plea Agreement and Statement of Facts filed September 29, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/09-29-10abbinc-plea.pdf; US v. ABB Ltd., Case No. 4_10-cr-00665 (S.D. Tex.), Deferred Prosecution Agreement filed September 29, 2010, accessed at www.fcpa.shearman.com;  US Department of Justice Press Release, \u0022ABB Ltd and Two Subsidiaries Resolve Foreign Corrupt Practices Act Investigation and Will Pay $19 Million in Criminal Penalties,\u0022 September 29, 2010.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Ltd_Deferred_Prosecution_Agreement_Sep_2010_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_US_Settlement_DOJ_PR_Sept_29_2010.pdf"},{"Case ID":"ST-6","Case Cluster ":"ABB Ltd. (Matter #15)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"09\/29","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,920,000.00","Criminal Fine\/Penalty (US$) ":"$1,920,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7","Offenses - Alleged":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud, Money laundering","Offenses - Settled":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud, Money laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On September 29, 2010, the Department also charged ABB Ltd\u0027s Jordanian subsidiary, ABB Ltd - Jordan, with one count of conspiracy to commit wire fraud and to violate the books and records provisions of the FCPA. According to court documents, from 2000 to 2004, ABB Ltd - Jordan and other ABB subsidiaries paid, or caused to be paid, more than $800,000 in kickbacks to the former Iraqi government to secure 27 contracts under the U.N. Oil-for-Food Program (OFFP). For example, from 2001 to 2002, ABB Ltd - Jordan paid more than $300,000 in kickbacks to three regional companies of the Iraqi Electricity Commission, an Iraqi government agency, in order to secure 11 purchase orders worth more than $5.9 million. All together, ABB subsidiaries allegedly earned more than $13,500,000 in revenue and $3,800,000 in profits from contracts obtained through illegal kickbacks under the OFFP.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US v. ABB Ltd., Case No. 4:10-cr-00665 (S.D. Tex.), Criminal Information filed September 29, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/09-29-10abbjordan-info.pdf; Deferred Prosecution Agreement (in US v. ABB Ltd. which pertains to ABB Ltd. - Jordan), filed September 29, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/09-29-10abbjordan-dpa.pdf; US Department of Justice Press Release, \u0022ABB Ltd and Two Subsidiaries Resolve Foreign Corrupt Practices Act Investigation and Will Pay $19 Million in Criminal Penalties,\u0022 September 29, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/September\/10-crm-1096.html.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Jordan_Information_Sep_29_2010.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Ltd_Deferred_Prosecution_Agreement_Sep_2010_1.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_US_Settlement_DOJ_PR_Sept_29_2010_0.pdf"},{"Case ID":"ST-7","Case Cluster ":"ABB Ltd. (Matter #15)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Mexico, Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits","Total Monetary Sanctions (US$)":"$234,357.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$234,357","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Books and records violations, Internal controls violations, Aiding and abetting ABB\u0027s falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Litigation Release by the US Securities and Exchange Commission, \u0022As alleged in the complaint, Hozhabri was a project manager for ABB Network Management (\u0022ABB NM\u0022), a division of a U.S. based ABB subsidiary, which provides products and services for managing power generation and transmission networks. The Commission alleges that, from 2002 through 2004, Hozhabri fraudulently submitted approximately $468,714 in cash and check disbursement requests to ABB NM for purported business expenses associated with projects in Brazil, Paraguay, and the United Arab Emirates. As alleged in the complaint, these purported expenses were phony, and inaccurately recorded as legitimate business expenses in ABB\u0027s books and records. The Commission further alleges that the funds disbursed by ABB NM as a result of these requests were not used to pay any business expenses, but rather were embezzled by Hozhabri and the former General Manager of ABB NM. According to the complaint, Hozhabri personally kept $234,357 of the embezzled funds.\u0022  (Source: US Securities and Exchange Commission, Litigation Release No. 20671 \/ August 6, 2008, SEC v. Ali Hozhabri, Civil Action No. 08 CV 1359 (D.D.C.), \u0022SEC Charges Former ABB Project Manager for Falsifying Company\u0027s Books and Records.\u0022)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. US Securities and Exchange Commission, Litigation Release No. 20671 \/ August 6, 2008, SEC v. Ali Hozhabri, Civil Action No. 08 CV 1359 (D.D.C.), \u0022SEC Charges Former ABB Project Manager for Falsifying Company\u0027s Books and Records,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2008\/lr20671.htm and Complaint filed August 6, 2008, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2008\/comp20671.pdf.  ABB Ltd. Case Documents: US Securities \u0026 Exchange Commission, Litigation Release No. 21673 \/ September 29, 2010, U.S. Securities and Exchange Commission v. ABB Ltd, Civil Action No. 1:10-CV-01648 (DDC) (PLF), \u0022SEC Charges ABB for Bribery Schemes in Mexico and Iraq - ABB to Pay $39 Million in Disgorgement and Civil Penalties,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21673.htm; US v. ABB Ltd., Case No. 1:10-cv-01648-PLF (D.D.C.), Complaint filed on September 29, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp-pr2010-175.pdf","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Hozhabri_SEC_Complaint_Aug_6_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Ali_Hozhabri_SEC_Litigation_Release_Aug_6_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Settlement_DOJ_PR_Sep_29_2010_0.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_SEC_Litigation_Release_Sep_29_2010_0.pdf"},{"Case ID":"ST-8","Case Cluster ":"ABB Ltd. (Matter #15)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Mexico","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"11\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$2,030,076.74","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$2,030,076.74 ","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Conspiracy to bribe foreign officials, Conspiracy to commit currency transfer structuring, Conspiracy to commit international money laundering, Conspiracy to falsify records in a federal investigation, Bribery of foreign officials, Currency transaction structuring","Offenses - Settled":"Conspiracy to bribe foreign officials, Conspiracy to commit money laundering, Falsification of records in a federal investigation","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, in 2005 ABB Ltd. self-reported to the US authorities that its Texan subsidiary ABB Inc. (which did business as ABB Network Management) may have made corrupt payments to public officials in Mexico to obtain contracts with the Comision Federal de Electricidad, a Mexian state-owned utility company.  The bribe payments were allegedly funnelled through a Mexican company that ABB NM hired, as well as through a company controlled by its representatives.  Mr. Basurto was an agent\/intermediary; he pleaded guilty to charged offenses on November 16, 2009. (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39.)  According to his plea agreement, Mr. Basurto \u0022agrees to forfeit to the United States in the form of a money judgment against him, voluntarily and immediately, all of his right, title and interest to all assets, and\/or their substitutes, which are subject to forfeiture pursuant to Title 18, United States Code, Section 981(a)(1)(C), Title 21 United States Code, Section 853, and Title 28, United States Code, Section 2461 as follows: the sum of $2,030,076.74. The defendant\u0027s forfeiture obligation shall be joint and several with that of his co-conspirators.\u0022  (Source: US v. Basurto, Case No. 4:09-cr-325 (S.D. Tex.), Plea Agreement filed November 23, 2009, para 10.)  On April 11, 2012, the $2,030,076.74 was forfeited to the United States.  (Source: US v. Basurto, Case No. 4_09-cr-325 (S.D. Tex.), Order of Forfeiture filed April 11, 2012 and Judgment in a Criminal Case filed April 5, 2012.)  The US Department of Justice Press Release acknowledged the assistance of the \u0022Federal Republic of Germany for supplying evidence in connection with this investigation.\u0022 (Source: US Department of Justice Press Release, \u0022Former General Manager of Texas Business Arrested for Role in Alleged Scheme to Bribe Officials at Mexican State-Owned Electrical Utility \/ Mexican Intermediary Pleads Guilty for His Role in Foreign Bribery Scheme,\u0022 November 23, 2009.)  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#15) at 37-39, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Basurto, Case No. 4:09-cr-325 (S.D. Tex.), Superseding Information filed November 23, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/basurto\/11-16-09basurto-supersed-info.pdf; Plea Agreement filed November 23, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/basurto\/11-23-09basurto-plea-agree.pdf and Order of Forfeiture filed April 11, 2012 and Judgment in a Criminal Case filed April 5, 2012, both accessed via PACER; US Department of Justice Press Release, \u0022Former General Manager of Texas Business Arrested for Role in Alleged Scheme to Bribe Officials at Mexican State-Owned Electrical Utility \/ Mexican Intermediary Pleads Guilty for His Role in Foreign Bribery Scheme,\u0022 November 23, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/November\/09-crm-1265.html.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Basurto_Plea_Agreement_Nov_23_2009.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Basurto_Plea_DOJ_PR_Nov_23_2008.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Basurto_Judgment_Apr_5_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Basurto_Forfeiture_Order_Apr_11_2012.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ABB_Basurto_Supeseding_Information_Nov_16_2009.pdf"},{"Case ID":"ST-9","Case Cluster ":"ABB Ltd. (Matter #76)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria, Kazakhstan, Angola","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"07\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Pofits, Prejudgment Interest","Total Monetary Sanctions (US$)":"$5,915,405.64","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$5,501,157","Civil Prejudgment Interest (US$) ":"$414,248.64","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials, Internal controls violations, Books and records violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, \u0022On July 6, 2004, the Securities and Exchange Commission filed a settled enforcement action in the United States District Court for the District of Columbia charging ABB Ltd, a global provider of power and automation technologies headquartered in Zurich, Switzerland, with violating the anti-bribery, books-and-records, and internal-accounting-controls provisions of the Foreign Corrupt Practices Act (FCPA). Simultaneously with the filing of the complaint, and without admitting or denying its allegations, ABB consented to the entry of a final judgment enjoining it from future FCPA violations, and requiring it (i) to pay $5.9 million in disgorgement and prejudgment interest, (ii) to pay a $10.5 million penalty, which would be deemed satisfied by two of its affiliates\u0027 payments of criminal fines totaling the same amount in parallel criminal proceedings brought by the Department of Justice; and (iii) to retain an independent consultant to review the company\u0027s FCPA compliance policies and procedures.  In its complaint, the Commission charged that, from 1998 through early 2003, ABB\u0027s U.S. and foreign-based subsidiaries doing business in Nigeria, Angola and Kazakhstan, offered and made illicit payments totaling over $1.1 million to government officials in these countries. According to the complaint, all of the payments were made to influence acts and decisions by the foreign officials receiving the payments, in order to assist ABB\u0027s subsidiaries in obtaining and retaining business.\u0022 (Source: US Securities and Exchange Commission, Litigation Release No. 18775 \/ July 6, 2004, \u0022SEC SUES ABB LTD IN FOREIGN BRIBERY CASE \/ ABB SETTLES FEDERAL COURT ACTION AND AGREES TO DISGORGE $5.9 MILLION IN ILLICIT PROFITS \/ TWO ABB AFFILIATES ALSO PLEAD GUILTY AND AGREE TO PAY $10.5 MILLION IN FINES IN CRIMINAL CASE BROUGHT BY THE DEPARTMENT OF JUSTICE,\u0022 Securities and Exchange Commission v. ABB Ltd, Case No. 1:04-cv-1141 [RBW] (U.S.D.C., D.D.C.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  U.S. Securities and Exchange Commission, Litigation Release No. 18775 \/ July 6, 2004, \u0022SEC SUES ABB LTD IN FOREIGN BRIBERY CASE \/ ABB SETTLES FEDERAL COURT ACTION AND AGREES TO DISGORGE $5.9 MILLION IN ILLICIT PROFITS \/ TWO ABB AFFILIATES ALSO PLEAD GUILTY AND AGREE TO PAY $10.5 MILLION IN FINES IN CRIMINAL CASE BROUGHT BY THE DEPARTMENT OF JUSTICE,\u0022 Securities and Exchange Commission v. ABB Ltd, Case No. 1:04-cv-1141 [RBW] (U.S.D.C., D.D.C.), accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr18775.htm; Final Judgment accessed at http:\/\/fcpa.shearman.com\/files\/83d\/83df1e6aaa984cd891ff6c8fadd5b441.pdf?i=d05688136f3cad2123104221e06a2b26.","Documents":""},{"Case ID":"ST-10","Case Cluster ":"ABB Ltd. (Matter #76)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"07\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$5,250,000.00","Criminal Fine\/Penalty (US$) ":"$5,250,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022The criminal information charges that the two companies [Vetco Gray, Inc. and Vetco Gray UK Ltd.] paid bribes to officials of NAPIMS, a Nigerian government agency that evaluates and approves potential bidders for contract work on oil exploration projects in Nigeria, including bidders seeking subcontracts with foreign oil and gas companies. According to the stipulated statement of facts, the companies paid more than $1 million in exchange for obtaining confidential bid information and favorable recommendations from Nigerian government agencies in connection with seven oil and gas construction contracts in Nigeria from which the companies expected to realize profits of almost $12 million.\u0022  The companies entered guilty pleas and agreed to each pay $5.25 million in criminal fines. (Source:  US Department of Justice Press Release, \u0022ABB Vetco Gray, Inc. and ABB Vetco Gray UK Ltd. Plead Guilty to Foreign Bribery Charges,\u0022 July 6, 2004.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. ABB Vetco Gray, Inc. and ABB Vetco Gray UK Ltd., Case No. 04-cr-279 (S.D. Tex.), Information filed on June 22, 2004, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/06-22-04abbvetco-info.pdf;  Vetco Gray, Inc. Plea Agreement (July 6, 2004), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/07-06-04abbvetco-plea.pdf; Vetco Gray UK Ltd. Plea Agreement (July 6, 2004), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/07-06-04abbvetco-plea-uk.pdf; US Department of Justice Press Release, \u0022ABB VETCO GRAY, INC. AND ABB VETCO GRAY UK LTD. PLEAD GUILTY TO FOREIGN BRIBERY CHARGES,\u0022  July 6, 2004, accessed at http:\/\/www.justice.gov\/opa\/pr\/2004\/July\/04_crm_465.htm","Documents":""},{"Case ID":"ST-11","Case Cluster ":"ABB Ltd. (Matter #76)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"07\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$5,250,000.00","Criminal Fine\/Penalty (US$) ":"$5,250,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials","Offenses - Settled":"Bribery of foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022The criminal information charges that the two companies [Vetco Gray, Inc. and Vetco Gray UK Ltd.] paid bribes to officials of NAPIMS, a Nigerian government agency that evaluates and approves potential bidders for contract work on oil exploration projects in Nigeria, including bidders seeking subcontracts with foreign oil and gas companies. According to the stipulated statement of facts, the companies paid more than $1 million in exchange for obtaining confidential bid information and favorable recommendations from Nigerian government agencies in connection with seven oil and gas construction contracts in Nigeria from which the companies expected to realize profits of almost $12 million.\u0022  The companies entered guilty pleas and agreed to each pay $5.25 million in criminal fines. (Source:  US Department of Justice Press Release, \u0022ABB Vetco Gray, Inc. and ABB Vetco Gray UK Ltd. Plead Guilty to Foreign Bribery Charges,\u0022 July 6, 2004.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. ABB Vetco Gray, Inc. and ABB Vetco Gray UK Ltd., Case No. 04-cr-279 (S.D. Tex.), Information filed on June 22, 2004, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/06-22-04abbvetco-info.pdf;  Vetco Gray, Inc. Plea Agreement (July 6, 2004), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/07-06-04abbvetco-plea.pdf; Vetco Gray UK Ltd. Plea Agreement (July 6, 2004), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/abb\/07-06-04abbvetco-plea-uk.pdf; US Department of Justice Press Release, \u0022ABB VETCO GRAY, INC. AND ABB VETCO GRAY UK LTD. PLEAD GUILTY TO FOREIGN BRIBERY CHARGES,\u0022  July 6, 2004, accessed at http:\/\/www.justice.gov\/opa\/pr\/2004\/July\/04_crm_465.htm","Documents":""},{"Case ID":"ST-12","Case Cluster ":"ABB Ltd. (Matter #76)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"07\/05","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$40,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0.00","Civil Fine \/ Penalty (US$)":"$40,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, False accounting violations, Aiding and abetting ABB\u0027s internal controls violations, Aiding and abetting ABB\u0027s falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, regarding the ABB Ltd. case, \u0022In a related case, on July 5, 2006, the Commission filed a settled civil complaint charging four former employees of ABB Ltd. subsidiaries with violating the anti-bribery provisions of the FCPA. The Commission\u0027s complaint alleged that the four former employees -- John Samson, a former regional sales manager for West Africa, John G. A. Munro, a former senior vice president of operations, Ian N. Campbell, a former vice president of finance, and John H. Whelan, a former vice president of sales -- participated in a scheme to offer, approve, and\/or pay bribes to Nigerian government officials in furtherance of ABB\u0027s bid to obtain a $180 million contract to provide equipment for an oil drilling project in Nigeria\u0027s offshore Bonga Oil Field. [  ] On July 5, 2006, Without admitting or denying the allegations in the complaint, Samson, Munro, Campbell, and Whelan consented to the entry of final judgments that: (1) permanently enjoined each of them from future violations of the FCPA; (2) ordered each to pay a civil monetary penalty ($50,000 as to Samson, and $40,000 each as to Munro, Campbell and Whelan); and (3) ordered Samson to pay $64,675 in disgorgement and prejudgment interest.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-13","Case Cluster ":"ABB Ltd. (Matter #76)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"07\/05","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$40,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0.00","Civil Fine \/ Penalty (US$)":"$40,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, False accounting violations, Aiding and abetting ABB\u0027s internal controls violations, Aiding and abetting ABB\u0027s falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, regarding the ABB Ltd. case, \u0022In a related case, on July 5, 2006, the Commission filed a settled civil complaint charging four former employees of ABB Ltd. subsidiaries with violating the anti-bribery provisions of the FCPA. The Commission\u0027s complaint alleged that the four former employees -- John Samson, a former regional sales manager for West Africa, John G. A. Munro, a former senior vice president of operations, Ian N. Campbell, a former vice president of finance, and John H. Whelan, a former vice president of sales -- participated in a scheme to offer, approve, and\/or pay bribes to Nigerian government officials in furtherance of ABB\u0027s bid to obtain a $180 million contract to provide equipment for an oil drilling project in Nigeria\u0027s offshore Bonga Oil Field. [  ] On July 5, 2006, Without admitting or denying the allegations in the complaint, Samson, Munro, Campbell, and Whelan consented to the entry of final judgments that: (1) permanently enjoined each of them from future violations of the FCPA; (2) ordered each to pay a civil monetary penalty ($50,000 as to Samson, and $40,000 each as to Munro, Campbell and Whelan); and (3) ordered Samson to pay $64,675 in disgorgement and prejudgment interest.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-14","Case Cluster ":"ABB Ltd. (Matter #76)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"07\/05","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$40,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0.00","Civil Fine \/ Penalty (US$)":"$40,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, False accounting violations, Aiding and abetting ABB\u0027s internal controls violations, Aiding and abetting ABB\u0027s falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, regarding the ABB Ltd. case, \u0022In a related case, on July 5, 2006, the Commission filed a settled civil complaint charging four former employees of ABB Ltd. subsidiaries with violating the anti-bribery provisions of the FCPA. The Commission\u0027s complaint alleged that the four former employees -- John Samson, a former regional sales manager for West Africa, John G. A. Munro, a former senior vice president of operations, Ian N. Campbell, a former vice president of finance, and John H. Whelan, a former vice president of sales -- participated in a scheme to offer, approve, and\/or pay bribes to Nigerian government officials in furtherance of ABB?s bid to obtain a $180 million contract to provide equipment for an oil drilling project in Nigeria\u0027s offshore Bonga Oil Field. [  ] On July 5, 2006, Without admitting or denying the allegations in the complaint, Samson, Munro, Campbell, and Whelan consented to the entry of final judgments that: (1) permanently enjoined each of them from future violations of the FCPA; (2) ordered each to pay a civil monetary penalty ($50,000 as to Samson, and $40,000 each as to Munro, Campbell and Whelan); and (3) ordered Samson to pay $64,675 in disgorgement and prejudgment interest.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-15","Case Cluster ":"ABB Ltd. (Matter #76)","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Nigeria","Year of Settlement":"2006","Month\/Day of Settlement (or Notes)":"07\/05","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$114,675.72","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$50,000","Civil Prejudgment Interest (US$) ":"$14,675.72","Civil Fine \/ Penalty (US$)":"$50,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, False accounting violations, Aiding and abetting ABB\u0027s internal controls violations, Aiding and abetting ABB\u0027s falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, regarding the ABB Ltd. case, \u0022In a related case, on July 5, 2006, the Commission filed a settled civil complaint charging four former employees of ABB Ltd. subsidiaries with violating the anti-bribery provisions of the FCPA. The Commission\u0027s complaint alleged that the four former employees -- John Samson, a former regional sales manager for West Africa, John G. A. Munro, a former senior vice president of operations, Ian N. Campbell, a former vice president of finance, and John H. Whelan, a former vice president of sales -- participated in a scheme to offer, approve, and\/or pay bribes to Nigerian government officials in furtherance of ABB?s bid to obtain a $180 million contract to provide equipment for an oil drilling project in Nigeria\u0027s offshore Bonga Oil Field. [  ] On July 5, 2006, without admitting or denying the allegations in the complaint, Samson, Munro, Campbell, and Whelan consented to the entry of final judgments that: (1) permanently enjoined each of them from future violations of the FCPA; (2) ordered each to pay a civil monetary penalty ($50,000 as to Samson, and $40,000 each as to Munro, Campbell and Whelan); and (3) ordered Samson to pay $64,675 in disgorgement and prejudgment interest.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, ABB Ltd. Case Summary (#76) at 114-116, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  ","Documents":""},{"Case ID":"ST-16","Case Cluster ":"AGA Medical Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"06\/03","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$2,000,000.00","Criminal Fine\/Penalty (US$) ":"$2,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials, bribery of foreign officials ","Offenses - Settled":"Conspiracy to bribe foreign officials; bribery of foreign officials ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release (June 3, 2008), there is no mention of an enforcement action by the Securities and Exchange Commission. (Source: US Department of Justice Press Release, \u0022AGA Medical Corporation Agrees to Pay $2 Million Penalty and Enter Deferred Prosecution Agreement for FCPA Violations,\u0022 June 3, 2008.).   The June 30, 2008 Deferrred Prosecution Agreement  outlines terms of the agreement, including: continued cooperation in investigations by DOJ and other domestic and foreign law enforcement authorities (para 5); Requirement on company not to withhold from DOJ any information, document, records, facilities and\/or employees on the basis of attorney-client privilege or work product claim (para 5.c); Company consent to DOJ disclosures to other (domestic and foreign) governmental authorities; and Agreement does not cover past or future misconduct.  (Source: US v. AGA Medical Corporation, Case no. 08-cr-00172 (D.C. Minn, 2008), Deferred Prosecution Agreement filed June 3, 2008.). According to DOJ Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Location and Time Period of Misconduct is China, 1997-2005, specifically corrupt payments by AGA, a high-ranking officer of AGA and other AGA employees to doctors in China who were employed at government-owned hospitals. Payments were made through AGA\u0027s local Chinese distributor. In exchange for the payments, the doctors directed government-owned hospitals to purchase AGA products rather than thoseof the company\u0027s competitors.  The Criminal Information also alleged that from 2000 through 2002, SGA sought patents on several products from the PRC State Intellectual Property Office, and as part of this effort made payments through their local Chinese disrtibutor to government officials employed at the State Intellectual Property Office.  AGA Medical admitted and accepted the allegations as part of its Deferred Prosecution Agreement with the Department of Justice. (Source: US v. AGA Medical Corporation, Case No. 08-cr-00172 (D.D.C.), Deferred Prosecution Agreement filed on June 3, 2008.)","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 AGA Medical Corporation, at 59-60, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response-appx-c\/pdf;      www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf: US Department of Justice Press Release, \u0022AGA Medical Corporation Agrees to Pay $2 Million Penalty and Enter Deferred Prosecution Agreement for FCPA Violations,\u0022 June 3, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/June\/08-crm-491.html (accessed on September 14, 2011).  US v. AGA Medical Corporation, Case no. 08-cr-00172 (D.C. Minn, 2008), Information and Deferred Prosecution Agreement (including Attachment A: Statement of Facts and other attachments), filed June 3, 2008. ","Documents":""},{"Case ID":"ST-17","Case Cluster ":"AGCO Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"09\/30","Other Jurisdictions of Settlement":"Denmark","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$18,307,393.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$13,907,393","Civil Prejudgment Interest (US$) ":"$2,000,000","Civil Fine \/ Penalty (US$)":"$2,400,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission\u0027s Litigation Release, the SEC\u0027s \u0022complaint alleges that from 2000 through 2003, certain AGCO subsidiaries made approximately $5.9 million in kickback payments in connection with their sales of equipment to Iraq under the United Nations Oil for Food Program (the \u0022Program\u0022). The kickbacks were characterized as \u0022after sales service fees\u0022 (\u0022ASSFs\u0022), but no bona fide services were performed. The Program was intended to provide humanitarian relief for the Iraqi population, which faced severe hardship under international trade sanctions. The Program required the Iraqi government to purchase humanitarian goods through a U.N. escrow account; however, AGCO\u0027s subsidiaries\u0027 kickbacks diverted funds out of the escrow account and into Iraqi-controlled accounts at banks in Jordan.\u0022 (Source: US Securities and Exchange Commission, Litigation Release No. 21229 \/ September 30, 2009, SEC v. AGCO Corporation, Civil Action No. 1:09-CV-01865-RMU (D.D.C.), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against AGCO Corporation For Improper Payments to Iraq Under the U.N. Oil for Food Program - AGCO Agrees to Pay Over $18.3 Million in Disgorgement, Interest, and Penalties.\u0022)   Please note that as part of its settlement with the SEC, AGCO Corporation did not admit or deny the agency\u0027s allegations against it.","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, AGCO Corporation Case Summary at 58-59, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21229 \/ September 30, 2009, SEC v. AGCO Corporation, Civil Action No. 1:09-CV-01865-RMU (D.D.C.), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against AGCO Corporation For Improper Payments to Iraq Under the U.N. Oil for Food Program -  AGCO Agrees to Pay Over $18.3 Million in Disgorgement, Interest, and Penalties,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21229.htm; SEC v. AGCO Corporation, Civil Action No. 1:09-CV-01865-RMU (D.D.C.),  Complaint filed September 30, 2009, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp21229.pdf.","Documents":""},{"Case ID":"ST-18","Case Cluster ":"AGCO Corporation","Jurisdiction of Settlement":"Denmark","Jurisdiction of Settlement \/ Enforcement Agency":"State Prosecutor for Serious Economic Crime","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"09\/30","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Criminal Confiscation","Total Monetary Sanctions (US$)":"$630,000.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$630,000","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Unspecified","Offenses - Settled":"Unspecified","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, on September 30, 2009, AGCO settled an ongoing investigation by the Danish State Prosecutor\u0027s Office for Serious Economic Crime: \u0022The charges were based on two Oil-for-Food contracts executed by AGCO\u0027s Danish subsidiary, AGCO Denmark A\/S.  AGCO agreed to pay approximately $630,000 in disgorgement of profits in connection with those charges.\u0022  (Source: US Department of Justice Press Release, \u0022AGCO Corp. to Pay $1.6 Million in Connection with Payments to the Former Iraqi Government Under the U.N. Oil-For-Food Program,\u0022 September 30, 2009.)  ","Sources ":"US Department of Justice Press Release, \u0022AGCO Corp. to Pay $1.6 Million in Connection with Payments to the Former Iraqi Government Under the U.N. Oil-For-Food Program,\u0022 September 30, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/September\/09-crm-1056.html ","Documents":""},{"Case ID":"ST-19","Case Cluster ":"AGCO Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"09\/30","Other Jurisdictions of Settlement":"Denmark","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$1,600,000.00","Criminal Fine\/Penalty (US$) ":"$1,600,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to falsify books and records, Conspiracy to commit wire fraud","Offenses - Settled":"Conspiracy to bribe foreign officials; bribery of foreign officials ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a US Department of Justice Press Release, on September 30, 2009, AGCO Limited, the wholly owned UK subsidiary of AGCO Corp (US Corporation based in Georgia) was charged with one count of conspiracy to commit wire fraud and to violate the books and records provisions of the Foreign Corrupt Practices Act.  As part of its Deferred Prosecution Agreement with the Department of Justice, AGCO Corp admitted that between 2000 and 2003, AGCO Ltd. with the assistance of a Jordanian agent, paid approximately $553,000to the former government of Iraq to secure three contracts under the purview of the UN Oil-for-Food Programme.  The contract price was inflated from 13 to 21 percent and the additional funds were then used to pay kickback to the former Iraqi Ministry of Agriculture.  (Source: US Department of Justice Press Release, \u0022AGCO Corp. to Pay $1.6 Million in Connection with Payments to the Former Iraqi Government Under the U.N. Oil-For-Food Program,\u0022 September 30, 2009.).  The Department of Justice acknowledged the assistance of the Danish State Prosecutor\u0027s Office for Serious Economic Crime. (Source: Ibid.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, AGCO Corporation Case Summary at 58-59, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   US Department of Justice Press Release, \u0022AGCO Corp. to Pay $1.6 Million in Connection with Payments to the Former Iraqi Government Under the U.N. Oil-For-Food Program,\u0022 September 30, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/September\/09-crm-1056.html; US v. AGCO Limited, Case No. 1:09-cr-00249-RJL (D.D.C.), Information filed September 30, 2009, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/agco-corp\/09-30-09agco-info.pdf","Documents":""},{"Case ID":"ST-20","Case Cluster ":"Akzo Nobel, N.V.","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Rijksrecherche (Dutch Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/15","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unspecified","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unspecified   ","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Unknown","Offenses - Settled":"Unknown","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Nonprosecution Agreement, \u0022It is understood that AKZO NOBEL will pay no monetary penalty in connection with this Agreement, based on AKZO NOBEL\u0027s representation that its former subsidiary, N.V. Organon, has agreed to enter into a criminal disposition with the Dutch National Public Prosecutor\u0027s Office for Financial, Economic and Environmental Offences (the \u0022Dutch Public Prosecutor\u0022). AKZO NOBEL represents that, pursuant to this contemplated disposition with the Dutch Public Prosecutor, N.V. Organon will admit criminal liability and pay a criminal fine of no less than \u20ac 381,602.  It is understood that if there is no such criminal disposition with the Dutch Public Prosecutor within 180 days of the signing of this Agreement, then AKZO NOBEL shall pay a monetary penalty of $800,000 to the United States Treasury. It is further understood that if the criminal fine paid as part of the criminal disposition with the Dutch Public Prosecutor is less than \u20ac 381,602, then AKZO NOBEL shall pay to the United States Treasury the difference between the amount of the fine paid as part of the criminal disposition with the Dutch Public Prosecutor and $800,000, at the currency exchange rate prevailing as ofthe date of the execution of the agreement between AKZO NOBEL and the Dutch Public Prosecutor.\u0022 (Source: US Department of Justice Nonprosecution Agreement, In re: Akzo Nobel N.V., December 20, 2007.)","Sources ":"US Department of Justice, In Re: Akzo Nobel N.V., Non-Prosecution Agreement of December 20, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/akzo-noble\/12-20-07akzo-noble-agree.pdf","Documents":""},{"Case ID":"ST-21","Case Cluster ":"Akzo Nobel, N.V.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"12\/20","Other Jurisdictions of Settlement":"Netherlands","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Penalty (contingent upon settlement with Dutch Public Prosecutor)","Total Monetary Sanctions (US$)":"","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"Unknown [Criminal Penalty (contingent upon settlement with Dutch Public Prosecutor]","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records ","Offenses - Settled":"Bribery of foreign officials, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release of December 20, 2007, \u0022Akzo Nobel, a Dutch company with its headquarters in Arnhem, Netherlands, has acknowledged responsibility for the actions of two of its subsidiaries whose employees and agents made improper payments to the Iraqi government in order to obtain contracts with Iraqi ministries. According to the agreement, between 2000 and 2002, the two subsidiaries, N.V. Organon and Intervet International B.V., sold by Akzo Nobel earlier this year, paid a total of approximately $280,000 to the Iraqi government by inflating the price of contracts, usually by adding 10% before submitting the contracts to the United Nations for approval, and concealing from the United Nations the fact that the prices contained a kickback to the Iraqi government.\u0022 (Source: US Department of Justice Press Release, \u0022Akzo Nobel Acknowledges Improper Payments Made by its Subsidiaries to Iraqi Government Under the U.N. Oil for Food Program, Enters Agreement with Department of Justice,\u0022 December 20, 2007.)  According to the US Department of Justice Nonprosecution Agreement, \u0022It is understood that AKZO NOBEL will pay no monetary penalty in connection with this Agreement, based on AKZO NOBEL\u0027s representation that its former subsidiary, N.V. Organon, has agreed to enter into a criminal disposition with the Dutch National Public Prosecutor\u0027s Office for Financial, Economic and Environmental Offences (the \u0022Dutch Public Prosecutor\u0022). AKZO NOBEL represents that, pursuant to this contemplated disposition with the Dutch Public Prosecutor, N.V. Organon will admit criminal liability and pay a criminal fine of no less than \u20ac381,602.  It is understood that if there is no such criminal disposition with the Dutch Public Prosecutor within 180 days ofthe signing ofthis Agreement, then AKZO NOBEL shall pay a monetary penalty of $800,000 to the United States Treasury. It is further understood that if the criminal fine paid as part ofthe criminal disposition with the Dutch Public Prosecutor is less than \u20ac381,602, then AKZO NOBEL shall pay to the United States Treasury the difference between the amount of the fine paid as part of the criminal disposition with the Dutch Public Prosecutor and $800,000, at the currency exchange rate prevailing as ofthe date of the execution of the agreement between AKZO NOBEL and the Dutch Public Prosecutor.\u0022  (Source: US Department of Justice Nonprosecution Agreement, In re: Akzo Nobel N.V., December 20, 2007.)","Sources ":"US Department of Justice Nonprosecution Agreement, In re: Akzo Nobel N.V., December 20, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/akzo-noble\/12-20-07akzo-noble-agree.pdf;  US Department of Justice Press Release, \u0022Akzo Nobel Acknowledges Improper Payments Made by its Subsidiaries to Iraqi Government Under the U.N. Oil for Food Program, Enters Agreement with Department of Justice,\u0022 December 20, 2007, accessed at http:\/\/www.justice.gov\/opa\/pr\/2007\/December\/07_crm_1024.html; US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Akzo Nobel, N.V. at 69-70, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.","Documents":""},{"Case ID":"ST-22","Case Cluster ":"Akzo Nobel, N.V.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"12\/20","Other Jurisdictions of Settlement":"Netherlands","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty ","Total Monetary Sanctions (US$)":"$2,981,513.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,647,363","Civil Prejudgment Interest (US$) ":"$584,150","Civil Fine \/ Penalty (US$)":"$750,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal Controls Violations, Falsification of Books and Records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Securities and Exchange Commission Litigation Release, the agency \u0022filed Foreign Corrupt Practices Act books and records and internal controls charges against Akzo Nobel N.V., a Netherlands-based pharmaceutical company, in the U.S. District Court for the District of Columbia. The Commission\u0027s complaint alleges that from 2000 to 2003, two of Akzo Nobel\u0027s subsidiaries [also incorporated in the Netherlands] authorized and made $279,491 in kickback payments in connection with their sales of humanitarian goods to Iraq under the U.N. Oil for Food Program (the \u0022Program\u0022). The kickbacks were characterized as \u0022after-sales service fees\u0022 (\u0022ASSFs\u0022), but no bona fide services were performed. The Program was intended to provide humanitarian relief for the Iraqi population, which faced severe hardship under international trade sanctions. It allowed the Iraqi government to purchase humanitarian goods through a U.N. escrow account. The kickbacks paid in connection with Akzo Nobel\u0027s subsidiaries\u0027 sales to Iraq bypassed the escrow account and were paid by third parties to Iraqi-controlled accounts in Lebanon and Jordan.\u0022 (Source: US Securities and Exchange Commission, Litigation Release No. 20410 \/ December 20, 2007, Securities and Exchange Commission v. Akzo Nobel, N.V., Civil Action No. 07-CV-02293 (D.D.C.) (HHK), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Akzo Nobel N.V. For Improper Payments to Iraq Under the U.N. Oil for Food Program --Company Agrees to Pay Over $2.9 Million.\u0022)  According to the SEC\u0027s complaint, the Akzo Nobel\u0027s subsidiary N.V. Organon  allegedly paid the additional \u0022commission\u0022 payments to an entity called \u0022Sabbah Drugstore\u0022 and that the payments from both schemes were allegedly paid to officials of (1) unnamed Iraqi ministry and (2) Iraqi Ministry of Health. (Source: Securities and Exchange Commission v. Akzo Nobel, N.V., Civil Action No. 07-CV-02293-HHK (D.D.C.), Complaint filed December 20, 2007.)","Sources ":"US Securities and Exchange Commission, Litigation Release No. 20410 \/ December 20, 2007, Securities and Exchange Commission v. Akzo Nobel, N.V., Civil Action No. 07-CV-02293 (D.D.C.) (HHK), \u0022SEC Files Settled Books and Records and Internal Controls Charges Against Akzo Nobel N.V. For Improper Payments to Iraq Under the U.N. Oil for Food Program ? Company Agrees to Pay Over $2.9 Million,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2007\/lr20410.htm; Securities and Exchange Commission v. Akzo Nobel, N.V., Civil Action No. 07-CV-02293-HHK (D.D.C.), Complaint filed December 20, 2007, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2007\/comp20410.pdf","Documents":""},{"Case ID":"ST-23","Case Cluster ":"Alcatel-Lucent S.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Costa Rica","Year of Settlement":"2007","Month\/Day of Settlement (or Notes)":"06\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$261,500.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$261,500","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 7","Offenses - Alleged":"Bribery of Foreign Officials","Offenses - Settled":"Bribery of Foreign Officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a September 23, 2008 US Department of Justice Press Release on sentencing of Christian Sapsizian, a French citizen and deputy vice president of Latin America for Alcatel CIT, Sapsizian admitted that between 2000 and September 2004, he conspired with Edgar Valverde Acosta, Alcatel\u0027s senior officer in Costa Rica, and others to make more than $2.5 million in bribe payments to Costa Rican officials to obtain a telecommunications contract on behalf of Alcatel. In addition to a sentence of 30 months\u0027 imprisonment, Sapsizian was ordered by the U.S. District Court for the Southern District of Florida in Miami to forfeit $261,500.  The Department of Justice Press Release noted that \u0022Substantial assistance was provided by the Southeast Regional Branch of the U.S. Securities and Exchange Commission, the Office of the Attorney General in Costa Rica, the Fiscalia de Delitos Economicos, Corrupcion y Tributarios in Costa Rica and French law enforcement authorities.\u0022  (Sources: US Department of Justice Press Release, \u0022Former Alcatel CIT Executive Sentenced for Paying $2.5 million in Bribes to Senior Costa Rican Officials,\u0022 September 23, 2008 and US v. Christian Sapsizian, Case No. 1:06-cr-20797-PAS (S.D.Fla.), Judgment in a Criminal Case filed September 25, 2008.)   According to the June 2011 United States Report to the OECD, Valverde Acosta \u0022is currently a fugitive.\u0022  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Alcatel CIT (Matter #73) Case Summary at 111-112, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.)  A May 31, 2011 Sworn Declaration by Edgar Valverde Acosta filed by the Institute Costarricense de Electricidad (ICE) noted that he was serving jail time in Costa Rica following his recent conviction in Costa Rica\u0027s criminal court, in connection with the Alcatel-Lucent case.  (Source: US v. Alcatel-Lucent France S.A. et al, Case No. 1:10-cr-20906 and U.S. v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907 (S.D.Fla.), Sworn Declaration of Edgar Valverde Acosta, May 31, 2011).  ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Alcatel CIT (Matter #73) Case Summary at 111-112, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Christian Sapsizian, Case No. 1:06-cr-20797-PAS (S.D.Fla.), Criminal Information filed December 5, 2006, accessed at  http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/sapsizianc\/12-05-06sapsizian-complaint.pdf; Superseding Indictment filed March 20, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/sapsizianc\/03-22-07sapsizian-indict.pdf; Plea Agrement of June 6, 2007, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/sapsizianc\/06-06-07sapsizian-plea.pdf; Factual Basis for the Plea, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/sapsizianc\/06-06-07sapsizian-fact.pdf; Judgment in a Criminal Case filed September 25, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/sapsizianc\/09-25-08sapsizian-judgment.pdf.  US Department of Justice Press Release, \u0022Former Alcatel CIT Executive Sentenced for Paying $2.5 million in Bribes to Senior Costa Rican Officials,\u0022 September 23, 2008, accessed at www.justice.gov\/opa\/pr\/2008\/September\/08-crm-848.html.  US v. Alcatel-Lucent France S.A. et al, Case No. 1:10-cr-20906 and U.S. v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907 (S.D.Fla.), Sworn Declaration of Edgar Valverde Acosta, May 31, 2011 (accessed via Pacer).","Documents":""},{"Case ID":"ST-25","Case Cluster ":"Alcatel-Lucent S.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Costa Rica","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/27","Other Jurisdictions of Settlement":"Costa Rica","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"Falsification of Books and Records, Internal Control Violations ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, Alcatel-Lucent and its subsidiaries engaged in the following: \u0022Specifically, Alcatel CIT won three contracts in Costa Rica worth a combined total of more than $300 million as a result of corrupt payments to government officials and from which Alcatel reaped a profit of more than $23 million, according to court documents. Alcatel CIT wired more than $18 million to two consultants in Costa Rica, which had been retained by Alcatel Standard, in connection with obtaining business in that country. According to court documents, more than half of this money was then passed on by the consultants to various Costa Rican government officials for assisting Alcatel CIT and Alcatel de Costa Rica in obtaining and retaining business. As part of the scheme, the consultants created phony invoices that they then submitted to Alcatel CIT. According to court documents, senior Alcatel executives approved the retention of and payments to the consultants despite obvious indications that the consultants were performing little or no legitimate work.  In addition, according to court documents, Alcatel Standard hired a consultant in Honduras who was a perfume distributor with no experience in telecommunications. The consultant was retained after being personally selected by the brother of a senior Honduran government official. Alcatel CIT executives knew that a significant portion of the money paid to the consultant would be paid to the family of the senior Honduran government official in exchange for favorable treatment of Alcatel CIT. As a result of these payments, Alcatel CIT was able to retain contracts worth approximately $47 million and from which Alcatel earned $870,000.  In addition, according to court documents, Alcatel Standard retained two consultants on behalf of another Alcatel subsidiary in Taiwan to assist in obtaining an axle counting contract worth approximately $19.2 million. Alcatel and its joint venture paid these two consultants more than $950,000 despite the fact that neither consultant had telecommunications experience. In fact, according to court documents, Alcatel Standard\u0027s purpose for hiring the consultants was so that Alcatel SEL could funnel payments through the consultants to Taiwanese legislators who had influence in the award of the contract. Alcatel earned approximately $4.34 million from this contract.\u0022 (Source: US Department of Justice Press Release, \u0022Alcatel-Lucent S.A. and Three Subsidiaries Agree to Pay $92 Million to Resolve Foreign Corrupt Practices Act Investigation,\u0022 December 27, 2010.)  According to the Deferred Prosecution Agreement, Alcatel-Lucent S.A. and the Department \u0022agree that any criminal penalties that might be im,posed by the Court on Alcatel-Lucent\u0027s wholly owned subsidiaries in connection with their guilty pleas and plea agreements entered into simultaneously herewith will be deducted from the $92,000,000 penalty agreed to under this Agreement.\u0022 (Source: US v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907-PAS (S.D. Fla.), Deferred Prosecution Agreement filed February 22, 2011.)   According to their respective Judgments, Alcatel-Lucent France S.A., Alcatel-Lucent Trade International and Alcatel Centroamerica were each ordered to a $500,000 fine; however, these sums are not recorded in this entry, so as to avoid double-counting along wtih the $92 million total ordered in this case.  (Sources: US v. Alcatel-Lucent France S.A., Case No. 1:10-cr-20906-MGC (S.D. Fla.), Judgment filed June 2, 2011; US v. Alcatel-Lucent Trade International, Case No. 1:10-cr-20906-MGC (S.D. Fla.), Judgment filed June 2, 2011; US v. Alcatel Centroamerica, Case No. 1:10-cr-20906-MGC (S.D. Fla.), Judgment filed June 2, 2011.) ","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Alcatel-Lucent S.A. (Matter #11) Case Summary at 27-29, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Alcatel-Lucent France, S.A. f\/k\/a \u0022Alcatel CIT, S.A.,\u0022 Alcatel-Lucent Trade International, A.G. f\/k\/a \u0022Alcatel Standard, A.G.,\u0022 and Alcatel Centroamerica, S.A. f\/k\/a \u0022Alcatel de Costa Rica, S.A.,\u0022 Case No. 1:10-cr-20906-PAS (S.D.Fla.), Information filed on December 27, 2010, Plea Agreements (filed February 22, 2011) and Judgments (filed June 2, 2011) for each subsidiary, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/alcatel-lucent-sa-etal.html. US Department of Justice Press Release, \u0022Alcatel-Lucent S.A. and Three Subsidiaries Agree to Pay $92 Million to Resolve Foreign Corrupt Practices Act Investigation,\u0022 December 27, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/December\/10-crm-1481.html.","Documents":""},{"Case ID":"ST-26","Case Cluster ":"Alcatel-Lucent S.A.","Jurisdiction of Settlement":"Costa Rica","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General; Fiscalia [Prosecutor] de Delitos Economicos, Corrupcion y Tributarios; Office of the Public Ethics Prosecutor","Jurisdiction of Foreign Public Official(s) ":"Costa Rica  ","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"01\/20","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Settlement Agreement ","Monetary Sanctions  (Types)":"Civil Restitution","Total Monetary Sanctions (US$)":"$10,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"$10,000,000","Other Civil Monetary Sanctions (Explanation)":"Restitution","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$10,000,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Enforcement by \u0022Affected\u0022 Jurisdiction","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Corrupt Payments; Causing Social Damage to Costa Rica","Offenses - Settled":"Causing Social Damage to Costa Rica","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, in addition to the settlements in the US, Alcatel-Lucent also \u0022agreed to pay $10 million to settle a corruption case brought by the Government of Costa Rica arising out of the bribery of Costa Rican officials by the company. The settlement marked the first time in Costa Rica\u0027s history that a foreign corporation agreed to pay the govenrment damages for corruption.\u0022 (Source: US Department of Justice Press Release, \u0022Alcatel-Lucent S.A. and Three Subsidiaries Agree to Pay $92 Million to Resolve Foreign Corrupt Practices Act Investigation,\u0022 December 27, 2010.)  Alcatel-Lucent had also issued a statement that the payment was made to the Costa Rican government for \u0022social damages,\u0022 to settle a civil suit filed on November 25, 2004 (amended subsequently) by the Attorney General of Costa Rica.  (Source: Alcatel-Lucent company statement, \u0022Controversies: Costa Rica,\u0022 September 10, 2010, at http:\/\/www.alcatel-lucent.com\/csr\/htm\/en\/home.html.).  The Settlement is detailed in Office of the Attorney General of the Republic, Request for Recognition of Settlement Agreement, filed in Case No. 04-6835-647-PE, Criminal Court of the II Judicial Circuit of San Jose (signed January 20, 2010), which was attached as Exhibit 1 of Government\u0027s Response to ICE\u0027s Petition for Victim Status and Restitution, in US v. Alcatel-Lucent France, S.A., et al, Case No. 1:10-cr-20906-MGC and US v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907-MGC (S.D. Fla. May 23, 2011).  According to the Request for Recognition of Settlement Agreement, \u0022civil claim as well as the criminal prosecution against the other civil and criminal defendants in the case - including the former employees of Alcatel - just as indicated in the agreement, remain intact.\u0022  The Settlement Agreement was undertaken pursuant to Article 219 of the Code of Civil Procedure, Articles 7 and 36 of the Code of Criminal Procedure, and Articles 1367 et seq. of the Civil Code.  See also report by the Attorney General of Costa Rica: Procuradora General de la Republica, Informe de Gestion 2004-2010, at 32-33, accessed at http:\/\/www.pgr.go.cr\/Informacion_General\/Informe%20de%20Gestion%202004-2010.pdf [which states 13 million dollars obtained in both Fischel and Alcatel cases]","Sources ":"US Department of Justice Press Release, \u0022Alcatel-Lucent S.A. and Three Subsidiaries Agree to Pay $92 Million to Resolve Foreign Corrupt Practices Act Investigation,\u0022 December 27, 2010, accessed at http:\/\/www.justice.gov\/opa\/pr\/2010\/December\/10-crm-1481.html; US v. Alcatel-Lucent France, S.A., et al, Case No. 1:10-cr-20906-MGC and US v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907-MGC (S.D. Fla.), Office of the Attorney General of the Republic, Request for Recognition of Settlement Agreement, filed in Case No. 04-6835-647-PE, Criminal Court of the II Judicial Circuit of San Jose (signed January 20, 2010), which was attached as Exhibit 1 of Government\u0027s Response to ICE\u0027s Petition for Victim Status and Restitution filed May 23, 2011; Alcatel-Lucent Company Statement, \u0022Controversies: Costa Rica,\u0022 September 10, 2010, at http:\/\/www.alcatel-lucent.com\/csr\/htm\/en\/home.html; report by the Attorney General of Costa Rica: Procuradora General de la Republica, Informe de Gestion 2004-2010, at 32-33, accessed at http:\/\/www.pgr.go.cr\/Informacion_General\/Informe%20de%20Gestion%202004-2010.pdf.","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/ICE_US_Opposition_Exhibit_1_Costa_Rica_Settlement_SDFLA_May_23_2011.pdf"},{"Case ID":"ST-27","Case Cluster ":"Alcatel-Lucent S.A.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Costa Rica, Honduras, Malaysia, Taiwan","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/27","Other Jurisdictions of Settlement":"Costa Rica","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Deferred Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$92,000,000.00","Criminal Fine\/Penalty (US$) ":"$92,000,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8","Offenses - Alleged":"Falsification of Books and Records, Internal Controls Violations","Offenses - Settled":"Falsification of Books and Records, Internal Control Violations ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, Alcatel-Lucent and its subsidiaries engaged in the following: \u0022Specifically, Alcatel CIT won three contracts in Costa Rica worth a combined total of more than $300 million as a result of corrupt payments to government officials and from which Alcatel reaped a profit of more than $23 million, according to court documents. Alcatel CIT wired more than $18 million to two consultants in Costa Rica, which had been retained by Alcatel Standard, in connection with obtaining business in that country. According to court documents, more than half of this money was then passed on by the consultants to various Costa Rican government officials for assisting Alcatel CIT and Alcatel de Costa Rica in obtaining and retaining business. As part of the scheme, the consultants created phony invoices that they then submitted to Alcatel CIT. According to court documents, senior Alcatel executives approved the retention of and payments to the consultants despite obvious indications that the consultants were performing little or no legitimate work.  In addition, according to court documents, Alcatel Standard hired a consultant in Honduras who was a perfume distributor with no experience in telecommunications. The consultant was retained after being personally selected by the brother of a senior Honduran government official. Alcatel CIT executives knew that a significant portion of the money paid to the consultant would be paid to the family of the senior Honduran government official in exchange for favorable treatment of Alcatel CIT. As a result of these payments, Alcatel CIT was able to retain contracts worth approximately $47 million and from which Alcatel earned $870,000.  In addition, according to court documents, Alcatel Standard retained two consultants on behalf of another Alcatel subsidiary in Taiwan to assist in obtaining an axle counting contract worth approximately $19.2 million. Alcatel and its joint venture paid these two consultants more than $950,000 despite the fact that neither consultant had telecommunications experience. In fact, according to court documents, Alcatel Standard\u0027s purpose for hiring the consultants was so that Alcatel SEL could funnel payments through the consultants to Taiwanese legislators who had influence in the award of the contract. Alcatel earned approximately $4.34 million from this contract.\u0022 (Source: US Department of Justice Press Release, \u0022Alcatel-Lucent S.A. and Three Subsidiaries Agree to Pay $92 Million to Resolve Foreign Corrupt Practices Act Investigation,\u0022 December 27, 2010.)  According to the Deferred Prosecution Agreement, Alcatel-Lucent S.A. and the Department \u0022agree that any criminal penalties that might be im,posed by the Court on Alcatel-Lucent\u0027s wholly owned subsidiaries in connection with their guilty pleas and plea agreements entered into simultaneously herewith will be deducted from the $92,000,000 penalty agreed to under this Agreement.\u0022 (Source: US v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907-PAS (S.D. Fla.), Deferred Prosecution Agreement filed February 22, 2011.)  ICE Petition: In May and June 2011, the Instituto Costarricense de Electriciad (ICE) petitioned the District Court for the Southern District of Florida considering the Alcatel-Lucent SA criminal cases for relief\/restitution and to obejct to the Alcatel-Lucent\u0027s plea agreement and deferred prosecution agreement with the US Government. ICE petitioned the court to be recognized as a victim and entitled to restitution, pursuant to the Crime Victims\u0027 Rights Act (18 USC Section 1651), US Federal Rules on Criminal Procedure and the Mandatory Victim Restitution Act (18 USC Section 3663A).  ICE argued that it had suffered direct and proximate damage from Alcatel-Lucent\u0027s conduct and refuted the argument by the US and Alcatel-Lucent (later supported by the court) that it had been a co-conspirator or co-participant in the bribery scheme.  (Sources: US v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907 (S.D. Fla.), Petition for Relief Pursuant to 18 U.S.C. Section 3771(d)(3) and Objection to Plea Agreements and Deferred Prosecution Agreement filed May 3, 2011 and Petition for Writ of Mandamus Pursuant to the Crime Victims\u0027 Rights Act, 18 USC Section 3771(d)(3) filed June 15, 2011.) The US Government\u0027s Response to ICE\u0027s Petition for Victim Status and Restitution, filed May 23, 2011, argued that \u0022Under the facts and circumstances in the instant matter, which reflect profound and pervasive corruption at the highest levels of ICE, the government does not believe it is appropriate to consider ICE a victim in these cases. [ ] Moreover, regardless of whether ICE is considered a victim, the government does not believe that restitution should be ordered in this matter, because, under the facts and circumstances present in this case, any restitution calculation woul dbe netirely speculative and would unduly prolong and complicate the sentencing process - something that the law does not support.\u0022  The US Government cited the involvement of the ICE board members and high level officers in the Alcatel scheme and as legal basis, US v. Lazarenko, 624 F.3d 1247, 1250-52 (9th Cir. 2010) (an individual who is both a victim and a participant in a money-laundering scheme who profited from the conspiracy cannot qualify as a \u0022victim\u0022 under restitution statutes), and in footnote 8, refuted ICE\u0027s contention that the DOJ had stated that foreign governments or instrumentalities could never be victims, much less that that was Department [of Justice] policy. ICE appealed the district court\u0027s ruling to the 11th Circuit Appeals Court, but its petition was also denied. The appeals court held that the \u0022district court did not clearly err in finding that \u0027Instituto Costarricense de Electricidad\u0027 (\u0022ICE\u0022), here seeking to be deemed a \u0022crime victim,\u0022 actually functions as the offenders\u0027 coconspirator.  The district court identified the pervasive, constant, and consistent illegal conduct by the \u0022principals\u0022 (i.e. members of the Board of Directors and management) of ICE, the organization claiming status as a victim under the CVRA.  Neither did the district court err in finding that ICE failed to establish that it was directly and proximately harmed by the offenders\u0027 criminal conduct.\u0022 (Sources:  In re: Instituto Costarricense de Electricidad, No. 11-12707-G and No. 11-12708-G (11th Cir.), On Petititon for Writ of Mandamus to the United States District Court for the Southern District of Florida filed June 17, 2011 and September 2, 2011 denial of ICE\u0027s motion for Petition for Rehearing En Banc; see also Consolidated Opposition of Alcatel-Lucent, S.A., Alcatel-Lucent France, S.A., Alcatel-Lucent Trade International, A.G. and Alcatel Centroamerica, S.A. to Petitions for Writs of Mandamus Pursuant to the Crime Victims Rights Act, 18 U.S.C. Section 3771 filed June 17, 2011.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alcatel-Lucent, S.A. Case Summary at 27-29, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.   US v. Alcatel-Lucent, SA, Case No. 1:10-cr-20907 (S.D. Fla.), Information filed December 27, 2010 and copies of the Deferred Prosecution Agreement and Order, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/alcatel-lucent-sa.html; US Department of Justice Press Release, \u0022Alcatel-Lucent S.A. and Three Subsidiaries Agree to Pay $92 Million to Resolve Foreign Corrupt Practices Act Investigation,\u0022 December 27, 2010, at http:\/\/www.justice.gov\/opa\/pr\/2010\/December\/10-crm-1481.html.  ICE Petition: US v. Alcatel-Lucent S.A., Case No. 1:10-cr-20907 (S.D. Fla.), Petition for Relief Pursuant to 18 U.S.C. Section 3771(d)(3) and Objection to Plea Agreements and Deferred Prosecution Agreement filed May 3, 2011 and Petition for Writ of Mandamus Pursuant to the Crime Victims\u0027 Rights Act, 18 USC Section 3771(d)(3) filed June 15, 2011; US Government\u0027s Response to ICE\u0027s Petition for Victim Status and Restitution, filed May 23, 2011; In re: Instituto Costarricense de Electricidad, No. 11-12707-G and No. 11-12708-G (11th Cir.), On Petititon for Writ of Mandamus to the United States District Court for the Southern District of Florida filed June 17, 2011 and September 2, 2011 denial of ICE\u0027s motion for Petition for Rehearing En Banc; see also Consolidated Opposition of Alcatel-Lucent, S.A., Alcatel-Lucent France, S.A., Alcatel-Lucent Trade International, A.G. and Alcatel Centroamerica, S.A. to Petitions for Writs of Mandamus Pursuant to the Crime Victims Rights Act, 18 U.S.C. Section 3771 filed June 17, 2011.","Documents":""},{"Case ID":"ST-28","Case Cluster ":"Alexander Yakovlev","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"United States Attorney for the Southern District of New York ","Jurisdiction of Foreign Public Official(s) ":"United Nations","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"12\/22","Other Jurisdictions of Settlement":"None","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$900,000.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$900,000","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art.1, Art. 7","Offenses - Alleged":"Conspiracy to commit wire fraud, wire fraud and conspiracy to commit money laundering","Offenses - Settled":"Conspiracy to commit wire fraud, wire fraud and conspiracy to commit money laundering","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US court documents, former United Nations officials Vladimir Kuznetsov and Alexander Yakovlev were charged with corruption and money laundering in U.S. federal court for their respective roles in the United Nations Oil-for-Food Programme case.  Mr. Kuznetsov was convicted of one count of money laundering following a jury trial in the U.S. District Court for Southern District of New York and ordered to pay a criminal fine of $73,671.  He satisfied this judgment on November 18, 2008.  His co-conspirator Alexander Yakovlev pleaded guilty in 2005 to three counts of wire fraud and money laundering.  As part of his plea agreement, Mr. Yakovlev had agreed to forfeit $900,000 held in bank accounts in Liechtenstein.  On December 22, 2010, the federal court for the Southern District of New York ordered the following accounts forfeited to the U.S. (pending any assertions of third-party claims):  (1) Liechtensteinische Landesbank AG and LLB Treuhand AG, 9490 Vaduz, Accounts numbered 208.63898 and 213.042.67, in the name of Alexander Yakovlev or Olga Yakoleva; and (2) LLB AG and LLB Treuhand AG, 9490 Vaduz, Accounts numbered 212.440.51 and 213.036.32 in the name of Angelus Finance Ltd, for which Alexander Yakovlev is the financial beneficiary.  On February 10, 2011, the court ented a Satisfaction of Forfeiture Money Judgment, noting that the accounts had been forfeited by the Principality of Liechtenstein.  (Sources: U.S. v. Kuznetsov, Case No. 1:05-cr-00916-DAB (S.D.N.Y.), Judgment filed in a criminal case, filed October 19, 2007; U.S. v. Yakovlev, Case No. 1:05-cr-00819-DAB (S.D.N.Y.), Consent Order of Forfeiture filed on December 22, 2010; Satisfaction of Forfeiture Money Judgment, filed February 10, 2011.)","Sources ":"U.S. v. Kuznetsov, no. 1:05-cr-00916-DAB (S.D.N.Y., Oct. 19, 2007), Judgment; US Department of Justice Press Release. \u0022U.S. Judge Sends Former High-Ranking United Nations Official to Prison for Money Laundering.\u0022 Oct. 12, 2007; Consent Order of Forfeiture, U.S. v. Yakovlev, no. 1:05-cr-00819-DAB, (Dec. 22, 2010); Order, U.S. v. Yakovlev, no. 05 Cr. 819 DAB (S.D.N.Y. Sept. 25, 2008); Independent Inquiry Committee into the United Nations Oil-for-Food Programme, Third Interim Report: The Conduct of Benon Sevan, The Conduct of Alexander Yakovlev, accessed at http:\/\/www.iic-offp.org\/documents\/Third%20Interim%20Report.pdf","Documents":""},{"Case ID":"ST-29","Case Cluster ":"Alfasan International BV Woerden","Jurisdiction of Settlement":"Netherlands","Jurisdiction of Settlement \/ Enforcement Agency":"Rijksrecherche (Dutch Public Prosecution Service)","Jurisdiction of Foreign Public Official(s) ":"Iraq (UN Oil-for-Food)","Year of Settlement":"2008","Month\/Day of Settlement (or Notes)":"07\/16","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Unknown form of out of court settlement","Monetary Sanctions  (Types)":"Criminal Fine, Criminal Confiscation","Total Monetary Sanctions (US$)":"$66,915.00","Criminal Fine\/Penalty (US$) ":"$50,684","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$16,230.90","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Unknown","Offenses - Settled":"Sanctions legislation by paying kickbacks when implementing UN Oil-for-Food Programme","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Netherlands Phase 2 Report of the OECD Anti-Bribery Working Group (December 17, 2008): \u0022As of October 2008, no foreign bribery cases had been brought before the Dutch courts. Nevertheless, the prosecution authorities have concluded out-of-court transactions with seven companies for paying kickbacks in the context of the Oil-for-Food Programme in Iraq, although the offence charged was the violation of sanctions legislation and not the foreign bribery offence.\u0022 (para 2); \u0022 the Prosecution Department reports that it has concluded financial transactions (out of court settlements) with 7 companies for violating sanction legislation by paying kickbacks when implementing the Oil for Food Programme. Criminal gains have also been confiscated. In July 2008 a press release has been issued about these settlements. Together with the names of the companies (Alfasan International B.V., N.V. Organon, Flowserve B.V., OPW Fluid Transfer Group Europe B.V., Prodetra B.V. Solvochem Holland B.V., Stet Holland B.V.) the settlements have been made public. For the following Oil-for-food transactions out-of-court settlements have been reached: 1. Alfasan International BV Woerden, fine: \u20ac 31.800,-- and confiscation \u20ac 10.183,55 2. NV Organon Oss, fine: \u20ac 381.602 3. Flowerserve bv te Etten-Leur, fine: \u20ac 76.274 and confiscation \u20ac180.260 4. OPW Fluid Transfer Group Europe BV, Nieuw Vennep, fine \u20ac 57.204 and confiscation \u20ac 24.600 5. Prodetra bv,Wadinxveen, fine: 64.751 and confiscation \u20ac 34.485,95 6. Solvochem Holland bv, Rotterdam, fine \u20ac 136.000 and confiscation \u20ac 144.592 7. Stet Holland bv,Emmeloord, fine \u20ac 119.712 and confiscation \u20ac 54.458.\u0022 (Source: Ibid., at 14.)","Sources ":"OECD Anti-Bribery Working Group, The Netherlands Phase 2 Report (December 17, 2008), accessed at http:\/\/www.oecd.org\/dataoecd\/61\/59\/41919004.pdf; Melissa Lipman, \u0022Cos. Settle Dutch Probe Into Oil-For-Food For \u20ac1.3M,\u0022 Law 360, July 16, 2008, accessed at http:\/\/www.law360.com\/articles\/62486\/cos-settle-dutch-probe-into-oil-for-food-for-1-3m (partial article, gives date of Dutch Public Prosecution Service press release.)","Documents":""},{"Case ID":"ST-30","Case Cluster ":"Alliance One International, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Kyrgyzstan, Thailand, Malawi, Greece, Indonesia, Mozambique, China","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits ","Total Monetary Sanctions (US$)":"$10,000,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$10,000,000","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Bribery of foreign officials, Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to DOJ Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Resulting Criminal Enforcement Actions: In Re Alliance One International, Inc. (August 6, 2010); U.S. v. Alliance One Tobacco Osh, LLC: Docket No. 10-CR-016-JLK (W.D. Va., August 6, 2010); U.S. v. Alliance One International AG: Docket No. 10-CR-017-JLK (W.D. Va., August 6, 2010); U.S. v. Bobby Jay Elkin, Jr.: Docket No. 10-CR-015-JLK (W.D. Va., August 3, 2010); Resulting Civil\/Administrative Enforcement Action(s): SEC v. Alliance One International, Inc. (D.D.C., August 6, 2010); SEC v. Bobby Jay Elkin, Jr., et al. (D.D.C., April 28, 2010),  Please note that the court docket numbers are from DOJ\/Fraud\/FCPA Enforcement Actions website (http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/a.html) and complete list of entities and individuals charged are in DOJ Report to Congress Appendix C, \u0022Alliance One International, Inc.\u0022 at 9-11, which also notes Location and Time Period of Misconduct: Kyrgystan, 1996-2004; Thailand, 2000-2004; Malawi, 2002-2003; Greece, 2003; Indonesia, 2003; Mozambique, 2004-2007; China and Thailand, 2005.","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Alliance One International, Inc. at 9-11, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf.  US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, AGCO Corporation Case Summary at 58-59, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21618 \/ August 6, 2010, SECURITIES AND EXCHANGE COMMISSION v. UNIVERSAL CORPORATION, INC., Civil Action No. 01:10-cv-01318 (RWR) (D.D.C.) (filed August 6, 2010), SECURITIES AND EXCHANGE COMMISSION v. ALLIANCE ONE INTERNATIONAL, INC., Civil Action No. 01:10-cv-01319 (RMU) (D.D.C.) (filed August 6, 2010), \u0022SEC FILES ANTI-BRIBERY CHARGES AGAINST TWO GLOBAL TOBACCO COMPANIES,\u0022 http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21618.htm; Complaint filed August 6, 2010, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2010\/comp21618-alliance-one.pdf","Documents":""},{"Case ID":"ST-31","Case Cluster ":"Alliance One International, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Kyrgyzstan, Thailand, Malawi, Greece, Indonesia, Mozambique, China","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement ","Monetary Sanctions  (Types)":"None ","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On August 6, 2010, two foreign subsidiaries of Alliance One International, Inc. (Alliance One), a global tobacco leaf merchant headquartered in Morrisville, N.C., were charged in separate three-count criminal informations with conspiring to violate the FCPA, violating the anti-bribery provisions of the FCPA, and violating the books and records provisions of the FCPA. On the same date, the SEC filed a settled civil action against Alliance One in the U.S. District Court for the District of Columbia. [  ] Previously, on August 3, 2010, Bobby Jay Elkin, Jr., Dimon?s former Kyrgyzstan country manager, was charged with one-count of conspiring to violate the FCPA\u0027s anti-bribery provisions. Elkin, along with three other former Alliance One employees, was also charged by the SEC in a settled civil enforcement action filed on April 28, 2010.The criminal and civil charges filed against Alliance One, its subsidiaries, and former employees stem from bribery schemes in multiple countries,\u0022 including from 1996 to 2004, $3 million in bribes to various officials in the Republic of Kyrgyzstan, including officials of the Kyrgyz Tamekisi, a government entity which controlled and regulated the tobacco industry in Kyrgyzstan as well as provincial and tax officials; from 2000 to 2004, more than $1.2 millionin bribes to the Thailand Tobacco Monopoly officials; in China and Thailand, gifts and entertainment to government officials; in Greece, $96,000 cash payment to a Greek tax official which resulted in a reduced tax payment from EUR 2.5 million to approximately EUR 600,000; in Indonesia, cash payment of approximately $44,000 to an Indonesian tax official in exchange for terminating an audit and obtaining a tax refund of $67,000.  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf. In Re: Alliance One International, Inc., Non-Prosecution Agreement dated August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/alliance-one\/08-06-10alliance-one-npa.pdf","Documents":""},{"Case ID":"ST-32","Case Cluster ":"Alliance One International, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Kyrgyzstan, Thailand, Malawi, Greece, Indonesia, Mozambique, China","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$5,251,200.00","Criminal Fine\/Penalty (US$) ":"$5,250,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"$1,200","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials, Falsification of books and records","Offenses - Settled":"Conspiracy to bribe foreign officials, Bribery of foreign officials, Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On August 6, 2010, two foreign subsidiaries of Alliance One International, Inc. (Alliance One), a global tobacco leaf merchant headquartered in Morrisville, N.C., were charged in separate three-count criminal informations with conspiring to violate the FCPA, violating the anti-bribery provisions of the FCPA, and violating the books and records provisions of the FCPA. On the same date, the SEC filed a settled civil action against Alliance One in the U.S. District Court for the District of Columbia. [  ] Previously, on August 3, 2010, Bobby Jay Elkin, Jr., Dimon?s former Kyrgyzstan country manager, was charged with one-count of conspiring to violate the FCPA\u0027s anti-bribery provisions. Elkin, along with three other former Alliance One employees, was also charged by the SEC in a settled civil enforcement action filed on April 28, 2010.The criminal and civil charges filed against Alliance One, its subsidiaries, and former employees stem from bribery schemes in multiple countries,\u0022 including from 1996 to 2004, $3 million in bribes to various officials in the Republic of Kyrgyzstan, including officials of the Kyrgyz Tamekisi, a government entity which controlled and regulated the tobacco industry in Kyrgyzstan as well as provincial and tax officials; from 2000 to 2004, more than $1.2 million in bribes to the Thailand Tobacco Monopoly officials; in China and Thailand, gifts and entertainment to government officials; in Greece, $96,000 cash payment to a Greek tax official which resulted in a reduced tax payment from EUR 2.5 million to approximately EUR 600,000; in Indonesia, cash payment of approximately $44,000 to an Indonesian tax official in exchange for terminating an audit and obtaining a tax refund of $67,000.  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Alliance One International, AG, Case No. 4:10-cr-017-JLK (W.D. Va.), Plea Agreement filed August 6, 2010; Amended Judgment against Alliance One International AG (October 22, 2010), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/alliance-one\/10-22-10alliance-one-intl-amended.pdf","Documents":""},{"Case ID":"ST-33","Case Cluster ":"Alliance One International, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Kyrgyzstan, Thailand, Malawi, Greece, Indonesia, Mozambique, China","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$4,201,200.00","Criminal Fine\/Penalty (US$) ":"$4,200,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"$1,200","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Conspiracy to bribe foreign officials, Bribery of foreign officials, Aiding and abetting falsification of books and records","Offenses - Settled":"Conspiracy to bribe foreign officials, Bribery of foreign officials, Aiding and abetting falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On August 6, 2010, two foreign subsidiaries of Alliance One International, Inc. (Alliance One), a global tobacco leaf merchant headquartered in Morrisville, N.C., were charged in separate three-count criminal informations with conspiring to violate the FCPA, violating the anti-bribery provisions of the FCPA, and violating the books and records provisions of the FCPA. On the same date, the SEC filed a settled civil action against Alliance One in the U.S. District Court for the District of Columbia. [  ] Previously, on August 3, 2010, Bobby Jay Elkin, Jr., Dimon\u0027s former Kyrgyzstan country manager, was charged with one-count of conspiring to violate the FCPA\u0027s anti-bribery provisions. Elkin, along with three other former Alliance One employees, was also charged by the SEC in a settled civil enforcement action filed on April 28, 2010.The criminal and civil charges filed against Alliance One, its subsidiaries, and former employees stem from bribery schemes in multiple countries,\u0022 including from 1996 to 2004, $3 million in bribes to various officials in the Republic of Kyrgyzstan, including officials of the Kyrgyz Tamekisi, a government entity which controlled and regulated the tobacco industry in Kyrgyzstan as well as provincial and tax officials; from 2000 to 2004, more than $1.2 millionin bribes to the Thailand Tobacco Monopoly officials; in China and Thailand, gifts and entertainment to goernmetn officials; in Greece, $96,000 cash payment to a Greek tax official which resulted in a reduced tax payment from EUR 2.5 million to approximately EUR 600,000; in Indonesia, cash payment of approximately $44,000 to an Indonesian tax official in exchange for terminating an audit and obtaining a tax refund of $67,000.  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Alliance One Tobacco Osh LLC, Case No. 4:10-cr-016-JLK (W.D. Va.), Plea Agreement filed August 6, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/alliance-one\/08-06-10alliance-tobacco-plea-agree.pdf; Judgment (October 21, 2010), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/alliance-one\/10-21-10alliance-one-tobacco-judgment.pdf","Documents":""},{"Case ID":"ST-34","Case Cluster ":"Alliance One International, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Kyrgyzstan, Thailand, Malawi, Greece, Indonesia, Mozambique, China","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"04\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction  ","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$80,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$80,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Bribery of foreign officials, Aiding and abetting Alliance\u0027s books and records violations, Aiding and abetting Alliance\u0027s internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On August 6, 2010, two foreign subsidiaries of Alliance One International, Inc. (Alliance One), a global tobacco leaf merchant headquartered in Morrisville, N.C., were charged in separate three-count criminal informations with conspiring to violate the FCPA, violating the anti-bribery provisions of the FCPA, and violating the books and records provisions of the FCPA. On the same date, the SEC filed a settled civil action against Alliance One in the U.S. District Court for the District of Columbia. [  ] Previously, on August 3, 2010, Bobby Jay Elkin, Jr., Dimon\u0027s former Kyrgyzstan country manager, was charged with one-count of conspiring to violate the FCPA\u0027s anti-bribery provisions. Elkin, along with three other former Alliance One employees, was also charged by the SEC in a settled civil enforcement action filed on April 28, 2010.The criminal and civil charges filed against Alliance One, its subsidiaries, and former employees stem from bribery schemes in multiple countries,\u0022 including from 1996 to 2004, $3 million in bribes to various officials in the Republic of Kyrgyzstan, including officials of the Kyrgyz Tamekisi, a government entity which controlled and regulated the tobacco industry in Kyrgyzstan as well as provincial and tax officials; from 2000 to 2004, more than $1.2 millionin bribes to the Thailand Tobacco Monopoly officials; in China and Thailand, gifts and entertainment to goernmetn officials; in Greece, $96,000 cash payment to a Greek tax official which resulted in a reduced tax payment from EUR 2.5 million to approximately EUR 600,000; in Indonesia, cash payment of approximately $44,000 to an Indonesian tax official in exchange for terminating an audit and obtaining a tax refund of $67,000. The Report noted that \u0022On April 28, 2010, the SEC filed a settled civil action against Elkin, Myers, Reynolds, and Williams, which permanently enjoined them from future violations of the FCPA. Myers and Reynolds were each required to pay a $40,000 civil penalty. The settlement against Elkin takes into account his cooperation with the Commission?s investigation.\u0022 (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US Securities and Exchange Commission, Litigation Release No. 21509 \/ April 29, 2010, Securities and Exchange Commission v. Bobby J. Elkin, Jr., Baxter J. Myers, Thomas G. Reynolds, and Tommy L. Williams, Civil Action No. 1:10-cv-00661 (RMU) (D.D.C.) (filed April 28, 2010), \u0022SEC Files Anti-Bribery Charges Against Former Finance Executives and Senior Employees Of Global Tobacco Company,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2010\/lr21509.htm","Documents":""},{"Case ID":"ST-35","Case Cluster ":"Alliance One International, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Kyrgyzstan","Year of Settlement":"2010","Month\/Day of Settlement (or Notes)":"08\/06","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea ","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$5,000.00","Criminal Fine\/Penalty (US$) ":"$5,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Conspiracy to bribe foreign officials","Offenses - Settled":"Conspiracy to bribe foreign officials","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the June 2011 United States Report to the OECD, \u0022On August 6, 2010, two foreign subsidiaries of Alliance One International, Inc. (Alliance One), a global tobacco leaf merchant headquartered in Morrisville, N.C., were charged in separate three-count criminal informations with conspiring to violate the FCPA, violating the anti-bribery provisions of the FCPA, and violating the books and records provisions of the FCPA. On the same date, the SEC filed a settled civil action against Alliance One in the U.S. District Court for the District of Columbia. [  ] Previously, on August 3, 2010, Bobby Jay Elkin, Jr., Dimon\u0027s former Kyrgyzstan country manager, was charged with one-count of conspiring to violate the FCPA\u0027s anti-bribery provisions. Elkin, along with three other former Alliance One employees, was also charged by the SEC in a settled civil enforcement action filed on April 28, 2010.The criminal and civil charges filed against Alliance One, its subsidiaries, and former employees stem from bribery schemes in multiple countries,\u0022 including from 1996 to 2004, $3 million in bribes to various officials in the Republic of Kyrgyzstan, including officials of the Kyrgyz Tamekisi, a government entity which controlled and regulated the tobacco industry in Kyrgyzstan as well as provincial and tax officials; from 2000 to 2004, more than $1.2 millionin bribes to the Thailand Tobacco Monopoly officials; in China and Thailand, gifts and entertainment to goernmetn officials; in Greece, $96,000 cash payment to a Greek tax official which resulted in a reduced tax payment from EUR 2.5 million to approximately EUR 600,000; in Indonesia, cash payment of approximately $44,000 to an Indonesian tax official in exchange for terminating an audit and obtaining a tax refund of $67,000.  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45.)","Sources ":"US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, Alliance One International, Inc. Case Summary at 41-45, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf.  US v. Bobby Jay Elkin, Jr., Case No. 4:10-cr-015-JLK (W.D. Va.), Plea Agreement filed August 3, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/elkin\/08-03-10elkin-plea-agmt.pdf; Judgment filed October 21, 2010, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/elkin\/10-21-10elkin-judgment.pdf","Documents":""},{"Case ID":"ST-36","Case Cluster ":"Allied Products Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Russia","Year of Settlement":"2001","Month\/Day of Settlement (or Notes)":"06\/22","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea ","Monetary Sanctions  (Types)":"None ","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8 ","Offenses - Alleged":"Falsification of books and records","Offenses - Settled":"Falsification of books and records","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Allied Products Corporation, at 120-121, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf and Information in US v. David Ray Rothrock, Case No. 5:01-cr-00343-OLG (W.D. Tex., June 13, 2001): Rothrock was the vice president of the Cooper Division of Allied Products Corporation with responsibility for international sales.  He pleaded guilty to one count of falsifying his employer\u0027s corporate books and records.  The Cooper Division agreed to pay a sales commission of $282,076 to a third party company (Trading and Business Services Ltd., an entity with principal business in Moscow; Biel, Switzerland; and Houston and co-owned by \u0022Nestro\u0022 and Comco Holding AG, a Swiss company) for ultimate benefit of the Director General of RVO Zarubezhneftstroy (\u0022Nestro\u0022), a Soviet government purchasing agency, in order to obtain a contract for the sale of 20 workover rigs to Nestro. Rothrock, in 2002, created false invoice that was purported to come from a company called \u0022Educa\u0022 in Vienna, Austria but that he knew was for TBS. Rothrock pleaded guilty and on September 20, 2001, he was sentenced to one year probation and ordered to pay court assessment of $100.  His presentencing report was sealed on September 24, 2001. (Sources: US v. Daniel Ray Rothrock, Case No. 5:01-cr-00343-OLG (W.D. Tex.), Information filed on June 13, 2001; Plea agreement filed June 13, 2011 and Judgment of September 20, 2001 and Court Docket Report, all accessed at Fcpa.Shearman.com, Case Summary Page, US v. David Ray Rothrock, http:\/\/fcpa.shearman.com\/index.php.","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Allied Products Corporation, at 120-121, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/rothrock.html; US v. Daniel Ray Rothrock, Case No. 5:01-cr-00343-OLG (W.D. Tex.), Information filed on June 13, 2001; Plea agreement filed June 13, 2011 and Judgment of September 20, 2001 and Court Docket Report, all accessed at Fcpa.Shearman.com, Case Summary Page, US v. David Ray Rothrock, http:\/\/fcpa.shearman.com\/index.php","Documents":""},{"Case ID":"ST-37","Case Cluster ":"Alstom S.A.","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Latvia, Malaysia, Tunisia","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"11\/22","Other Jurisdictions of Settlement":"World Bank","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Payment of Reparation (Art. 53 Swiss Criminal Code)","Monetary Sanctions  (Types)":"Reparation","Total Monetary Sanctions (US$)":"$1,089,510.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"$1,089,510","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$1,089,510","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Reparations via International Committee of the Red Cross","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8, Art. 9","Offenses - Alleged":"Art. 102 Criminal Code (Liability for acts committed by subsidiary) ","Offenses - Settled":"Art. 53 Criminal Code (Costs of Prosecution)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Press Release issued by the Swiss Office of Attorney General, \u0022As far as the proceedings were also brought against Alstom SA, based in France, they have been dismissed with regard to the actions in Latvia, Tunisia and Malaysia based on Art. 53 SCC, imposing on the company the costs of the proceedings allotted to Alstom SA in this regard. In the opinion of the OAG, Alstom SA as the senior holding company is responsible in part for the organizational deficiencies identified. However, after payment of CHF 1 m as reparation and bearing the remaining costs of the proceedings by Alstom SA, the OAG refrained from sanctioning Alstom SA in addition to Alstom Network Schweiz AG regarding the established acts of bribery. It did so particularly considering the demonstrated willingness to cooperate and the considerable improvements in the internal compliance procedures before and after the opening of the investigations.Within the proceedings against Alstom Network Schweiz AG and Alstom SA, the OAG in close cooperation with the Federal Criminal Police investigated further twelve projects in the power station sector, divided over all continents. In this regard, it in some part detected additional breaches of internal compliance regulations. Despite considerable investigative efforts however, no additional acts of bribery could be established for the time after article 102 SCC had come into effect. The proceedings against the two defendant Alstom entities for these additionally investigated twelve projects were dismissed due to the lack of any criminal conduct (Art. 319(1)(a) Swiss Code of Criminal Procedure) and due to the lack of criminal liability of the companies prior to October 2003 (Art. 319(1)(b) Swiss Code of Criminal Procedure), without granting compensation and by imposing the costs allotted for this part of the proceedings on the two Alstom companies. [  ]  The amount of CHF 1 m paid by Alstom SA as reparation under Art. 53 SCC was transferred to the International Committee of the Red Cross. One-third of these funds each shall be used in projects of the ICRC in Tunisia, Latvia and Malaysia respectively. The costs allotted for the part of the proceedings resulting in the dismissal amount to about CHF 90,000 and have been imposed on the two Alstom companies for which they are jointly liable.  Due to Alstom renouncing to appeal, this decision also has become legally binding.\u0022 (Source: The Office of the Attorney General Press Release, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011.)  Please note that the CHF 90,000 in costs of the proceedings have been included only in the Alstom Network Schweiz AG entry so as to prevent double counting of the sum. ","Sources ":"Organisation of Economic Co-operation and Development, Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland, Adopted by the OECD Working Group on Bribery on December 16, 2011, para 40, accessed at http:\/\/www.oecd.org\/daf\/anti-bribery\/anti-briberyconvention\/Switzerlandphase3reportEN.pdf    http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf; The [Swiss] Office of the Attorney General Press Release, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011, accessed at http:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=42300","Documents":"\nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Alstom_SA_Swiss_Attorney_General_Summary_Punishment_Order_PR_Nov_22_2011.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Alstom_Company_Statement_Nov_2011.pdf, \nhttps:\/\/star.worldbank.org\/corruption-cases\/sites\/corruption-cases\/files\/settlements\/Switzerland_OECD_Phase_3_Report_Dec_2011.pdf"},{"Case ID":"ST-38","Case Cluster ":"Alstom S.A.","Jurisdiction of Settlement":"","Jurisdiction of Settlement \/ Enforcement Agency":"Integrity Vice Presidency","Jurisdiction of Foreign Public Official(s) ":"Zambia","Year of Settlement":"2012","Month\/Day of Settlement (or Notes)":"02\/22","Other Jurisdictions of Settlement":"Switzerland","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Administrative","Legal Form of Settlement":"Negotiated Resolution Agreement","Monetary Sanctions  (Types)":"Restitution","Total Monetary Sanctions (US$)":"$9,500,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"$9,500,000","Other Civil Monetary Sanctions (Explanation)":"Restitution","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$9,500,000 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Restitution to World Bank","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Improper payment to an entity controlled by a former senior government official ","Offenses - Settled":"Improper payment to an entity controlled by a former senior government official ","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According  to the Workd Bank press release dated February 22, 2012, \u0022The World Bank Group today announced the debarment of Alstom Hydro France and Alstom Network Schweiz AG (Switzerland) - in addition to their affiliates - for a period of three years following Alstom?s acknowledgment of misconduct in relation to a Bank-financed hydropower project.  The debarment is part of a Negotiated Resolution Agreement between Alstom and the World Bank which also includes a restitution payment by the two companies totaling approximately $9.5 million. The debarment can be reduced to 21 months - with enhanced oversight - if the companies comply with all conditions of the agreement. [ ] In 2002, Alstom made an improper payment of \u20ac110,000, to an entity controlled by a former senior government official for consultancy services in relation to the World Bank-financed Zambia Power Rehabilitation Project. During the debarment period of Alstom Hydro France and Alstom Network Schweiz AG, Alstom SA and its other affiliates are conditionally non-debarred. Under the Agreement, Alstom SA, Alstom Hydro France, Alstom Network Schweiz AG and their affiliates commit to cooperating with the World Bank?s Integrity Vice Presidency and continuing to improve their internal compliance program. The debarment of Alstom Hydro France and Alstom Network Schweiz qualifies for cross-debarment by other MDBs under the Agreement of Mutual Recognition of Debarments that was signed on April 9, 2010.\u0022  (Source: The World Bank Press Release No: 2012\/282\/INT, \u0022Enforcing Accountability: World Bank Debars Alstom Hydro France, Alstom Network Schweiz AG, and their Affiliates,\u0022 February 22, 2012.)","Sources ":"The World Bank Press Release No: 2012\/282\/INT, \u0022Enforcing Accountability: World Bank Debars Alstom Hydro France, Alstom Network Schweiz AG, and their Affiliates,\u0022 February 22, 2012, accessed at http:\/\/web.worldbank.org\/WBSITE\/EXTERNAL\/NEWS\/0,,print:Y~isCURL:Y~contentMDK:23123315~pagePK:34370~piPK:34424~theSitePK:4607,00.html","Documents":""},{"Case ID":"ST-39","Case Cluster ":"Alstom S.A.","Jurisdiction of Settlement":"Switzerland","Jurisdiction of Settlement \/ Enforcement Agency":"Office of the Attorney General","Jurisdiction of Foreign Public Official(s) ":"Latvia, Malaysia, Tunisia","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"11\/22","Other Jurisdictions of Settlement":"World Bank","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Summary Punishment Order ","Monetary Sanctions  (Types)":"Criminal Fine, Confiscation of Profits, Legal Costs","Total Monetary Sanctions (US$)":"$42,485,594.00","Criminal Fine\/Penalty (US$) ":"$2,723,790","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$39,658,300","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"$103,504 ","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"$0","UNCAC Articles(s) Implicated":"Art.16, Art.23, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 7, Art. 8, Art. 9","Offenses - Alleged":"Bribery of foreign officials, Not take all necessary and reasonable organizational precautions to prevent bribery of foreign officials in the course of its business operations (Art. 102 Section 2 Swiss Criminal Code in conjunction with Art. 322 of the Swiss Criminal Code)","Offenses - Settled":"Bribery of foreign officials, Not take all necessary and reasonable organizational precautions to prevent bribery of foreign officials in the course of its business operations (Art. 102 Section 2 Swiss Criminal Code in conjunction with Art. 322 of the Swiss Criminal Code)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Summary Punishment Order of the Office of the Swiss Attorney General, dated November 22, 2011, \u0022In complete disregard of the internal provisions [for selecting and using consultants] . . . the Defendant [Alstom] through its representatives signed consultancy agreements with pure offshore and shell companies in the cases relevant to the current proceedings. [   ] The fact that payments were carried out and made by the Defendant on the basis of such consultancy agreements into the accounts of offshore and shell companies both nationally and abroad, i.e. into accounts located outside the project country, meant that there was a higher risk, as a matter of principle not tolerated by internal guidelines, that such payments could be used for bribery or for other illegal purposes.\u0022 (Source: Summary Punishment Order at para 10.)  According to the Summary Punishment Order, this misconduct continued after active foreign bribery sanctions entered into effect, and \u0022It must be held in the OAG\u0027s [Office of the Attorney General\u0027s] consideration that the company did not take all necessary and reasonable precautions to prevent the bribery of foreign public officials, as a result of which bribery of foreign public officials did in fact occur in three cases.\u0022  (Source: Summary Punishment Order at para 11.)  (1) In Latvia, from 2006 onwards, bribe payments were funnelled to legal entities SIA Energy Consulting (Latvia) and Kenmore OU (Estonia) controlled by Andrejs Livanovics, a former Alstom business development manager for the Baltics but the beneficiaries of the success fees were executives of the state owned company LATVENERGO AS who were decisively involved in decisions related to awarding contracts; (2) in Tunisia, \u0022consultancy\u0022 payments to companies controlled by Slim CHIBOUB, a son-in-law of the former President of Tunisia; the companies were Roserton Overseas SA (Panama) and Dalmel Trading, Inc. (BVI); and (3) in Malaysia, in connection with the state-licensed Teknologi Tenaga Perlis Consortium Sdtn Bhd, Alstom companies were used as intermediary companies for \u0022consulting agreements\u0022 for which the beneficiaries were TTPC executives Chee Liang TI and Abdul Hamid PAWANTEH (latter was also a local politician in the constituent state of Perlis where the power station was to be built).  The involved Alstom companies were: in Latvia - Alstom Power Sweden AB and Alstom Hydro Sweden AB; in Tunisia - Alstom Power Centrales; in Malaysia - Alstom Schweiz AG and Alstom power O\u0026M AG.  Alstom was fined CHF 2.5 million; compensatory claim of CHF 36.4 million; and CHF 95,217,70 in procedural fees.  (Source: Office of the Swiss Attorney General, Summary Punishment Order, in the Investigation of Alstom Network Schweiz AG, November 22, 2011.)  According to a statement by Alstom, the Swiss Attorney General issued a dismissal order regarding any other proceedings against Alstom; and the company decided not to challenge the decision of the Attorney General. (Source: Alstom Company Statement, \u0022The Swiss Office of Attorney General confirms the absence of any bribery system at Alstom. It fines the company for \u0027corporate negligence\u0027 in three isolated cases,\u0022 November 22, 2011.)\t\t\t\t","Sources ":"Office of the Swiss Attorney General, Summary Punishment Order, in the Investigation of Alstom Network Schweiz AG, November 22, 2011, accessed at scribd.com (link provided at Samuel Rubenfeld, Wall Street Journal Corruption Currents, \u0022Alstom Fined By Switzerland in Bribery Case,\u0022 November 22, 2011, at http:\/\/blogs.wsj.com\/corruption-currents\/2011\/11\/22\/alstom-fined-by-switzerland-in-bribery-case\/; The [Swiss] Office of the Attorney General Press Release, \u0022Criminal proceedings against Alstom entities are brought to a close,\u0022 November 22, 2011, accessed at http:\/\/www.news.admin.ch\/message\/index.html?lang=en\u0026msg-id=42300; Alstom Company Statement, \u0022The Swiss Office of Attorney General confirms the absence of any bribery system at Alstom. It fines the company for \u0027corporate negligence\u0027 in three isolated cases,\u0022 November 22, 2011, accessed at http:\/\/www.alstom.com\/news-and-events\/press-releases\/The-Swiss-Office-of-Attorney-General-confirms-the-absence-of-any-bribery-system-at-Alstom\/.  See also, Organisation of Economic Co-operation and Development, Phase 3 Report on Implementing the OECD Anti-Bribery Convention in Switzerland, Adopted by the OECD Working Group on Bribery on December 16, 2011, at 55 and throughout, accessed at http:\/\/www.oecd.org\/dataoecd\/59\/53\/49377354.pdf","Documents":""},{"Case ID":"ST-40","Case Cluster ":"AMAC International","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"China","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"04\/07","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Criminal","Legal Form of Settlement":"Guilty Plea","Monetary Sanctions  (Types)":"Criminal Forfeiture","Total Monetary Sanctions (US$)":"$386,740.00","Criminal Fine\/Penalty (US$) ":"$0","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"$386,740","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Bribery of foreign officials, Unlawful export of a defense article","Offenses - Settled":"Bribery of foreign officials, Unlawful export of a defense article","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 AMAC International, at 56-57, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf:  Time period of misconduct in China 2003-2007; native Chinese physicist Shu Quan-Sheng allegedly offered illicit payments worth $189,300 to officials within the PRC\u0027s 101st Research Institute, a component of the China Academy of Launch Vehicle Technology prior to the awarding of a $4 million project contract and that the successful brokering of the deal between AMAC and a French company (identified only as \u0022French Company A\u0022 in criminal information) earned Shu and AMAC a commission.  Resulting criminal enforcement action: US v. Shu Quan-Sheng (E.D. Va., November 12, 2008). ","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 AMAC International, at 56-57, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; US Department of Justice Press Release, \u0022Virginia Physicist Pleads Guilty to Illegally Exporting Space Launch Data to China and Offering Bribes to Chinese Officials,\u0022 November 17, 2008, accessed at http:\/\/www.justice.gov\/opa\/pr\/2008\/November\/08-nsd-1020.html (accessed September 15, 2011); US v. Shu Quan-Sheng, Case 2:08-cr-00194-HCM-TEM (E.D. Va., 2008), Criminal Information filed on November 12, 2008, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/quan-shengs\/11-12-08sheng-info.pdf.","Documents":""},{"Case ID":"ST-41","Case Cluster ":"AMEC plc","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Serious Fraud Office","Jurisdiction of Foreign Public Official(s) ":"Unspecified","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"10\/26","Other Jurisdictions of Settlement":"United States","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Civil Recovery Order (Proceeds of Crime Act)","Monetary Sanctions  (Types)":"Civil Recovery Order, Legal Costs","Total Monetary Sanctions (US$)":"$8,057,800.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$8,057,800","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Inaccurate books and records, in violation of Section 221 of Companies Act 1985","Offenses - Settled":"Inaccurate books and records, in violation of Section 221 of Companies Act 1985","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the October 26, 2009 press release by the UK Serious Fraud Office (SFO), AMEC made a referral to the SFO in March 2008, following an internal investigation into the receipt of irregular payments made between November 2005 and March 2007, and associated with a project [unnamed] in which AMEC is a shareholder. SFO investigated and in a Consent Order agreed before the High Court on October 26, 2009, AMEC agreed to a settlement payment of GBP 4,943,648 plus the costs incurred [amount not given; unable to add to entry] as a result of the Civil Recovery proceedings. The press release stated that \u0022It is not possible to make any further comment as there is an ongoing criminal investigationinto related matters.\u0022  (Source: UK Serious Fraud Office Press Release, \u0022SFO Obtains Civil Recovery Order against AMEC plc,\u0022 October 26, 2009, accessed at http:\/\/www.sfo.gov.uk\/press-room\/latest-press-releases\/press-releases-2009\/sfo-obtains-civil-recovery-order-against-amec-plc.aspx.)  AMEC\u0027s announcement on the settlement noted that the payments totalled some US $9 million and was associated with the last remaining Private-Public Partnership project and the division it belonged to was divested in mid-2007. (Source: AMEC plc, \u0022AMEC plc - Statement on civil recovery order,\u0022 October 26, 2009, accessed at http:\/\/www.amec.com\/media\/news_releases\/2009\/AMEC_statement_on_civil_recovery_order.htm).  Media reports that the project in question was the Incheon Bridge project in South Korea. (Source: Simon Bowers, \u0022Amec and Serious Fraud Office settle $9m \u0027irregular receipts\u0027 case,\u0022 The Guardian, October 26, 2009, accessed at http:\/\/www.guardian.co.uk\/business\/2009\/oct\/26\/amec-sfo-settlement\/print.)","Sources ":"UK Serious Fraud Office Press Release, \u0022SFO obtains Civil Recovery Order against AMEC plc,\u0022 October 26, 2009, accessed at http:\/\/www.sfo.gov.uk\/press-room\/press-release-archive\/press-releases-2009\/sfo-obtains-civil-recovery-order-against-amec-plc.aspx; AMEC plc, \u0022AMEC plc - Statement on civil recovery order,\u0022 October 26, 2009, accessed at http:\/\/www.amec.com\/media\/news_releases\/2009\/AMEC_statement_on_civil_recovery_order.htm; Simon Bowers, \u0022Amec and Serious Fraud Office settle $9m \u0027irregular receipts\u0027 case,\u0022 The Guardian, October 26, 2009, accessed at http:\/\/www.guardian.co.uk\/business\/2009\/oct\/26\/amec-sfo-settlement\/print.","Documents":""},{"Case ID":"ST-42","Case Cluster ":"AMEC plc","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice; General Services Administration Inspector General","Jurisdiction of Foreign Public Official(s) ":"United Kingdom, United States ","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"02\/02","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Agree to Civil Penalties, Forfeit previous claim","Monetary Sanctions  (Types)":"Civil Penalty, Forfeit Previous Claim","Total Monetary Sanctions (US$)":"$19,040,256.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"$19,040,256","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Fraud, False Claims, Kickbacks; Excessive re-procurement costs","Offenses - Settled":"Fraud, False Claims, Kickbacks; Excessive re-procurement costs","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to a US Department of Justice Press Release, AMEC Construction Management Inc. agreed to pay $19 million to settle litigation regarding fraud, false claims, kick-backs and re-procurement costs on US federal construction projects.  In one of the counterclaims filed in the US Court of Federal Claims, the US had sought damages and penalties under the False Claims Act, the Anti-Kickback Act and common law theories for false bond reimbursement claims submitted by AMEC Construction Management Inc. (ACMI) to the US General Services Administration (GSA) and bond premium kickbacks paid by the company\u0027s bond broker to ACMI\u0027s United Kingdom parent company, AMEC plc, on four federal contracts. (Source: US Department of Justice, U.S. Recovers $19 Million from AMEC Construction Management to Settle Litigation Regarding Fraud, False Claims, Kickbacks \u0026 Re-Procurement Costs on Federal Construction Contracts,\u0022 February 2, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/February\/09-civ-085.html). Additional details also in US General Services Administration Inspector General Press Release, \u0022GSA OIG Recovers Over $19 Million in False Claims from GSA Contractor -- Contractor Also Forfeits $83.5 Million in Pending Claims,\u0022 accessed at http:\/\/www.gsaig.gov\/index.cfm\/news\/gsa-oig-recovers-over-19-million-in-false-claims-from-gsa-contractor-contractor-also-forfeits-83,5-million-in-pending-claims\/.","Sources ":"US Department of Justice Press Release, \u0022U.S. Recovers $19 Million from AMEC Construction Management to Settle Litigation Regarding Fraud, False Claims, Kickbacks \u0026 Re-Procurement Costs on Federal Construction Contracts,\u0022 February 2, 2009, accessed at http:\/\/www.justice.gov\/opa\/pr\/2009\/February\/09-civ-085.html; US General Services Administration Inspector General Press Release, \u0022GSA OIG Recovers Over $19 Million in False Claims from GSA Contractor -- Contractor Also Forfeits $83.5 Million in Pending Claims,\u0022 accessed at http:\/\/www.gsaig.gov\/index.cfm\/news\/gsa-oig-recovers-over-19-million-in-false-claims-from-gsa-contractor-contractor-also-forfeits-835-million-in-pending-claims\/.","Documents":""},{"Case ID":"ST-43","Case Cluster ":"American Bank Note Holographics, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2001","Month\/Day of Settlement (or Notes)":"07\/18","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$75,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$75,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2","Offenses - Alleged":"Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 American Bank Note Holographics, Inc. at 114-115 and Information filed in US v. Joshua Cantor:  On July 17, 2001, Cantor pleaded guilty to a 4-count information charging him with conspiracy to commit securities fraud, falsify books and records, lie to auditors and conspiracy to violate the FCPA.  Cantor was the president of American Bank Note Holographics, and the company was approached by the Saudi Arabian Monetary Agency with the opportunity to be the supplier of the hologram for a commemorative Saudi Arabian banknote.  In May 1998, one of ABNH\u0027s overseas agents informed ABNH that its bid would need to include \u0022an additional sum to cover consultancy fees.\u0022 ABNH eventually won the bid and consultancy fees in the amount of $239,000 were transferred to Bank Account #47377V at Credit Agricol Indosuez in Geneva, Switzerland held in the name of an entity \u0022Satapco\u0022 and the Saudi foreign official, who served as Director of the Issues and Vaults Department of SAMA, received at least a portion of the $238,000 consultancy fee. As of July 11, 2012, Cantor had not yet been sentenced. (Source: US v. Cantor, Case No. 1:01-cr-687-BSJ (S.D.N.Y.), Information, Plea and transcript of Plea Hearing, all July 17, 2001, accessed at fcpa.shearman.com; court docket report as of July 11, 2012 accessed via PACER.) ABNH settled with the SEC without admitting or denying the charges in the complaint and agreed to pay $75,000 in civil penalties. (Source: SEC v. American Bank Note, Case No. 1:01-cv-06453-JSR (S.D.N.Y.), Court Docket Report, entry of Judgment on July 20, 2001.). In addition to criminal case against Joshua Cantor, related civil enforcement actions: SEC v. Joshua Cantor (S.D.N.Y., April 10, 2003); SEC v. American Bank Note Holographics, Inc. (S.D.N.Y., July 18, 2001); and In the Matter of American Bank Note Holographics, Inc. (S.D.N.Y., July 18, 2001) ","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 American Bank Note Holographics, Inc. at 114-115, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf;  http:\/\/www.justice.gov\/opa\/pr\/2005\/March\/05_crm_090.htm; US v. Joshua C. Cantor, Case No. 1:01-cr-687-BSJ (S.D.N.Y.), Information, Plea and transcript of Plea Hearing, all July 17, 2001, accessed at fcpa.shearman.com; court docket report as of October 12, 2011, obtained via Pacer; SEC v. American Bank Note, Case No. 1:01-cv-06453-JSR (S.D.N.Y.), Court Docket Report, entry of Judgment on July 20, 2001, accessed at fcpa.shearman.com","Documents":""},{"Case ID":"ST-44","Case Cluster ":"American Bank Note Holographics, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Saudi Arabia","Year of Settlement":"2003","Month\/Day of Settlement (or Notes)":"04\/11","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order","Monetary Sanctions  (Types)":"None ","Total Monetary Sanctions (US$)":"$0.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 8","Offenses - Alleged":"Falsification of books and records","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 American Bank Note Holographics, Inc. at 114-115 and Information filed in US v. Joshua Cantor:  On July 17, 2001, Cantor pleaded guilty to a 4-count information charging him with conspiracy to commit securities fraud, falsify books and records, lie to auditors and conspiracy to violate the FCPA.  Cantor was the president of American Bank Note Holographics, and the company was approached by the Saudi Arabian Monetary Agency with the opportunity to be the supplier of the hologram for a commemorative Saudi Arabian bank note.  In May 1998, one of ABNH\u0027s overseas agents informed ABNH that its bid would need to include \u0022an additional sum to cover consultancy fees.\u0022 ABNH eventually won the bid and consultancy fees in the amount of $239,000 were transferred to Bank Account #47377V at Credit Agricol Indosuez in Geneva, Switzerland held in the name of an entity \u0022Satapco\u0022 and the Saudi foreign official, who served as Director of the Issues and Vaults Department of SAMA, received at least a portion of the $238,000 consultancy fee.  (Source: SEC v. American Bank Note, Case No. 1:01-cv-06453-JSR (S.D.N.Y.), Court Docket Report, entry of Judgment on July 20, 2001.)   According to the Final Judgment in Mr. Cantor\u0027s SEC case, without admitting or denying the alleged offenses, he consented to the entry of a Cease and Desist Order. (Source: US SEC v. Joshua Cantor, Case No. 03-cv-2488 (S.D.N.Y.), Final Judgment filed April 11, 2011.)","Sources ":"US Department of Justice Report to Congress, Appendix C \u0022Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 American Bank Note Holographics, Inc. at 114-115, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf. SEC v. American Bank Note, Case No. 1:01-cv-06453-JSR (S.D.N.Y.), Court Docket Report, entry of Judgment on July 20, 2001, accessed at fcpa.shearman.com; US SEC v. Joshua Cantor, Case No. 03-cv-2488 (S.D.N.Y.), Final Judgment filed April 11, 2011, accessed at fcpa.shearman.com","Documents":""},{"Case ID":"ST-45","Case Cluster ":"American Rice, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Haiti","Year of Settlement":"2004","Month\/Day of Settlement (or Notes)":"12\/30","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Individual","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Civil Penalty","Total Monetary Sanctions (US$)":"$11,000.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$11,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.27","OECD Anti-Bribery Convention Articles Implicated":"Art. 1","Offenses - Alleged":"Aiding and abetting co-defendants\u0027 bribery of foreign officials","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"No (Customs) ","Summary":"According to the US Securities and Exchange Commission\u0027s Litigation Release, on December 30, 2004, the US District Court for the Southern District of Texas entered a Final Judgment enjoining Mr. Theriot from future FCPA violations and ordered him to pay a $11,000 civil penalty.  Mr. Theriot, a consultant to American Rice, Inc. consented to the Final Judgment without admitting or denying the SEC\u0027s allegations.  The SEC had alleged that Mr. Theriot aided and abetted a bribery scheme in violation of the FCPA, namely that from 1998 to 1999, an American Rice vice president authorized and the company made at least 12 separate bribery payments to Haitian customs officials, totalling approximately $500,000.  In exchange, Haitian customs officials permitted American Rice to illegally avoid approximately $1.5 million in Haitian import taxes.  (Source:  US Securities and Exchange Commission, Litigation Release No. 19026 \/ January 7, 2005, SEC v. Douglas A. Murphy, David G. Kay and Lawrence H. Theriot, Civil Action No. H-02-2908 (S.D. Texas), \u0022Lawrence H. Theriot Consents to Permanent Inunction and Payment of Civil Penalty for Aiding and Abetting Violations of the Foreign Corrupt Practices Act\u0022).  According to the June 2011 US Report to the OECD on the Enforcement of the Anti-Bribery Convention, \u0022The civil matter against [co-defendants] Kay and Murphy were suspended until sentencing, and the SEC has not yet moved to reopen the case.\u0022 The same report noted that Kay and Murphy were convicted on October 6, 2004.  (Source: US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, American Rice, Inc. Case,  at 126-127.)  ","Sources ":"US Securities and Exchange Commission, Litigation Release No. 19026 \/ January 7, 2005, SEC v. Douglas A. Murphy, David G. Kay and Lawrence H. Theriot, Civil Action No. H-02-2908 (S.D. Texas),\u0022Lawrence H. Theriot Consents to Permanent Injunction and Payment of Civil Penalty for Aiding and Abetting Violations of the Foreign Corrupt Practices Act,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/lr19026.htm; copy of complaint accessed at http:\/\/www.sec.gov\/litigation\/complaints\/comp17651.htm; US Report to the Organisation for Economic Co-operation and Development, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions,\u0022 Information as of May 31, 2011, American Rice, Inc. at 126-127, accessed at http:\/\/www.oecd.org\/dataoecd\/18\/8\/42103833.pdf","Documents":""},{"Case ID":"ST-46","Case Cluster ":"Aon Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"Bangladesh, Bulgaria, Costa Rica, Egypt, Indonesia, Myanmar, Panama, the United Arab Emirates, and Vietnam","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"12\/20","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement ","Monetary Sanctions  (Types)":"Criminal Fine ","Total Monetary Sanctions (US$)":"$1,764,000.00","Criminal Fine\/Penalty (US$) ":"$1,764,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"Falsification of books and records, Internal controls violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release, \u0022Aon Corporation, a publicly traded corporation headquartered in Chicago and one of the largest insurance brokerage firms in the world, has entered into an agreement with the Department of Justice to pay a $1.76 million penalty to resolve violations of the Foreign Corrupt Practices Act (FCPA). [ ] According to the non-prosecution agreement, Aon\u0027s United Kingdom subsidiary, Aon Limited, administered certain training and education funds in connection with its reinsurance business with Instituto Nacional De Seguros (INS), Costa Rica\u0027s state-owned insurance company.   The supposed purpose of the funds was to provide education and training for INS officials.   However, between 1997 and 2005, Aon Limited used a significant portion of the funds to reimburse INS officials for non-training related activity, including travel with spouses to overseas tourist destinations, or for uses that could not be determined from Aon\u0027s books and records.   Many of the invoices and other records for trips taken by INS officials did not provide any business purpose for the expenditures, or showed that the expenses were clearly not related to a legitimate business purpose.   As part of the agreement, Aon admitted that Aon Limited\u0027s accounting books and records related to the funds, which were consolidated into Aon\u0027s books and records, did not accurately and fairly reflect the purpose for which the expenses were incurred.   Aon also admitted that it failed to devise and maintain an adequate system of internal accounting controls with respect to foreign sales activities sufficient to ensure compliance with the FCPA.\u0022 (Source: US Department of Justice Press Release, \u0022Aon Corporation Agrees to Pay $1.76 Million Criminal Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 December 20, 2011.)  The Non-Prosecution Agreement stated that \u0022The Department enters into this Non-Prosecution Agreement based, in part, on the following factors: (a) Aon\u0027s extraordinary cooperation with the Department and the U.S. Securities and Exchange Commission (\u0022SEC\u0022); (b) Aon\u0027s timely and complete disclosure of the facts described in Appendix A as well as facts relating to Aon\u0027s improper payments in Bangladesh, Bulgaria, Egypt, Indonesia, Myanmar, Panama, the United Arab Emirates, and Vietnam that it discovered during its thorough investigation of its global operations; (c) the early and extensive remedial efforts undertaken by Aon, including the substantial improvements the company has made to its anti-corruption compliance procedures; (d) the prior financial penalty of [GBP] 5.25 million paid to the United Kingdom\u0027s Financial Services Authority (\u0022FSA\u0022) by Aon Limited, a U.K. subsidiary of Aon, in 2009, covering the conduct in Bangladesh, Bulgaria, Indonesia, Myanmar, the United Arab Emirates, and Vietnam; and (c) the FSA\u0027s close and continuous supervisory oversight over Aon Limited.\u0022 (US Department of Justice, In Re: Aon Corporation, Non-Prosecution Agreement of December 20, 2011.)","Sources ":"US Department of Justice, In Re: Aon Corporation, Non-Prosecution Agreement, December 20, 2011, accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/aon\/2011-12-20-aon-final-executed-npa.pdf; US Department of Justice Press Release, \u0022Aon Corporation Agrees to Pay $1.76 Million Criminal Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 December 20, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/December\/11-crm-1678.html","Documents":""},{"Case ID":"ST-47","Case Cluster ":"Aon Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"Costa Rica, Egypt, Vietnam, Indonesia, United Arab Emirates, Myanmar, Bangladesh and other unspecified countries","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"12\/20","Other Jurisdictions of Settlement":"United Kingdom","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest ","Total Monetary Sanctions (US$)":"$14,545,020.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$11,416,814","Civil Prejudgment Interest (US$) ":"$3,128,206","Civil Fine \/ Penalty (US$)":"$0","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Falsification of books and records, Internal controls violations","Offenses - Settled":"No admission or denial of alleged offenses","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the Securities and Exchange Commission Litigation Release, on December 20, 2011, the Commission \u0022today filed a settled enforcement action in the U.S. District Court for the District of Columbia against Aon Corporation (Aon), an Illinois-based global provider of risk management services, insurance and reinsurance brokerage, alleging violations of the books and records and internal controls provisions of the Foreign Corrupt Practices Act (FCPA). Aon will pay a total of approximately $14.5 million in disgorgement and prejudgment interest to the SEC. In a related action, Aon will pay a $1.764 million criminal fine to the U.S. Department of Justice (DOJ).  The Commission\u0027s complaint alleges that Aon\u0027s subsidiaries made over $3.6 million in improper payments to various parties between 1983 and 2007 as a means of obtaining or retaining insurance business in those countries. The complaint alleges that some of the improper payments were made directly or indirectly to foreign government officials who could award business directly to Aon subsidiaries, who were in position to influence others who could award business to Aon subsidiaries, or who could otherwise provide favorable business treatment for the company\u0027s interests. The complaint alleges that these payments were not accurately reflected in Aon\u0027s books and records, and that Aon failed to maintain an adequate internal control system reasonably designed to detect and prevent the improper payments.  According to the Commission\u0027s complaint, the improper payments made by Aon\u0027s subsidiaries fall into two general categories: (i) training, travel, and entertainment provided to employees of foreign government-owned clients and third parties; and (ii) payments made to third-party facilitators. Aon subsidiaries made these payments in various countries around the world, including Costa Rica, Egypt, Vietnam, Indonesia, United Arab Emirates, Myanmar, and Bangladesh. The complaint alleges that Aon realized over $11.4 million in profits from these improper payments.\u0022  The SEC Litigation Release acknowledged the assistance of the UK Financial Services Authority in this matter. (Source: US Securities and Exchange Commission, Litigation Release No. 22203 \/ December 20, 2011, Securities and Exchange Commission vs. Aon Corporation, Civil Action No. 1:11-cv-02256 (D.D.C.) (filed Dec. 20, 2011), \u0022SEC Files Settled FCPA Charges against Aon Corporation.\u0022) ","Sources ":"US Securities and Exchange Commission, Litigation Release No. 22203 \/ December 20, 2011, Securities and Exchange Commission vs. Aon Corporation, Civil Action No. 1:11-cv-02256 (D.D.C.) (filed Dec. 20, 2011), \u0022SEC Files Settled FCPA Charges against Aon Corporation,\u0022 accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr22203.htm; Copy of Complaint (filed December 20, 2011), accessed at http:\/\/www.scribd.com\/doc\/76161974\/SEC-Complaint-Aon.","Documents":""},{"Case ID":"ST-48","Case Cluster ":"Aon Corporation","Jurisdiction of Settlement":"United Kingdom","Jurisdiction of Settlement \/ Enforcement Agency":"Financial Services Authority","Jurisdiction of Foreign Public Official(s) ":"[payments to third parties in Bahrain, Bangladesh, Bulgaria, Burma, Indonesia, and Vietnam]","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"1\/6","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Final Notice (of Penalty)","Monetary Sanctions  (Types)":"Civil Penalty  ","Total Monetary Sanctions (US$)":"$7,632,400.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$0","Civil Prejudgment Interest (US$) ":"$0","Civil Fine \/ Penalty (US$)":"$7,632,400","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Financial Services Authority Principle 3 (reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems)","Offenses - Settled":"Financial Services Authority Principle 3 (reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems)","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the UK Financial Services Authority\u0027s Final Notice of January 6, 2009 to Aon Limited, the FSA issued the penalty of GBP 5.25 million (US $7,864,970) in respect to Aon Limited\u0027s breach of Principle 3 of the FSA\u0027s Principles for Businesses which occurred between January 2005 and September 2007.  The Final Notice stated that the company qualified for a 30% discount under the FSA\u0027s settlement discount scheme and that without the discount the fine would have been GBP 7.5 million. As a result of the systems and controls failings at Aon Limited, this gave rise to unacceptable risk that Aon Ltd could become involved in potentially corrupt payments to win or retain busines.  During the relevant period, 66 suspicious payments amounting to US$2.5 million and EUR 3.4 million were paid to nine \u0022Overseas Third Parties\u0022 (and a number of other suspicious payments to those Overseas Third Parties were made prior to the 2005, before Aon became regulated by the FSA).  The Final Oder stated that as a result of the suspicious payments, business that may have been secured or retained amounted to approximately US $7.2 million and EUR 1 million. An Explanatory Note of February 27, 2009 to the Final Order noted that while certain payments were made through Aon\u0027s Bahraini business (Aon Re Middle East WLL) during the Relevant Period, the Final Notice relates solely to Aon Ltd in the UK and the FSA\u0027s investigation did not identify any payments made to Bahraini individuals or companies. (Source: UK Financial Services Authority, Final Notice of January 6, 2009 to AON Limited and \u0022Explanatory Note to the Final Notice for Aon Limited dated 6 January 2009,\u0022 February 27, 2009, accessed at http:\/\/www.fsa.gov.uk\/pubs\/final\/aon.pdf and UK Financial Services Authority Press Release, \u0022FSA fines AON Limited [GBP] 5.25m for failings in its anti-bribery and corruption systems and controls,\u0022 FSA\/PN\/004\/2009, January 8, 2009, accessed at http:\/\/www.fsa.gov.uk\/pages\/Library\/Communication\/PR\/2009\/004.shtml.)  ","Sources ":"UK Financial Services Authority, Final Notice of January 6, 2009 to AON Limited and \u0022Explanatory Note to the Final Notice for Aon Limited dated 6 January 2009,\u0022 February 27, 2009, accessed at http:\/\/www.fsa.gov.uk\/pubs\/final\/aon.pdf and UK Financial Services Authority Press Release, \u0022FSA fines AON Limited [GBP] 5.25m for failings in its anti-bribery and corruption systems and controls,\u0022 FSA\/PN\/004\/2009, January 8, 2009, accessed at http:\/\/www.fsa.gov.uk\/pages\/Library\/Communication\/PR\/2009\/004.shtml; see also, United Kingdom Report to the OECD, \u0022Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Information as of 16 August 2011), accessed at http:\/\/www.oecd.org\/dataoecd\/17\/30\/48362318.pdf","Documents":""},{"Case ID":"ST-49","Case Cluster ":"Armor Holdings, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Department of Justice","Jurisdiction of Foreign Public Official(s) ":"United Nations","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"07\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Criminal","Legal Form of Settlement":"Non-Prosecution Agreement","Monetary Sanctions  (Types)":"Criminal Fine","Total Monetary Sanctions (US$)":"$10,290,000.00","Criminal Fine\/Penalty (US$) ":"$10,290,000","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"","Civil Prejudgment Interest (US$) ":"","Civil Fine \/ Penalty (US$)":"","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Failure to maintain books and records, Internal controls violations","Offenses - Settled":"Failure to maintain books and records, Internal controls violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release regarding its Non-Prosecution Agreement with Armor Holdings, the company \u0022accepts responsibility for its subsidiary\u0027s payment of more than $200,000 in commissions to a third-party sales agent, a portion of which it knew was to be passed on to a U.N. procurement official to induce the official to award two separate U.N. contracts to Armor?s subsidiary. The contracts were for the sale of approximately $6 million of body armor.   Armor also acknowledged that it falsely recorded the commission payments on its books and records. In addition, Armor admitted that it kept off its books and records approximately $4.4 million in additional payments to agents and other third-party intermediaries used by its Products Group to assist it in obtaining business from foreign government customers.   Armor acknowledged that it failed to devise and maintain an appropriate system of internal accounting controls.  In a related matter, Armor reached a settlement today with the U.S. Securities and Exchange Commission (SEC) and agreed to pay more than $5.69 million in disgorgement of profits, including pre-judgment interest, and a civil money penalty.\u0022 (Source:  US Department of Justice Press Release, \u0022Armor Holdings Agrees to Pay $10.2 Million Criminal Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 July 13, 2011.)","Sources ":"US Department of Justice, In Re: Armor Holdings, Inc., Non-Prosecution Agreement (July 13, 2011), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/armor\/07-31-11armor-holdings.pdf; US Department of Justice Press Release, \u0022Armor Holdings Agrees to Pay $10.2 Million Criminal Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 July 13, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/July\/11-crm-911.html","Documents":""},{"Case ID":"ST-50","Case Cluster ":"Armor Holdings, Inc.","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"United Nations","Year of Settlement":"2011","Month\/Day of Settlement (or Notes)":"07\/13","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Permanent Injunction","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$5,690,744.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$1,552,306","Civil Prejudgment Interest (US$) ":"$458,438","Civil Fine \/ Penalty (US$)":"$3,680,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"Unspecified","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Failure to maintain books and records, Internal controls violations","Offenses - Settled":"Failure to maintain books and records, Internal controls violations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to the US Department of Justice Press Release regarding its Non-Prosecution Agreement with Armor Holdings, the company \u0022accepts responsibility for its subsidiary\u0027s payment of more than $200,000 in commissions to a third-party sales agent, a portion of which it knew was to be passed on to a U.N. procurement official to induce the official to award two separate U.N. contracts to Armor\u0027s subsidiary. The contracts were for the sale of approximately $6 million of body armor.   Armor also acknowledged that it falsely recorded the commission payments on its books and records. In addition, Armor admitted that it kept off its books and records approximately $4.4 million in additional payments to agents and other third-party intermediaries used by its Products Group to assist it in obtaining business from foreign government customers.   Armor acknowledged that it failed to devise and maintain an appropriate system of internal accounting controls.\u0022  (Source:  US Department of Justice Press Release, \u0022Armor Holdings Agrees to Pay $10.2 Million Criminal Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 July 13, 2011.)  According to the US Securities and Exchange Commission Litigation Release, Without admitting or denying the allegations in the Commission\u0027s complaint, Armor Holdings has consented to a court order permanently enjoining it from violating Sections 30A, 13(b)(2)(A), and 13(b)(2)(B) of the Exchange Act; ordering it to pay disgorgement of $1,552,306, together with prejudgment interest of $458,438; imposing on it a civil penalty of $3,680,000 [  ] The proposed settlement is subject to court approval.\u0022 (Source: US Securities and Exchange Commission, Litigation Release No. 22037 \/ July 13, 2011, Securities and Exchange Commission v. Armor Holdings, Inc., Case No. 1:11-cv-01271(D. D.C.)(ESH) (filed July 13, 2011), \u0022SEC FILES SETTLED ANTI-BRIBERY, BOOKS AND RECORDS, AND INTERNAL CONTROLS CHARGES AGAINST ARMOR HOLDINGS, INC.\u0022)   Please note that according to the Court Docket Report, as of December 28, 2011, the case had been reassigned to another judge in July 2011 and no judgment ordered yet in this case. (Source: SEC v. Armor Holdings, Inc. Case No. 1:11-cv-01271 (D.D.C.), Court Docket Report as of December 28, 2011.)","Sources ":"US Department of Justice, In Re: Armor Holdings, Inc., Non-Prosecution Agreement (July 13, 2011), accessed at http:\/\/www.justice.gov\/criminal\/fraud\/fcpa\/cases\/armor\/07-31-11armor-holdings.pdf; US Departmento of Justice Press Release, \u0022Armor Holdings Agrees to Pay $10.2 Million Criminal Penalty to Resolve Violations of the Foreign Corrupt Practices Act,\u0022 July 13, 2011, accessed at http:\/\/www.justice.gov\/opa\/pr\/2011\/July\/11-crm-911.html; US Securities and Exchange Commission, Litigation Release No. 22037 \/ July 13, 2011, Securities and Exchange Commission v. Armor Holdings, Inc., Case No. 1:11-cv-01271 (D. D.C.)(ESH) (filed July 13, 2011), \u0022SEC FILES SETTLED ANTI-BRIBERY, BOOKS AND RECORDS, AND INTERNAL CONTROLS CHARGES AGAINST ARMOR HOLDINGS, INC.,\u0022 accessed at  http:\/\/www.sec.gov\/litigation\/litreleases\/2011\/lr22037.htm; Complaint filed July 13, 2011, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2011\/comp22037.pdf; SEC v. Armor Holdings, Inc. Case No. 1:11-cv-01271 (D.D.C.), Court Docket Report as of December 28, 2011 (accessed via Pacer).","Documents":""},{"Case ID":"ST-51","Case Cluster ":"Avery Dennison Corporation","Jurisdiction of Settlement":"United States","Jurisdiction of Settlement \/ Enforcement Agency":"Securities and Exchange Commission","Jurisdiction of Foreign Public Official(s) ":"China and several (unnamed) countries","Year of Settlement":"2009","Month\/Day of Settlement (or Notes)":"07\/28","Other Jurisdictions of Settlement":"Unknown","Settlement with Individual or Legal Person?":"Legal Person","Type of Settlement":"Civil","Legal Form of Settlement":"Consent to Cease-and-Desist Order ","Monetary Sanctions  (Types)":"Disgorgement of Profits, Prejudgment Interest, Civil Penalty","Total Monetary Sanctions (US$)":"$518,470.00","Criminal Fine\/Penalty (US$) ":"","Criminal Fine \/ Penalty (Explanation)":"","Criminal Forfeiture \/ Confiscation (US$)":"","Criminal Restitution \/ Reparation (US$)":"","Criminal Legal \/ Procedural Costs (US$)":"","Civil Disgorgement of Profits (US$) ":"$273,213","Civil Prejudgment Interest (US$) ":"$45,257","Civil Fine \/ Penalty (US$)":"$200,000","Other Civil Monetary Sanctions (US$)":"","Other Civil Monetary Sanctions (Explanation)":"","Monetary Sanctions Returned \/ Ordered Returned (US$)":"$0 ","Monetary Sanctions  Returned \/ Ordered Returned (Explanation)":"","UNCAC Articles(s) Implicated":"Art.16, Art.26","OECD Anti-Bribery Convention Articles Implicated":"Art. 1, Art. 2, Art. 8","Offenses - Alleged":"Internal Controls Violations, Falsification of books and records","Offenses - Settled":"No admission or denial of allegations","Public Procurement Contract \/ SOE Involved?":"Yes","Summary":"According to US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Avery Dennison Corporation, at 39-40: Misconduct in China took place 2002-2005; (1) the Reflective Division of Avery (China) Co. Ltd. (Avery China) paid or authorized the payments of approximately $300,000 in kickbacks, sightseeing trips, and gifts to Chinese government officials; In one transaction, Avery China secured a sale to a state-owned end user by agreeing to pay a Chinese official a kickback of nearly $25,000 through a distributor. Avery China realized $273,313 in profits from this transaction. (2) illegal payments of approximately $51,000 by an Avery-acquired company, after acquisition, of making illegal petty cash payments to customs or other officials in several countries. Civil disposition: In administrative proceeding, SEC ordered Avery to cease and desist from such violations and to disgorge $273,213, with $45,257 in prejudgment interest. In federal civil action, Avery agreed to the entry of a final judgment requiring it to pay a civil penalty in the amount of $200,000.  Cases are: SEC v. Avery Dennison Corporation (C.D. Cal., July 28, 2009), In the Matter of Avery Dennison Corporation (July 28, 2009).","Sources ":"US Department of Justice Report to Congress, \u0022Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010,\u0022 Avery Dennison Corporation, at 39-40, accessed at www.justice.gov\/criminal\/fraud\/fcpa\/docs\/response3-appx-c.pdf; In the Matter of Avery Dennison Corporation, Administrative Proceeding, File No. 3-13564, Order Instituting Cease-and-Desist Proceedings Pursuant to Section 21 C of the Securities Exchange Act of 1934, Making Findings, and Imposing a Cease-and-Desist Order (July 28, 2009), accessed at http:\/\/www.sec.gov\/litigation\/admin\/2009\/34-60393.pdf; Litigation Release No. 21156 \/ July 28, 2009, accessed at http:\/\/www.sec.gov\/litigation\/litreleases\/2009\/lr21156.htm; SEC v. Avery Dennison, Corporation, Case No. 09-cv-5493-DSF (C.D. Cal.), Complaint filed July 28, 2009, accessed at http:\/\/www.sec.gov\/litigation\/complaints\/2009\/comp21156.pdf","Documents":""}]}